Here are few key points about our privacy practices:
• We are an AI-powered platform that serves as a professional stylist while you shopping online. We make a personal recommendation of the clothes (or say if the selected items match your style) and ready-to-wear outfits by analyzing a photo of your face, figure type, height, gender and other information.
• We also make recommendation of the clothes that helps visually correct the figure. For that service you provide us with measurements of you figure.
• For services How to wear and Color Inspiration you can upload any photos you have to create outfits with them.
• For our work we use third-party cloud providers – specifically, Amazon Web Services.
• We do not use the photographs you provide, and other personal information's when you use the Service for any reason other than to provide you with the clothing recommendation and improve our Service. 1. Who is the data controller?
In order to provide you with the full range of DNA Style products and services, we may need to collect personal information about you which will be collected by the controller AI STYTLE BY DNA SLU
with VAT ES B-67543991, registered office at Aribau street, 185, 3rd
floor, 08021, Barcelona, Spain, and firstname.lastname@example.org
, hereafter "DNA Style".
DNA Style is legally obliged to safeguard and use your personal information in line with all laws concerning the protection of personal information, including the General Data Protection Regulation (EU) 2016/679.
Here's more on our privacy practices. Individuals located California should also read our Notice to Californian user below. 2. What information do we collect?
We will collect personal information appropriate to the service you choose to sign up to. "Personal Information" means information that can be used to identify you (whether alone or in combination with other data). The types of Personal Information that we may collect about you are:
via your camera or camera roll (if you have given us express permission to access your camera or camera roll), figure measurements, body type, height, gender and other that you provide when you use Service
, or your social media account
(if you choose to connect expressly to your social media account). We obtain only the specific images you chose to modify using the mobile application; we do not collect neither storage your photo albums even if you grant us your access to them.
· The Personal Information you provide to us In order to register
as a user of the mobile application and / or perform certain actions with us you must fill out the electronic registration form providing the necessary information for the provision of our service. The Personal Details form specifies the required data which must be filled in by you, the failure of you to provide these will mean you are unable to register (in the case of the registration form) or will not be able to perform certain actions with our Service or safe the results of your services. Also, being a registered the Service involves having a profile with open fields where you can indicate what you deem appropriate.
The data requested in the registration form is as follows: e-mail or social media account log-in details, username, name, surname, age, gender and password if using the e-mail to register. The extended registration data may be
required to make Service more personalized for you: Profile picture, Your location, favorite gender category of clothing, clothing size, favorite colors, price preference's and other information. Payment details
If you want to use paid service we do need your full name, ID number, post address, and financial data, like bank account, credit card number or apple ID if you use in-app payments. To receive the consultation:
Personal style or Color type you provide us your photographs, figure type, gender. For the Figure correction service you provide figure measurements. For other service you can provide any photographs you have in order to create the outfits.
· Application usage information
, such as information about how you use the Service and interact with us, including your preferred language, the date and time when you first installed the Service and the date and time you last used the Service. Your geolocation, to the extent you have configured your device to permit us to collect such information, date and time stamps associated with transactions, and locale preferences. Click-stream data (internet or other electronic information regarding you browsing history, search history, the web page visited before you came to our website, length of visit and number of page views, click-stream data meaning the page-by-page paths you take as you browse through our Services).
· Data we receive from third parties
(websites, services, and products when you interact with Social Features of our application).
· Purchase history
, if you choose to purchase the services and application subscription, such as confirmation that you are a paid subscriber to the application.
· Social media information
, if you choose to login to the DNA Style application or web site via a third-party platform or social media network such as Facebook, or Instagram Inc and etc or web portal where you are redirected form our Service. We may collect information from that platform or networks they provide us about you under their own privacy policies and/ or cookies from them (to which you has previously consented). We will try our hardest in order to not access more data than deemed necessary to ensure a good user experience and proper operation of the application.
· Device data
, such as your computer and mobile device operating system type and version number, manufacturer and model, device ID, push tokens, Google Advertising ID, Service ID for Advertising, browser type, screen resolution, IP address (and the associated country in which you are located), and other information about the device you are using to visit the application.
· Online activity data
, such as information about your use of and actions on the Service and the Sites, including pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens and etc.
