Privacy Policy

This Privacy Policy explains how Formentia LLC ("Company", "we", "us", or "our") collects, uses, and shares information about you when you use our MyCloset web application and website (collectively, the "Service").

By using the Service, you agree to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree with our policies and practices, do not use the Service.

This Privacy Policy should be read alongside our Terms and Conditions, which provides additional information about using our Service.

1. Introduction

MyCloset is a web-based clothing organization application that uses artificial intelligence (AI) to help users categorize, organize, and get recommendations for their clothing items. To provide these features, we need to collect and process certain information, including images of your clothing items.

This Privacy Policy explains:

• What information we collect and why
• How we use that information
• How we share information with third parties
• How we protect and store your information
• Your rights regarding your information
• How we handle children's privacy

We are committed to protecting your privacy and handling your data in an open and transparent manner.

2. Information We Collect

We collect several types of information from and about users of our Service:

2.1. Information You Provide to Us

• Account Information: When you create an account, we collect your email address, phone number (for authentication), and any optional profile information you choose to provide.
• Clothing Images: The photos of clothing items you upload to the Service.
• User Preferences: Information about your style preferences, clothing categories, outfit combinations, and other settings you configure within the Service.
• Communications: If you contact us directly, we may receive additional information about you, such as your name, contact information, and the contents of your message.
• Payment Information: If you purchase a subscription, we collect payment information through our payment processors. We do not store complete credit card information on our servers.

2.2. Information We Collect Automatically

• Usage Data: Information about how you interact with the Service, such as the features you use, the actions you take, and the time, frequency, and duration of your activities.
• Device Information: We collect information about the device you use to access the Service, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Location Information: With your consent, we may collect your precise or approximate location information as determined by data such as IP address or mobile device's GPS.
• Cookies and Similar Technologies: We use cookies and similar tracking technologies to track activity on our Service and hold certain information. Cookies are files with a small amount of data that may include an anonymous unique identifier.

We use this information to provide and improve the Service, analyze usage patterns, prevent fraud, and provide customer support.

3. How We Use Your Information

We use the information we collect for various purposes, including to:

3.1. Legal Bases for Processing (for EEA, UK, and Similar Jurisdictions)

If you are located in the European Economic Area (EEA), United Kingdom, or a jurisdiction with similar data protection laws, we process your personal data based on the following legal bases:

• Performance of Contract: Processing necessary to provide the Service to you under our Terms and Conditions.
• Legitimate Interests: Processing necessary for our legitimate interests, such as improving and personalizing the Service, ensuring security, and developing new features.
• Consent: Processing based on your specific consent, such as for marketing communications or certain types of data processing.
• Legal Obligation: Processing necessary to comply with a legal obligation to which we are subject.

4. AI and Image Processing

Our Service uses artificial intelligence and machine learning technologies to analyze the clothing images you upload. This section explains how this processing works and what we do with your images.

4.1. Image Processing Technologies

We use both custom in-house and third-party AI and image processing technologies to:

• Identify and categorize clothing items (e.g., "shirt," "pants," "dress")
• Extract and generate metadata (e.g., color, pattern, style, season)
• Analyze features and attributes of clothing items
• Generate outfit recommendations based on your clothing items

4.2. How We Process Your Images

When you upload an image to the Service:

1. The image is securely transmitted to our servers using encryption
2. Our systems analyze the image to identify clothing items and their attributes
3. We extract relevant data points and metadata for categorization
4. The original image and processed data are stored in your account
5. The extracted features may be used (in anonymized form) to train and improve our AI models

4.3. Model Training and Improvement

To improve our AI capabilities, we may use anonymized and aggregated data derived from user images to train and enhance our machine learning models. This process:

• Does not use or expose personally identifiable information
• Transforms images into abstract features and patterns
• Combines data across many users to prevent re-identification

You can object to this processing by contacting us at info@formentia.com, but this may affect the quality of the Service's recommendations and categorizations for your account.

5. Information Sharing and Disclosure

We may share your information in the following situations:

5.1. Third-Party Service Providers

We share information with third-party vendors, service providers, and contractors who help us operate our business and the Service, including:

• Cloud Storage Providers: To store your data and the Service infrastructure
• AI and Image Processing Services: To help analyze and categorize clothing images
• Payment Processors: To process subscription payments
• Analytics Providers: To help us understand how users interact with the Service
• Customer Support Services: To assist with support inquiries

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.2. Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information.

