Legal

Privacy policy

How ExactHue Pte. Ltd. handles personal data — written to be read, not to be survived.

1. Who we are

ExactHue Pte. Ltd. (“ExactHue”, “we”, “us”) is a private company limited by shares, registered with the Accounting and Corporate Regulatory Authority (ACRA), Singapore, with its registered office at 352 Yishun Ring Road, Singapore 760352. Our colour-science laboratory and research operations are based at the same address.

We build ExactHue Core, a shade-matching engine licensed to beauty brands, retailers and marketplaces. We do not sell a consumer product.

2. Scope of this policy

This policy covers personal data we handle:

  • when you visit exacthue.com or contact us;
  • when you hold an account on the ExactHue console as a customer or prospective customer;
  • when you contribute to our colour-science research programme;
  • when ExactHue Core processes an end customer's capture on behalf of a brand.

Controller and processor. For our website, our customers and our research programme, ExactHue is the controller — we decide why and how the data is used. When ExactHue Core processes a shopper's capture inside a brand's storefront, that brand is the controller and ExactHue acts as a processor under their instructions and our data-processing agreement. If you are a shopper, the brand's own privacy notice governs, and requests are best directed to them — though we will always help.

3. What we collect

CategoryExamplesSource
Identity and contactName, work email, company, job title, countryYou, directly
AccountCredentials (hashed), environment scopes, sign-in events, API key metadataYou and our systems
CommercialPlan, billing contact, invoices, contract recordsYou and our payment provider
Enquiry contentWhatever you write to us in a form or an emailYou, directly
TechnicalIP address, user agent, pages requested, timestamps, error tracesAutomatic, on request
AnalyticsAggregated page views and referrers, if you accept optional cookiesCookies, with consent
Capture dataImages submitted to ExactHue Core and colour values derived from themEnd customers, via our brand customers
Research dataSkin colour measurements, session metadata, consent and payment recordsResearch contributors

We do not buy personal data from brokers, and we do not enrich your record with third-party profiling data.

4. Facial captures and ExactHue Core

This section matters most, so it is the most specific.

4.1 What the engine does

ExactHue Core measures colour from skin regions of a submitted image in order to recommend a cosmetic shade. It estimates the lighting, inverts the camera's processing, recovers an estimate of skin reflectance, and compares that against a catalogue of measured product colour.

4.2 What the engine does not do

  • It does not perform facial recognition, identification or verification.
  • It does not generate or store a face template, faceprint or biometric identifier.
  • It does not attempt to infer age, gender, ethnicity, health or emotional state.
  • It does not make any dermatological, diagnostic or medical assessment. Fitzpatrick classification is used solely as a research sampling taxonomy.

4.3 Retention of captures

A capture is processed to produce the match result and is then deleted. Our default is that captures are not retained and are not used to train or improve our models. Retention for model improvement occurs only where a brand customer has explicitly opted in under a separate written agreement, and only on the basis that the brand has obtained appropriate consent from the individual.

4.4 Sensitivity

Although the engine does not perform biometric identification, an image of a person can be sensitive under several legal regimes. We therefore treat captures as personal data throughout: minimised, encrypted, region-pinned where required, and never repurposed. Where your jurisdiction requires specific consent before this processing, the brand's consent flow governs, and we provide the technical controls needed to honour it — including refusing to process where consent has not been recorded.

5. Research contributor data

Our shade library is built from controlled research sessions rather than from scraped imagery or repurposed customer photographs. If you contribute:

  • you are told the purpose before the session and given a written information sheet;
  • you are compensated for your time;
  • your samples are stored under a pseudonymous identifier, separated from your contact details;
  • you may withdraw at any time, and withdrawal removes your samples from the library and from future training. Where a model has already been trained, we cannot un-train it, but your samples will not inform any subsequent version;
  • your samples are never sold, licensed or shared, and are never used to identify you.

6. Why we process it

  • To operate the service — authenticate you, run matches, ingest catalogues, report accuracy.
  • To answer you — respond to enquiries, pilots, technical questions and complaints.
  • To bill and administer — contracts, invoices, tax and accounting records.
  • To secure the service — rate limiting, abuse detection, audit logging, incident investigation.
  • To improve accuracy — using research library data, and customer captures only where explicitly opted in.
  • To comply with law — statutory record-keeping and lawful requests.
  • To send updates — only where you asked for them, and unsubscribe is one click.

7. Lawful bases

Where the EU or UK GDPR applies, we rely on:

PurposeLawful basis
Providing the service to a customerPerformance of a contract
Responding to enquiriesLegitimate interests — answering people who contact us
Security, fraud and abuse preventionLegitimate interests — keeping the service safe
Optional analytics cookiesConsent
Marketing emailsConsent
Research contributionExplicit consent
Statutory recordsLegal obligation

Where Singapore's Personal Data Protection Act applies, we rely on consent, deemed consent, or the legitimate interests exception as appropriate to each purpose above.

