Privacy Policy
1 · Who We Are
CLAi (“CLAi”, “we”, “us”, “our”) is the trading name of The Closet App LTD, a company registered in England and Wales under company number 16742543, with its registered office at 20 Lesney Park Road, United Kingdom.
You can contact us about data protection matters at: info@theclai.co.
2 · Scope of This Policy
This Privacy Policy applies to personal information we collect when you:
- join our waitlist;
- take part in our beta or early access programme;
- use the CLAi fashion intelligence chatbot; or
- contact us or interact with us in any other way.
This policy does not cover third-party websites or services linked from CLAi.
3 · Information We Collect
3.1 · Information you give us
- Your name and email address when you join the waitlist or sign up.
- Messages you send to the CLAi chatbot, including descriptions of your style, preferences, and goals.
- Photographs or images you choose to upload of clothing, outfits, or yourself (always optional - see Section 6).
- Feedback, ratings, survey responses, and comments.
3.2 · Information we collect automatically
- Device type, browser, operating system, and IP address.
- Usage data: pages visited, features used, session duration.
- Cookie and similar tracking data (see our Cookie Notice).
4 · How We Use Your Information and Our Lawful Bases
| Purpose | Lawful Basis |
|---|---|
| To operate the CLAi chatbot and waitlist | Contract / Legitimate interests |
| To generate styling and fashion guidance | Contract / Legitimate interests |
| To process images, you upload | Consent |
| To improve and develop the product | Legitimate interests |
| To send you waitlist and launch communications | Consent (PECR) / Contract |
| To send optional marketing emails | Consent |
| To comply with legal obligations | Legal obligation |
| To protect our rights and the platform | Legitimate interests |
5 · AI Processing and Third Parties
To generate responses, the content of your chats - including text and any images you upload - is processed by our AI provider, Google Gemini via Vertex AI on Google Cloud Platform, which acts as our data processor under a written agreement with us.
We do not sell your personal information to any third party.
6 · Photographs and Image Processing
Uploading a photograph is always optional. You can use CLAi without uploading any images.
If you choose to upload an image, we use it only to provide you with more personalised fashion guidance.
We do not use your images for advertising or marketing purposes.
7 · Sharing Your Information
We share personal information only in the following circumstances:
- Service providers: companies that help us operate CLAi, including our AI provider (Google), hosting provider, and analytics tools, each under contracts requiring them to protect your information.
- Legal requirements: where we are required to disclose information by law, court order, or regulatory authority.
- Business transfers: in the event of a merger, acquisition, or sale of assets, your information may be transferred to the relevant third party, who will be required to honour this policy.
- Protection of rights: where necessary to protect the security or integrity of the platform, or the rights of CLAi or its users.
We do not sell, rent, or trade your personal information.
8 · International Transfers
CLAi is operated by The Closet App LTD, a company registered in England and Wales. Our primary markets are the United Kingdom, the United States, Canada, Nigeria, and selected additional African and Middle Eastern markets. Your personal information may be processed in countries other than the one in which you are located, including in the United Kingdom and the United States, where our AI provider Google (Vertex AI / Gemini) and certain hosting and analytics infrastructure are located.
Where your personal information is transferred across borders, we ensure that appropriate safeguards are in place in accordance with the data protection laws applicable to your location, as set out below.
8.1 · Transfers Involving UK Users (UK GDPR)
For transfers of personal information from the United Kingdom to third countries, we rely on the following mechanisms under the UK GDPR and the Data Protection Act 2018:
- UK Adequacy Regulations: Where the UK Secretary of State has determined that a destination country provides an adequate level of data protection, we may transfer personal information on that basis without additional safeguards.
- UK International Data Transfer Agreement (IDTA):For transfers to countries not covered by a UK adequacy decision, we rely on the IDTA, the standard contractual clauses approved by the Information Commissioner's Office (ICO). We have entered into, or will enter into, UK IDTAs with all relevant service providers handling UK personal data outside the UK.
- UK Addendum to EU Standard Contractual Clauses: Where a service provider uses the EU SCCs as their primary transfer mechanism, we supplement those with the UK Addendum issued by the ICO, which adapts the EU SCCs for UK law.
8.2 · Transfers Involving EEA Users (EU GDPR)
For transfers of personal information from the European Economic Area to third countries, we rely on the following mechanisms under EU GDPR 2016/679:
- EU Adequacy Decisions (Article 45): Where the European Commission has determined that a destination country provides adequate protection.
