Introduction

This Privacy Policy (the "Policy") describes the personal information handling practices of GLOBAL META UNIVERSE PTE. LTD. (together with its affiliates, "FashionLabs," "we," "us," or "our"). This Policy applies to the information we collect through our website (the "Site"), our mobile applications (the "Apps") that hyperlink to this Policy (including those available in app stores or pre-installed on devices), and all related features, content, and services offered by FashionLabs (collectively, including the Site and Apps, the "Services"). By accessing or using the Services, you acknowledge and agree that your personal information will be handled in accordance with this Policy.

This Policy is incorporated into and governed by our Terms of Service (the “ToS”), and by using our Services, you consent to the practices described herein. Unless this Policy expressly provides a different definition for a specific term, any capitalized term used in this Policy has the meaning assigned to it in the ToS.

1. Acceptance of this Policy

By accessing, visiting or using our Services, you warrant and represent that you have read, understood and agreed to this Policy and our ToS. If you disagree with anything in this Policy, you must not use or access the Services.

2. Amendments to this Policy

We may periodically make changes to this Policy as we update or expand our Services. We will notify you of any material changes to this Policy by notifying you via the email we have on file for you, or by means of a notice on our Services in advance of the effective date of the changes. If you do not agree to the changes, you should discontinue your use of the Services prior to the time the modified Policy takes effect. If you continue using the Services after the modified Policy takes effect, you will be bound by the modified Policy.

Furthermore, we may provide you with "just-in-time" disclosures or additional information about the data collection, use and sharing practices of specific Services. These notices may provide more information about our privacy practices, or provide you with additional choices about how we process your Personal Information.

3. Information Collected through the Services

In this Policy, the term "Personal Information" includes any information that identifies or makes an individual identifiable. When you access or use our Services, we may generally collect the Personal Information described below.

3.1 Information You Directly and Voluntarily Provide to Us

When you access or use our Services, you may provide the following information to us:

User Support Information: If you are a visitor to the Site, or a user of the Apps, we may collect information that you provide to us when you communicate with any of our departments such as customer service or technical services.
Account and Contact Information: When you register for an account, you may provide your email address or choose to log in using your Apple ID or Google account ("Third-Party Account"). When using a Third-Party Account, we typically only receive the email address associated with that account; any additional information sharing is subject to your consent through the third-party platform.
Profile Information: To enhance your virtual try-on experience, you may voluntarily choose to provide certain personal details such as your age, body measurements (e.g., height, weight, body shape), nickname, profile picture, or country. Please note that providing this information is entirely optional and not required to use the basic features of our Services.
Your Content: When using some of our Services, you can create, post, upload or share content by providing us with access to your photos, media and files, and your device's camera and microphone. Access to these features will occur only after you grant explicit permission through your device settings. You have full control over whether to allow or deny such access, and you can adjust your choices at any time in your device’s Settings. Please note that declining permission may limit certain functionalities of the Services, but it will not prevent you from using other features. We respect your decisions regarding how your information and device data are shared and used.
Facial Data: When you use the AI-powered virtual try-on and content generation features of our Services (the "AI Functions"), we may process facial data contained in the photos, images and videos you upload ("Facial Data"). This includes using AI and machine learning technologies to detect facial regions, features, and key points from your images to generate realistic virtual try-on simulations of clothing, styling, and different environmental scenarios as you request. Facial Data may include geometric data representing facial features but does not include the original image itself. Depending on the laws of your jurisdiction, such data may be considered "biometric identifiers" or "biometric information."
- We process Facial Data solely to generate and deliver the virtual try-on results or other output that you request through the AI Functions, and to support the functionality, performance, and accuracy of those features. This includes enabling the system to detect facial areas, apply digital garments or styling effects, and render realistic previews of how clothing, accessories, or other visual elements may appear on you. Facial Data is not used for any secondary or incompatible purpose.
- The content you upload (including photos, images, and videos) may be temporarily transmitted to our carefully selected service providers for the exclusive purpose of generating the requested output. They process such content only under our documented instructions and only to return the requested output to you. Neither the uploaded content nor the associated Facial Data is retained beyond the time necessary to perform the processing; once the requested output has been generated and returned to you, the uploaded files and any Facial Data derived from them are automatically deleted from our systems, and from our service providers’ systems, in accordance with our data retention practices (see Section 8).
- We do not use Facial Data to identify or authenticate any individual, create or maintain biometric templates, build user profiles, or use such data for advertising, marketing, analytics, or tracking. We do not use Facial Data to train, improve, or develop any general-purpose artificial intelligence or machine learning models, unless you provide separate, prior, informed, and explicit consent as outlined in this Policy.
- Designated Countries: For users located in the European Economic Area, United Kingdom, or Switzerland (the "Designated Countries"), we process Facial Data solely based on your prior, explicit, and informed consent. Such data will not be used for advertising, profiling, or for training general-purpose AI or machine learning models unless you provide separate consent.
- For users located in California, Facial Data is considered Sensitive Personal Information under the CCPA/CPRA, and we do not sell or share it for behavioral advertising. Users may exercise their rights to limit the use of such Sensitive Personal Information at any time.

