Privacy Policy

Last updated: 13 August 2026

Introduction
Data Controller
Data We Collect
How We Use Data
Legal Basis for Processing (GDPR)
AI Image Analysis
Automated Decision-Making
Data Sharing and Sub-processors
Data Retention
Your Rights (GDPR)
Data Security
International Transfers
Cookies
Children's Privacy
Changes to This Policy
Contact

1. Introduction

This policy explains what happens to your data when you use Estima at estima.lazo.build (the "Service"), operated by LAZO.

The short version, before the detail:

We do not store your photographs. They are held in memory for the length of a single request, used to produce your reading, and discarded. They are never written to disk, never placed in storage, and never attached to your account.
Your photographs are sent to Google to be analysed. On the free service tier we currently use, that has real consequences, and section 6 sets them out plainly rather than burying them.
We keep the reading and the result built from it, not the images they came from.
You can export everything, and delete everything, from the settings page.

2. Data Controller

The data controller is LAZO, an independent one-person studio that builds and operates its own products. The controller is an individual, not a company.

For anything in this policy, including access, correction, deletion and export requests, contact support@lazo.build. Requests sent there reach the controller directly.

3. Data We Collect

3.1 Account Data

When you sign in with Google we receive your email address, your name as held by Google, and your Google account identifier. We never receive or hold your Google password.

3.2 Profile Data

Whether you have short or long hair, which decides only which haircuts you are shown, your language, the fact that you accepted the Terms, and the fact that you confirmed you are 18 or over, each with a timestamp.

Your age confirmation is calculated in your browser. We do not receive or store your date of birth, only the outcome of the check.

3.3 Photographs

Held in memory for the duration of a single request, and only for as long as the analysis takes. Never written to disk, never placed in object storage, never linked to your account, and never retained after the request ends.

3.4 Readings and Results

What the analysis returns about the photographs: face shape, jawline, forehead, undertone, depth, contrast, chroma, eye colour, natural hair colour, hair texture, how light or dark your skin, hair, eyebrows and eyes read on a scale of 1 to 10, an assessment of the lighting, a confidence value, and any image quality flags.

Alongside it we store the result built from that reading, and the version of the reference data and prompt used.

3.5 Feedback You Send Us

If you tell us whether a reading matched you, we store your verdict (right, partly or wrong), which part of the reading it was about, and the optional note you type, up to 280 characters. It is stored against your account and the reading it belongs to.

Sending feedback is entirely optional and it never changes your reading. We use it to find where the reference data is systematically off. If you delete your account, your feedback goes with it.

3.6 Usage Data

How many scans you have run in the current period, so that plan limits can be applied.

3.7 Technical and Anti-abuse Data

To keep the Service within the capacity of its AI provider and to prevent abuse, we hold short-lived counters keyed to a one-way hash of your IP address and to a random identifier stored in a cookie. We do not store your IP address itself, the hash is salted and cannot be reversed, and the counters expire automatically.

4. How We Use Data

To produce your reading and the styling result built from it
To save your scans so you can return to them, and to show your history
To apply plan limits and to keep the Service inside the daily capacity of its AI provider
To detect and prevent abuse, including repeated submissions of images that contain no face
To answer you when you write to us
To comply with the law where we are required to

We do not use your data for advertising, we do not profile you for marketing, and we do not sell it.

Consent (Art. 6(1)(a)): analysing your photographs, including their transmission to Google as described in section 6. You give it at upload and can withdraw it by not uploading again.
Contract (Art. 6(1)(b)): running your account and storing your scan history so the Service you signed up for works.
Legitimate interests (Art. 6(1)(f)): preventing abuse, applying usage limits, and keeping the Service secure and available, balanced against your rights.
Legal obligation (Art. 6(1)(c)): where processing is necessary to comply with the law.

Withdrawing consent does not affect processing that already happened.

6. AI Image Analysis

Your photographs are analysed by a third-party AI model. Specifically:

Provider: Google, through the Gemini API (Google Ireland Limited / Google LLC)
What is sent: only the photographs you upload for that scan, together with a fixed set of instructions. Your account data, your email and your previous scans are never sent
What comes back: a description of what is visible in the images, in a fixed structure. The model does not choose your season, your palette or your haircuts; those are read from our own reference data by our own code
Service tier: Estima currently uses Google's free tier. Under Google's Gemini API Additional Terms of Service, on that tier Google may use submitted content to provide, improve and develop its products, services and machine learning technologies, and human reviewers may read, annotate and process the input and the output
If you are in the EEA, Switzerland or the United Kingdom, Google states that it applies its paid-service data terms to all use, including free quota, which means content is not used to improve Google's products
If we move to Google's paid tier, this section will be updated and the difference will be visible here

This is the one part of the process that is not in our hands, which is why it is stated before you upload and not afterwards.

