Privacy Policy

This Privacy Policy describes how CUBRIK S.R.L. ("we", "our" or the "Company"), with registered office at Via Grange Palmero 47, Alpignano (TO) 10091, Italy, collects, uses and protects the information of users of the OutfitMatch application (the "App").

1. Data Controller

The data controller is CUBRIK S.R.L., VAT no. 12966980018, with registered office at Via Grange Palmero 47, 10091 Alpignano (TO), Italy. For any privacy-related request, you can contact us at: privacy@cubrik.it.

2. The AI Features and the Data They Process

OutfitMatch offers four AI-powered features. For each one, we indicate below what data you send, which third-party AI service it is transmitted to and for what purpose:

• Color analysis (armocromia): you upload a photo of your face (selfie). The image is analyzed to determine your skin undertone, eye and hair color and to suggest your seasonal palette. The photo is transmitted to the AI service OpenAI for visual analysis.
• Outfit evaluation: you upload a photo of the outfit you are wearing (which may include your face and body). The image is analyzed to give you a score and style advice. The analysis is performed via the AI service Ollama.
• Outfit suggestions: the images of the clothing items in your wardrobe (and, where relevant, the color-analysis results) are used to generate outfit matches and suggestions, via the AI service Ollama.
• Virtual Try-On: you upload a photo of yourself (face and body) together with the clothing images. The images are transmitted to the AI service Google (Gemini / Vertex AI) solely to generate an image showing how the selected items would look on you.

3. Face Data

Some features process images depicting your face (the selfie for color analysis and the person photo for virtual try-on). We believe it is important to be transparent about this:

• What we collect: only the photographs you voluntarily upload. We do not create, extract or store biometric templates, face "prints", facial vectors or biometric identifiers. We do not perform facial recognition or identification of individuals.
• How we use them: face images are used solely to provide the requested feature (color analysis or virtual try-on generation). They are not used for profiling, advertising, model training or for any purpose other than the requested one.
• Who we share them with: the images are transmitted to the AI providers listed in point 2 — OpenAI for color analysis, Ollama for outfit evaluation and Google (Gemini / Vertex AI) for virtual try-on — for processing purposes only. These providers process the images transiently and do not use them to train their models.
• Where they are stored: temporarily on our servers (Amazon Web Services) for only the time necessary for processing.
• For how long: the worn-outfit photo for evaluation is processed and then deleted, without being stored on our servers (it is saved only if you choose to share the result). The color-analysis selfie is kept to show you your result, until you run a new analysis (which replaces it) or delete your account. The person photo used for virtual try-on, together with the generated image, is kept until you delete it from the App or delete your account.

4. Other Data Collected

Authentication data:

When you sign in via Apple Sign In or Google Sign In, we receive your name, email address and a unique identifier provided by the authentication provider. We do not have access to your password.

Purchase data:

When you make in-app purchases (credits or subscriptions), the transaction data is handled by Apple via the App Store and by RevenueCat, our subscription management provider. We do not collect or store your credit card or payment method data.

Technical and usage data:

We collect usage data via Google Firebase Analytics and PostHog, including device type, operating system, interactions with the App and performance information, to improve the service.

5. Purposes of Processing

• Provide you with access to the App's features through secure authentication
• Process the uploaded images to offer color analysis, outfit evaluation, suggestions and virtual try-on
• Manage in-app purchases, credits and subscriptions
• Improve the App's performance and user experience
• Comply with legal obligations

6. Third-Party Services

The App uses the following third-party services that may process data on our behalf:

• OpenAI — AI service used for color analysis (armocromia). OpenAI Privacy Policy
  • Data transmitted: the face photo (selfie) uploaded for color analysis.
  • Purpose: visual analysis to determine the seasonal palette.
  • Retention: real-time processing; the data is not used to train the models.
• Ollama — AI service used for outfit evaluation and analysis of wardrobe item images. Ollama Privacy Policy
  • Data transmitted: the photo of the worn outfit (which may include face and body) and the clothing images.
  • Purpose: visual analysis for the score, style advice and outfit-matching suggestions.
  • Retention: transient processing; the data is not used to train the models.
• Google (Gemini / Vertex AI) — AI service used to generate the virtual try-on and outfit images. Google AI Privacy Policy
  • Data transmitted: the person photo (face and body) and the selected clothing images.
  • Purpose: generate the image showing the user wearing the chosen items.
  • Retention: transient processing; the data is not used to train the models.
• Firebase (Google) — Authentication (Google Sign In) and Analytics. Firebase Privacy Policy
• Apple Sign In — Authentication. Apple Privacy Policy
• Amazon Web Services (AWS) — Hosting and temporary data storage. AWS Privacy Policy
• RevenueCat — In-app purchase and subscription management. RevenueCat Privacy Policy

We confirm that the third parties with whom we share data provide an adequate level of protection and process the data solely for the purposes indicated above.

7. Legal Basis for Processing

• Consent (Art. 6(1)(a) GDPR): for sending images to third-party AI services and for cookies/analytics
• Performance of a contract (Art. 6(1)(b) GDPR): to provide the requested service
• Legitimate interest (Art. 6(1)(f) GDPR): to improve the service and ensure security

8. Data Retention

The outfit-evaluation photo is deleted after processing and not stored (it is saved only if you choose to share the result, as a shareable image). The color-analysis selfie is kept until you run a new analysis (which replaces it) or delete your account. The virtual try-on photos (person photo and generated images) and the digital wardrobe item images are kept until you delete them or delete your account. Account data is kept until the account is deleted. Analytics data may be kept for a maximum of 26 months.

9. Data Transfer

Your data may be transferred and processed on servers located outside the European Economic Area (EEA), in particular in the United States, via the services of AWS, Google, OpenAI, Ollama and Apple. Such transfers take place on the basis of adequate safeguards, including the Standard Contractual Clauses approved by the European Commission.

10. Your Rights

In accordance with the General Data Protection Regulation (GDPR), you have the right to:

• Access your personal data
• Rectify inaccurate data
• Request the deletion of your data
• Restrict the processing of your data
• Data portability
• Object to processing
• Withdraw consent at any time

To exercise your rights, contact us at privacy@cubrik.it. You also have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).

11. Security

We adopt appropriate technical and organizational measures to protect your personal data from unauthorized access, loss, destruction or alteration. However, no method of transmission over the Internet or electronic storage is 100% secure.

12. Minors

The App is not intended for minors under the age of 16. We do not knowingly collect personal data from minors under 16. If we discover that we have collected data from a minor, we will delete it promptly.

13. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Changes will be posted on this page with the update date. Continued use of the App after changes constitutes acceptance of the new Privacy Policy.

14. Contact

For any questions or requests regarding this Privacy Policy, you can contact us:

CUBRIK S.R.L.
Via Grange Palmero 47
10091 Alpignano (TO), Italy
Email: privacy@cubrik.it