Paletteline: Privacy Policy (draft for legal review)

Last updated: 2026-09-16 Controller: Maximilian Kuchlbauer, mk-sd (Impressum: https://mk-sd.com/impressum) Contact: maximilian.kuchlbauer@gmail.com

The short version

Paletteline is a personal colour analysis that runs entirely on your iPhone. We do not collect your data. There is no account, no server and no upload. The app itself makes no network connection. Your photo is processed on the device and never uploaded. Nothing you save leaves your device unless you yourself export and share it.

What the app stores, and where

Your analyses (season, the four dimensions undertone, depth, clarity and contrast, the measured values, the trace, your corrections and a manual override) are stored as JSON files inside the app's own container on your device.
Your photos are stored in the app's own container on your device. They are not written to your photo library.
Your settings (language, appearance, operating side, the lock and similar) are stored in the app's preferences (UserDefaults) on your device.
The lock, if enabled, uses Apple's Face ID or your device passcode. The biometric data never leaves the Secure Enclave and is never seen by the app; the app only learns whether the system accepted the unlock.

The photo

The photo you take or choose is processed only on your iPhone: Apple's Vision face detection finds the face and the sample points, and the colour values are computed on the device. There is no upload. The photo is stored permanently only if you save the analysis; it stays in the app's container. Deleting the analysis deletes its photo with it.

What we collect

Nothing. The app makes no network request, has no analytics, no advertising identifier, no crash reporter and no third-party SDK. The App Store privacy label is therefore Data Not Collected.

You buy a subscription through the App Store. Apple handles the payment; we receive no payment data, no name and no account data. The app reads the subscription status only locally on the device.

The app writes a CSV or PDF file only when you tap export, and hands it to the iOS share sheet. Where it goes from there is your choice and your action. We are not involved and receive no copy.

Retention and deletion

Your data stays until you delete it. Settings, Reset app data deletes every analysis and every photo on the device; your subscription and your settings stay. Deleting the app deletes its container and everything in it. Because we hold no copy, there is nothing for us to delete on a server and no account to close.

Backups

If you back your iPhone up to iCloud or a computer, the app's container is included in that backup according to Apple's settings, which are outside our control.

Children

Paletteline is not directed at children. It gives colour guidance and no medical advice.

Colour guidance disclaimer

Paletteline measures, explains and recommends inside an unregulated colour consulting tradition. **It is not medical advice and not a diagnosis, and the app makes no claim of scientific accuracy.** Lighting, make-up, filters and screen settings change the result.

Changes

If this policy changes, the new version ships with the app and its date is updated above.

Your rights

Because we process no personal data, there is no processing to access, correct, export or erase on our side. Under the GDPR you nevertheless have the right to contact us with any question, and to complain to your data protection authority.