Privacy Policy.

1 · Introduction

This Privacy Policy explains how Closet Remix (the App), operated by Fashion Fusion CIC (company number 14394719), collects, uses, stores, and protects your personal data.

We are committed to protecting your privacy and being transparent about what data we handle. As a Community Interest Company, we have no incentive to monetise your personal data — our mission is to help you dress sustainably, not to sell your information.

2 · Data Controller

3 · What Data We Collect

3.1 Data You Provide

• Profile information — name, body measurements (optional), style preferences, body shape, gender preference, accessibility needs.
• Wardrobe data — photos of your clothes, categories, colours, fabrics, brands, occasion tags, garment details (closure type, neckline, fit, etc.).
• Usage data — outfit selections, wear logs, feedback (likes/dislikes), saved outfits, calendar entries.
• Subscription information — your chosen tier (payment processing is handled entirely by Apple/Google, not by us).
• Date of birth — collected when you select the Edit · Under 21s tier to verify age eligibility. Not used for any other purpose.
• University email address — collected when you select the Student tier for .ac.uk verification. Stored temporarily on your device pending verification. Not used for marketing or shared with third parties.

3.2 Data We Process Automatically

• Device information — device type, operating system version (for compatibility).
• Location data — approximate location for weather-based outfit suggestions (only when you grant permission, never stored permanently).
• App performance data — crash reports, loading times (anonymised).

3.3 Data We Do NOT Collect

• We do not collect or store payment card details (handled by Apple/Google).
• We do not collect social media profiles or contacts.
• We do not track browsing history outside the App.
• We do not use cookies (the App is native, not web-based).
• We do not collect biometric data.
• We do not collect any personal sustainability data unless you explicitly opt in to Anonymous Sustainability Insights — see section 4.4. Even then, the data is anonymised and cannot be linked to you.

3.4 Age and Student Verification

When you select the Edit · Under 21s tier, we ask for your date of birth to confirm eligibility. This date is stored locally on your device only. It is not uploaded to our servers.

When you select the Student tier, we ask for a valid university email address ending in .ac.uk. This email is stored temporarily on your device while verification is pending. Once verified it is used only to confirm student status and is not used for marketing or shared with third parties. If verification is not completed the email is not retained.

Neither your date of birth nor your university email is used for any purpose other than eligibility verification.

4 · How We Use Your Data

4.1 To Provide the App's Core Features

• Generate personalised outfit suggestions based on your wardrobe, preferences, weather, and occasion.
• Calculate sustainability metrics (CO₂ saved, rewears, utilisation rate).
• Process wardrobe photos including optional background removal and cropping tools, handled on-device.
• Display your wardrobe, saved outfits, capsules, and calendar.

4.2 To Improve the App

• Analyse anonymised, aggregated usage patterns to improve outfit suggestions.
• Identify and fix bugs and performance issues.
• Develop new features based on how the App is used.

4.3 To Communicate With You

• Respond to support enquiries.
• Send important updates about the App (e.g. terms changes, security alerts).
• We will never send marketing emails without your explicit opt-in consent.

4.3b · Automated Processing and Profiling

The App generates personalised outfit suggestions using an algorithm that processes your wardrobe items, style preferences, weather data and occasion tags. This is automated processing, but it does not constitute profiling in the legal sense under UK GDPR Article 22 because:

• No decisions are made that have legal or similarly significant effects on you.
• The suggestions are recommendations only — you remain in full control.
• No inferences are made about sensitive characteristics such as health, finances, or beliefs.

You can stop receiving outfit suggestions at any time by not using the home screen recommendation feature.

4.4 Anonymous Sustainability Insights (Opt-In)

We're building a future feature that will let us understand the collective environmental impact of the Closet Remix community — how many rewears we're racking up together, how much water we're saving, what fabrics dominate UK wardrobes. To do that well, we need real numbers from real wardrobes.

This is strictly opt-in. During onboarding you'll see a toggle called "Share anonymous sustainability data." It is OFF by default. You can switch it on or off at any time in Profile → Privacy.

If you are under 18, we recommend you discuss this choice with a parent or guardian before opting in.

If — and only if — you turn it on, once a month we will prepare a small snapshot of fully anonymised data:

• A random device ID (a hashed code, not your real device ID, and not linked to your name, email, or account).
• The month the snapshot covers.
• How many items are in your wardrobe.
• How many rewears you logged that month.
• Estimated CO₂ saved (kg) and water saved (litres).
• Your top three most-worn fabric types.
• Your most-used occasion tag.
• How many items you added, donated, and sold that month.
• How many capsules you built that month.
• Your subscription tier (Free, Edit · Under 21s, Student, Plus, Premium).
• Your country, taken from your phone's language setting (never your GPS location).

What we do NOT include: your name, email, photos, GPS location, payment details, browsing history, contacts, advertising IDs, or anything else that could identify you personally.

