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Privacy Policy

Effective Date: November 4, 2025

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.
  • 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.
  • 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.
  • 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.
  • California Residents: 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.

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.

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.

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.

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.

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.

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.

4.4 To send you Service-related communications

We use your contact information to send you administrative or account-related information to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information to you.

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.

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.

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.

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.

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.

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. These Service Providers will only have access to the Personal Information needed to perform these limited functions on our behalf.

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. Our current providers include ByteDance Ltd. (operating the "SeeDream 4.0" model) for virtual try-on image generation, and Google LLC, which provides the Gemini family of models for image-generation and inference.

5.2 Response to Subpoenas or Court Orders

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.

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.

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.

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.

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.

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.

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. While retention requirements can vary by country, we generally apply the retention periods noted below:

  • Marketing: We store information used for marketing purposes indefinitely until you unsubscribe.
  • Your Interactions and Content: We may store any information about your interactions on our Services indefinitely after the closure of your account for the establishment or defense of legal claims.
  • Web Behavior Data: We retain any information collected via cookies and other technical tools up to one year from expiry of the cookie or the date of collection.
  • Telephone Records: 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. 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 thirty (30) days.

9. Information for Residents in Designated Countries

This section only applies to users of our Services who are located in the Designated Countries (European Economic Area, United Kingdom, and Switzerland) at the time of data collection.

9.1 Our Relationship to You

FashionLabs is the data controller with regard to any Personal Information collected from users of its Services.

9.2 Legal bases for processing Personal Information

The legal bases on which we rely to process your Personal Information include: your consent to the processing; satisfaction of our legal obligations; necessity to protect your vital interests; necessity to carry out our obligations arising from any contracts we entered with you; 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.

9.4 Individual Rights

We provide you with the following rights when you use our Services:

  • Right to withdraw consent
  • Right of access and rectification
  • Right to erasure (the "Right to be Forgotten")
  • Right to restriction
  • Right to object to processing
  • Right to data portability
  • Right not to be subject to automated decision-making
  • Right to lodge a complaint with a supervisory authority

9.5 Transfer of Personal Information

We transfer your Personal Information subject to appropriate safeguards as permitted under the Data Protection Laws. Specifically, when your Personal Information is transferred out of the Designated Countries, we have the required contractual provisions for transferring Personal Information in place with the third-parties to which your information is transferred.

10. California Residents

This section only applies to residents of California or individuals whose information has been collected in California. We have adopted and included this notice to comply with the California Consumer Privacy Act of 2018 ("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 us to disclose certain information about our collection and use of your Personal Information over the past twelve (12) months.
  • Deletion Request Rights: You have the right to request us to delete any of your Personal Information that we collected from you and/or retained.
  • Do Not Sell Opt-Out Rights: You have the right to opt-out of any sales of Personal Information. However, we do not sell your information.

Exercising Your Rights

To exercise your rights, you may submit a verifiable consumer request by email to us at the address provided in the "How to Contact Us" section. We endeavor to respond to a verifiable consumer request within 45 days of its receipt.

11. How to Contact Us

If you have any questions about this Policy, please feel free to contact us:

You can also find our contact information by visiting the App Store or Google Play Store, browsing or searching for our app, and reviewing the contact information listed on the app's detailed page.