Privacy Policy

PRIVACY FRAMEWORK • DPDP ACT, 2023 COMPLIANCE

Privacy Policy & Biometric Data Safeguards

Huewise ("we", "us", or "our") is deeply committed to protecting your personal data, sensitive personal data or information (SPDI), and facial privacy. Under India's Digital Personal Data Protection Act, 2023 (DPDP Act) and the Information Technology (SPDI) Rules, 2011, Huewise operates as the Data Fiduciary and you, the user, are the Data Principal.

Last Updated: October 14, 2026 • Effective Date: Immediately upon usage

No Public Model Training

Your selfies are never used to train public or 3rd-party foundation models without opt-in.

Zero Biometric Surveillance

We only extract mathematical colorimetry (CIELAB L*a*b* & ITA°) for personal palette analysis.

1-Click Data Erasure

You can delete your account, analysis history, and photos anytime from your settings.

1. Information We Collect

As a Data Fiduciary, we collect only the personal data necessary to deliver personalized seasonal color analysis and smart digital wardrobe assistance:

  • User Account Details: Name, email address, phone number (for WhatsApp stylist updates), and profile preferences.
  • Facial Photographs & Selfies: Images uploaded by you for the sole purpose of daylight colorimetry and skin undertone classification.
  • Wardrobe & Shopping Preferences: Uploaded garment images, category tags, purchase URLs pasted into the Item Checker, and cost-per-wear parameters.
  • Transaction & Billing Data: Payment order ID, amount, and subscription status processed securely via Razorpay. We do not store credit card numbers, CVVs, or netbanking passwords.

2. Purpose Limitation for Facial Image Processing

In alignment with the consent and purpose limitation principles of India's DPDP Act, 2023, your facial photographs are collected solely on the basis of your explicit consent and processed under strict purpose limitation:

  • Calculating your Individual Typology Angle (ITA°) and CIELAB color values across calibrated skin, eye, and lip coordinates.
  • Assigning your seasonal color palette (Deep Autumn, Warm Spring, Cool Summer, Deep Winter).
  • Generating personalized cultural jewelry and lipstick flattery recommendations.
  • We do not create facial recognition biometric databases, law enforcement surveillance indices, or sell biometric datasets to data brokers.

3. Data Security & Storage Architecture

We implement industry-standard organizational and technical measures:

  • Encryption in Transit: TLS 1.3 cryptographic protocols with mandatory HTTPS.
  • Encryption at Rest: AES-256 encrypted relational databases and secure cloud buckets via Supabase.
  • Access Controls: Role-based access control (RBAC) ensuring automated API processing without human inspection unless explicitly authorized for customer support.

4. Rights of Data Principals & Consent Withdrawal

Under Chapter III of the DPDP Act, 2023, you have the following enforceable statutory rights:

  • Right to Access: View your full Style DNA dossier, analyzed parameters, and wardrobe ledger at any time.
  • Right to Correction & Erasure: Update or permanently delete any photo, wardrobe entry, or your entire user account.
  • Right to Withdraw Consent: You have the right to withdraw your consent to personal data and facial processing at any time as easily as giving consent. You can execute this by clicking "Delete Account & Data" in Settings or emailing our Grievance Officer.
  • Consequences of Consent Withdrawal: Upon withdrawal, your active Style DNA analysis sessions and personalized wardrobe matching will be discontinued, and your uploaded selfie will be immediately expunged from active cloud storage.
  • Right to Nominate: You have the right to designate a nominee to exercise your rights in the event of death or incapacity, in accordance with DPDP rules.

5. Third-Party Service Providers & AI Sub-Processors

In accordance with Section 8(2) of the DPDP Act, we engage reputable Data Processors under strict security and confidentiality obligations:

  • Google LLC (Google Gemini Cloud AI API): Automated multimodal vision inference for skin undertone, contrast, and colorimetric analysis. Your image is transmitted over TLS-encrypted enterprise API connections solely for instant mathematical inference and is not used to train public foundation models.
  • Supabase Inc.: SOC2 Type II certified backend infrastructure, user authentication, and AES-256 encrypted database storage.
  • Razorpay Software Private Limited: RBI-authorized Payment Aggregator for secure INR billing.
  • Open-Meteo: Open-source weather forecast API (anonymized coordinate query with zero personal profile data passed).

6.Protection of Children's Personal Data (Section 9 Compliance)

Huewise is strictly designed and intended for individuals aged 18 years and above.

  • In adherence to Section 9 of the DPDP Act, 2023, we do not knowingly solicit or process the facial images or personal data of children under 18 years without verifiable consent from a parent or lawful guardian.
  • We do not engage in behavioral tracking, targeted advertising, or automated profiling directed at children.
  • If we discover that personal data of a minor has been submitted without verifiable parental consent, we will take immediate steps to permanently delete the image and account data.

7. Data Retention & Erasure Schedule

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or to comply with applicable statutory laws:

  • Guest Analyses: Temporary session analyses and selfie thumbnails are automatically purged or stored only in your local browser cache until you choose to register.
  • Registered Users: Data is retained for the lifetime of your active account to maintain your continuous wardrobe history. Upon account deletion, personal records are permanently erased within 30 days.
  • Financial & Invoice Records: Retained for statutory periods mandated under Indian tax and corporate laws (GST Act, Companies Act).

8. Grievance Redressal Officer

In alignment with statutory provisions under the Information Technology Act, 2000 and the DPDP Act, 2023, the details of our designated Grievance Redressal Officer are provided below:

Grievance Redressal Officer

Designated Legal & Compliance Lead

Huewise Private Limited (HQ)

Indore, Madhya Pradesh, India

Contact & SLA

Email: support.huewise@gmail.com

Acknowledgment: Within 24 Hours • Resolution: Within 15 Days