Important to know right now: at the date of this policy, this snapshot is prepared and stored on your device only — nothing is sent anywhere. We're telling you about it now so that when we switch on transmission in a future App update, the rules are already clear and you've already chosen. When transmission goes live, we will:

• Notify you in the App before any data leaves your device.
• Send only over an encrypted (HTTPS) connection.
• Send only to a secure server operated on our behalf.
• Continue to make it one tap to turn off.

The snapshot uses a randomly generated device identifier — a one-way hash that is created fresh each month and is not derived from your actual device ID, name, email, or any persistent account identifier. This means there is no technical mechanism to link a snapshot back to you. We have assessed this against the ICO's anonymisation standard and are satisfied the data is genuinely anonymous rather than merely pseudonymous. We will review this assessment if our data processing changes.

You can stop any future snapshots at any time by turning the toggle off, and you can clear any snapshots still on your device by switching the toggle off and reopening the App.

5 · Legal Basis for Processing (UK GDPR)

We process your data on the following legal bases:

• Contract performance — processing necessary to provide the App's features (Article 6(1)(b)).
• Legitimate interests — anonymised analytics to improve the App, provided this does not override your rights (Article 6(1)(f)).
• Consent — location data access, marketing communications, and anonymous sustainability insights (Article 6(1)(a)). For sustainability insights specifically, your consent is the explicit opt-in toggle in onboarding or Profile → Privacy, and you can withdraw it at any time.

You can withdraw consent at any time through the App settings or by contacting us.

6 · Data Storage and Security

6.1 Where Your Data Lives

Your wardrobe data (photos, items, outfits, preferences) is stored locally on your device using AsyncStorage. This means your data stays on YOUR phone — we do not upload your wardrobe to our servers unless you explicitly use the Export feature.

6.2 Third-Party Processing

When you add a wardrobe photo (Premium/Teen users), the image is sent to remove.bg for background removal. remove.bg processes the image and returns the result — they do not store your images permanently. Their privacy policy is available at remove.bg/privacy.

6.3 Security Measures

• All data transmission uses HTTPS encryption.
• Local data is stored in the App's sandboxed storage (not accessible by other apps).
• We do not store passwords (authentication is handled by Apple/Google).
• API keys for third-party services are stored securely and never exposed to users.

7 · Data Sharing

We do not sell your personal data. Ever.

We share data only in these limited circumstances:

• Apple App Store / Google Play — subscription management and payment processing.
• Legal requirements — if required by law, court order, or regulatory authority.

We do not share your wardrobe data, style preferences, body measurements, or any personal information with advertisers, data brokers, or any other third parties.

8 · Your Rights (UK GDPR)

Under UK data protection law, you have the right to:

• Access — request a copy of the personal data we hold about you.
• Rectification — ask us to correct inaccurate data.
• Erasure — ask us to delete your data ("right to be forgotten").
• Data portability — receive your data in a structured, machine-readable format (the App's Export feature provides this).
• Object — object to processing based on legitimate interests.
• Withdraw consent — withdraw consent for location data or marketing at any time.
• Complaint — lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

To exercise any of these rights, contact us at hello@closetremix.co.uk. We will respond within 30 days.

9 · Data Retention

Your wardrobe data is stored locally on your device for as long as you use the App. If you delete the App, your local data is removed with it.

If you request account deletion, we will remove any server-side data within 30 days.

Anonymised, aggregated analytics data (which cannot identify you) may be retained indefinitely to improve the App.

Server-side logs. If you contact us by email, we retain that correspondence for up to 2 years. Anonymised crash and performance logs are retained for up to 12 months. Student tier verification emails are deleted once verification is confirmed or after 90 days if unverified.

10 · Children's Privacy

The App's Edit · Under 21s tier is designed for users aged 13–21. Users selecting this tier are asked to verify their age using their date of birth. We do not knowingly collect data from children under 13. If you believe a child under 13 has provided personal data, please contact us and we will delete it promptly.

Users aged 13–17 accessing the app are considered children under UK data protection law. We apply additional protections for these users — wardrobe data is private by default, cannot be shared publicly, and we do not use their data for profiling or targeted content. We recommend parents and guardians discuss the Anonymous Sustainability Insights toggle with younger users before it is enabled.

11 · International Data Transfers

Your wardrobe data is stored locally on your device. We do not currently transfer personal data outside the UK as part of normal App operation.

If you contact us by email, that correspondence is processed via our email provider which may operate servers within the EEA. Apple and Google process subscription data in accordance with their own international transfer frameworks.

We will update this section if our data processing arrangements change.

12 · Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes through the App. The effective date at the top of this policy indicates when it was last updated.

13 · Accessibility

This Privacy Policy is available in the App under Profile → Help & FAQ. If you need this policy in an alternative format due to accessibility requirements, please contact us at hello@closetremix.co.uk.

14 · Contact Us

For any privacy-related questions or to exercise your data rights:

You also have the right to contact the Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Telephone: 0303 123 1113