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Data Sharing Policy

Last updated: January 2025

This policy explains how and when we share your data with third parties.

1. Categories of Data Shared

Essential Data (always shared for service operation):

  • Authentication tokens (with Apple/Google)
  • Payment information (with Apple/Google for subscriptions)
  • Chat content (with AI providers for recommendations)

Optional Data (with your consent):

  • Anonymous usage trends (with analytics providers)
  • Style profile data (with partner brands for offers)

2. Third-Party Processors

AI Services

  • Provider: Google (Gemini AI)
  • Purpose: Process conversations for recommendations
  • Data: Chat messages, style preferences
  • Location: EU/UK data centres
  • Retention: Messages deleted after processing

Authentication

  • Providers: Apple, Google
  • Purpose: Secure sign-in
  • Data: Email, name, profile photo (if provided)

Hosting & Infrastructure

  • Provider: Railway (cloud hosting)
  • Purpose: App backend services
  • Location: EU region
  • Security: Encrypted at rest and in transit

3. Your Consent Choices

In the app (Profile > Data & Privacy), you can control:

Anonymous Data Sharing

  • Aggregated trends and usage patterns
  • No personally identifiable information
  • Helps improve recommendations for everyone

Style Profile Sharing

  • Share preferences with partner brands
  • Receive personalised offers
  • Can opt out anytime

Note: Users under 18 have data sharing disabled by default for their protection.

4. California Privacy Rights (CCPA)

California residents have additional rights:

  • Do Not Sell or Share: Opt out of sharing your style profile with partners in the app under Profile > Data & Privacy > California Privacy Rights
  • Right to Know: Request information about what data we share
  • Right to Delete: Request deletion of shared data

We will respond to verifiable consumer requests within 45 days.

5. Data Sharing Log

We maintain a log of all third-party data sharing, accessible in the app under Profile > Data & Privacy > View Data Sharing Log.

6. International Transfers

Your data may be processed outside the UK. We ensure:

  • Adequate protection through standard contractual clauses
  • Compliance with UK GDPR requirements
  • Data processing agreements with all providers

7. Your Rights

You can:

  • View what data is shared (Data Sharing Log)
  • Withdraw consent anytime (affects future sharing only)
  • Request deletion of shared data
  • Lodge a complaint with the ICO

8. Changes to This Policy

We'll notify you of material changes via email or in-app notification. Continued use after changes means acceptance.

9. Contact

Data Protection queries:

Information Commissioner's Office:

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