DressGenius Privacy Policy

1. Introduction and Data Controller

DressGenius is an AI-powered fashion consultant mobile application that analyzes your outfit photos, provides style recommendations, and helps manage your digital wardrobe. This Privacy Policy explains how DressGenius Tecnologia LTDA ("DressGenius," "we," "us," "our") collects, uses, discloses, and safeguards your information when you use our mobile application (the "Service").

We are committed to complying with applicable privacy laws, including the General Data Protection Regulation (GDPR) for European residents, the Lei Geral de Proteção de Dados (LGPD) for Brazilian residents, the California Consumer Privacy Act (CCPA) for California residents, and comparable privacy laws in other jurisdictions.

2. Personal Data We Collect

We collect various categories of personal data to operate our Service and provide you with personalized fashion recommendations. Below is a comprehensive breakdown:

2.1 Registration and Authentication Data

When you create a DressGenius account, we collect:

• Name — Your full name as provided during registration
• Email address — Used for account access, password recovery, and communications
• Password — Hashed using bcrypt, not stored in plain text
• Confirmation of age — Your affirmation that you are at least 13 years old

2.2 Social Authentication Data

If you authenticate via third-party providers, we collect:

Provider	Data Collected
Google OAuth	Google user ID, email address, name, profile picture URL
Apple Sign-In	Apple user ID (sub claim), email address (real or @privaterelay.appleid.com alias if you chose "Hide My Email"), name (only if you chose to share it on first sign-in)

Apple Sign-In — Private Relay: When you sign in with Apple and choose "Hide My Email", Apple generates a unique, randomized email address ending in @privaterelay.appleid.com and forwards messages to your real email. We only store the relay address — we never receive your real email. Push notifications are delivered via device tokens and do not depend on email.

Apple Sign-In — Security (SHA-256 nonce): To prevent replay attacks, our mobile app generates a cryptographically random 32-byte nonce per sign-in, sends its SHA-256 hash to Apple, and forwards the raw nonce to our backend. Our backend validates that the hash in Apple's identity token matches the raw nonce we received. This ensures each authentication token can only be used once and only by the client that initiated the request.

2.3 Profile and Photo Data

• Profile information — Display name, bio, profile photo
• Profile photo — Images in JPG, PNG, or WebP format (max 10MB)
• Location data — GPS coordinates (latitude/longitude), country, state, city, neighborhood. Collected via GPS, manual entry, or reverse geocoding

2.4 Outfit and Wardrobe Photos

• Outfit photos — Images you upload for AI analysis. Used to extract colors, style, occasion suitability, and weather compatibility
• Wardrobe item photos — Images of individual clothing pieces for digital wardrobe management
• Generated outfit images — AI-generated images based on our analysis and suggestions

2.5 Preference and Customization Data

We collect your AI analysis preferences as slider values (0–100 scale):

• Tone — Strictness of recommendations
• Detail level — Depth of analysis
• Creativity — How experimental vs. conservative
• Trendiness — Fashion-forward vs. classic
• Comfort priority — Weight given to comfort
• Weather sensitivity — Importance of weather context
• Budget — Price sensitivity for suggestions

2.6 Device and Push Notification Tokens

• Expo push notification token — Unique identifier for sending notifications
• Device platform — iOS or Android
• Device name — Your device identifier (e.g., "iPhone 15 Pro")

2.7 Usage and Analytics Data

• Monthly analysis count — Number of outfit analyses performed
• Chat session count — Conversations with AI about outfits
• Image generation count — Generated outfit images created
• Outfit scores and feedback — Your ratings and comments on recommendations
• Wardrobe statistics — Number of items, color distribution, category breakdown
• Feature usage — Which features you interact with most

2.8 Error Logs and Diagnostic Data

• Screen and action logs — Which screens you visit, actions taken
• Error messages and status codes — Crashes or failures you encounter
• Device details — Device model, OS version, app version
• Timestamps — When events occur

2.9 Sharing and Social Data

• Share tokens — Unique UUID for sharing outfits
• View and engagement metrics — Clicks, views, sign-ups from shared content
• Platform information — How shares were distributed (link, social media, etc.)
• Shared tone preferences — Your AI preferences sent with shared outfits

