Privacy policy Kledingkleuradvies
Version 2026-09. This policy explains which personal data we process when you order a colour advice, why, how long we keep it and what your rights are. We keep it as plain as we can; if you still have a question, e-mail us. This is a translation of our Dutch "Privacyverklaring"; if the two differ, the Dutch text prevails.
1. Who is responsible
Beste Prijs, Schapendreef 455, 3034 ZM Rotterdam, Dutch Chamber of Commerce (KVK) 74982591, is the controller for the data you share with us through Kledingkleuradvies. Contact: advies@kledingkleuradvies.nl. We reply within 1 working day. We have no data protection officer; all privacy questions go to this address.
2. In short
- Your photos stay on our server for at most 36 hours and are deleted right after delivery.
- Your photos show your face. We use them solely to measure colours, not to recognise or identify you.
- For the photo check and the wardrobe check we send some of your photos to our AI provider Anthropic. Your eye and wrist photos are never sent to an AI.
- We do not sell data, do not share it for advertising and never use your photos to train AI models.
- Until your advice is approved you can have everything deleted by cancelling your order.
- There are no tracking cookies. Only your language choice is remembered in your browser.
3. Which data we process
| Data | Where it comes from |
|---|---|
| E-mail address, language, chosen delivery option, whether you added the wardrobe check | You, when ordering |
| Photos: close-up of one eye, inside of your wrist, face (outdoors and indoors), side view, hair, five photos in different tops; optionally up to three photos of your clothes | You, through the upload page |
| Answers to the short questionnaire: hair dyed (yes/no) and your natural hair colour, no hair or head covering (yes/no), coloured lenses (yes/no), a note of at most 500 characters | You, through the upload page |
| Measurements derived from your photos: colour values of skin, eyes and hair, your position on the four axes, your palette, the outcome of the comparison of your tops, and the text of your advice | Our software and our colour expert |
| Photo-check result per photo (for example "paper found", "not sharp", "glasses") | Our software and the AI provider |
| Payment data: amount, payment method, status, Mollie payment and refund identifiers, invoice number | Mollie; we never see your account or card number |
| Consents: which boxes you ticked, when, the version of the text and a hashed version of your IP address | You, when ordering |
| Technical data: timestamps, order status, error messages, IP address for abuse limiting (short-lived and hashed in logs), whether e-mails to you were delivered or bounced | Our server and our e-mail provider |
We do not ask for your name, address, date of birth or gender. The invoice is a simplified invoice without name and address.
4. Purposes and legal bases
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Accepting your order, securing your order page, e-mailing you about your order | E-mail address, language, delivery option, status, technical data | Performance of the contract (art. 6(1)(b)) |
| Analysing your photos and producing your colour advice | Photos, questionnaire, measurements, photo check | Your explicit consent (art. 6(1)(a) and art. 9(2)(a)), see section 5 |
| Processing the payment and issuing an invoice | Payment data, invoice number | Performance of the contract; legal obligation (art. 6(1)(c): fiscal retention) |
| Refunding and issuing retry codes | Payment data, e-mail address | Performance of the contract |
| Proving that you gave consent and accepted the terms | Consents with timestamp, version and hashed IP address | Legal obligation (accountability, art. 7(1)) |
| Preventing abuse, spam and attacks; fixing errors | IP address (hashed, short-lived), technical logs | Legitimate interest (art. 6(1)(f)): a safe, working service |
| Handling complaints and disputes | Order data, correspondence | Legitimate interest; legal obligation |
We do not use your data for advertising, newsletters, profiling or behaviour tracking. You only receive e-mails that belong to your order.
5. Your photos: what we do and do not do
They show your face. That is unavoidable: we measure the colour of your skin, eyes and hair. Photos of a face can also say something about your ethnic origin, your health (for example a skin condition) or your religion (for example a head covering). That is why we ask for your explicit consent beforehand and treat your photos as special-category personal data, even though we use them only for colours.