· Data associated with the Cookies Policy:
see our Cookies policy
. 3. How do we use your personal data?
DNA Style will use your personal information for the following purposes: 1) to provide services to you that you have requested or related to; 2)commercial proposals: to let you know about other services in which you may be interested (where you have agreed to this); 3) to inform you about changes and improvements to the application and some cases. All this based on the principle of minimization by which the data we can deal with will be adequate, relevant and limited to those necessary in terms of the purposes for which they were collected and always respecting the user's will.
For the nature of the provided service, based on the pacifically use of the mobile application "DNA Style", this includes: Manage Your Account
If you provide us with Personal Information, we may use it to: (i) process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our programs; (ii) monitor and manage your account; (iii) track your shopping, deliver you any rewards or payments, and identify opportunities for rewards and/or offers; (iv) send you technical notices, updates, security alerts, and administrative messages; (v) provide you customer service regarding your account and reply to your questions, comments and requests; and (vi) comply with legal and regulatory provisions in force and with the competent judicial authorities in each geographical jurisdiction that the Company operates in. We may also use your information to assess risk and prevent fraud. To monitor your activity
on web portals that you are redirected to from the application or web site (usually e-commerce portals of fashion companies or online stores), including the registration of product purchases or potential purchases in order to tracking affiliate program and manage the relationship between Us and those responsible for such web portals Improve Our Services
We may process information through analyzing and monitoring usages and trends and performing statistical analyses to improve our Services and the websites, Service applications, marketing efforts, and the products and services of our affiliates to provide a better service to you in the future. We may also use this information to adapt Service content to be more likely be of interest to you. Also, we can internally use your photos in order to improve our service and train the neural networks for IT and scientific purposes. To display advertisements to you.
We can work with advertising partners to display advertisements within the Service. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled "Targeted online advertising." For compliance, fraud prevention, and safety.
We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or Service appropriate to: (a) protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. With your consent.
In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. To send you e-
mail about the features of our services. And also we will ask for your consent to send you advertising by email. To create anonymous, aggregated or de-identified data.
We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes or use for our internal business improves. To commercial purposes by sending electronic communications
: we only are able to do this communication if you have consented this previously. At the time of registration, we'll ask for your permission. In this sense we grant you'll be able to revoke the consent easily by pressing the button "unsubscribe" or by a similar way that you'll find in any commercial communication.
To sum up, we'll inform you the following purposes by category:
Category «a) Data from the forms on the Service and the User Profile»: the Service (especially the Website) may include forms that are clearly linked to specific purposes and this shall be indicated on the Service (eg data collected in the "contact form" will be processed for the purpose of responding to and communicating with those who wish to communicate with us).
Category «f) Data associated with the Cookies Policy» : will also be processed for the purposes stated in the Cookies Policy.
Category «h) Data included in the User Content»: will only be processed on behalf of DNA Style as data processors. 4.Which is the lawfulness of the data processing?
The legal basis for data processing and treatment is your consent granted to carry out the purposes described above, which will be requested at the moment in which the user registers with the platform and accepts the conditions of service.
Failure to provide the requested personal data or failure to accept this data protection policy means an impossibility to subscribe, register or receive information about the Provider's products and services.
In cases in which a prior contractual relationship between the parties exists, the legitimacy for the development of administrative, tax, accounting and labor obligations that might be necessary under current legislation shall be grounded on the prior existence of the commercial relationship established between the parties.
In any case, your voluntary subscription to DNA Style will be considered as a formal establishment of a contractual relationship between us and the User. This contractual relationship is an agreement in order to send and to receive information about the fashion industry, service features, newsletters, all kind of regular updates regarding clothing and any kind of accessories related to fashion and trends. The sending of all forms of communication regarding these fashion topics mentioned is to be considered part of the service contracted by you when subscribing to DNA Style. At any time, you may unsubscribe to any communications that they may not desire to receive or modify your profile settings in order to stop or rearrange any further notices or forms of communication.
To unsubscribe, you can go directly to the application at any time, enter into the section: "profile" and choose the option to unsubscribe.
In case the previous option is not enabled or does not work for any reason, you can also revoke your consent at any time by sending an email with the subject "User Low" to email@example.com, including in the content of the email your (username) and the email or username of the social network that you used when registering with the Service.
