ClosyAI Privacy Policy

Effective Date: September 9, 2025
Last Updated: October 18, 2026

ClosyAI Inc. ("ClosyAI," "we," "our," or "us") provides a mobile application and website that helps users organise their wardrobes, generate AI-powered outfits, and plan what to wear for events. We respect your privacy and are committed to protecting your personal information.

1. Information We Collect

Account Information
Your email address and password (stored as a secure hash) when you register. If you sign in via Apple or Google, we receive only the information those services make available (typically email and name).

User Content
Photos of clothing items you upload, outfit combinations you save, style preferences, occasion and weather settings, and any notes or custom labels you add. When you upload a clothing photo, it is sent to Google Cloud's AI services in the EU for automated garment detection and attribute classification (colour, type, fit, formality, material). This powers your digital closet — no photo is shared with other users or used to train third-party AI models.

Profile and Preferences
Gender, style preferences (e.g. casual, elegant, sporty), colour preferences, occasion preferences, hair and nail colour, and other personalisation settings you provide.

Calendar Data
ClosyAI works with two kinds of events: events you create inside the app, and events already on your device calendar. If you grant calendar access, we read your device calendar so we can show your upcoming events in the app and plan outfits around them. If you also turn on Calendar Sync in Settings, ClosyAI writes your ClosyAI events and outfit plans into your device calendar, and updates or removes those entries when you change or delete them in the app. It does not modify events it did not create. Turning Calendar Sync off, or deleting your account, removes the entries ClosyAI created.

Event titles become the occasion. When you create an outfit for an event — for example by tapping "Create your outfit" on the next-event card on the Style screen, by picking an event from the date list on the Style screen, or by planning an outfit from the Calendar screen for a date that has an event on it — that event's own title is filled into the occasion field and is used as the occasion for that request. The occasion field is always shown on the Style screen, and you can edit or clear it before you generate. This applies both to events you created in ClosyAI and to events read from your device calendar. Because the occasion is what we describe to the AI model, the event title is sent to Google Cloud as part of the outfit prompt (see Section 3). It is also recorded in our own service records (see "Service and Diagnostic Records" below): once for the generation itself, and once when the next-event card appears, is tapped, or is dismissed — so the title reaches our records from the moment that card is shown to you, not only when you generate. If you save the resulting outfit, the title is stored with it as that outfit's occasion and its default name. The event title is not sent to our analytics provider: PostHog receives only a broad category (for example "work" or "party") and whether the occasion was typed or chosen from a preset.

We use the title because it is the most accurate description of what you are dressing for, and it lets the feature work without asking you to retype what is already in your calendar. It does mean that a device-calendar title leaves your device. If an event title is something you would rather not send, edit the occasion field on the Style screen before you generate, or generate without choosing the event. Apart from what is described here, we do not copy your device calendar to our servers — those events stay on your device unless you also create them in ClosyAI.

Shared Events
When you host an event and share its link, or join someone else's, the people taking part (the host and the guests who accepted) see your name, your RSVP and the comments you post. The host also sees whether each guest has planned an outfit for the event and, for a trip, each guest's packing progress. Your comments stay on the event if you leave it: the host can still delete them, and they are deleted with the event or with your account. To remove them yourself, delete them before you leave, or ask support@closyai.com.

Reports and Blocks
If you report a comment, a profile or an event, we keep your report so we can review it: the reason, any note you add, and a copy of what you reported as it was then. If you block someone, we keep the block: it stops notifications between you and keeps them from rejoining an event you host by its link. See Section 4 for how long each is kept.

Location Data
If you allow location access, we use your approximate GPS coordinates to look up local weather conditions and suggest weather-appropriate outfits. We do not store your precise location or build a location history.

Push Notification Tokens
If you grant notification permission, we store a device token to send you the notifications described in Section 2: your daily outfit reminder, calendar planning reminders, reminders to add clothes and notices when an upload or receipt import finishes, and updates about your events. You can revoke permission at any time in your device Settings.

