PRIVACY POLICY

Last updated: June 25, 2026

This Privacy Notice for Unnamed Development LLC ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application Terrosa, or any other application of ours that links to this Privacy Notice
• Use Terrosa. Terrosa is a mobile application that uses your device camera to analyze your skin tone and recommend a personalized seasonal color palette. The App captures a still image, performs all analysis entirely on-device using Apple's CoreImage framework, and returns your seasonal color type (from a 12-season system) along with personalized guidance for clothing, makeup, and accessories. Premium features include a Closet Scanner (match scanned garments against your palette) and Color History (review past analyses). No photos or analysis data are ever transmitted off your device.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@unnameddev.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice. You can find more details about any of these topics by using the table of contents below.

What personal information do we process? Very little. The App stores analysis results (your seasonal color type, undertone, and a dominant skin color hex value) locally on your device using SwiftData. This data never leaves your device and we cannot access it. See Section 1 for full details.

Do we process any sensitive personal information? The App analyzes skin tone to derive a seasonal color classification. The resulting data (a season label and hex color string) is stored only on your device and is never transmitted. We do not process or retain the underlying photograph. See Section 1.

Do we collect any information from third parties? No. We do not collect any information from third parties.

How do we process your information? We process locally stored information to provide the App's core features — Color History and Closet Scanner — which depend on retaining your past analysis results on-device. See Section 2.

In what situations and with whom do we share personal information? We do not share, sell, or disclose your personal information to third parties, except in the event of a business transfer as described in Section 4.

How do we keep your information safe? All personal data is stored in your device's protected app sandbox using SwiftData. The app makes no network requests and transmits no data to any external server. See Section 7.

What are your rights? Depending on where you are located, the applicable privacy law may grant you certain rights regarding your personal information. See Section 9.

How do you exercise your rights? You can exercise your rights by contacting us at support@unnameddev.com or by phone at (213) 545-6196. Most locally stored data can be deleted directly by uninstalling the App.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

In Short: We collect very little personal information. No photos are ever stored or transmitted. Analysis results are stored locally on your device only.

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect may include the following:

• Support communications: if you contact us via email, we receive your email address and the content of your message.

Sensitive Information. The App uses your device camera to capture a still photograph of your skin for the sole purpose of deriving a seasonal color classification. This photograph is processed in device memory by Apple's CoreImage framework (CIAreaAverage) and is never written to disk, never stored in any database, and never transmitted off your device. The output of this processing — a seasonal label (e.g., "True Winter"), an undertone classification (e.g., "Cool"), a dominant skin color expressed as a hex value, and a luminosity float — is stored locally on your device using SwiftData. This data never leaves your device. We do not receive, access, or process this information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by Apple Inc. You may find their privacy notice at: https://www.apple.com/legal/privacy/. All subscription purchases for Terrosa are processed by Apple Inc. through the App Store and StoreKit. We do not receive, process, or store any payment card information, billing addresses, or other financial details — this information is collected and managed solely by Apple in accordance with Apple's Privacy Policy. The App receives only a cryptographic boolean indicating whether your subscription entitlement is active, which is cached locally on your device.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information collected automatically

In Short: No information is automatically collected. The App makes no network requests and uses no analytics, advertising, or crash-reporting SDKs.

Unlike many apps, Terrosa does not automatically collect any data through the Services. There is no analytics SDK (no Firebase, Mixpanel, Amplitude, or equivalent), no advertising SDK (no AdMob or equivalent), no crash-reporting SDK (no Crashlytics or Sentry), and no backend server. The App contains no URLSession calls and makes no network requests outside of Apple's own StoreKit framework (which is governed by Apple's privacy policy).

Third-Party Frameworks

All third-party code used by Terrosa is Apple-provided system frameworks:

• StoreKit 2 — subscription purchase and verification. Apple's servers handle all payment processing. See Apple's privacy policy for details.
• AVFoundation — camera session management. Camera frames are sampled in memory only; no frames are stored.
• CoreImage — CIAreaAverage filter for on-device skin color extraction.
• SwiftData — on-device SQLite database. No CloudKit container is configured; data never leaves the device.

Local Storage Details

The following data is stored locally on your device in the app's protected sandbox and is never transmitted or accessible to us:

UserDefaults (app sandbox, never synced to iCloud):

• Subscription entitlement cache (boolean)
• UserProfile struct: last season name, analysis count

SwiftData database (app sandbox, never synced):

• AnalysisHistoryEntry — date, season string, undertone string, dominant color hex string, skin luminosity float
• ClosetItem — date, dominant color hex string, match result string, season name string

Photo library (write-only): The App requests add-only photo library access. This permission is used only when you explicitly tap the share button and choose to save a generated share card PNG to your photo library. The App never reads from your photo library.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process locally stored information to provide the App's features. No data is processed on external servers.