According to the LSSI, DNA Style does not perform SPAM practices, therefore, it does not send any commercial e-mails that have not been previously requested or authorized by you. Consequently, in all communications that you may receive from DNA Style you have the possibility of cancelling this express consent to receive our communications.
We shall not treat or process your personal data for any other purpose than those described except from those required by legal obligation or judicial requirement.
Data processing shall not be subject to decisions based on automated processing that may produce effects on your data. 5. How long will we keep your personal data?
Your data shall be kept while your business relationship with us lasts or to exercise your right of cancellation or opposition, or limitation to data processing. However, we shall keep certain personal identification and traffic data for a maximum period of 3 years in case it is required by Judges and Courts or in order to initiate internal actions derived from the improper use of the Service .About the photographs you hang up to use the services, we don't conserve that photos only the results of the consultation. Once we done the analytics, we don't need anymore this photo, so in accordance with the data minimization principle (art. 5 GDPR) we'll only keep for a few period of time (e.g. photos of your face only 6 months since your last visit and photo of the clothes for a 3 months) and after we'll delete it. 6. Will we share your personal data?
We do not disclose your photographs to third parties (with the exception of uploading an encrypted image to our cloud providers Google Cloud Platform and Amazon Web Services). Nevertheless, you could share your outfits photos in our feed or in your social medias, like Instagram, Facebook… but it concerns to you. We don't share them without your consent or knowledge.
We may share your non-photograph information in the following circumstances: Affiliates.
When we use third-party cookies and other tracking tools, our advertising partners may collect information from your device to help us analyze use of the Site and the Service, display advertisements on the Service and advertise the Site and Service (and related content) elsewhere online. Third-party platforms and social media networks.
We may disclose your personal information to professional advisors, such as lawyers, bankers, IT developers, auditors and insurers, where necessary in the course of the professional services that they render to us. For compliance, fraud prevention and safety.
We may share your personal information for the compliance, fraud prevention and safety purposes described. Business transfers.
We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. Compliance with Law:
We may be required to use and share your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities. 7. Rights:
In this section, we describe the rights and choices available to all users. Opt out of marketing communications and other push notifications.
You may opt out of marketing-related communications and other notifications we may send you via push notification by changing the settings on your mobile device or web site. Device permissions.
You may revoke any permissions you previously granted to us, such as permission to access your camera or camera roll, through the settings on your device. Cookies & Browser Web Storage.
Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Site may not work properly. Similarly, your browser settings may allow you to clear your browser web storage. Targeted online advertising.
Some of the business partners that collect information about users' activities on or through the Site or Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile Service usage for purposes of targeted advertising.
In addition, your mobile device settings may provide functionality to limit our, or our partners', ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Service ID for Advertising associated with your mobile device.
If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed. Choosing not to share your personal information.
Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to use the Service by designating it as required at the time of collection or through other Service means. Third-party platforms or social media networks.
If you choose to connect to the Service via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Service using the third-party's authentication service or otherwise connect your account. Data protection rights
We respect your right to access your personal data, correct them, request their removal or request that our use of your personal data be restricted within the limits established by current law. We also take the necessary measures to ensure that the personal information we collect is accurate and up-to-date.
Anyone has the right to access his personal data.
If your personal information is incorrect or incomplete, you have the right to ask us to update it.
You can ask us to delete your personal information.
You may request the limitation of the processing of their data or their portability, in which case we will only keep them for the exercise or defense of claims.
In certain circumstances and for reasons related to their particular situation, the interested parties may object to the processing of their data. If you have granted consent for a specific purpose, you have the right to withdraw it at any time, without affecting the legality of the treatment based on the consent prior to its withdrawal. In these cases, we will stop treating the data or, where appropriate, we will stop doing so for that specific purpose, except for compelling legitimate reasons or the exercise or defense of possible claims.
You can exercise any of your rights by sending a written request in Aribau street, 185, 3rd floor, Barcelona, Spain 08021, or by email to firstname.lastname@example.org
Once we receive your request and as long as it contains all the requirements required by the data protection law (copy of your ID card), we will respond to your request to guarantee the exercise of your rights.
You can consult the rest of data personal right and its exercising according your nationality in the section 15 and 16. 8. Other Sites, Mobile applications and Services
The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use. 9. Data Security and Retention.