Device and Usage Information
App version, device model, operating system version, and pseudonymised event data (e.g. screens visited, features used) to diagnose issues and improve the app. In production builds, crash reports and error stack traces are collected via Sentry to help us identify and fix bugs. Sentry events are tagged with a pseudonymised 8-character prefix derived from your Supabase user UUID (not your email, name, or any other personal identifier); this prefix is stable per-user so we can correlate crash patterns for a single account during diagnostics. Sentry data does not include your clothing photos or outfit content.

Service and Diagnostic Records
When you use a feature, we record what our systems did so we can operate the Service and fix it when it breaks: that an outfit generation ran and which rules applied, that a photo upload succeeded, failed, or was rejected (for example because it contained more than one garment), that an email or notification was sent, and that an error occurred. These records are keyed to your account and do not include your photos or outfit content. They are mostly identifiers and short reason codes. The one free-text field they carry is the occasion you generated for, recorded as you gave it — including when it is an event title taken from your calendar, as described under "Calendar Data" above.

We keep these records whether or not you enable Usage analytics, because without them we cannot tell that something went wrong for you, cannot answer a support request, and cannot fix the fault. They are separate from the behavioural analytics described below, they are never shared with our analytics provider, and they are covered by the same retention, export and deletion rights as the rest of your data. You may object to this processing at any time by emailing support@closyai.com.

Analytics Data (optional — off unless you turn it on)
Behavioural usage events — such as screens visited, sessions, and features tapped — collected only if you enable Usage analytics in Settings → Privacy. Pseudonymised usage events are also sent to PostHog when this setting is enabled. PostHog distinct_id is your Supabase user UUID — a pseudonymous identifier that does not contain your email, name, or any other directly identifying field, but is a stable per-user reference. This data does not include photos or outfit content. These identifiers are not personally identifying on their own but can be joined with our user database if we re-identify them; we treat them as pseudonymised data and protect them accordingly.

Subscription and Purchase Data
If you subscribe to Closy Pro or Closy Pro+, Apple processes payment on your behalf. We receive confirmation of your subscription status (active, cancelled, expired) and the subscription expiry date from RevenueCat, our subscription management provider. We do not receive or store your payment card details.

Receipt-Ingestion Data

ClosyAI offers optional ways to add items to your closet beyond uploading photos: forwarding retailer order-confirmation emails to a unique ClosyAI alias, pasting product URLs, or uploading screenshots of receipts. If you use these features, we collect:

• Forwarded email content. If you forward an email to your unique alias (<token>@inbound.closyai.com), we receive the full email — sender address, subject, body text and HTML, and message headers including authentication signatures used to verify the sender is a legitimate retailer. We never read your mailbox; we only receive what you (or a forwarding rule you set up in your email provider) explicitly send to your alias.
• Purchase information extracted from those receipts. Item names, brands, colours, sizes, prices, order numbers, retailer names, and product image URLs. This information is presented to you for review before any closet entry is created — nothing is added to your closet without your explicit Approve action.
• Pasted URLs and uploaded receipt images. If you use an "Import a Receipt" feature, we receive the URL or image you submit. URLs are fetched server-side to extract product details. Receipt images are processed via OCR and pattern recognition.

Receipt-ingestion retention. Raw forwarded email content (including third-party CC addresses, original message headers, and any personal correspondence visible in the message) is automatically purged from our systems within 30 days of receipt. Only the structured item attributes that you explicitly approve persist as your closet entries.

Body Photo (Optional, Virtual Try-On feature)
If you enable the Virtual Try-On feature, you may optionally upload a single full-body photo of yourself to render outfits onto. Pro+ includes 30 Virtual Try-On renders a month; Free accounts can generate 2 renders in total and Pro accounts 10, so they can try the feature, and may upload a body photo for that purpose. This photo is private to your account.

