Privacy Policy
*Last updated: 2026-01-27*

This Privacy Policy describes how **Musa Tasci** (“we”, “us”, “our”) collects, uses, and protects information when you use the **Shade** mobile application and related services (the **“Service”**).

If you do not agree, please do not use the Service.

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## 1. Data Controller

**Controller:**
Musa Tasci

**Contact:**
[email protected]

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## 2. Data We Collect

We collect information to provide and improve our AI-powered hair color transformation service:

### 2.1. Information You Provide
- **Photos:** When you use the hair color editor, you upload a portrait photo.
- **Feedback:** Any messages or feature requests you send us.
- **Account Data:** If you create an account, we store your email address and authentication details via Firebase.

### 2.2. Automatically Collected Information
- **Device Information:** Model, operating system, and unique device identifiers.
- **Usage Data:** Information about how you interact with the app (e.g., which features you use).
- **Subscription Data:** Purchase history and subscription status via RevenueCat.

### 2.3. AI Processing Data
- **Image Data:** Your photos are sent to our AI partners (Google Gemini and OpenAI) for the sole purpose of processing your requested transformation.

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## 3. Purposes & Legal Bases (GDPR Art. 6)

We process personal data based on the following legal grounds:

| Purpose | Legal Basis |
| --- | --- |
| AI Image Transformation | Performance of a contract |
| Providing core app functionality | Performance of a contract |
| Subscription management | Performance of a contract |
| Analytics, diagnostics, security | Legitimate interest |
| Push notifications | Consent |
| Legal compliance | Legal obligation |

You may withdraw your consent at any time via your device settings.

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## 4. Service Providers (Processors)

We use trusted processors that may process data on our behalf:

- **Google Firebase** (Authentication, Firestore Database, Cloud Functions, Storage)
- **Google Gemini** (AI Image Processing)
- **OpenAI** (AI Image & Text Processing)
- **RevenueCat / Superwall** (Subscription & Paywall Management)
- **Expo** (Push Notifications)

These providers are contractually bound to comply with GDPR and CCPA.

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## 5. Photo Handling & Privacy

We prioritize your privacy, especially regarding your photos:
- **Immediate Deletion:** Original photos uploaded for hair color transformation are deleted from our servers immediately after the AI processing is complete.
- **Result Storage:** The generated result images are stored in your private Firebase Storage and are accessible only to you. They are deleted upon account deletion.
- **No Training:** We do not use your photos to train our AI models.

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## 6. International Transfers

Data may be transferred to countries outside the EU, including the United States (where our AI partners and Firebase servers are located). Where required, we rely on **Standard Contractual Clauses (SCCs)** or equivalent safeguards to ensure your data remains protected.

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## 7. Data Retention

- **Account Data:** Retained as long as your account is active.
- **Result Images:** Stored until you delete them or your account is closed.
- **Original Uploads:** Deleted immediately after processing.
- **Subscription Records:** Retained as required for financial and legal compliance.

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## 8. Your Rights (GDPR)

If you are located in the EU/EEA, you have the right to:
- Access your personal data
- Rectify inaccurate data
- Delete your data (Right to be forgotten)
- Restrict processing
- Data portability
- Object to processing
- Withdraw consent at any time
- Lodge a complaint with a supervisory authority

You can exercise these rights by contacting us at **[email protected]**.

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## 9. Your Rights (CCPA / CPRA – California)

California residents have the right to:
- Know what personal information is collected
- Request deletion of personal information
- Request correction of inaccurate data
- Opt-out of the sale or sharing of personal data
- Not be discriminated against for exercising these rights

> We do not sell or share personal information as defined by the CCPA.

Requests can be made via **[email protected]**.

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## 10. Children’s Privacy

The Service is not intended for children under 13 years of age. If we identify that such data has been collected, it will be deleted promptly.

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## 11. Security

We apply appropriate technical and organizational security measures to protect your data. However, no system is completely secure, and we cannot guarantee absolute security.

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## 12. Changes to This Policy

We may update this Privacy Policy from time to time. Changes become effective when published in the app.

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## 13. Contact

For privacy-related questions or requests:
**[email protected]**