1. About company and this WROBE privacy policy
We, a company GARMA LABS, LLC (EIC: 208022367), which owns the rights of use through the TM WROBE license agreement, (“Company”, "we", "us", "we", "our", "we", and their forms) are interested in protecting your privacy. The Company is a controller for the purposes of the General Data Protection Regulation ("GDPR") and the UK GDPR.
This Privacy Policy describes Company’s privacy practices with respect to the "Wrobe" mobile applications in the App Store and Google Play Store (the "App"), partners.wrobe.ai and wrobe.ai websites (the "Site").
Company’s site and services are not intended for children. If you have questions about this Privacy Policy, please contact the Data Protection Officer at help@wrobe.ai
If you choose not to read the entire Privacy Policy, we want you to understand a few key points about Company’s privacy practices
- The App includes a 3D body scan for creating virtual avatars.
- Due to mobile devices' limited computing resources, we use third-party cloud providers — specifically Hetzner, Host Key — to process and edit photos and videos.
- The App only uploads videos and photos to the cloud that you record with the App.
- Videos and photos are encrypted with a key stored locally on your mobile device.
- We do not use the videos you provide when using the App to identify you or for any reason other than to provide you with 3D body scanning features in the App or for internal use of anonymized data to improve the technology.
2. Third-party sites
Our App and Site may contain links to our partners, retailers, and brands (collectively, our "Partners"), advertisers, affiliates, etc. When you click on a link to any of these sites, please be aware that this Privacy Policy does not apply to those sites. We are not responsible for the privacy policies or practices of these sites, so we recommend you read their policies before submitting any personal data to these sites.
3. What information we collect and how we collect it
When you use the App, we may collect information about you, including:
- The video and TrueDepth data provided when you use the App with your camera (hereinafter, video refers to TrueDepth video and data). We only receive the specific video you record with the App; we do not record videos other than screen scans, even if you give us access to do so.
- App usage information, such as information about how you use the App and interact with us, including your preferred language, the date and time you first installed the App, and the date and time you last used the App.
- Email address, if you sign in with your email address.
- Device data, such as your computer and mobile device operating system type and version number, manufacturer and model, device ID, push tokens, Google ID for ads, Apple ID for ads, browser type, screen resolution, IP address (and the applicable country you are located in), the website you visited prior to visiting our Site; and other information about the device you use to access the App and the Site.
- Web activity data, such as information about your usage and activities on the App and Site, including pages or screens viewed, time spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access. Our service providers and certain third parties (such as online advertising networks and their clients) may also receive similar information over time on third party websites and mobile applications. This information may be collected on our Site through cookies, browser web storage (also known as locally stored objects, or "LSOs"), web beacons, and similar technologies. We may collect this information directly or through third-party software development kits (SDKs). SDKs may allow third parties to gather information directly from our App.
4. Why do you use my data
We do not use the videos you provide when you operate the App for any reason other than to provide you with the 3D body scanning features of the App or for internal use of anonymized data to improve technology. We may use information other than video for the following purposes:
For the purposes of registering your Wrobe account on our Site, App and managing it
We collect information about your name, email address, password, and other additional information you may add to your account. To fulfill our contract with you, we are legally required to do this.
To manage and improve the App
- To enable you to use the App features.
- To communicate with you about the App, including sending you announcements, updates and security alerts via push notifications, and responding to your requests, questions and feedback.
- To provide technical support and maintenance of the App.
- To analyze your App usage (using FireBase and Amplitude).
To send you marketing and promotional messages
We may send you marketing messages where permitted by law. You will have the option to opt out of receiving our marketing and promotional communications in your account settings.
To provide you with customer service support including help with any questions about our services, information about any changes to our terms of service, or asking you to share your experiences using our services, we collect information about your name, email address, password, phone number and addresses, and our common contact history. The legal basis for this is to fulfill our contract with you and our legitimate interests in retaining you as a customer.
To create anonymous, consolidated or de-identified data
We may create anonymous, consolidated or de-identified data based on personal information of yours and others whose personal information we collect. We turn personal information into anonymous, consolidated or de-identified data by removing information that makes it personally related to you. We may use this anonymized, consolidated or de-identified data and share it with third parties for legitimate business purposes.