5.3. Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

5.4. Protection of Rights

We may disclose your information to protect and defend the rights, property, or safety of Formentia LLC, our users, or others.

5.5. With Your Consent

We may share your information with third parties when we have your consent to do so.

6. Data Retention and Deletion

We retain your personal information for as long as necessary to provide you with the Service and for legitimate and essential business purposes, such as maintaining the performance of the Service, making data-driven business decisions, complying with our legal obligations, and resolving disputes.

6.1. Account Information

We retain your account information for as long as your account is active. If you delete your account, we will delete or anonymize your account information within 30 days, except as noted below.

6.2. Clothing Images and Derived Data

If you delete specific images or your entire account:

• Original images will be deleted from our active systems within 30 days
• Derived data (metadata, features) may remain in our systems for up to 90 days to allow for system maintenance and backup procedures; backups containing these data will be purged within 90 days thereafter
• Abstract patterns derived from your data and incorporated into our machine learning models cannot be specifically removed without rebuilding the entire model, which is technically infeasible

6.3. Backup and Legal Retention

Even after you delete your account or specific content, copies of some information may remain in our backup systems for a limited period (typically up to 90 days). Additionally, we may retain certain information as necessary to:

• Comply with legal obligations
• Resolve disputes
• Enforce our agreements
• Protect our legal rights

7. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing, accidental loss, destruction, or damage.

7.1. Security Measures

Our security measures include:

• Encryption of data in transit using TLS/SSL protocols
• Encryption of sensitive data at rest using industry‑standard AES‑256 encryption
• Regular security assessments and penetration testing
• Access controls and authentication requirements
• Monitoring for suspicious activities
• Data backup procedures

7.2. Limitations

While we take reasonable steps to secure your information, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.

7.3. Your Role in Security

You also play a role in protecting your information. We encourage you to:

• Use a strong, unique password for your MyCloset account
• Keep your login credentials confidential
• Sign out of your account after using shared devices
• Keep your device's operating system and browser updated
• Contact us immediately if you suspect unauthorized access to your account

8. International Data Transfers

Formentia LLC is based in the United States, and we store and process data on servers located in the United States and potentially other countries. This means that your personal information may be transferred to, stored, or processed in jurisdictions that may not provide the same level of data protection as your jurisdiction.

8.1. Data Transfer Mechanisms

When we transfer personal information from the European Economic Area (EEA), United Kingdom, or Switzerland to countries that have not received an adequacy decision, we use legal mechanisms to ensure an adequate level of protection for your data, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Where applicable and properly certified, the EU-U.S. Data Privacy Framework (DPF) and UK Extension to the EU-U.S. DPF
• Other valid transfer mechanisms as they become available

8.2. Third-Party Transfers

When we share your personal information with third-party service providers in other countries, we ensure appropriate safeguards are in place to protect your information, consistent with this Privacy Policy and applicable laws.

Formentia LLC does not target individuals in the EEA or UK on a commercial basis and processes EU/UK personal data only on an occasional, non‑large‑scale basis; therefore, we believe we are exempt from appointing a representative under GDPR/UK GDPR Article 27. Should this change, we will designate a representative and update this Privacy Policy accordingly.

9. Children's Privacy

Our Service is intended for users who are at least 13 years of age (16 years in the European Economic Area). We do not knowingly collect personally identifiable information from children under these age thresholds.

9.1. Age Restrictions

If you are under 13 years of age (or 16 years in the EEA), please do not use or attempt to register for our Service or provide any personal information about yourself.

9.2. Parental Consent

If you are between the ages of 13 and 18 (or the age of legal majority in your jurisdiction), you may only use our Service with the consent and supervision of a parent or legal guardian who agrees to be bound by these terms.

9.3. Parental Rights

Parents and legal guardians of users under the age of 18 have the right to review and request deletion of their child's personal information. If you believe we might have collected information from a child under the applicable age threshold, please contact us at info@formentia.com.

10. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information. This section describes the rights that may be available to you and how to exercise them.

10.1. Access and Portability

You may have the right to access the personal information we hold about you and to receive a copy of this information in a structured, commonly used, and machine-readable format.

