Privacy Notice

1. Who we are

Closet Circle (“Closet Circle”, “we”, “us” or “our”) is a platform designed to help friends organise, share and borrow clothes, plan outfits and make better use of the things they already own.

This Privacy Notice explains how we collect and use personal data when you use our mobile application, website and related services (the “Service”).

For the purposes of the GDPR, UK GDPR and similar data protection laws, Closet Circle is the controller of the personal data described in this Notice.

Questions about privacy? Contact us at privacy@closetcircle.app.

2. Information we collect

Depending on how you use Closet Circle, we may collect:

• Account and profile information, such as your name, email address and profile photo;
• Content you provide, such as photographs, descriptions and tags relating to clothing or other items;
• Group and activity information, including group memberships and lending or borrowing activity;
• Communications, including feedback, support requests and correspondence; and
• Technical and usage information, such as device and operating system information, app version, browser information, timestamps, logs and information about how the Service is used.

Information you choose to share in a group may be visible to other members of that group.

We also use Aptabase for optional in-app analytics and Google/Firebase technologies for website analytics. Where required by law, analytics are used only with your consent. For more information, including how to change your choices, please see our Information about Tracking Technologies.

3. How and why we use your information

We use personal data:

Where applicable law requires consent for processing that would otherwise rely on another lawful ground, we will obtain that consent.

Where we rely on legitimate interests, we balance those interests against your rights, interests and reasonable expectations.

4. How we share information

We do not sell your personal information.

We may share information:

• With other users, where you choose to share information within a group or otherwise interact with them;
• With service providers, such as hosting, infrastructure and analytics providers, where necessary to operate the Service;
• Where required by law or for safety or legal purposes; and
• In connection with a business transaction, such as a merger, acquisition, restructuring or sale.

Service providers processing personal data on our behalf are subject to appropriate contractual and data protection requirements.

5. International data transfers

Some of our service providers may process personal data outside your country.

Where personal data protected by the GDPR or UK GDPR is transferred outside the EEA or UK, we use an appropriate transfer mechanism where required, such as an adequacy decision, the EU–US Data Privacy Framework where applicable, Standard Contractual Clauses or another mechanism permitted by applicable law.

Our Aptabase in-app analytics service is configured to process analytics data in the EU and is designed not to include persistent user identifiers. Certain Google/Firebase services may involve processing outside the EEA/UK.

You may contact us for more information about applicable transfer safeguards.

6. Data retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Notice.

Generally, account information is retained while your account is active. If you delete your account, we aim to delete or anonymise associated personal data within 30 days, unless we need to retain certain information to comply with law, protect legal rights, prevent fraud or abuse, or complete our normal secure backup cycle.

Anonymous information that can no longer reasonably be linked to you may be retained.

7. Your privacy rights

Depending on where you live, you may have the right to:

• access your personal data;
• correct inaccurate or incomplete data;
• request deletion of your data;
• restrict certain processing;
• object to processing based on legitimate interests, and to direct marketing at any time;
• receive certain data in a portable format;
• withdraw consent at any time where processing is based on consent; and
• lodge a complaint with your competent data protection or privacy authority.

These rights are subject to applicable legal conditions and exceptions.

To exercise your rights, contact privacy@closetcircle.app. We may need to verify your identity before completing your request.

8. Security

We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful loss, alteration, disclosure or access.

No online service can guarantee absolute security, but we maintain safeguards appropriate to the nature and risk of the information we process.

9. Children

Closet Circle is not intended for children under 13, and we do not knowingly collect personal data from children under 13.

If we become aware that such information has been collected, we will take appropriate steps to delete it.

10. Changes to this Notice

We may update this Privacy Notice as Closet Circle develops or legal requirements change.

We will post the updated Notice and update the “Last updated” date. Where required by law, we will provide additional notice or obtain consent.

11. Contact us

If you have questions, requests or concerns about privacy, please contact:

Closet Circle
privacy@closetcircle.app