To provide you with personalized recommendations and improve your experience
We collect information about your name, email address, phone number, browsing history and online behavior, device information, aliases, cookie identifiers, internal identifiers, country. The legal basis for this is our legitimate business interests and our desire to make your shopping experience more convenient and enjoyable.
To conduct research, analysis and surveys regarding your use of our Site
We collect your name, address, email address, and device information. The legal basis for this is our legitimate interests in conducting our business, improving our Site and your experience.
For advertising and retargeting with our products and services and those of our partners
We collect your email address, cookie identifiers, and device information. This is based on our legitimate business interests.
To create aggregated statistical reports
We use your order history — such reports do not identify you as a result. The legal basis for this is our legitimate interests in conducting our business and improving our Site.
5. To whom you provide my information
We do not share user videos with third parties, with the exception of our cloud service providers (Hetzner) when uploading encrypted images to provide 3D body scanning features in the App, and to our service providers for annotating data to improve technology (in which case user data is not linked to an account).
To provide our services and operate the Site, we partner with several third parties who have been carefully screened. As part of this partnership, we may share your information with third parties in the instances listed below.
Service Providers
We may share your personal information with service providers who provide services on our behalf or help us operate the App (e.g., payment services, customer hosting, analytics, email delivery, marketing, and database management services). These third parties may only use your personal information under our direction or authorization and in accordance with this Privacy Policy. They are prohibited from using or disclosing your information for other purposes.
Our partners and the brands you purchase from
We work with carefully selected partners who supply the products on our Site. With your consent, we may also share your name, contact details, and purchase information with our partners in relation to products you have purchased from them for their own marketing purposes. The use of your personal information for these purposes will be in accordance with the relevant partner's privacy policy.
To third party service providers for the business benefit
- Courier companies that we engage to deliver goods to you: as such they must have access to your order information, including your name and address. These service providers operate worldwide and, depending on the delivery address, may involve local companies.
- The payment service providers we engage to process your payment information (including your credit or debit card details) to enable us to collect payments from you. They are based in the European Union, USA and are engaged depending on your location.
- Analytics and search engine providers that we engage to improve and optimize the Site. These vendors are located in the United States and Europe.
- Customer service providers who operate our customer service operations and help us improve and manage the customer experience. Our current service provider is based in the United States.
- Suppliers of marketing tools that help us conduct our marketing activities. These suppliers are located in the United States and Europe.
- Performance marketing and recommendation service providers who help us advertise and recommend Wrobe products according to your interests and needs. These service providers are based in Europe (primarily in the UK) and the United States.
- Research companies that help us conduct surveys regarding your use of our Site and our services. These service providers are primarily located in Europe (primarily in the UK) or the United States.
- The IT/technology providers we use to support, maintain, and provide our technology and IT infrastructure that underpin the operation of our Site and the storage of your information.
6. Transfer of your personal information
By using our App and Site, you acknowledge and agree that your personal information will be processed on the territory of cloud service providers.
In order to operate our App, Site and provide our services in accordance with the purposes set out above, we may transfer the personal information we collect from you to a destination outside the UK or European Economic Area ("EEA") — predominantly the United States, to one of our partners or to one of the third parties we collaborate with, and store such information there as set out below.
- When we transfer personal information outside the EEA, namely to the United States, Brazil, Russia, Japan, or China, we use the Commission's standard contracts for personal data transfer to third countries.
- We transfer personal information to one of our partners outside the EEA where such transfer is necessary for the performance of a contract between you and such partner from whom you order goods.
- When we transfer personal information to one of the aforementioned third-party service providers, we employ various measures to ensure adequate protection as described below:
Model clauses
When transferring personal data to third countries, we rely on the European Commission's Standard Contractual Clauses and the Supplement to International Data Transfer to the European Commission's Standard Contractual Clauses (UK).
7. Cookies and authorizations
Device Permissions
You may revoke any permissions previously granted to us, such as permission to access a camera or a list of cameras. This is done through your mobile device settings.