2.10 Transactional Data

• Subscription status — Free or premium tier
• Credit pack purchases — Image generation credit purchases
• In-app purchase history — Managed by RevenueCat
• Payment method type — Not card details; RevenueCat handles PCI compliance

2.11 Communication Data

• Support messages — Any messages sent to our support team
• Feedback — Feature requests, bug reports, general feedback
• Email communications — Marketing messages, updates (with your consent)

2.12 Closed Beta Program Data

If you participate in our Closed Beta Program (invite-only, capped at 75 users), we collect and make the following additional data visible to our administrators for cost control and program management:

• Invite code redemption record — The code you redeemed, the date, and the associated user record (immutable audit log)
• Aggregated monthly usage per beta user — Count of outfit analyses, chat sessions, and image generations performed each month, along with the estimated API cost in USD
• Beta participation status and timestamp — When you joined the beta tier and your current status (active, graduated, downgraded)

This data is derived from the same usage tracking we already perform for all users (Section 2.7); what differs for beta participants is the administrative visibility of per-user totals in an internal dashboard, used to (a) enforce the monthly quota, (b) monitor aggregate AI costs during the pre-launch phase, and (c) inform graduation decisions when the beta program concludes. Beta data is retained under the same schedule as regular account data (Section 7.1) and you retain all rights described in Section 8 (including the right to leave the beta program at any time by contacting dpo@dressgenius.app).

3. How We Use Your Data

We use the personal data we collect for the following purposes:

3.1 Service Delivery and Personalization

• Creating and maintaining your account
• Processing outfit photos through Google Gemini Vision API for AI analysis
• Generating style scores, color analyses, and improvement recommendations
• Enabling multi-turn conversational chat about your outfits (Gemini Chat API)
• Creating digital wardrobe management features
• Applying your custom AI preferences to analyses
• Generating outfit images via AI image generation services
• Computing style analytics and trend insights

3.2 Location-Based Services

• Using GPS location and reverse geocoding to tailor weather-aware recommendations
• Integrating weather data via Open-Meteo API (anonymously) for occasion and climate analysis

3.3 Communications and Notifications

• Sending push notifications about analyses, recommendations, and premium features
• Sending transactional emails (password reset, purchase confirmations, account updates)
• Sending marketing communications (with consent)
• Responding to support requests

3.4 Account Management

• Managing authentication and authorization
• Enforcing credit and subscription limits
• Processing payment transactions (via RevenueCat)
• Handling password resets and account recovery

3.5 Analytics and Improvement

• Analyzing usage patterns to improve service quality
• Debugging errors and improving stability
• Understanding user behavior (e.g., which features are most used)
• Conducting A/B testing and optimization

3.6 Legal Compliance and Safety

• Complying with applicable laws and regulations
• Responding to lawful requests from authorities
• Protecting against fraud, abuse, and security threats
• Enforcing our Terms of Service

3.7 Sharing Features

• Enabling outfit sharing with public or private links
• Tracking views, clicks, and referral metrics
• Gamifying sharing through "roasts" and comments

4. Legal Basis for Processing

We process your personal data based on the following legal foundations:

4.1 Consent

• For marketing emails and communications
• For location data collection beyond what's necessary for the service
• For optional analytics beyond error tracking

4.2 Contract Performance

• Processing necessary to provide the DressGenius service
• Outfit analysis, chat, image generation, and wardrobe management
• Account and subscription management
• Payment processing

4.3 Legitimate Interest

• Service improvement and optimization
• Fraud and security monitoring
• Enforcing agreements and preventing misuse
• Business analytics and reporting

4.4 Legal Obligation

• Compliance with tax, regulatory, and law enforcement requests
• Retention of records as required by law

4.5 Vital Interests

• Protecting user safety in cases of imminent harm or abuse

5. Third-Party Data Sharing

We share your personal data with the following third-party service providers only to the extent necessary to deliver our Service. These services are contractually bound to use your data solely as instructed and maintain appropriate security safeguards:

Service Provider	Purpose	Data Shared
Google Gemini Vision API	AI outfit analysis: colors, style, occasion, climate assessment	Outfit photos (base64), location context, preferences
Google Gemini Chat API	Conversational AI about outfit recommendations	Chat messages, outfit analysis data, user preferences
OpenAI DALL-E / GPT-Image (if deployed)	AI-generated outfit image creation	Outfit context, color palette, style description
Anthropic Claude API (alternative)	Alternative AI analysis and conversation	Analysis context, messages, preferences
FASHN.ai	Outfit photo editing and enhancement	Outfit images, editing instructions
Google OAuth / Apple Sign-In	Account authentication	Email, name, profile picture, unique ID
Expo Push Service	Sending push notifications to your device	Push tokens, notification content
RevenueCat	Subscription and in-app purchase management	Purchase history, subscription status (PCI DSS compliant)
Open-Meteo API	Weather data for contextual recommendations	Location (anonymous, no user ID)
Render.com	Hosting our backend servers	All application data (encrypted in transit and at rest)
PostgreSQL / Supabase (planned)	Database storage	All personal data (encrypted)
Cloudflare R2 (planned)	File storage (outfit photos, profile photos)	Photos and generated images (encrypted)

5.1 Legal and Business Disclosures

We may disclose your information if required by law or in response to valid legal process (subpoena, court order, government request), to protect our rights, privacy, safety, or property, or to establish, exercise, or defend legal claims.

6. International Data Transfers

DressGenius is based in Brazil and operates services in multiple jurisdictions. Your data may be transferred to, stored in, and processed in countries other than your country of residence, including:

• United States — Google Cloud (Gemini APIs), OpenAI (DALL-E), Anthropic, Expo, RevenueCat, Render.com
• Brazil — Primary backend infrastructure
• European Union — For EU residents, additional safeguards apply (see Section 12)

These countries may not have equivalent privacy laws. However, we implement appropriate safeguards:

• Standard Contractual Clauses (SCCs) — For transfers to non-adequate jurisdictions
• Encryption — Data encrypted in transit (TLS 1.3) and at rest
• Data Processing Agreements — With all processors
• Privacy Shield / Adequacy Decisions — Where applicable

7. Data Retention and Deletion

7.1 Retention Period

Currently, we retain your personal data for the duration of your account and for as long as necessary to provide our Service, comply with legal obligations, and resolve disputes. Specific retention periods are as follows:

• Account data (name, email, password) — For the life of your account plus 30 days post-deletion
• Outfit photos and analyses — For the life of your account plus 90 days post-deletion
• Chat history — For the life of your account plus 90 days post-deletion
• Wardrobe and item photos — For the life of your account plus 90 days post-deletion
• Error logs and diagnostics — 90 days
• Push notification tokens — Until device removal or token expiration
• Payment records — 7 years (tax and fraud compliance)
• Marketing consent logs — Until withdrawal plus 3 years

7.2 Account Deletion

You can request deletion of your account at any time through the app settings or by contacting support@dressgenius.app. Upon account deletion:

• Your personal data (name, email, password) is deleted immediately
• Outfit photos, analyses, and chat history are securely deleted within 90 days
• Wardrobe data is deleted within 90 days
• Your account becomes inaccessible immediately
• Aggregate/anonymized analytics may be retained for business intelligence

7.3 Right to Erasure

You may request deletion of specific data categories under GDPR (right to be forgotten) and LGPD. Requests are processed within 30 days, except where legal obligations require retention.

8. Your Privacy Rights

Depending on your location, you have certain rights regarding your personal data:

8.1 Universal Rights (All Users)

8.2 How to Exercise Your Rights

To exercise any of the above rights, please submit a written request to:

• Email: support@dressgenius.app
• Mail: DressGenius Tecnologia LTDA, Ponta Grossa, PR, Brazil

We will respond within 30 days (GDPR / LGPD) or as required by law. We may request proof of identity to verify the request.

