Privacy Policy

1. Who this policy covers

This policy applies to two groups of people:

• Consultants — the colour analysis professionals who hold an account and use True Colours to manage their practice.
• Clients — the individuals whose colour analysis information a consultant records and who may receive a report via a private link.

Consultants act as the party responsible for the personal information of their own clients. True Colours processes that information on the consultant’s behalf.

2. Information we collect

We collect the following categories of personal information:

• Account information — name, email address, password (stored hashed), practice name, and contact details you provide at signup or in settings.
• Billing information — subscription plan and payment status. Card details are collected and processed directly by our payment processor; we do not store full card numbers.
• Client records — client names, email addresses, and the colour analysis details a consultant enters (such as undertone, season, and session notes).
• Voice and report content — audio you choose to record for transcription, transcripts, and generated report drafts.
• Technical information — log data, device and browser type, and usage information collected automatically to operate and secure the service.

3. Why we collect it (identifying purposes)

We use personal information only for the purposes for which it was collected, namely to:

• provide, maintain, and improve the True Colours platform;
• authenticate consultants and secure accounts;
• generate colour analysis reports from consultant inputs;
• deliver reports to clients via private tokenized links;
• process subscriptions and send service-related communications;
• respond to support requests; and
• comply with legal obligations.

4. Consent

We collect, use, and disclose personal information with consent, except where permitted or required by law. Consultants are responsible for obtaining any consent required from their clients before entering client information into True Colours. You may withdraw consent at any time, subject to legal and contractual restrictions, by contacting us — though doing so may limit your ability to use the service.

5. How we use AI and transcription

True Colours uses third-party AI and speech-to-text providers to transcribe voice notes and to generate report drafts from consultant-supplied content. Only the content needed for these features is sent to those providers, and it is used solely to return the requested result. The AI generates reports from saved season content and session notes; it does not create new seasonal advice on its own.

6. Disclosure to third parties

We do not sell personal information. We share it only with service providers who help us operate True Colours — including cloud hosting, database and storage, email delivery, payment processing, and AI/transcription providers — and only to the extent needed to perform their function. These providers are bound by contractual obligations to protect the information. We may also disclose information where required by law or to protect our rights and the safety of others.

7. Where information is stored

Personal information may be stored and processed in Canada, the United States, or other countries where our service providers operate. Where information is transferred outside your jurisdiction, it may be subject to the laws of those countries. We take reasonable steps to ensure comparable protection wherever it is processed.

8. Retention

We retain personal information only as long as needed to fulfil the purposes described in this policy, to provide the service, and to meet legal, accounting, or reporting requirements. Consultants may request deletion of their account and associated client data; we will process such requests as described in Section 11.

9. Safeguards

We protect personal information with administrative, technical, and physical safeguards appropriate to its sensitivity, including encryption in transit, access controls, row-level data isolation between consultant accounts, and hashed passwords. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Your rights and access

Subject to applicable law, you have the right to access the personal information we hold about you, to request correction of inaccuracies, and to ask about how it has been used or disclosed. Clients who wish to exercise these rights should first contact the consultant who created their record. Account holders may contact us directly at the address below. We will respond within the timeframe required by applicable law.

11. Data deletion requests

To request deletion of your account and associated data, email us at [privacy@yourdomain.com]. We will verify your identity and process verified requests within a reasonable period, except where retention is required by law.

12. Children's information

True Colours is intended for use by professional consultants and is not directed to children. We do not knowingly collect personal information directly from children without appropriate consent.

13. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be reflected by updating the “Last updated” date above and, where appropriate, by additional notice. Continued use of True Colours after a change constitutes acceptance of the updated policy.

14. Contact and complaints

For questions, access requests, or complaints about how we handle personal information, contact our privacy officer at [privacy@yourdomain.com]. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada, or the applicable regulator in [PROVINCE/STATE].