We take our responsibility to protect your information very seriously and employ multiple safeguards in order to help ensure that your information is protected as it is transmitted from your device and stored on our servers. So, we use the next data security: Encryption
: When dealing with your personal/private information our server, and working in partnership with your browser, use an industry standard security protocol (Secure Sockets Layer – SSL) to help ensure that the information is encrypted and protected from eavesdropping. SSL helps ensure that the conversation your browser is having with our servers is private and that the information contained therein is safe and delivered only to our computers Firewall:
Once your information reaches our servers we protect it in many ways including storing the information on secure servers and using a device known as a firewall which protects your information by detecting and preventing un-authorized access to the information. Authorized access
: Working with our firewalls and other mechanisms we also protect your information by only allowing access to your information by employees and authorized parties who have a legitimate and verified need to access the information in order to service your requests and administer policies and claims.
. 10.Cross-Border Data Transfers
We store the information we collect in connection with the Service on Amazon Web Services and Google Cloud Platform. For Amazon Web Services, we specify the US as the data storage location, for Google Cloud Platform, we specify data storage at an available location closest to you when you use the device. Your personal information may be accessed by our service providers in other locations outside of your state, province, or country. Your device ID (and general Service usage information) may also be accessed by the Company's technical support team in other locations outside of your state, province, or country. We rely on the Privacy Shield, as described for transfers of data from the EU and Switzerland to United States. 11. Children
Acording to article 8 GDPR the personal data of a child shall be lawful where the child is at least 16 years old. Where the child is below the age of 16 years, such processing shall be lawful only if and to the extent that consent is given or authorised by the holder of parental responsibility over the child.
For all purposes, relationships between DNA Style and you of this telematic services, which are present on this platform, are subject to Spanish legislation and jurisdiction to which the parties hereby expressly submit themselves, then the Courts and Tribunals of BARCELONA being competent for the resolution of all and any disputes arising or related to the use of said services. 14. How to Contact Us
Please direct any questions or comments about this Policy or privacy practices to email@example.com You may also write to us via postal mail at:
AI STYLE BY DNA, S.L.
Aribau street, 185, 3 d floor, Barcelona, Spain 08021
firstname.lastname@example.org Personal information we collect :
· Service usage information
· Purchase history
· Social media information
· Device data
· Online activity data
· Physical description
· Online identifiers
· Internet or network information
· Online identifiers
· Сommercial information
· Online identifiers
· You Automatic collection
· The Service store provider through which you purchased your subscription (i.e., Google or Servicele)
· Third-party platforms Purposes for which we may collect and use the personal information :
· To operate and improve the Service
· To operate and improve the Service
· To send you marketing and promotional communications
· To display advertisements to you Data Sharing
· Shared with third-party platforms (e.g., social media networks) at your direction
· Shared with cloud service providers (i.e., Google Cloud Platform and Amazon Web Services)
· Shared with affiliates that provide services to us
· Shared with third-party platforms (e.g., social media networks) at your direction
· Collected directly by advertising partners 15. Notice to California Residents
We are required by the California Consumer Privacy Act of 2018 ("CCPA") to provide to California residents an explanation of how we collect, use and share their personal information, and of the rights and choices we offer California residents regarding our handling of their personal information.
In addition to disclosures of personal information to our service providers and professional advisors, for compliance, fraud prevention and safety, and in connection with a business transfer, the following chart further describes our privacy practices with respect to the personal information of our California consumers. 16. California Residents' Privacy Rights
Except as excluded from the scope of this notice above, the CCPA grants California residents the following rights.
You can request information about how we have collected, used and shared and used your personal information during the past 12 months. We have made this this information available to California residents without having to request it by including it in this notice, in the above chart.
You can request a copy of the personal information that we maintain about you.
You can ask us to delete the personal information that we collected or maintain about you.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
You are entitled to exercise the rights described above free from discrimination.
How to Submit a Request
To request access to or deletion of personal information:
email email@example.com Identity verification.
The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We may attempt to verify your identify by asking you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer. Authorized agents.
California residents can empower an "authorized agent" to submit requests on their behalf. We will require the authorized agent to have written authorization confirming such authority.