Privacy Policy

This Privacy Notice for Crepz Limited ('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:

• Visit our website at https://crepz.ai or any website of ours that links to this Privacy Notice
• Download and use our mobile application (Crepz), or any other application of ours that links to this Privacy Notice
• Use Crepz - a mobile application that helps users discover and find trainers (sneakers) using AI-powered recommendations. Users can search for trainers by brand, style, or occasion, upload photos of outfits for matching trainer suggestions, and save their favourites. The app provides links to third-party retailers where users can purchase recommended products.
• 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 privacy@crepz.ai.

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide 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.

Personal Information Provided by You. The personal information we collect may include:

• Names
• Usernames
• Email addresses
• Style preferences and favourite brands
• UK shoe size and budget preferences
• Age range (for personalisation)

Sensitive Information. We do not process sensitive information.

Application Data

Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out, you may turn them off in your device's settings.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, including:

• To deliver services to the user. We process your information to provide you with the requested service.
• To respond to user inquiries/offer support. We process your information to respond to your inquiries and solve any potential issues.
• To send administrative information. We may send you details about our products and services, changes to our terms and policies.
• To protect our Services. We process your information as part of our efforts to keep our Services safe and secure.
• To identify usage trends. We process information about how you use our Services to better understand how they are being used.
• To provide personalised AI-powered recommendations. We process your search queries, style preferences, and browsing behaviour to generate relevant trainer recommendations.
• To process and analyse user-submitted photos for outfit matching. When you upload an outfit photo, we process the image using AI to suggest matching trainers.
• To enforce subscription usage limits. We track search usage to enforce free tier limits and manage premium subscription entitlements.
• To personalise content based on user preferences. We use your saved preferences to customise the recommendations you receive.

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:

The GDPR and UK GDPR require us to explain the valid legal bases we rely on:

• 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.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you.
• Legitimate Interests. We may process your information when reasonably necessary to achieve our legitimate business interests, such as:
  • Analyse how our Services are used so we can improve them
  • Diagnose problems and/or prevent fraudulent activities
  • Provide personalised AI-powered product recommendations
• Legal Obligations. We may process your information where necessary for compliance with our legal obligations.
• Vital Interests. We may process your information where necessary to protect vital interests.

If you are located in Canada:

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

4. When And With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf. We have contracts in place with our third parties to help safeguard your personal information.

The third parties we may share personal information with are:

• AI Service Providers: Google Cloud AI (Gemini)
• Third-Party Account Connections: Google account, Apple account
• Cloud Computing Services: Google Cloud Platform, Railway
• Invoice and Billing: Apple Pay and Google Play Billing

We may also share your information in these situations:

• Business Transfers. We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

5. What Is Our Stance On Third-Party Websites?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications. We do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. You should review the policies of such third parties and contact them directly to respond to your questions.

6. Do We Use Cookies And Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

7. Do We Offer Artificial Intelligence-Based Products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, 'AI Products'). These tools are designed to enhance your experience and provide you with innovative solutions.

Use of AI Technologies

We provide the AI Products through third-party service providers ('AI Service Providers'), including Google Cloud AI. Your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products.

Our AI Products

• AI-powered trainer recommendations based on user queries
• Outfit photo analysis for matching trainer suggestions
• Natural language understanding for conversational search

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties, ensuring high security and safeguarding your personal information.

8. Is Your Information Transferred Internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the Netherlands and United Kingdom. If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

9. How Long Do We Keep Your Information?

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

• Account data: Retained while your account is active
• Chat history: 12 months, then anonymised
• After account deletion: 30 days to fully remove from all systems

10. How Do We Keep Your Information Safe?

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

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. 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. You should only access the Services within a secure environment.

11. What Are Your Privacy Rights?

In Short: Depending on your state of residence in the US or in some regions, 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, you have certain rights under applicable data protection laws. These may include:

• To request access and obtain a copy of your personal information
• To request rectification or erasure
• To restrict the processing of your personal information
• If applicable, to data portability
• Not to be subject to automated decision-making

You can make such a request by contacting us at privacy@crepz.ai. 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 believe we are unlawfully processing your personal information, you have the right to complain to your Member State data protection authority or UK data protection authority.

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 by contacting us at privacy@crepz.ai.

Cookies and similar technologies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. For further information, please see our Cookie Notice.

12. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals. 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.

14. 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 'Revised' date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

15. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at privacy@crepz.ai or contact us by post at:

For California residents: We will respond to verifiable consumer requests within 45 days.

For UK/EU residents: You may also contact the Information Commissioner's Office (ICO) if you have concerns about how we handle your data.

16. 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, 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. To request to review, update, or delete your personal information, please email us at privacy@crepz.ai.