• Why we collect it. Your body photo is the reference image used to generate Virtual Try-On renders showing how outfits from your closet would look on you.
• Where it is stored. In a private, access-controlled storage bucket hosted by our database and storage provider, Supabase, in the United States. Only your authenticated account can read, replace, or delete it. ClosyAI staff do not access body photos in normal operation. This transfer is covered by the EU Standard Contractual Clauses — see §6.
• Where it is sent. When you initiate a Try-On render with your body photo, your photo is sent — alongside the relevant clothing item images from your closet — to Google Cloud's AI image-generation service for the rendering call. The image-generation processing takes place outside the EEA (e.g. in the United States). This transfer is governed by Google's Cloud Data Processing Addendum, the EU Standard Contractual Clauses, and Google's EU-US Data Privacy Framework certification. Google's terms state that this content is not used to train Google's models. Google does not review it in the ordinary course of providing the service; content that Google's automated systems flag for potential abuse may be assessed by authorized Google employees and retained by Google for up to 90 days for that purpose. Apart from that case, ClosyAI stores no copy of your body photo on Google's systems beyond the rendering call, though Google may hold it in a cache of its own in order to serve requests — a cache Google documents as encrypted and as holding content for no more than 24 hours. (The same applies to all image generation — the "Me" render, the mannequin, and the full-body reconstruction step: all of it is processed outside the EEA under the same safeguards. All text and vision analysis continues to be processed in the EU.)
• You control it. You can re-take or delete your body photo at any time via Settings → Virtual Try-On. Deletion removes the photo from our storage immediately. Account deletion also removes any uploaded body photo.
• Mannequin alternative. You may use Virtual Try-On without uploading a body photo. In that case, ClosyAI generates a one-time fashion mannequin tailored to your gender and skin-shade profile fields. The mannequin is not based on your photograph.
• Sharing privacy invariant. When you share or save a Virtual Try-On render, you choose at the time of action whether to use the version rendered on your body photo or the mannequin variant. The default is the variant you are currently viewing. We surface a [Me] / [Mannequin] toggle prominently so the choice is explicit. The mannequin-only fallback for shared images remains available at server level should it be re-enabled in the future.

Virtual Try-On Rendered Images
The PNG images produced by Virtual Try-On renders are stored in your account's private storage and are deleted automatically after 90 days of generation, or sooner if you delete your account. Renders attached to an outfit you have saved are kept for as long as you keep that outfit, so a look you deliberately saved does not disappear or cost you a re-render. If you delete the outfit, its renders are deleted on the same schedule as any other: 90 days after they were generated (at the next daily clean-up if that date has already passed). Deleting your account deletes them all at once. You can re-render any outfit at any time within your quota (30 renders a month with Pro+, plus Try-On Power Pack credits; 2 in total on Free and 10 on Pro).

1A. Legal Basis for Processing (EEA/UK users)

Where the EU General Data Protection Regulation (GDPR) or UK GDPR applies, we rely on the following legal bases for processing your personal data:

• Contract (Art 6(1)(b)) — account creation, closet storage, outfit generation, calendar planning, subscription management, transactional emails (welcome, password reset, deletion confirmation). Required to deliver the Services you signed up for.
• Consent (Art 6(1)(a)) — location access, push notifications, product analytics (both the in-app behavioural events and the pseudonymised events sent to PostHog), body-photo upload and Virtual Try-On, calendar sync, receipt-email forwarding, monthly Style Digest. You may withdraw consent at any time in Settings; withdrawal does not affect prior lawful processing. Where you decline or withdraw, behavioural analytics stops, no events are sent to PostHog, and any behavioural data PostHog already holds for your account is deleted.
• Legitimate interest (Art 6(1)(f)) — service and diagnostic records (see Section 1: records of what our systems did, kept so we can operate the Service, detect faults, and answer support requests), crash diagnostics (Sentry), fraud prevention, security monitoring. Our interest is operating a reliable, secure Service; we balance this against your privacy by keeping these records minimal — identifiers, reason codes and the occasion you generated for, with no photos or outfit content — retaining them under the schedule in Section 4, and never sharing them with our analytics provider. These records are kept whether or not you enable Usage analytics, because a Service that cannot see its own failures cannot fix them for you. You may object via support@closyai.com.
• Legal obligation (Art 6(1)(c)) — tax records, lawful disclosure requests, App Store / RevenueCat receipt retention required by accounting law.