8. Who we share it with

We share personal data only with service providers who need it to run the service, each under a written contract that restricts them to our instructions:

  • Cloud infrastructure — hosting and processing, in the region you are pinned to.
  • Email delivery — transactional and, where consented, update emails.
  • Payment and invoicing — we never see or store full card details.
  • Error and performance monitoring — with personal data scrubbed from traces where feasible.
  • Professional advisers — accountants and lawyers, under professional duties of confidence.

A current list of sub-processors is provided to customers on request and, for Enterprise agreements, is maintained under a contractual notification obligation before any addition takes effect.

We do not sell personal data. We do not share it for third-party advertising. If ExactHue is ever involved in a merger, acquisition or asset sale, personal data may transfer as part of that transaction, and we will notify affected individuals before it becomes subject to a materially different policy.

9. International transfers

ExactHue operates from Singapore, and our infrastructure providers operate globally. Singapore is not covered by a European Commission adequacy decision, so where personal data of individuals in the EEA or the UK is transferred to us we rely on Standard Contractual Clauses (with the UK Addendum where applicable), supported by a transfer risk assessment. Where a particular destination is covered by an adequacy decision, we rely on that instead.

Customers on Enterprise plans can pin processing to EU, UK, US or APAC regions so that capture data does not leave the chosen region during processing.

10. How long we keep it

DataRetention
Captures submitted to ExactHue CoreDeleted after processing; not retained by default
Match results and derived colour valuesAggregated and de-identified within 30 days
Account recordsDuration of the account, then 30 days after termination
Enquiry correspondence24 months from last contact
Contracts, invoices and tax recordsAs required by law, typically 5–7 years
Security and audit logs12 months
Research samplesUntil withdrawal, or 5 years from collection, whichever is sooner
Marketing consent recordsUntil you unsubscribe, plus proof-of-consent record

11. How we protect it

Encryption in transit (TLS 1.2 or above) and at rest; least-privilege access with multi-factor authentication for staff; credentials scoped per environment so a sandbox key cannot reach production; audit logging; dependency and vulnerability scanning; and an incident response process with a defined notification path. Further detail, including what is not yet in place, is on our security page.

No system is perfectly secure. If a breach affects your personal data and poses a risk to you, we will notify you and the relevant supervisory authority within the timeframes the law requires.

12. Your rights

Depending on where you are, you may have the right to:

  • Access — obtain a copy of the personal data we hold about you.
  • Rectification — correct data that is inaccurate or incomplete.
  • Erasure — ask us to delete data where there is no overriding reason to keep it.
  • Restriction — ask us to pause processing while a dispute is resolved.
  • Portability — receive data you gave us in a structured, machine-readable format.
  • Objection — object to processing based on legitimate interests, and to direct marketing at any time.
  • Withdraw consent — where processing relies on consent, withdraw it without affecting prior processing.
  • Complain — to your supervisory authority. In the UK that is the Information Commissioner's Office; in Singapore, the Personal Data Protection Commission. We would appreciate the chance to resolve it first.

How to exercise each of these, step by step →

Write to privacy@exacthue.com. We acknowledge requests within 72 hours and respond within one month, extendable by two months for complex requests, in which case we will tell you why. Exercising these rights is free; we will not penalise you for it.

If your data was processed by ExactHue Core inside a brand's storefront, that brand is the controller. Send your request to them, and we will support them in fulfilling it — or send it to us and we will route it.

13. Children

ExactHue Core is licensed for use by adults. Our website and console are not directed at children, and we do not knowingly collect personal data from anyone under 16. Our brand customers are contractually required not to deploy the engine to audiences under the applicable age of digital consent. If you believe a child's data has reached us, write to privacy@exacthue.com and we will delete it.

14. Cookies

We use a small number of strictly necessary cookies, and optional analytics cookies only with your consent. The notice you saw on arrival records that choice. Full detail, including names and durations, is in the cookie policy.

15. Changes to this policy

We update this policy when our practices change. The effective date and version above always reflect the current text. For material changes affecting how we use data you have already given us, we will notify account holders by email at least 30 days before the change takes effect, and we keep prior versions available on request.

16. Contacting us

Privacy questions and rights requests: privacy@exacthue.com
General enquiries: hello@exacthue.com
Security disclosures: security@exacthue.com

By post:
Data Protection
ExactHue Pte. Ltd.
352 Yishun Ring Road
Singapore 760352

ExactHue Pte. Ltd. · Registered with the Accounting and Corporate Regulatory Authority (ACRA), Singapore.