We process your personal information for the following purposes:

• To deliver and facilitate delivery of services to the user. We process locally stored analysis results to power the Color History feature (displaying your past seasonal color analyses) and the Closet Scanner feature (matching garment colors against your palette).
• To fulfill and manage your orders. We process subscription entitlement data (a boolean cached locally) to determine which premium features are available to you.
• To respond to user inquiries and offer support. We process your name and email address when you contact us for support.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. We may rely on the following legal bases:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time by contacting us.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you. This covers processing subscription entitlement data to deliver premium features.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process locally stored analysis data in order to provide you with Color History access across sessions on your own device.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including for investigations and fraud detection and prevention, for business transactions provided certain conditions are met, and if disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We do not share, sell, or disclose your personal information to third parties. The only exception is a potential business transfer.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information belonging to users of the Services.

We may need to share your personal information in the following situation:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: The App makes no network requests and transmits no user data internationally. Subscription processing by Apple may involve international data flows governed by Apple's own privacy policy.

Terrosa contains no network requests from app code. All analysis, storage, and display of personal data occurs on your device. We do not operate servers that receive, store, or process user data from the App.

The one external communication that occurs is subscription management via Apple StoreKit, which involves Apple's servers. This is governed entirely by Apple's Privacy Policy (apple.com/legal/privacy/), not by this notice.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, please note that Apple, as our payment processor, may transfer data internationally. We will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

We have implemented measures to protect your personal information where applicable, including by using the European Commission's Standard Contractual Clauses for transfers of personal information. Our Standard Contractual Clauses can be provided upon request.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than 2 years.

Most personal information collected by the App — including your seasonal color analysis results, closet scan history, and undertone data — is stored locally on your device and retained only for as long as the App remains installed. This data is deleted automatically and permanently when you uninstall the App. We do not retain copies of this information on our servers.

Support communications (emails you send to us) are retained for as long as necessary to resolve your inquiry and comply with applicable legal obligations, and in any case no longer than 2 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. Key security properties of Terrosa include:

• All locally stored data resides in your device's protected app sandbox, inaccessible to other apps.
• No CloudKit or iCloud sync is configured — data never leaves your device via Apple's cloud services.
• Photos and camera frames are never written to disk and are discarded from memory immediately after processing.
• The App contains no network code that could transmit data to external servers.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 years of age or the equivalent age as specified by law in your jurisdiction, or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@unnameddev.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or your region, such as the EEA, UK, Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section How Can You Contact Us About This Notice? below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section How Can You Contact Us About This Notice? below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at support@unnameddev.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have certain rights regarding your personal information.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months.

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	NO
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	NO
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G. Geolocation data	Device location	NO
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics	NO
L. Sensitive personal information	Account login information, biometric data, health data, precise geolocation, and similar sensitive categories	NO

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to users and other consumers.

Note on locally stored data: The App stores seasonal color analysis results (a season label, undertone label, hex color value, and luminosity float) locally on your device using SwiftData. This data never leaves your device and we cannot access it. Because we never receive this data, it does not constitute personal information "collected" by us within the meaning of applicable US state privacy laws.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at support@unnameddev.com, by calling us at +1 (213) 545-6196, or by referring to the contact details at the bottom of this document.

Note that most data held by the App is stored locally on your device. You can delete this data at any time simply by uninstalling the App.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at support@unnameddev.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section How Can You Contact Us About This Notice?

12. COLOR ANALYSIS DISCLAIMER

The App allows you to use your device camera to capture a still image for the purpose of on-device skin tone analysis and seasonal color palette classification. The image is analyzed entirely on-device and is never stored on disk or transmitted to us or any third party.

The locally stored outputs of this analysis — your seasonal color label, undertone classification, dominant skin color hex value, and luminosity measurement — are used solely to power the App's Color History and Closet Scanner features on your device. This information is not used to create a medical or biometric profile, is not shared with healthcare providers, and does not constitute medical, dermatological, or professional styling advice.

Seasonal color classifications are based on an algorithmic interpretation of a widely used but inherently subjective color theory framework. Results may vary based on lighting conditions, camera hardware, skin preparation, and other factors. See our Terms and Conditions for additional disclaimers regarding the informational nature of the App's color analysis features.

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@unnameddev.com or contact us by post at:

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please email us at support@unnameddev.com.

Deleting locally stored data: Because most of your data is stored only on your device and is inaccessible to us, the most complete way to delete your Terrosa data is to uninstall the App. This permanently removes all SwiftData records (Color History, Closet Scanner history) and all UserDefaults entries from your device. If you reinstall the App, it will start fresh with no prior data.