Cloud Processing
You may request that we delete your information, including videos, by clicking the "Delete User" button in the "Legal Information" section of the App settings on your mobile device.
Browser Cookies and Web Stores
Most browsers allow you to delete or reject cookies. To do so, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you disable cookies, the Site may not function properly. Similarly, your browser settings may allow you to clear your browser's web storage.
Opting out of sharing your personal information
If we are required by law to collect your personal information, or if your personal information is necessary for us to provide you with an application, then if you do not give us this information when requested (or later ask to have it removed), we may not be able to deliver our services to you. We will tell you what information you must provide to use the App by specifying it as required at the time of collection or by other appropriate means.
Third-Party Platforms or Social Media
If you choose to sign in to the App through a third party platform or social network, such as by logging into Facebook, you may have the option to limit the information we may collect from the third party at the time you log into the App by using a third party authentication service or other connection to your account. You may manage your settings through a third-party platform or service. For example, you can access and change your settings through Facebook's settings page for the Apps and Websites. If you deny us the ability to access certain information from a third-party platform or social network, that choice will not apply to information we have already received from that third party.
Other Websites, Mobile Apps and Services
The App may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement or representation that we are affiliated with any third party. In addition, our content may appear on web pages, mobile applications or online services not affiliated with us. We do not control third party websites, mobile applications or online services and are not responsible for their actions. Other websites, mobile applications, and online services have different policies regarding personal information collection, use, and transfer. We encourage you to review the privacy policies of other websites, mobile applications, and online services that you use.
8. Security
We use commercially reasonable security practices to protect information collected through the App. We take reasonable steps to verify your identity before granting you access to your account (if you have an account with us). However, Wrobe cannot ensure the security of any information you transmit to Wrobe or ensure that information in the App cannot be accessed, disclosed, altered or destroyed. Please do your part to help us. You are responsible for maintaining the confidentiality of your login information and device identifiers, and for monitoring access to communications between you and Wrobe at all times. Your privacy settings may also be affected by changes that the social networks you connect to Wrobe make to their services. We are not responsible for other organizations' functionality, privacy or security measures.
9. How long you will use my information
We may store anonymized video information for technology enhancement purposes with our cloud providers (Hetzner) for as long as necessary to fulfill the purposes set forth in this Privacy Policy. With respect to non-video information that we may collect, we will retain such information in a personally identifiable format only for as long as necessary to fulfill the purposes set forth in this Privacy Policy.
You may also ask us to delete your information by contacting help@wrobe.ai
10. What are my confidentiality rights
Regarding the personal information we hold about you, the following rights are available. Some of these rights only apply in certain circumstances, as described below. In addition, we set out how these rights are implemented. Note: before responding to any request to implement your rights, we will require you to confirm your identity. This may involve a set of questions to verify that it is you who is trying to reach this information. If you have appointed another person to make requests on your behalf, that person or entity must show a valid power of attorney issued by you. We must respond to your request to exercise these rights without undue delay and within one month at the latest (subject to a further two-month extension in some cases).
To exercise your rights, please complete this data subject request form.
Access
You have the right to know whether we are processing personal data about you and, if so, to access the data we hold about you and certain information about how we use it and to whom we share it (including the categories of personal data we share with other businesses for their use for direct marketing purposes and the names and addresses of those businesses). Note: The dashboard in your Wrobe account allows you to view information about yourself: name, email address, phone number, date of birth, and more.
You may also request a copy of your information. If you require more than one copy of the information we hold about you, a reasonable charge may be made for providing such copies.
We may not be able to share certain personal data with you if sharing that data affects others' rights (for example, if providing your personal data would result in the disclosure of information about another person) or if another exemption applies.
Transferability
You have the right to receive a certain part of the personal data we have collected from you in a structured, common machine-readable format. You also have the right to request that personal data be transferred to another person. The relevant part of personal data means data that you provide to us with your consent or for the purposes of performing our contract with you. If you want us to transfer personal data to another person, please specify that other person. Note: we can only do this if we are technically able to do so. We are not responsible for personal data security or processing once received by a third party. We may also not be able to provide you with certain data if sharing that data affects others' rights (for example, if sharing personal data we hold about you would result in the disclosure of information about another person or information that constitutes our trade secrets or intellectual property).