3.2 Information Collected Automatically

When you use the Services, certain information is collected automatically to enable functionality, maintain security, and improve user experience. This may include:

Device Information: When you access or use the Services, we automatically collect certain technical information from your device. This may include device and usage information such as the type of mobile device you use, device brand and model, operating system and version, screen resolution, device language, time zone, browser type, IP address, general location information (for example, country or city-level information inferred from your IP address, but not precise geolocation), network connection type (such as mobile network or Wi-Fi), device identifiers (such as your advertising ID if you have not disabled ad tracking), and diagnostic or performance-related data necessary to ensure that the Services function properly.
Cookies and Similar Technologies: We use cookies, pixel tags, and similar technologies to collect information about how you interact with our Services. This may include, for example, when you activated your account, the content or advertisements shown to you and whether you engaged with them, URLs you have visited within the Services, notifications displayed on your device, your Internet Protocol (“IP”) address, mobile country code, and user ID. These technologies help us understand usage patterns, improve our Services, and personalize your experience.
Network Connection: We may collect limited information about your network connection type (e.g., mobile network or Wi-Fi) to ensure service compatibility, optimize content delivery, and maintain performance stability.

You can limit the amount of information collected from your device by adjusting your device or browser settings. However, some features of the Services may not function properly if you do so. The processing of this automatically collected information is based on our legitimate interests in providing, maintaining, and improving the Services, ensuring security, and delivering a consistent user experience, as permitted under applicable Data Protection Laws.

3.3 Information You Share on Third Party Websites or through Social Media Services

The Services may include links to third-party websites and social media services where you may be able to post comments, stories, reviews or other information. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.

4. How We Use the Information We Collect

We use the Personal Information we gather through the Services for the purposes described below. If we use your Personal Information in any other way, we will disclose this to you. You can choose not to share your information with third parties for marketing purposes, or to allow us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your consent. If you choose to limit the ways we can use your Personal Information, some or all of the Services may not be available to you.