2. How We Use Your Information

We use your information to:

• Provide core app functionality — closet storage, AI outfit generation, event planning, and outfit history.
• Personalise outfit suggestions based on your style preferences, saved items, and occasion.
• Send transactional emails (account confirmation, password reset, subscription status changes).
• Send push notifications, only if you have granted permission: your daily outfit reminder; calendar planning reminders; reminders to add clothes, and notices when an upload or a receipt import finishes; and updates about your events (a reminder before an event, a host asking for your RSVP, new comments, and guests joining or saying they are going). We do not send tips or promotional notifications unless you have opted in to them.
• Detect weather at your location to generate weather-appropriate outfit suggestions.
• Read your device calendar to show your upcoming events in the app for outfit planning, and — if you turn on Calendar Sync — write your ClosyAI events and outfit plans back to your device calendar (only if you grant calendar access).
• Use an event's title as the occasion when you choose to create an outfit for that event, for events you created in ClosyAI and for events read from your device calendar alike. See "Calendar Data" in Section 1.
• Generate AI-powered wardrobe insights for Pro+ subscribers, including seasonal readiness scores, wardrobe gap analysis, and closet analytics.
• Generate Virtual Try-On image renders (30 a month with Pro+; 2 in total on Free and 10 on Pro) — composite your body photo (or a generated mannequin) with clothing item images from your closet, via Google Cloud's AI image-generation service.
• Send a monthly personalised Style Digest email to Pro+ subscribers who have opted in, summarising their most-worn pieces and outfit patterns.
• Analyse pseudonymised usage data to fix bugs and improve the product.
• Process and manage your Closy Pro subscription.
• Respond to support inquiries.
• Enforce our Terms of Use and comply with legal requirements.

We do not use your clothing photos or outfit data to train AI models belonging to third parties.

3. Data Sharing

We do not sell or rent your personal data.

We share limited data with the following categories of service providers solely to operate the app:

Provider: Supabase
Purpose: Database, file storage, authentication, serverless functions
Data shared: Account data, user content, preferences

Provider: RevenueCat
Purpose: Subscription lifecycle management
Data shared: Subscription status, expiry date, Apple subscriber ID

Provider: Resend
Purpose: Email delivery (account emails, onboarding and plan emails, promotional email if you opted in, and the Style Digest)
Data shared: Email address, first name

Provider: Expo / EAS
Purpose: App distribution and push notification delivery
Data shared: Push notification tokens, and the text of the notifications we send you. Most of that text is fixed wording we wrote. Event notifications and calendar planning reminders also carry the event's title as its host wrote it in ClosyAI and, when one is about a person, that member's name as it appears on their profile (for example "Sam Lee added a comment" or "Sam Lee joined your event"). They never carry the text of a comment. Your daily outfit reminder may greet you by your first name and name the occasion of an event you have that day. Device-calendar titles are not used in notifications.

Provider: PostHog
Purpose: Pseudonymised product analytics (EU-hosted). Identified by a pseudonymous account identifier — not directly identifying on its own, but joinable with our user database.
Data shared: Usage events (no photos or content)

Provider: Sentry
Purpose: Crash reporting and error diagnostics (production only). User events tagged with a pseudonymised 8-character prefix derived from the Supabase user UUID.
Data shared: Device model, OS version, pseudonymised crash traces and stack traces

Provider: Mapbox / Photon
Purpose: Event location geocoding — converts location names you enter into coordinates for weather lookup
Data shared: Location text entered by you for events (e.g. "Paris, France")