10.2. Correction

You may have the right to correct inaccurate or incomplete personal information we hold about you.

10.3. Deletion

You may have the right to request deletion of your personal information in certain circumstances, subject to certain exceptions.

10.4. Restriction and Objection

You may have the right to restrict or object to our processing of your personal information under certain conditions.

10.5. Withdrawal of Consent

Where we process your information based on consent, you have the right to withdraw that consent at any time.

10.6. How to Exercise Your Rights

To exercise any of these rights, please contact us at info@formentia.com. We will respond to your request within the timeframe required by applicable law (typically 30 days for most jurisdictions).

10.7. Verification

To protect your privacy, we may need to verify your identity before fulfilling your request. We may request specific information to help us confirm your identity.

10.8. Limitations

Your rights may be limited in some circumstances by local law requirements. We will inform you if we cannot fulfill your request due to such limitations.

11. State-Specific Privacy Notices

Depending on where you live, you may have additional rights under state privacy laws. This section provides information for residents of states with comprehensive privacy laws.

11.1. California Residents

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have specific rights:

• Right to Know: You can request information about the personal information we've collected about you, including categories of information, sources, purposes, and third parties with whom we've shared it.
• Right to Delete: You can request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Correct: You can request correction of inaccurate personal information about you.
• Right to Opt-Out of Sale or Sharing: You have the right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising purposes. We do not sell or share your personal information as defined by California law.
• Right to Limit Use of Sensitive Personal Information: You can request that we limit the use of your sensitive personal information to specified purposes.
• Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.

To exercise these rights, please contact us at info@formentia.com.

11.2. Colorado, Connecticut, Virginia, Utah, and Other States

Residents of states with comprehensive privacy laws (including Colorado, Connecticut, Virginia, and Utah) may have similar rights to those described for California, though specific rights may vary by state. These typically include:

• Right to access personal data
• Right to correct inaccuracies
• Right to delete personal data
• Right to data portability
• Right to opt out of targeted advertising, profiling, or sales

To exercise these rights, please contact us using the information provided in the "Contact Us" section.

12. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top.

For material changes, we will provide more prominent notice, which may include:

• Email notification to the address specified in your account
• Notice within the Service
• Banner notification on our website

We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you continue to use the Service after we post changes to the Privacy Policy, you acknowledge that your continued use means you accept those changes.

13. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

• Email: info@formentia.com
• Postal Address: Formentia LLC, 30 N Gould St Ste R, Sheridan, WY 82801

For data protection inquiries specific to the European Economic Area, United Kingdom, or Switzerland, you may also contact our data protection representative at gdpr@formentia.com.

We will respond to your inquiry as soon as reasonably possible and within the timeframe required by applicable law.

14. Cookies & Similar Technologies

We only use first‑party cookies and local‑storage tokens that are strictly necessary to authenticate you, keep you signed in, and remember basic preferences. We do not use any third‑party cookies or embedded trackers for advertising, analytics, or marketing purposes.

Because we do not engage in cross‑site tracking or advertising, a browser's Do‑Not‑Track (DNT) header has no effect on your experience. However, if you send a Global Privacy Control (GPC) signal, we will treat it as an opt‑out of the sale or sharing of personal information to the extent required by applicable U.S. state privacy laws—even though we do not sell or share such information for marketing.

By using the MyCloset web application, you acknowledge that you have read, understood, and agree to this Privacy Policy.

15. Handling of Incidental Personal Data in Images

While the Service is designed to process clothing images, some photos may incidentally contain personal or identifying information (such as faces, tattoos, or identifiable backgrounds). We do not use these incidental elements for facial recognition, biometric analysis, or other unrelated processing.

Users may delete such images at any time through their account settings. Upon deletion, the original images will be removed from our active systems within 30 days. However, anonymized and aggregated data already incorporated into AI models cannot be removed without retraining the model, which is technically infeasible.

16. Data Portability

In addition to rights under specific laws such as the GDPR and certain U.S. state privacy laws, all users may request a copy of their account data in a structured, commonly used, and machine‑readable format. This export will include uploaded images, clothing metadata, and relevant account details. Requests should be sent to info@formentia.com and will be fulfilled in accordance with applicable legal timeframes.