4.1 To provide Services to you. We process Personal Information to operate and deliver the Services, including enabling core product features such as account creation, device compatibility, applying virtual try-on effects, and generating requested output. This may include your account credentials, device identifiers, and Facial Data (where applicable). We share this information only with service providers and partners to the extent necessary to operate the Services.
4.2 To provide customer support. We process your Personal Information when you contact us to help you with any questions, concerns, disputes or issues, or to provide us with your feedback. Without your Personal Information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
4.3 To enforce terms, agreements or policies. To ensure your safety and adherence to our terms, agreements or policies, we may process your Personal Information to: actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services; investigate, prevent, or mitigate violations of our terms and policies; enforce our agreements with third parties and partners; and, collect fees based on your use of our Services. We cannot perform our Services in accordance with our terms, agreements or policies without processing your Personal Information for such purposes.
4.4 To send you Service-related communications. We use your contact information to send you administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information to you. Service-related communications are not promotional in nature. You cannot unsubscribe from such communications because you could miss important developments relating to your account or the Services that may affect how you can use our Services.
4.5 For security purposes. We process your Personal Information to: improve and enforce our security measures; combat spam, malware, malicious activities or security risks; and to monitor and verify your identity so that unauthorized users do not access your account with us. We cannot ensure the security of our Services if we do not process your Personal Information for security purposes. Designated Countries: For all purposes listed above, pursuant to the EU General Data Protection Regulation ("GDPR") or any equivalent legislation (collectively "Data Protection Laws"), we process the Personal Information of users located in the European Economic Area ("EEA"), United Kingdom and Switzerland (collectively, the "Designated Countries") based on our contract with you.
4.6 To maintain legal and regulatory compliance. We process your Personal Information to pay our taxes or fulfill our other business obligations, and/or to manage risk as required under applicable law. We cannot perform the Services in accordance with our legal and regulatory requirements without processing your Personal Information for such purposes. Designated Countries: Pursuant to the Data Protection Laws, we process the Personal Information of users located in the Designated Countries to comply with our legal obligations.
4.7 To personalize your experience on the Services. We allow you to personalize your experience on our Services via social media plugins on our Services (e.g., Apple ID, Google and etc.), by keeping track of your preferences (e.g., nickname or display name, time zone, language preference, etc.), and more. Without such processing, you may not be able to access or personalize part or all of our Services. Designated Countries: Pursuant to the Data Protection Laws, we process the Personal Information of users located in the Designated Countries to satisfy our legitimate interests as described above.
4.8 To conduct research and development. We process information about the way you use and interact with our Services to: help us improve our Services; build new Services; and build customized features or Services; and to train and improve our technology such as our machine learning modules, algorithms, and labs. Such processing ensures your continued enjoyment of part or all of our Services. The output generated by AI-powered virtual try-on features, including images or videos derived from your uploaded content, will not be used to make automated decisions or perform profiling that has legal or similarly significant effects on you, unless you provide explicit, informed, and prior consent. Designated Countries: Pursuant to the Data Protection Laws, we process the Personal Information of users located in the Designated Countries to satisfy our legitimate interests as described above.
4.9 To engage in marketing activities. We may process your contact information or information about your interactions on our Services to: send you marketing communications; deliver targeted marketing; inform you about events, webinars, or other materials, including those of our partners; and, keep you up-to-date with our relevant products and Services. Transactional communications about your account or our Services are not considered "marketing" communications. In addition, when you share your friends' contact information with us, we may reach out to them to invite them to our Services and to continue receiving our communications. You can opt-out of our marketing activities at any time.

5. How We Share Your Information with Third Parties

We may share your Personal Information with third parties in the following circumstances:

5.1 Employees, Third-Party Processors and Third-Party Service Providers

We disclose your Personal Information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers ("Service Providers") who provide certain services to us or on our behalf, such as operating and supporting the Services, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the Personal Information needed to perform these limited functions on our behalf. These service providers act exclusively as processors on our behalf and are contractually prohibited from using Facial Data or other Personal Information for independent purposes, including model training, profiling, analytics, product improvement, or marketing. Any temporary caching of content or Facial Data is strictly controlled and automatically deleted once the processing for your requested output is complete.

Designated Countries: Pursuant to the Data Protection Laws, we process the Personal Information of users located in the Designated Countries based on our contract with you. We do not sell or share your Personal Information, including Facial Data or other Sensitive Personal Information, for behavioral advertising purposes.

5.2 Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies

To the extent permitted by law, we will disclose your Personal Information if:

Required to do so by law, or in response to a subpoena or court order or similar request from a judicial authority, law enforcement authorities or other competent public authorities;
We believe, in our sole discretion, that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or
We believe that you have abused the Services by using it to attack our systems or to gain unauthorized access to our system, to engage in spamming or otherwise to violate applicable laws.

Designated Countries: Pursuant to the Data Protection Laws, we process the Personal Information of users located in the Designated Countries based on our legal obligations, in the public interest, or your vital interests.

5.3 Business Transfers or Bankruptcy

In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any Personal Information owned or controlled by us may be one of the assets transferred to third parties. We will notify you via email or a prominent notice within our Services of any change in ownership or use of your Personal Information, as well as any choices you may have regarding your Personal Information. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Information will be subject to this Policy. However, any Personal Information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

Designated Countries: Pursuant to the Data Protection Laws, we process the Personal Information of users located in the Designated Countries based on legitimate interests described above.