Provider: Google Cloud
Purpose: All AI/ML processing: garment photo analysis, outfit generation, AI-powered wardrobe report, monthly style digest copy, receipt content extraction, receipt-screenshot OCR, in-store item check, mannequin generation, and Virtual Try-On image rendering. Text and vision processing (garment analysis, outfit generation, wardrobe report, style digest, receipt extraction and OCR, in-store item check, moderation) is routed to Google's EU region, keeping that processing inside the EU. All image generation — mannequin generation, mannequin renders, the Virtual Try-On "Me" render, and full-body reconstruction — is processed outside the EEA (e.g. the US), on Google's global endpoint, under Google's Cloud DPA + EU Standard Contractual Clauses + EU-US Data Privacy Framework. Google's terms prohibit training on your content; Google does not review it in the ordinary course, and content flagged by its automated abuse detection may be assessed by authorized Google employees and retained for up to 90 days.
Data shared: Clothing photos, anonymised item attributes, prompts (including the occasion text you enter, or that is taken from an event title — see "Calendar Data" in Section 1), wardrobe summary data (Pro+ wardrobe report), receipt content (forwarded retailer emails, pasted product URLs, uploaded receipt images), body photo and selected clothing images during Try-On render calls.

Provider: Postmark
Purpose: Inbound email reception for the receipt-ingestion forwarding alias
Data shared: Forwarded retailer email content (subject, body, headers) when you use email-forwarding receipt-import.

Provider: Bright Data
Purpose: Server-side fetching of product pages from retailers that block direct fetches (Amazon, etc.)
Data shared: The URL you pasted; the page content received from the retailer (used solely for item extraction; not stored beyond the 30-day raw-payload retention window).

Provider: Clipdrop (Stability AI)
Purpose: Fallback background removal when client-side cutout is unavailable
Data shared: Limited fallback for client-side cutout failure on receipt-imported items only. Native iOS/Android on-device background removal is the primary cutout path for user-uploaded photos and most scanner items; Clipdrop is rarely invoked.

Provider: Replicate (Marqo / fashionSigLIP)
Purpose: Visual embeddings used to improve outfit variety and similar-item lookup
Data shared: Closet item images (cutout) and pseudonymous user identifier. Vendor's posted policy is no training on customer content; DPA pending (see §6).

Provider: Apple / Google
Purpose: Payment processing for in-app subscriptions
Data shared: Handled entirely by the respective platform; we receive only subscription status

We may disclose personal data if required by applicable law, court order, or to protect ClosyAI's legal rights.

3A. Automated Processing and AI Models

ClosyAI uses automated processing extensively to deliver core features: garment classification (color, garment type, material, formality, season), outfit generation, wardrobe-gap analysis, weather-appropriate scoring, body-photo classification (full-body vs partial), and Virtual Try-On image rendering. We rely primarily on AI models provided by Google Cloud. Text and vision analysis (understanding your garment photos and generating outfit suggestions) is processed in the EU. Image generation (Virtual Try-On renders, the mannequin, and full-body reconstruction) is processed outside the EEA, on Google's global endpoint. See §6. We update the specific models we use as Google releases and retires them; the safeguards described here apply to all of them.

Provenance watermarking. Images generated for you — Virtual Try-On renders, the generated mannequin, Style the Scene background edits, and full-body reconstruction — carry an invisible, machine-readable watermark applied by our AI provider (Google) that identifies them as AI-generated. The watermark is embedded in the image itself and travels with any copy you export or share. It marks the image as AI-generated; it does not identify you, and we do not use it to track you or your images. Renders with a generated background additionally carry a visible AI-generated label in the share footer.

These automated decisions do not produce legal or similarly significant effects on you under Art 22 GDPR. You can override any AI suggestion, edit any item attribute we have inferred about your closet, regenerate any outfit, and request human review of any automated outcome by contacting support@closyai.com.

4. Data Retention

We retain your data for as long as your account is active. If you delete your account:

• Personal data (account information, uploaded photos, closet items, outfits, events, preferences, and associated records) is deleted from our systems immediately upon account deletion, except for safety reports, which follow the "Reports, blocks and hidden comments" item below.
• Receipt-ingestion raw payloads — raw forwarded email content, pasted URL contents, and uploaded receipt images you submit are automatically purged from our systems within 30 days of receipt, regardless of whether your account is active. Only the structured item attributes you explicitly approve persist as closet entries.
• Body Photo (Virtual Try-On) — retained until you delete it via Settings → Virtual Try-On, or until account deletion. Replacing it removes the prior version. The photo is never shared between users or used for any purpose besides generating Virtual Try-On renders for your own account.
• Virtual Try-On rendered images — automatically purged from our systems 90 days after generation, regardless of whether your account is active, except a render attached to an outfit you have saved, which we keep for as long as you keep that outfit, so that reopening a saved look does not require re-generating it. Once you delete the outfit, its renders are purged on the same 90-day schedule. You can re-render any outfit at any time within your quota (30 renders a month with Pro+, plus Try-On Power Pack credits; 2 in total on Free and 10 on Pro).
• Per-user generated mannequin — if you have used Virtual Try-On with the mannequin option, a single generated PNG sized to your gender and skin-shade profile fields is cached in access-controlled private storage. It is regenerated when you tap "Regenerate mannequin" in Settings. Account deletion removes it.
• Email forwarding aliases — if you configure a per-user alias for receipt-ingestion, you can revoke it from in-app Settings at any time, which immediately invalidates the alias at our mail provider; future mail to the old alias is dropped. Account deletion also revokes any active alias.
• Deleted items and outfits — when you delete a closet item or a saved outfit, an internal snapshot of that record is briefly retained so we can answer data-access requests and measure deletion rates. These snapshots are not readable by anyone using the app, are automatically purged after 90 days, and are removed immediately on account deletion.
• Reports, blocks and hidden comments — a report of a comment, a profile or an event (whether you filed it or it is about you) is kept, with the reporter's note and its copy of what was reported, while we review it. Once it is resolved, the reporter's note and the copy are removed after 30 days (within a day if the reported account has been deleted), and the report itself is deleted after 180 days. Deleting your account removes your account from the reports, filed by you or about you (from a report about your profile, at the next daily clean-up); the note and the copy follow the dates above (an open report keeps them until it is resolved). A block is kept until the person who made it unblocks, or until either account is deleted. A comment hidden after two people report it is kept, out of view, until the review ends; it is then restored or deleted.
• Usage and diagnostic records — behavioural events such as feature usage patterns and generation counts, and service records such as job outcomes and errors. On account deletion the user identifier on these records is overwritten with a single shared placeholder value that is identical for every deleted account; because the original identifier is overwritten rather than stored, that step cannot be reversed. What remains is the action name, timing, technical context, and the occasion you generated for (see "Calendar Data" and "Service and Diagnostic Records" above). Nothing in those rows links them to your account any more. We stop short of calling them anonymous, because an occasion is your own words and an event title can name a person or a place. These records may be retained indefinitely and are used for aggregate product analytics, and to keep the service working and diagnosable. If you would rather the occasion text were not kept at all, email support@closyai.com before you delete your account, while we can still find your records.

While your account is active these same records are linked to you by your account identifier. We describe them as pseudonymised, not anonymous: they remain personal data, and your access, correction, and erasure rights apply to them in full.

You may request deletion at any time by using the "Delete account" option in Settings, or by emailing support@closyai.com. While your account is active we can locate and delete your usage records on request, because they are linked to your account identifier. Once an account has been deleted, the records described above no longer carry any account identifier of yours, so we can no longer single them out in order to act on them.

5. Subscriptions and In-App Purchases

ClosyAI offers optional paid subscriptions ("Closy Pro" and "Closy Pro+") processed entirely through Apple's App Store. We do not collect, see, or store your payment details — all billing is handled by Apple.

Subscription plans:

• Closy Pro Monthly: $14.99 per month, no free trial
• Closy Pro Annual: $119.99 per year ($10.00/month), with a 7-day free trial for new subscribers
• Closy Pro+ Monthly: $29.99 per month, no free trial
• Closy Pro+ Annual: $199.99 per year ($16.67/month), with a 7-day free trial for new subscribers

Free trial: A 7-day free trial is available on both annual plans (Closy Pro Annual and Closy Pro+ Annual) for new subscribers only (one trial per Apple ID). Full plan access is granted during the trial. Payment is charged to your Apple ID account at the end of the trial period unless cancelled at least 24 hours before the trial ends.