We do not identify you. Our software uses face and eye detection only to find where in the photo your skin, iris and hair are. From that we calculate colour values. We do not build a face profile or "template" to recognise you, we do not compare your photos with other photos or databases, and the temporary landmark points are discarded after the measurement. Our software and our AI instructions forbid inferring or mentioning ethnic origin, religion or health; the advice is exclusively about warm–cool, muted–clear, light–deep and contrast.
Your browser does the preparation. Before a photo leaves your phone or computer: - all metadata is removed (location, date, device, colour profile); - the photo is reduced to at most 1600 pixels; - for face, hair and top photos the background is replaced by grey so your surroundings are not included (the white paper stays visible); - the eye and wrist photos are cropped to just the eye or wrist; - on wardrobe photos you can grey out parts yourself.
You see exactly what will be uploaded before it is sent. What we cannot mask automatically: reflections (for example in glasses) and the background of wardrobe photos. So make sure only you are in the picture; we cannot use a photo with more than one person.
On our server your photos are rebuilt without metadata and stored encrypted with a key that applies to your order only (section 9).
After delivery we immediately delete the photos, the intermediate results and the photo-check results. If the advice is not delivered within 36 hours after payment, we delete them at that point regardless.
6. Artificial intelligence (AI)
An AI system plays a role in our service. We say so clearly here, as the EU AI Act requires.
What the AI does - Photo check on upload: the AI model judges whether a face, hair, top or wardrobe photo is usable (paper visible, sharp, good light, one person, no filter). The result is a set of codes that we translate into the message you see. - Wardrobe check (only if you order it): the model recognises garments and their colours in your wardrobe photos. - Text of the advice: the model drafts a text based on numbers and names only (your measurements, your position on the axes, your palette, the comparison results and your questionnaire answers). No photos are sent for the text.
What the AI does not do - Your eye and wrist photos are never sent to an AI; we check those only with software on our own server. - The AI system makes no decisions about you. The final assessment of your advice and of your photos is made by our colour expert, a person. A rejection, refund or retry is always decided by that person. - Nothing you upload is used to train AI models. Not by us and, under our agreements with the provider, not by the provider either.
Who provides the AI. We use models from Anthropic. Your face, hair, top and (if ordered) wardrobe photos are sent to Anthropic for the photo check and the wardrobe check, together with a short instruction. Anthropic processes the photos as a processor, on our instructions, under a data processing agreement. Anthropic retains request data [FILL IN RETENTION: for example "for no longer than 30 days, solely for abuse detection" or "not at all (zero data retention)"; verify this in the agreement with Anthropic] and does not use it to train models.
Transfers outside the EU. [FILL IN: pick the text that matches the chosen configuration.] - If an EU region is used: The AI models run in a data centre inside the European Union ([fill in region]); your photos do not leave the EU. - If the direct Anthropic API is used: Processing takes place in the United States. Anthropic is certified under the EU-US Data Privacy Framework [verify] and in addition the European Commission's standard contractual clauses (SCCs) are in place. You can request a copy of those clauses from us.
The model we use may change; the name of the provider is always kept current in this policy and next to the consent box.
7. Who we share data with
We do not sell data and do not share it with advertisers. The following parties process data for us:
| Party | What | Role | Where |
|---|---|---|---|
| [HOSTING PROVIDER, city/country to fill in] | Our server, storage and backups run there | Processor | [EU country to fill in] |
| Mollie B.V., Amsterdam | Payment and refunds; Mollie does not receive your e-mail address from us, only the amount, a description with your order number and the language of the payment page. Mollie naturally sees the data you enter yourself when paying | Independent controller (see Mollie's privacy policy) | EU |
| [E-MAIL PROVIDER, for example Postmark (ActiveCampaign) or your SMTP provider, to fill in] | Sending our e-mails to you, including the PDF attachment; records whether an e-mail was delivered or bounced | Processor | [country/region to fill in; for a US party: EU-US DPF/SCCs] |
| Anthropic | Photo check, wardrobe check and draft text (section 6) | Processor | [see section 6] |
Beyond this we share data only when the law obliges us to, for example on a lawful demand by a competent authority.