5.4 Our Affiliates

Based on your consent, we may share some or all of your contact information with our parent company, subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us. If you would like us to stop providing your information to our affiliates for their own marketing purposes, you may opt-out by contacting us as provided in the "How to Contact Us" section.

Designated Countries: Pursuant to the Data Protection Laws, we process the Personal Information of users located in the Designated Countries based on your consent.

5.5 Third-Party Business Partners

Based on your consent, we may work with and share some of your information with our third-party advertising partners to provide you with advertisements or other tailored content. We may share information related to users of our service with affiliates or unaffiliated third parties on a de-identified, aggregate basis.

When you engage with the AI-powered virtual try-on features within the Services, we may process the images or videos you upload, including facial data generated from or embedded within such content (“Facial Data”), for the sole purpose of fulfilling your virtual try-on request. To perform the requested rendering, garment fitting, or model inference, your content may be transmitted to trusted third-party AI model providers. Our current providers include (i) ByteDance Ltd. (including its enterprise cloud/AI subsidiaries operating the “SeeDream 4.0” model), which performs virtual try-on image generation and rendering and (ii) Google LLC, which provides the Gemini family of models for image-generation and inference.

These providers act exclusively on our behalf as data processors and are bound by written agreements requiring them to follow our documented instructions, implement appropriate technical and organizational security measures, and provide adequate protection for any cross-border transfers in accordance with Data Protection Laws. Processing performed by these AI model providers is strictly limited to the duration necessary to generate your requested output, and they are contractually prohibited from retaining images, Facial Data, or any Personal Information beyond that temporary processing, as well as from using the data for independent purposes such as model training, profiling, analytics, product improvement, or marketing.

In addition, we integrate certain analytics and attribution SDKs, such as Adjust SDKs, to improve service performance, troubleshoot technical issues, and understand aggregated usage patterns. These SDKs do not access, collect, or process images, videos, or any Facial Data. Their collection is limited to technical or anonymous statistical information, such as device identifiers, performance metrics, or interaction logs, and such information is used exclusively for analytics and service optimization purposes.

We do not and will not authorize any of these providers to use Facial Data or other Personal Information for their own purposes, including model training, data analytics, profiling, product improvement, or marketing. They are prohibited from storing Facial Data beyond what is necessary to fulfill the requested processing, and they may not disclose or share Facial Data with any additional parties.

Designated Countries: Pursuant to the Data Protection Laws, we process the Personal Information of user located in the Designated Countries based on your consent.

6. Children

We do not knowingly collect Personal Information from children under the age of 13 (or under 16 for users located in the Designated Countries), unless permitted to do so by applicable law. Children are not permitted to use our Services unless they provide us with consent from their parents or guardians. If we become aware that we have unknowingly collected Personal Information from a child, we will make commercially reasonable efforts to delete such information from our database. If you are a parent or guardian of a child, and you believe your child has provided us with their Personal Information on our Services, please contact us immediately at security@fashionlabs.ai. We may request reasonable proof of parental identity and authority to provide consent.

Parents or guardians have the right to review, update, or request deletion of their child’s Personal Information at any time. Upon receipt of a valid request, we will promptly delete the minor’s Personal Information, including any uploaded images and Facial Data, from our systems and instruct our service providers to do the same.

7. Security

We are committed to ensuring the security of your Personal Information. We have physical, technical and administrative safeguards in place to protect the confidentiality of your Personal Information. In addition, we require that our service providers handling Personal Information also maintain appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the Personal Information you provide to us.

However, we cannot guarantee the security of your Personal Information or that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. We also have no way of protecting any of your Personal Information that is not in our control, such as any information transmitted via email or wireless connections.

If you think there has been unauthorized access to or use of your account, please contact us immediately at security@fashionlabs.ai.

In the unlikely event of a security breach that may compromise your Personal Information, including Facial Data, we will take immediate steps to contain and remediate the incident. Where required under applicable Data Protection Laws, we will notify affected users and relevant supervisory authorities without undue delay and, where feasible, within the legally required timeframe.