Auto-renewal: Subscriptions automatically renew at the end of each billing period unless cancelled at least 24 hours before the renewal date. Your Apple ID account is charged for renewal within 24 hours prior to the end of the current period.

Managing or cancelling: Go to iOS Settings → [Your Name] → Subscriptions → Closy Pro, or visit apple.com/bill (https://support.apple.com/billing). Cancelling stops future renewals; you retain Pro access until the end of the current paid period.

Refunds: All refund requests are handled directly by Apple. To request a refund, visit reportaproblem.apple.com (https://reportaproblem.apple.com).

Downgrade: When a subscription expires or is cancelled, your account reverts to the free tier. Your closet, outfit history, and all data are always retained — nothing is deleted on downgrade.

6. International Data Transfers

Personal data may be transferred to and processed in the United States and other countries outside the EEA/UK by the following processors: Supabase (US), Google Cloud (text and vision processing in the EU region; all image generation outside the EEA, on Google's global endpoint; covered by Google's Cloud DPA, SCCs, and EU-US Data Privacy Framework), Postmark (US), Sentry (per DSN region), PostHog (EU), Resend (US), RevenueCat (US), Apple (US, IAP infrastructure includes EU regions), Expo/EAS (US), Mapbox (US) / Photon (DE) for geocoding, Bright Data (distributed), Clipdrop / Stability AI (EU — France), and Replicate (US).

For transfers to countries that the European Commission has not deemed to provide an adequate level of protection, we rely on:

• EU Standard Contractual Clauses (2021/914) with each US-based processor;
• UK International Data Transfer Addendum for UK users;
• Supplementary technical and organisational measures including TLS-in-transit, at-rest encryption (Supabase Storage + Postgres), EU region configuration for text and vision processing (all such calls are routed to Google's EU region), per-user access controls on stored photos, and access logging;
• A review of each named processor's transfer safeguards, recorded in our internal compliance records.

Copies of the SCCs and a summary of these safeguards are available on request from support@closyai.com.

7. Security

We use industry-standard safeguards including encryption in transit (TLS), encrypted storage, and row-level security on our database. However, no system is 100% secure. If you believe your account has been compromised, contact us immediately at support@closyai.com.

8. Cookies and Tracking

Mobile app. The ClosyAI mobile app does not use browser cookies. It uses PostHog for pseudonymised in-app analytics as described in Section 1, which you can disable in Settings → Privacy → Usage analytics. The app does not include any third-party advertising SDKs, cross-app tracking SDKs, or cross-site tracking technologies, and does not request App Tracking Transparency (ATT) permission.

Website (closyai.com). Our marketing website may use strictly necessary cookies to operate the site, and where applicable a consent banner for any non-essential analytics or preference cookies (EEA/UK only). You can control cookies through your browser settings. Where the consent banner is shown, you may accept, reject, or manage individual categories.

9. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Access and Portability: Request a copy of the data we hold about you. You can also generate a portable export yourself from Settings (look for "Download my data"), which produces a JSON archive of your account data (closet, outfits, events, preferences).
• Correction: Request correction of inaccurate data. Most profile and item attributes are editable directly in the app.
• Deletion ("right to be forgotten"): Use Settings → Delete Account for immediate self-service deletion, or email support@closyai.com (see Section 4 for what is deleted, retained, or anonymised).
• Objection / Restriction (Art 21): You may object to processing based on our legitimate interests (e.g. diagnostics analytics) — see channel-specific controls below — or request restriction by emailing support@closyai.com.
• Withdraw consent (Art 7(3)): Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Channel-specific opt-outs (Art 21 right to object to marketing):