9. Data Security

We implement comprehensive technical and organizational measures to protect your personal data against unauthorized access, alteration, and destruction:

9.1 Encryption

• In Transit: TLS 1.3 for all API communications
• At Rest: AES-256 encryption for sensitive data in the database
• Passwords: Hashed with bcrypt (non-reversible)
• Payment Data: Managed by RevenueCat (PCI DSS 3.2.1 compliant)

9.2 Access Controls

• Authentication: Laravel Sanctum Bearer Token authentication
• Authorization: Role-based access control (RBAC)
• Admin Access: Restricted to authorized personnel only
• Audit Logs: Tracked for compliance verification

9.3 Infrastructure Security

• Firewalls: Network-level protection via Render.com managed infrastructure
• DDoS Protection: Cloudflare (planned) for edge security
• Vulnerability Scanning: Regular security audits and penetration testing
• Patch Management: Timely updates for dependencies

9.4 Third-Party Security

• All processors maintain SOC 2 or ISO 27001 certifications
• Data Processing Agreements ensure adequate safeguards
• Annual security assessments of critical vendors

9.5 Incident Response

In the event of a data breach, we will notify affected individuals within 72 hours (GDPR), 30 days (LGPD), or as required by law. Notifications will include the nature of the breach, data affected, and remedial steps.

10. Children's Privacy (Age Requirement: 13+)

DressGenius is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. By using DressGenius, you confirm that you are at least 13 years old.

If we discover that a user is under 13, we will:

• Immediately delete their account and associated data
• Notify the parent or guardian
• Comply with COPPA (US), GDPR (EU), and equivalent child protection laws

For users aged 13–18, we:

• Limit data collection to what's necessary
• Provide clear, age-appropriate privacy information
• Respect any parental consent requirements in your jurisdiction

If you are a parent or guardian and believe a child has provided information to DressGenius, please contact support@dressgenius.app immediately.

11. CCPA-Specific Rights (California Residents)

If you are a California resident, the California Consumer Privacy Act (CCPA) grants you specific rights regarding your personal information (as defined in CCPA § 1798.100 et seq.):

11.1 Right to Know

You have the right to request and receive:

• The specific pieces of personal information we have collected
• The categories of personal information collected
• The sources of the personal information
• Our business purposes for collection
• Categories of third parties with whom we share the information

11.2 Right to Delete

You may request deletion of personal information collected from you, except where exemptions apply (e.g., legal obligations, fraud prevention). We will delete the requested information within 45 days.

11.3 Right to Correct

You may request correction of inaccurate personal information.

11.4 Right to Opt-Out of Sale or Sharing

We do not sell or share your personal information for cross-context behavioral advertising. You may still opt-out of any future sale or sharing by contacting support@dressgenius.app.

11.5 Right to Limit Use

You may request that we limit our use of sensitive personal information (SSI) to necessary purposes. We do not use SSI for purposes not necessary to provide the Service.

11.6 Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. You will receive the same service quality and pricing, and we will not limit access to our Service.

11.7 How to Submit CCPA Requests

Send requests to:

• Email: support@dressgenius.app
• Mail: DressGenius Tecnologia LTDA, Ponta Grossa, PR, Brazil

Provide sufficient information to verify your identity (account email, account ID, or other identifying information). Authorized agents may submit requests on your behalf with proper power of attorney.

11.8 Household Requests

CCPA allows household requests for families using the same device or account. Contact our privacy team to coordinate household requests.

11.9 Shine the Light Law (CA Civil Code § 1798.83)

California residents may request information about personal information shared with third parties for marketing purposes. We do not share personal information for third-party direct marketing, so this request is not applicable. However, you may contact us for clarification.

12. GDPR-Specific Rights (EU Residents)

If you are a resident of the European Union, United Kingdom, or European Economic Area (EEA), the General Data Protection Regulation (GDPR) grants you specific rights:

12.1 Right of Access (Article 15)

You have the right to obtain confirmation of whether your personal data is processed and to receive a copy of your data in a structured, commonly used, machine-readable format (e.g., CSV, JSON).

12.2 Right to Rectification (Article 16)

You may correct inaccurate or incomplete personal data without undue delay.

