Privacy Notice

The short version

This notice explains what personal data Onyou collects, why, who we share it with, how long we keep it, and the rights you have. It follows the structure recommended by the UK Information Commissioner's Office (ICO).

The most important point: your photo creates your look — then it's gone. We never keep it, never use it to train AI, and handle it under formal data-protection agreements.

Who we are

Onyou ("we", "us", "our") is operated by ⟦LEGAL ENTITY⟧, a company registered in England & Wales (company number ⟦COMPANY NO.⟧) with its registered address at ⟦REGISTERED ADDRESS⟧.

We are the data controller for the personal data described in this notice, and we are registered with the UK Information Commissioner's Office (ICO).

For any privacy question, or to exercise your data-protection rights, contact us at privacy@onyou.beauty. For general help, contact support@onyou.beauty.

The personal data we collect

We collect this directly from you when you use Onyou. We keep it to the minimum we need.

• Your selfie — a facial image, which we treat as special-category (sensitive) data. It is sent to our AI providers to create your analysis and looks. We never keep it. On the free reveal it is processed in the moment and never written to our servers. When you buy your Edit, so we can finish creating your looks even if you close the tab, it is held in secure, encrypted storage for up to 15 minutes, then deleted automatically. We never retain it beyond that, and we never build a library of faces.
• Optional intake details — e.g. your first name, eye color, skin tone, and (after purchase) style preferences. These are optional and just sharpen the result.
• Your results — report, color season, palette, and generated look images — saved to your account so you can return to them, with one-tap delete any time. Your report, season and palette are kept for as long as you keep your account. Your look images are kept for 90 days, then deleted. Your looks are yours to download. We keep a copy for 90 days, then delete it — and we don't recreate them afterward, so save the ones you love before then. When your results are generated you can opt out of saving them — if you do, we keep nothing. Free-reveal images are never stored. Your look images show your face, so where saved we protect them as special-category data.
• Account & contact data — your email address, for your account, receipts, and essential service messages.
• Age-confirmation — a simple "18 or over: yes" flag plus a timestamp. We do not collect your date of birth.
• Consent records — what you agreed to, when, and the policy version, so we can demonstrate valid consent.
• Technical / anti-abuse data — an anonymous device token and a hashed (not plain-text) version of your IP address, used to meter the free reveal and prevent abuse.
• Payment data — payments are handled by our merchant of record, which acts as a separate, independent data controller for your payment and tax records under its own privacy policy. We receive confirmation a purchase succeeded; we do not see or store your full card details.

How and why we use your data — and our lawful basis

Under UK GDPR we must have a lawful basis for each use of your data. Ours are:

• To create your color analysis and AI looks — lawful basis: performance of a contract (you ask us for the service, and your selfie is necessary to provide it), together with your explicit consent for the facial special-category data (see below).
• To create and deliver your paid Edit — including finishing your looks if you close the tab, and emailing you when they're ready — lawful basis: performance of a contract.
• To store your report and (unless you opt out) your looks so you can return to them — lawful basis: contract and consent.
• To run your account, send receipts and essential messages — lawful basis: contract.
• To confirm you are 18+ before any face is processed — lawful basis: legal obligation and our legitimate interests in operating an adults-only service responsibly.
• To screen images for harmful content — lawful basis: our legitimate interests in keeping the service safe and preventing misuse.
• To meter the free reveal and prevent abuse (device token, hashed IP, bot protection) — lawful basis: our legitimate interests in protecting the service and controlling cost, balanced against your privacy and kept minimal.
• To understand and improve the product (privacy-respecting, EU-hosted analytics) — lawful basis: our legitimate interests.
• To keep required business records (e.g. tax records) — lawful basis: legal obligation.
• Marketing emails (only if you opt in) — lawful basis: consent, which you can withdraw at any time.

Special-category (facial) data and your explicit consent

A facial image is sensitive (special-category) data — it can reveal characteristics such as ethnic origin. Out of caution we treat your selfie and the images we generate as special-category data and rely on the condition of your explicit consent (Article 9(2)(a)) — even though we use them only to create your styling results, and not to identify you, recognize you, or match you against any database.

Before any photo is processed there is a dedicated, separate, un-ticked checkbox:

"I agree to Onyou analyzing my photo — including features like skin tone, hair, and eye color — to find my color season and style my look. My photo is never kept and never used to train AI."

We never pre-tick these and never bundle them into one catch-all box. You can withdraw this consent at any time. Withdrawal stops future processing and lets you delete any looks stored under your account; it does not affect processing that already happened while consent was in place.

Do you have to provide your data?

You can browse this website without giving us anything. To get your analysis and looks you need to provide a selfie and give the consents above — without them we cannot create your report. The optional intake details are not required; they simply improve the result. If you don't pass the 18+ check, you cannot use the service.

Automated processing

Onyou uses AI to analyze your selfie and generate your color analysis and look images — so the service involves automated processing. However, this does not produce legal effects or similarly significantly affect you: it is styling guidance and entertainment, not a decision about things like credit, employment, insurance, or eligibility. We do not use your data for that kind of automated decision-making, and we do not use it to identify or match you against any database.