• Push notifications: three switches in Settings → Notifications turn off the daily outfit reminder, calendar planning reminders and upload reminders. Event updates and the notices that an upload or import has finished have no switch of their own: turn them off by turning off notifications for ClosyAI in your device Settings, which revokes all push permission at once. We do not send tips or promotional notifications unless you have opted in to them: from version 1.0.1 of the app, the Tips & offers switch in Settings → Notifications turns them on, and it is off unless you turn it on.
• Transactional email (account confirmation, password reset, subscription receipts, deletion confirmation): these are sent on the contractual legal basis and cannot be opted out of while your account is active; deleting your account stops them.
• Onboarding and plan email (welcome, getting started, notes about your plan's features): stop them at any time with the unsubscribe link in any of them.
• Promotional email (offers and product news): sent only if you said yes to "Receive occasional updates" when you signed up or, from version 1.0.1 of the app, turned on Product update emails in Settings → Notifications; turning that switch off, or the unsubscribe link in each one, stops it.
• Style Digest (Pro+ monthly summary): turn it on or off in Settings → Notifications; the unsubscribe link in each one also stops it.
• In-app product analytics (PostHog): opt out in Settings → Privacy → Usage analytics.

GDPR (EEA/UK): ClosyAI Inc. is the data controller for the personal data described in this Policy. You have the right to lodge a complaint with your local data protection supervisory authority (a list is maintained by the European Data Protection Board at edpb.europa.eu). For UK residents, the supervisory authority is the Information Commissioner's Office (ico.org.uk).

CCPA (California): We do not sell or share personal information for cross-context behavioural advertising. California residents may request disclosure of categories of personal information collected and shared in the prior 12 months.

LGPD (Brazil): For users in Brazil, ClosyAI Inc. is the data controller (controlador) and processes personal data under the Lei Geral de Proteção de Dados (Law No. 13.709/2018, "LGPD"). Under LGPD Art. 18 you may request: confirmation that we process your data; access to it; correction of incomplete or inaccurate data; anonymisation, blocking, or deletion of unnecessary or excessively processed data; data portability; deletion of data processed with your consent; information about the entities with which we share your data; and revocation of consent. To exercise any of these rights, or to reach our Data Protection Officer (Encarregado), email support@closyai.com. You also have the right to lodge a complaint with Brazil's data-protection authority, the ANPD (Autoridade Nacional de Proteção de Dados, gov.br/anpd).

Response time. We will acknowledge requests within a reasonable time and respond substantively within 30 days of verifying your identity. Where a request is particularly complex or numerous, GDPR Art 12(3) permits us to extend by a further two months; we will tell you within the first 30 days if that applies.

To exercise any right not covered by the in-app controls above, email support@closyai.com.

10. Children's Privacy

ClosyAI is not directed to children. We do not knowingly collect personal data from anyone under the age of 13 in the United States (per COPPA), or under the digital-consent age set by your EEA member state under GDPR Art 8 (this is 16 by default and is set lower — between 13 and 16 — by some member states; for example, France, Germany, Luxembourg and the Netherlands set 16, while Belgium, Denmark, Estonia, Finland, Portugal, Spain and Sweden set 13). If you are below the applicable age, you may not use the Services without a parent or legal guardian's verified consent. In Brazil, under the LGPD, the personal data of children (under 12) is subject to specific parental-consent requirements (Art. 14); our 13-year minimum age excludes this group, and personal data of adolescents (12–17) is processed in their best interest.

If you believe a child has provided us with personal data without the required consent, contact us at support@closyai.com and we will delete it promptly.

11. Business Transfers

If ClosyAI is involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you via email and/or a prominent in-app notice before your data is subject to a different privacy policy.

12. Law Enforcement

We may disclose your personal information if required to do so by law, valid legal process, or to protect the rights, property, or safety of ClosyAI, our users, or the public.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date above and notify you via email or an in-app notice. Continued use of the Services after changes take effect constitutes acceptance of the updated Policy.

Contact Us

Data Controller
ClosyAI Inc.
Email: support@closyai.com
Website: https://www.closyai.com

Data Protection contact
For privacy enquiries, subject-rights requests, or data-protection complaints, please email support@closyai.com. We respond within 30 days as required by GDPR Art 12(3). For complex requests we may extend by up to two further months and will notify you of any such extension within the initial 30 days.

EEA / UK users
You may also lodge a complaint with your local Data Protection Authority. UK users may complain to the Information Commissioner's Office (ico.org.uk).