12.3 Right to Erasure / "Right to Be Forgotten" (Article 17)

You may request erasure of your personal data, except where:

• Processing is necessary to fulfill contractual obligations
• Processing is based on legal obligations
• Processing is necessary for the establishment, exercise, or defense of legal claims
• Processing is necessary for archiving, research, or statistical purposes

12.4 Right to Restrict Processing (Article 18)

You may restrict processing of your data in cases of accuracy disputes, unlawful processing, or when you object but we still have a lawful basis.

12.5 Right to Data Portability (Article 20)

You have the right to receive your personal data in a portable, machine-readable format and to transmit it to another controller without hindrance.

12.6 Right to Object (Article 21)

You may object to processing based on legitimate interests or for direct marketing purposes at any time. We will cease processing unless we can demonstrate compelling legitimate grounds.

12.7 Rights Related to Automated Decision-Making and Profiling (Article 22)

You have the right not to be subject to decisions based solely on automated processing, including profiling, that produces legal or similarly significant effects. DressGenius uses AI for recommendations, not binding decisions, so this right has limited application. However, you may request human review of AI analyses.

12.8 Right to Lodge a Complaint

If you believe we have violated your rights under GDPR, you have the right to lodge a complaint with your local Data Protection Authority (DPA). The supervisory authorities for major EU countries are:

• Germany (BfDI): www.bfdi.bund.de
• France (CNIL): www.cnil.fr
• Italy (Garante): www.garanteprivacy.it
• Spain (AEPD): www.aepd.es
• UK (ICO): www.ico.org.uk

12.9 EU Representative

For GDPR compliance, DressGenius Tecnologia LTDA designates a representative within the EU. Contact our DPO for representative details.

13. LGPD-Specific Rights (Brazilian Residents)

If you are a resident of Brazil, the Lei Geral de Proteção de Dados (LGPD, Federal Law 13.709/2018) grants you the following rights:

13.1 Right of Access (Lei 13.709, Art. 18)

You have the right to obtain information regarding how your personal data is processed, including:

• Purpose of processing
• Basis for processing
• Recipients of data
• Retention period
• Origins of data

13.2 Right to Rectification (Lei 13.709, Art. 19)

You may request correction of inaccurate or incomplete personal data.

13.3 Right to Erasure (Lei 13.709, Art. 17)

You may request deletion of your personal data, subject to exceptions including legal obligations and data necessary for the service's core functionality.

13.4 Right to Data Portability (Lei 13.709, Art. 20)

You may request your personal data in a portable, structured format and transfer it to other controllers.

13.5 Right to Block or Restrict (Lei 13.709, Art. 18, § 5º)

You may request that your data be blocked temporarily or permanently, in accordance with LGPD guidelines.

13.6 Right to Oppose Processing (Lei 13.709, Art. 18, § 6º)

You have the right to object to processing based on legitimate interests, legal obligations, or other lawful grounds.

13.7 Right to Information About Sharing (Lei 13.709, Art. 18, § 4º)

You have the right to know which third parties your data is shared with and for what purposes.

13.8 Right to Lodge a Complaint

If you believe we have violated your rights under LGPD, you may lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at www.gov.br/cidadania/pt-br/acesso-a-informacao/lgpd.

13.9 How to Submit LGPD Requests

Submit requests in Portuguese or English to:

• Email: support@dressgenius.app
• DPO: dpo@dressgenius.app
• Mail: DressGenius Tecnologia LTDA, Ponta Grossa, PR, Brazil

We will respond within 15 business days. Requests may be extended for an additional 15 days with notice. We may request proof of identity.

13.10 Opt-Out of Marketing Communications

You may opt-out of marketing and promotional emails at any time by clicking the "unsubscribe" link in the email or contacting our privacy team.

14. Changes to This Privacy Policy

DressGenius may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The "Last Updated" date at the top of this policy indicates when it was last revised.

When we make material changes, we will:

• Notify you via email to the address associated with your account
• Display a prominent notice on our app or website
• Request your explicit consent if required by applicable law

Your continued use of DressGenius after changes become effective constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you may delete your account.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

15.1 Customer Support

For general support or feature requests unrelated to privacy, visit the DressGenius app settings or contact support@dressgenius.app.