This Privacy Policy explains how Closetary Ltd collects, uses, and protects personal information when you use our website, waitlist, mobile application, or related services. Closetary is currently in early product development, with a private beta planned for the UK market.

1. Who We Are

Closetary Ltd is a UK-based company building an AI-powered wardrobe intelligence platform.

For privacy questions, you can contact us at:

  • Email: privacy@closetary.uk
  • Data Controller: Closetary Ltd
  • Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

2. Information We May Collect

Depending on how you interact with Closetary, we may collect:

Information you provide

  • Name and email address
  • Waitlist sign-up information
  • Account details if you create an account
  • Wardrobe item information, such as clothing photos, descriptions, brands, sizes, or preferences
  • Style preferences and feedback you choose to provide
  • Optional appearance details you choose to add for colour matching, such as skin undertone, depth and contrast

Information collected automatically

  • Device and browser information
  • Usage data, such as pages viewed or features used
  • Basic analytics and performance information
  • Error logs and crash reports

Information from third-party services

If you choose to sign in using services such as Google or Apple, we may receive basic profile information such as your name and email address, depending on your permissions.

Information from your device (with your permission)

If you turn on weather-based features, your device location is rounded to an approximate 11 km grid on your device before it is sent, and used only to fetch local weather. We do not store your precise GPS location or a location history.

Sensitive (special category) information

The optional appearance details above (for example skin tone) may count as special category data under Article 9 of the UK GDPR. They are entirely optional, self-provided, used solely to tailor colour and outfit suggestions to you, and processed only where you give your explicit consent. You can leave them blank or remove them at any time. Closetary is not otherwise designed to collect special category data. Wardrobe photos may incidentally show your face, but the numerical fingerprints we derive describe the garment, not your face, and are not used to identify you.

3. How We Use Your Information

We may use your information to:

  • Provide and improve the Closetary service
  • Manage waitlist sign-ups and beta access
  • Create and manage user accounts
  • Support wardrobe organisation and outfit recommendation features
  • Improve product performance, reliability, and user experience
  • Communicate service updates and respond to support requests
  • Meet legal and regulatory obligations

We do not sell your personal data.

4. AI and Wardrobe Data

Closetary uses AI-assisted features to help organise your wardrobe, suggest outfits, and provide wardrobe insights.

To provide these features, when you add an item its photo and related wardrobe details are processed using trusted third-party AI services acting on our behalf. We ask for your explicit consent before any photo is sent for AI processing, and you can decline (in which case the automated add-item features are unavailable, but you can still use Closetary).

Your photos and personal wardrobe data are used to provide the service to you. They are not used to train third-party AI models without your clear, separate consent.

Where UK data protection law applies, we may process personal information based on:

  • Contract performance: to provide services you request
  • Consent: where you choose to provide optional information or receive marketing
  • Legitimate interests: to improve, secure, and operate the service
  • Legal obligations: where required by law

Where you provide optional appearance details (special category data), we also rely on your explicit consent under Article 9(2)(a) of the UK GDPR. You can withdraw this consent at any time by removing the data in the app, without affecting processing carried out before withdrawal.

6. Data Sharing

We may share limited data with trusted service providers who help us operate Closetary, such as:

  • Hosting and infrastructure providers
  • Analytics and performance tools
  • Authentication and communication providers
  • Trusted third-party AI providers, to help provide AI-assisted features

We require service providers to handle data responsibly and only for the purposes we specify.

International transfers. Some of our service providers, including certain AI and infrastructure providers, are based outside the UK (for example in the United States). Where personal data is transferred outside the UK, we rely on appropriate safeguards such as UK adequacy regulations or the UK International Data Transfer Agreement (including the UK Addendum to the EU Standard Contractual Clauses), so that your data keeps an equivalent level of protection.

7. Data Storage, Retention and Security

We take reasonable technical and organisational measures to protect personal information against unauthorised access, loss, misuse, or disclosure, including hashed passwords, encryption in transit (HTTPS/TLS), access-controlled storage and continuous error monitoring.

We keep personal information only for as long as necessary. Your account, wardrobe items, photos, style profile, wear history and outfits are kept for the life of your account and erased when you delete the item or your account. Items you delete in the app are permanently purged after 30 days. Other data is removed automatically on set schedules, for example: in-app notifications after 180 days; verification, password and account-deletion codes within about 24 hours of expiry; abandoned upload drafts after 24 hours; and AI usage logs after 12 months. Payment and transaction records are kept for the period required by law and then deleted. Full detail is set out in our internal Data Retention Schedule, which is available on request.

8. Age Requirement

Closetary is an adults-only service. Because it includes a community, a peer marketplace and payments, you must be at least 18 years old to create an account or use the service. We ask for your date of birth at sign-up to confirm this and do not knowingly collect personal data from anyone under 18. As the service is not intended for or directed at under-18s, the ICO Age Appropriate Design Code (Children’s Code) is not engaged. If you believe someone under 18 has provided us with personal data, contact privacy@closetary.uk and we will delete it.

9. Your Rights

Depending on your location and applicable law, you have rights to access, correct, delete, restrict or object to the processing of your personal data, and to data portability. You can download a copy of your data or permanently delete your account and all associated data from within the app, or by contacting us at privacy@closetary.uk. We respond to requests within one month.

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) gives you the following rights over your personal information:

  • Right to know what personal information we collect, use, and disclose.
  • Right to access a copy of the personal information we hold about you.
  • Right to delete the personal information we hold about you.
  • Right to correct inaccurate personal information.
  • Right to opt out of the sale or sharing of personal information.
  • Right to limit the use of sensitive personal information.
  • Right to non-discrimination for exercising any of these rights.

We do not sell or share your personal information as those terms are defined under the CCPA/CPRA, and we do not use sensitive personal information for any purpose that gives rise to the right to limit. There is therefore nothing for you to opt out of, but you may still exercise your other rights at any time.

To exercise any of these rights, use the in app controls or contact us at privacy@closetary.uk. We will not discriminate against you for exercising your rights, and you may use an authorised agent to submit a request on your behalf. We may need to verify your identity before we act on a request.

11. Contact

For questions about this Privacy Policy or how we handle personal data, you can contact us at:

  • Address: Closetary Ltd, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
  • Email: privacy@closetary.uk

You also have the right to raise concerns with the UK Information Commissioner’s Office at ico.org.uk.