Who we share your data with

We use a small number of trusted providers. Each handles only what it needs to, under a data-processing agreement. For security and commercial reasons we describe them by role rather than naming each one:

• An enterprise AI vision provider — reads your selfie and writes your analysis. Your image is not used to train AI models.
• Enterprise AI image-generation and safety-screening providers — generate your look images and run the automated nudity/violence safety screening. Processed under data-protection agreements; your image is not used to train AI models, and the safety scanner does not store your images.
• A Tier-1 hosting provider based in the EU — provides the database, authentication, and storage for the data we keep (your report, saved looks, account). Data is encrypted at rest (AES-256) and in transit (TLS).
• Our merchant of record — sells to you and handles payments and tax, as a separate, independent data controller for that transaction.
• A privacy-respecting, EU-hosted analytics provider — used only for aggregate traffic and performance metrics. We do not profile you, track you across other sites, or build a profile of your behavior.
• A transactional email provider — sends receipts and essential account messages.
• A bot-protection provider — protects the free reveal from automated abuse.

We will not use a provider that processes your facial image without appropriate data-protection terms in place. We never sell your data, and we don't share it for advertising.

Sending data outside the UK

The data we store is hosted in the UK and EU. Some AI processing of your selfie takes place on our AI providers' global infrastructure, which may be outside the UK/EEA, including in the United States — this processing is transient, and your selfie is not stored during it beyond the short windows described below.

Where personal data is transferred outside the UK, we rely on appropriate safeguards, including the UK International Data Transfer Agreement / Addendum (IDTA) and the Standard Contractual Clauses, supported by the UK Extension to the EU–US Data Privacy Framework where the provider is certified. You can ask us for more detail on the safeguards in place.

How long we keep your data

• Your selfie — we never keep it. On the free reveal it is never written to our servers. When you buy your Edit, it is held in secure, encrypted storage for up to 15 minutes while your looks are created, then deleted automatically.
• Delivering your looks — if you close the tab while your looks are being made, we hold the finished images in secure storage for up to 72 hours so we can email them to you, then delete them once you've downloaded them or the 72 hours pass.
• Generated look images — kept for 90 days, then deleted. We don't recreate them afterward, so save the ones you love before then. Not stored at all if you opt out of saving. Free-reveal images are never stored.
• Your report, color season, and palette — kept for as long as you keep your account, and deletable any time — unless you opt out of saving, in which case they aren't stored at all.
• Consent and age-confirmation records — up to 6 years, so we can demonstrate you gave valid consent and confirmed you were 18+.
• Order records — retained by our merchant of record, and by us only where tax or accounting law requires, up to 6 years.
• Anti-abuse data (device token, hashed IP) — only as long as needed to meter the free reveal and protect the service.
• Usage / analytics data — in detailed form for around 90 days, then only in aggregate, anonymous form.

Cookies and similar technologies

We keep this light and use only what's needed:

• Essential storage — to keep you signed in, remember your session, and run the free reveal and metering safely.
• Bot protection — sets only what's needed to tell humans from bots on the free reveal.
• Privacy-respecting, EU-hosted analytics — aggregate traffic and performance metrics only.

We do not use advertising trackers, cross-site tracking, or behavioral profiling.

Children

Onyou is strictly for adults aged 18 and over, because it creates AI images of faces. You must confirm you are 18+ before you can upload a photo. If we learn that someone under 18 has used the service, we will delete their data.

Your rights and how to use them

Under UK GDPR (and EU GDPR where it applies) you have the right to:

• be informed about how we use your data (this notice);
• access the personal data we hold about you;
• have inaccurate data rectified;
• have your data erased ("right to be forgotten");
• restrict or object to processing;
• data portability — receive your data in a usable format;
• withdraw consent at any time, including consent to process your facial image and store your looks;
• not be subject to solely automated decisions with legal or similarly significant effects (we don't make these).

One-tap delete for your stored looks and report is available in the app. To exercise any other right, email privacy@onyou.beauty. We will respond within one month, and we won't charge a fee unless a request is excessive or repetitive. Because we never keep your selfie, the most sensitive item is already beyond retrieval. For your payment records, our merchant of record is the controller, so we will help you direct that request to them.

Your US privacy rights (California and other US states)

Because our primary audience is in the United States, this section summarizes rights under California law (CCPA/CPRA) and similar state laws (e.g. Virginia, Colorado, Connecticut, Oregon). If you are a US resident:

• We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising. We never have.
• We do not use your facial image or generated looks for targeted advertising or profiling.
• You have the right to know what personal information we collect and how we use it (this notice), to access and delete it, to correct it, and to be free from discrimination for exercising these rights.
• We treat your facial image as sensitive personal information and use it only to create your results — never to infer characteristics about you.
• We honor recognized universal opt-out signals where the law requires.
• To exercise any of these rights, email privacy@onyou.beauty. You may use an authorized agent. We will verify your request and respond within the timeframes the law requires.

How to complain

If you have a concern about how we handle your data, please contact us first at privacy@onyou.beauty — we'd like the chance to put it right.

You also have the right to complain to the ICO:

• Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
• Helpline: 0303 123 1113 · Website: ico.org.uk

If you are in the EU/EEA, you may also complain to your local data protection authority.

Changes to this notice

We may update this notice as the product and the law evolve. We'll update the "Last updated" date and version above, and where appropriate let you know. Material changes to how we use your facial data may require fresh consent.

Contact us

• Privacy / data-protection queries: privacy@onyou.beauty
• General support: support@onyou.beauty
• Postal: ⟦LEGAL ENTITY⟧, ⟦REGISTERED ADDRESS⟧