- EU Standard Contractual Clauses (Article 46): For transfers not covered by adequacy, we rely on the European Commission's Standard Contractual Clauses adopted in June 2021 (Decision 2021/914), incorporating Module 2 (Controller to Processor) where applicable. We have entered into, or will enter into, EU SCCs with all relevant processors handling EEA personal data outside the EEA.
- Transfer Impact Assessments: Where we rely on SCCs, we conduct or obtain a Transfer Impact Assessment (TIA) to assess whether the laws of the destination country allow the SCCs to be effective.
- EU-US Data Privacy Framework (DPF): The European Commission adopted an adequacy decision for the EU-US DPF in July 2023.
9 · Retention
We keep your personal information only for as long as necessary for the purposes described in this policy, or as required by applicable law.
| Data Type | Retention Period |
|---|---|
| Waitlist email and name | 1 year |
| Chat logs (text) | 1 year |
| Uploaded images | Not retained; deleted immediately after processing |
| To improve and develop the product | Legitimate interests |
| Beta feedback | 1 year |
| Legal / compliance records | 6 year |
10 · Your Rights
If you are located in the United Kingdom or the European Economic Area, you have certain rights under the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR 2016/679), and the Data Protection Act 2018 (UK). If you are located outside the United Kingdom or the European Economic Area, you may have the following rights regarding your personal information:
| Right | What It Means |
|---|---|
| Access | To request a copy of the personal information we hold about you. |
| Correction | To ask us to correct inaccurate or incomplete information. |
| Deletion | To ask us to delete your personal information in certain circumstances. |
| Restriction | To ask us to limit how we use your information. |
| Objection | To object to our processing based on legitimate interests. |
| Portability | To receive your data in a structured, machine-readable format. |
| Withdraw Consent | Where processing is based on consent, to withdraw it at any time. |
| CCPA / CPRA (California) | If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you the following rights in addition to those listed above: Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purpose for collecting, selling, or sharing it, the categories of third parties to whom we disclose it, and whether we sell or share your personal information. Right to Delete: You have the right to request deletion of personal information we have collected from you, subject to certain exceptions (for example, where retention is necessary to complete a transaction, detect security incidents, or comply with a legal obligation). Right to Correct: You have the right to request correction of inaccurate personal information we maintain about you. Right to Opt Out of Sale or Sharing: You have the right to opt out of the sale of your personal information and the sharing of your personal information for cross-context behavioural advertising purposes. CLAi does not sell your personal information. To opt out, contact:info@theclai.co . Right to Limit Use of Sensitive Personal Information: Where CLAi processes sensitive personal information (which may include the contents of your messages, photographs, and information about your style preferences), you have the right to direct us to limit our use of that information to the purposes permitted under the CPRA (broadly, providing the service you requested). To exercise this right, contact: info@theclai.co .Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny you goods or services, charge you different prices, provide a different level or quality of service, or suggest that you will receive a different price or quality of service because you exercised a right under the CCPA/CPRA. Right to Data Portability: To the extent applicable, you have the right to receive your personal information in a portable, usable format. How to Exercise Your California Rights: Submit a verifiable consumer request to info@theclai.co. We will respond within 45 days of receiving a verifiable request (extendable by a further 45 days where necessary, with notice). You may designate an authorised agent to submit a request on your behalf, subject to verification. California "Shine the Light" Law (Civil Code § 1798.83): California residents may also request, once per calendar year, information about personal information shared with third parties for their direct marketing purposes. If applicable, contact info@theclai.co. |
| PIPEDA (Canada) | To access information, challenge accuracy, and complain to the Office of the Privacy Commissioner. |
To exercise any right, contact us at info@theclai.co. We will respond within the timeframe required by applicable law (in the UK, within one calendar month).
You also have the right to complain to a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO): ico.org.uk / 0303 123 1113.
11 · Children
CLAi is not intended for use by anyone under the age of 16. We do not knowingly collect personal information from children under this age. If you believe we have inadvertently collected information from a child, please contact us at info@theclai.co and we will delete it promptly.
12 · Changes to This Policy
We may update this Privacy Policy from time to time. We will post any updated version on our website with a revised "last updated" date. Where changes are material, we will notify you by email (if we have your address) or by a prominent notice on the platform before the changes take effect.
13 · Contact
For any questions about this Privacy Policy or to exercise your rights:
- Privacy / data rights enquiries: info@theclai.co
- General enquiries: info@theclai.co
- Postal address: The Closet App LTD, 20 Lesney Park Road, United Kingdom