8. Retention of Personal Information

We will try to limit the storage of your Personal Information to the time necessary to serve the purpose(s) for which your Personal Information was processed, to enforce our agreement, policies or terms, to resolve disputes, or as otherwise required or permitted by law.

Marketing. We store information used for marketing purposes indefinitely until you unsubscribe.
Your Interactions and Content on Our Services. We may store any information about your interactions on our Services or any content created, posted or shared by you on our Services indefinitely after the closure your account for the establishment or defense of legal claims, audit and crime prevention purposes.
Web Behavior Data. We retain any information collected via cookies, clear gifs, webpage counters and other technical or analytics tools up to one year from expiry of the cookie or the date of collection.
Telephone Records. As required by applicable law, we will inform you that a call will be recorded before doing so. Any telephone calls with you may be kept for a period of up to six years.
Facial Data. Facial Data and the related uploaded content are stored on secure servers only for the minimum time required to process your request and deliver the requested AI functionality. We do not store AI-generated image or video results. Once the requested output has been generated and delivered to you, any stored images and associated Facial Data are automatically deleted from our systems within a short retention window (no later than thirty (30) days). We permanently delete or irreversibly anonymize Facial Data once (i) the processing purpose has been fulfilled, or (ii) your deletion request is received and processed—whichever occurs first.

9. Information for Residents in Designated Countries

This section only applies to users of our Services who are located in the Designated Countries at the time of data collection. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to users in the Designated Countries.

9.1 Our Relationship to You

FashionLabs is the data controller with regard to any Personal Information collected from users of its Services. Any third parties that act as our service providers are "data processors" that handle your Personal Information in accordance with our instructions.

9.2 Legal bases for processing Personal Information

We describe our legal bases for processing in Section 4 and Section 5 under headings entitled "Designated Countries." The legal bases on which we rely include: your consent; satisfaction of our legal obligations; necessity to protect your vital interests; necessity to carry out our obligations arising from any contracts; necessity to process in the public interest; or for our legitimate interests.

9.3 Marketing Activities

If you are located in the Designated Countries and are a current user, we will only contact you by electronic means (such as email or SMS) per your communication preferences and/or with information about our Services that are similar to the Services you previously purchased. For new users, we will contact you by electronic means for marketing purposes only based on your consent. You can always withdraw your consent at any time.

9.4 Individual Rights

We provide you with the rights described below when you use our Services. Please contact us at security@fashionlabs.ai to exercise these rights:

Right to withdraw consent.
Right of access and rectification.
Right to erasure (the "Right to be Forgotten").
Right to restriction of processing.
Right to object to processing.
Right to data portability.
Notification to third-parties.
Automated individual decision-making, including profiling.
Right to Lodge a Complaint.

9.5 Transfer of Personal Information

Your Personal Information may be transferred to, processed and maintained on servers or databases located outside of the country where you are located. We transfer your Personal Information subject to appropriate safeguards such as the European Commission’s Standard Contractual Clauses (“SCCs”) or the EU-U.S. Data Privacy Framework.

10. California Residents

This section only applies to residents of California or individuals whose information has been collected in California under the California Consumer Privacy Act of 2018 (“CCPA”).

Selling Information. We do not sell your Personal Information, as defined under CCPA.
Your rights and Choices. The CCPA provides individuals residing in California with specific rights regarding their Personal Information.
Access to Specific Information and Data Portability Rights. You have the right to request disclosure of certain information over the past twelve (12) months.
Deletion Request Rights. You have the right to request deletion of your Personal Information.
Do Not Sell Opt-Out Rights. You have the right to opt-out of any sales, however, we do not sell your information.
Exercising Your Rights. Submit a verifiable consumer request to us via email.
Response Timing and Format. We endeavor to respond within 45 days of receipt.

11. How to Contact Us

If you have any questions about this Policy, please feel free to contact us. How to find our contact information:

Open the Google Play /Apple App Store;
Browse or search the app you're using;
Tap the app to open the detailed page;
Scroll down to review the contact information listed.