7. Automated Decision-Making

The reading is produced by an automated system, and the result is derived from it by a fixed rule table. There is no human review of your individual scan.

This processing does not produce legal effects concerning you or similarly significantly affect you within the meaning of Article 22 GDPR: it produces styling suggestions. It does not assess your health, your creditworthiness, your employment or your access to any service, and it does not rank or score you against anyone.

Where the system is uncertain, the Service says so. Where you disagree with a reading, you can tell us so, and say why if you want to. That feedback is stored alongside the reading and does not change it. Nothing about a reading is presented as a verdict on you.

We share data with the following providers solely to operate the Service:

Google (Google Ireland Limited / Google LLC) — image analysis through the Gemini API, and Google Sign-In
Supabase (Supabase, Inc.) — database, authentication and the counters used for usage limits. Our database is hosted in the European Union (Frankfurt)
Vercel (Vercel, Inc.) — application hosting and edge network
Paddle (Paddle.com Market Limited) — payment processing as Merchant of Record, once paid plans exist. No payment data is processed today

That is the entire list. If we add an anti-abuse check, analytics or any other processor, this section changes before it goes live. We may publish anonymised, aggregated statistics that cannot identify anyone. We do not otherwise share or sell your personal data.

You can create a public link to one of your readings. It is off by default and nothing is public until you turn it on.

A share link shows only your colour season, its one-line description, and its five colours.
It does not contain your photographs, your face shape, your undertone, depth, contrast, or any haircut advice. Those stay behind your sign-in.
It does not contain your name or your email address.
Anyone who has the link can open it without signing in. That is the point of the link, so treat it like anything else you post.
Share pages are marked noindex, so we do not put them in search engines. We cannot control what someone else does with a link after you give it to them.
You can turn the link off at any time, from the reading it belongs to. It stops working immediately and permanently: if you switch sharing on again you get a brand new link, and the old one never works for anyone again.

We never create a share link for you, and we never share a reading on your behalf.

9. Data Retention

Photographs: not retained at all. Discarded within the request that produced your reading
Readings, results and profile: kept while your account exists, until you delete them or delete your account
Usage counters: kept per period so limits can be applied
Anti-abuse counters: hours to days, then they expire automatically
Feedback: kept while your account exists, and deleted with it
Share links: the link exists only while you leave sharing on. Turning it off deletes the token and the link stops working permanently
After account deletion: your profile, scans, feedback, share links and sign-in record are deleted immediately, not on a schedule
Deletion records: we keep an anonymous record that a deletion happened, containing no personal data, as evidence of compliance
Backups: residual copies may persist in our provider's backups for a short period after deletion

You have the rights of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), objection (Art. 21) and withdrawal of consent (Art. 7(3)), as well as the right to lodge a complaint with a supervisory authority in your country.

Two of these are built into the product rather than left to email:

Export: the settings page downloads everything held about you as a JSON file
Erasure: the settings page deletes your profile, every scan and your sign-in record, at once and irreversibly

For anything else, write to support@lazo.build. We answer within 30 days and may need to verify your identity first.

11. Data Security

Encryption in transit: all traffic uses TLS
Encryption at rest for stored data, through our database provider
Row level security: database policies mean a signed-in user can only ever read their own rows, enforced by the database itself rather than by application code
No photograph storage: the strongest protection for an image is never keeping it, and that is the design
Administrative keys are held server side only and never reach the browser

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. International Transfers

Your data may be processed outside the European Economic Area, including in the United States, where providers such as Google and Vercel operate infrastructure. Where data is transferred outside the EEA we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses or an adequacy decision. Section 6 describes the transfer that matters most in your case.

13. Cookies

We set only what is strictly necessary to operate the Service: your sign-in session, the outcome of your age confirmation, and a random identifier used to count scan attempts. There are no advertising, tracking or analytics cookies, which is why you are not asked to dismiss a consent banner. Each cookie is listed in the Cookie Notice.

14. Children's Privacy

The Service is intended only for people aged 18 or over, which is higher than the age of digital consent under Article 8 GDPR. We ask for age confirmation before the first scan and we do not knowingly process the data of anyone under 18.

If you are a parent or guardian and you believe a person under 18 has used Estima, write to support@lazo.build and the account and all associated data will be deleted promptly.

15. Changes to This Policy

If this policy changes materially we will make it visible in the Service. The date at the top always reflects the current version. Changes that affect what happens to your photographs will be stated before you upload, not only here.

16. Contact

LAZO Email: support@lazo.build