Correction
You have the right to correct any inaccurate personal information we hold about you. You may change your personal information in the settings "My Account" section. You may also request such corrections by emailing us. Note: In some cases, we may ask you to explain in detail why you believe the personal information we have about you is incorrect or incomplete. This is so we can assess whether a correction is required. Please note that while we assess whether the personal data we have about you is inaccurate or incomplete, you may use your right to restrict the processing of the relevant data by us as set out below.
Erasure
Under certain circumstances, you may request deletion of the personal data we hold about you. Such circumstances are described below.
You believe that we no longer need to keep your personal data.
We process your personal data on the basis of your consent. You wish to withdraw your consent and there are no other grounds on which we may process such personal data.
We process personal data we hold about you based on our legitimate interests, where you object to such processing. Please provide us with detailed reasons to determine whether there is an overriding interest on the basis of which we may retain such personal data.
You no longer want us to use your personal data to send you promotions and special offers.
You believe that we are unlawfully processing personal data about you.
Please also note that during the period we consider your request, you may exercise your right to restrict data processing by us as described below.
Provide as much detail as possible about the reasons for this request. This will enable us to determine whether you have valid grounds for erasing such data. Note: We may retain such personal data if we have a valid legal basis to do so (for example, for the defense of legal claims or to protect the right to freedom of expression), in which case we will notify you
If you require us to erase data that we have published and there are grounds for erasing such data, we will take reasonable steps to inform others who display or link to such data of the need to remove such data.
Limiting processing to storage only
You have the right to request that we stop processing your personal data, other than for storage purposes, in certain circumstances. Note: if we stop processing personal data, we may use it again if there are valid grounds for doing so under data protection law (e.g. to defend legal claims or to protect another person).
The following are cases where you can request that we stop processing your personal data, limiting it to storage only.
If you believe that the personal data is inappropriate, the data will be held for a period while we verify your claim.
You wish to erase your personal data because our data processing is unlawful. However, you wish us to keep this personal data and stop processing.
We want to erase personal data because it is no longer needed for our purposes. However, you request that it be retained for drafting and pursuing legal claims and defenses thereto.
You object to us processing the personal data we hold about you on the basis of our legitimate interests. You wish us to stop processing such personal data while we determine whether there is an overriding interest on the basis of which we can retain such personal data.
Objection
You have the right to object at any time to our processing of data about you for the purpose of sending you promotions and special offers. This includes when we create profiles for such purposes, and we will stop processing data for this purpose. You can do this by changing your marketing settings in your Wrobe account, by selecting "Unsubscribe" at the bottom of email marketing messages or by completing an unsubscribe form. Note: you will continue to receive emails related to orders you place through our Site and updates to our Terms and Privacy Policy.
You also have the right to object to our processing of data about you. We will consider your request in other circumstances, as described below.
We process personal data we hold about you (including profiling purposes) on the basis of our legitimate interests or a third party, where you object to such processing. Provide us with detailed reasoning to enable us to determine whether there is a compelling overriding interest on the basis of which we may continue to process such data, or whether there is a need for us to process such data in connection with legal claims. Please also note that you may request that we stop processing the data for the period during which we assess the overriding interest.
Revoking consent
You may withdraw your consent at any time by changing your marketing settings in your Wrobe account.
11. Pretensions
If you have questions or concerns about this Privacy Policy, please contact us at help@wrobe.ai
12. Representative in the eu
Wrobe is the controller of your personal information covered by this Privacy Policy for the purposes of European data protection legislation.
13. Governing law
This Privacy Policy and the relations between the user and the Site arising in connection with the use of the Site and/or the App are subject to the law of the United Kingdom of England and Wales, and, where applicable, the law of the relevant other State of the territory of the EU.
14. Updates to this policy
Any changes we make to this Privacy Policy will be posted on this page and, where applicable, we will notify you by email. Check this page regularly to keep up to date with the latest updates or changes to this Privacy Policy.