8. How long we keep data
| Data | Retention |
|---|---|
| Photos, intermediate results, measurement file, draft text, photo-check results | Deleted immediately after delivery of your advice. At the latest 36 hours after payment, even if nothing was delivered |
| Photos of an order that was not paid for | 3 days (72 hours) after your last activity; then deleted. You receive one reminder before that |
| Approved photos after a rejection with a retry code | At most 7 days, so you only need to retake the photos we point out; earlier once your retry is delivered |
| Report (PDF) and zip with images | 14 days after delivery, downloadable from your order page; then deleted |
| Your note, natural hair colour, expert's notes, error messages | Wiped when the photos are deleted |
| Order data: e-mail address, status, timestamps, amounts, consents, invoice number | 1 year after the order for support and disputes; after that your e-mail address is replaced by an unrecognisable hash |
| Simplified invoice and any credit note (amounts, date, invoice number, no name or address) | 7 years (statutory fiscal retention) |
| E-mails at our e-mail provider | [Fill in: for example 7 days at Postmark; attachments not stored / verify] |
| Backups (database and invoices only, never photos) | 30 days |
| Technical logs | Short: overwritten automatically after about 50 MB, usually within a few weeks |
Deletion is thorough: when we wipe your photos we also destroy the encryption key of your order, which makes any remnants on disk or in backups unreadable.
9. Security
- All connections use HTTPS.
- Your photos and report are stored encrypted with a key per order; that key is itself encrypted with a master key that is not kept in the same place as the data.
- Your order page can only be reached through the link in your e-mail. That link starts a secure session in your browser; the secret from the link never appears in a web address we share with Mollie or anyone else.
- Our own review page sits behind a separate login for the colour expert.
- We store no passwords of yours, because you have no account.
- Honest about the limits: encryption protects against loss of disks, snapshots and backups. It does not protect against an attacker who fully takes over the running server. That is why we keep your photos as briefly as possible.
Should there nevertheless be a data breach that poses a risk to you, we report it to the Dutch Data Protection Authority and inform you by e-mail.
10. Cookies and local storage
We use no tracking cookies, no third-party analytics and no social-media buttons.
- Language choice: your chosen language (Dutch or English) is kept in your browser's local storage (localStorage). It never leaves your browser.
- Session cookie for your order (
order_session): as soon as you open the link from your e-mail, our server sets a functional, secure cookie that lets your browser view your order page. Valid for 7 days. The order page does not work without it. - Session cookie for the administrator: only on our own review pages, not for customers.
These functional cookies do not require consent, so we show no cookie banner.
11. Your rights
You have the right to: - access the data we hold about you; - have data corrected (for example your e-mail address; until payment you can also do this yourself on your order page); - have data erased. You erase photos yourself by cancelling your order; we erase order data on request, except the invoice data we must keep for 7 years by law; - withdraw your consent for processing your photos, until your advice is approved, by cancelling your order. You then get your money back. Withdrawal does not affect processing that was lawful before it; - object to processing based on our legitimate interest; - have processing restricted; - take your data with you (portability): your report and the zip can be downloaded for 14 days; other data we send you on request in a common file format.
E-mail your request to advies@kledingkleuradvies.nl from the e-mail address of your order, or mention your order number. We reply within 1 working day and handle your request within one month. We do not ask for a copy of your ID; the e-mail address of your order is enough.
If you feel we are not handling your data properly, you can lodge a complaint with the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). If you live in another EU country you may also contact your own supervisory authority. We would of course rather hear from you first.
12. No automated decisions with effects on you
The measurement and the draft text are automated, but every advice is assessed and approved by a person before it is sent to you. A rejection, refund or retry is also decided by a person. So there is no decision based solely on automated processing that has legal effects on you.
13. Children
Our service is for people aged 16 and over. When ordering you confirm that you are 16 or older. If our software or our expert suspects that a photo shows a child, the photo is not used and we get in touch. Do you think a child has ordered without permission? E-mail us; we delete the data.
14. Changes
We update this policy when our service or the law changes. The version at the top shows when that last happened. For a material change in how we use your photos we ask for your consent again.
15. Contact
Beste Prijs Schapendreef 455, 3034 ZM Rotterdam KVK 74982591 advies@kledingkleuradvies.nl