Política de Privacidade

Introduction

FASHN LTD ("FASHN", "we", "us", or "our") is a company registered in England and Wales under company number 14979714. This Privacy Policy explains how we collect, use, share, retain, and protect personal information when we act as a Controller. We act as a Controller when we decide why and how that information is processed.

This Policy applies to personal information we process as a Controller in connection with our website, web and mobile applications, API, and related services (collectively, the "Services"). This includes information about website visitors, direct users, account holders, Organization administrators, billing contacts, and people who otherwise interact directly with FASHN.

This Policy does not apply to personal information that FASHN processes on behalf of a business customer as a Processor or Sub-processor. That processing is governed by our Data Processing Addendum and the business customer's own privacy notice. If a FASHN business customer submitted your information, including an image of you, please direct your privacy request to that customer. This Policy does, however, apply to account, billing, support, business-relationship, security, and similar information that FASHN processes as a Controller.

Information We Collect

Account and Organization Information: When you create an account, we receive your name, email address, profile picture, authentication identifiers, and other profile information from our authentication provider. If you use a social login, we receive the profile information that service makes available to us. When you create, join, or administer an Organization, we also process its name, logo, membership, roles, invitations, and related account preferences.

Direct-User Content: When you use our AI services directly and FASHN acts as a Controller, we process the images, video, prompts, instructions, generation parameters, reference media, attachments, Agent messages, and generated outputs involved in your requests. Where a Service includes a history feature, we store the relevant content so you can access it later, such as generated media in your Gallery or messages in your Agent conversation history.

Payment, Subscription, and Credit Information: We process customer and transaction identifiers, purchase amounts, currencies, dates and statuses, subscription plans and statuses, credit balances, auto top-up settings, mobile-store subscription information, and related billing records. Payment card details are handled by our payment processors and app-store providers. FASHN does not store full payment card numbers.

Usage and Technical Information: We collect information about how you interact with the Services, including pages or screens visited, features and AI models used, API key names and identifiers, request and prediction identifiers, generation status, credits used, timestamps, and account-level activity. We also collect technical information such as IP address, browser and operating-system information, device or cookie identifiers, approximate location derived from IP address, and error and performance data. Where enabled, we collect interaction and session-replay information to understand and troubleshoot use of the application.

Support Communications: When you contact us through support chat, email, or another support channel, we process the content of the communication and any attachments, together with relevant account information such as your name, email address, user identifier, profile picture, subscription plan, and credit status.

Feedback and Survey Responses: We collect information you choose to provide through surveys, ratings, cancellation feedback, support feedback, and questions such as how you discovered FASHN. This information may be associated with your account or the relevant request.

Sources and Required Information: We receive personal information directly from you, from Organization owners or administrators who invite or manage you, from authentication, payment, app-store, and subscription providers, and automatically from your device and use of the Services. Account, authentication, billing, subscription, and request information identified as required is necessary to provide the relevant Service. Optional profile information, surveys, feedback, marketing choices, and non-essential cookies are voluntary.

Personal information processed solely on behalf of a business customer, including content or request information submitted through that customer's use of the Services, is outside this Policy as explained in the Introduction and is governed by the Data Processing Addendum.

Images and video may reveal a depicted person's physical characteristics or other personal information. FASHN processes face images to provide requested generation and editing features, not to verify or establish identity. You must have the rights and permissions required by our Terms of Service and applicable law before submitting media depicting another person.

How We Use Your Information

Where FASHN acts as a Controller, we use personal information to:

• Provide the Services: Create and administer accounts and Organizations, authenticate users, process requests and content, operate requested features, and deliver generated results.
• Manage payments and credits: Process purchases and manage subscriptions, credit balances, billing records, and related account settings.
• Communicate with you: Send transaction confirmations, security alerts, notices about the Services or our legal terms, and other essential communications. We may also send product or marketing communications in accordance with your preferences and applicable law.
• Provide support: Respond to questions, investigate reported problems, and troubleshoot the Services.
• Maintain and improve the Services: Monitor performance, analyse account and product usage, correct errors, and improve functionality and user experience.
• Protect the Services and our users: Detect and prevent fraud, abuse, security incidents, and other harmful or unlawful activity, apply content-safety measures, and enforce our Terms of Service.
• Measure and promote our Services: Understand the effectiveness of our communications and advertising, including attributing signups and purchases, as described under Cookies and Tracking Technologies.
• Comply with law and protect legal rights: Maintain required records, respond to lawful requests, comply with applicable law, and establish, exercise, or defend legal claims.

Lawful bases

The lawful basis depends on the purpose and context of the processing:

• Contract: To create and administer your account or Organization, provide Services requested directly by you, manage payments and credits, and send essential service communications.
• Legitimate interests: To secure, maintain, and improve the Services, prevent fraud and abuse, provide support, understand product use, operate and promote our business, and protect our legal rights, where those interests are not overridden by your rights.
• Consent: Where we rely on your consent, including for certain cookies and similar technologies, marketing communications, and other processing, you may withdraw your consent at any time.
• Legal obligations: To maintain required financial and regulatory records, respond to lawful requests, and comply with applicable law.

How We Share Your Information

For the Controller processing covered by this Policy, we disclose personal information to the following categories of recipients. The information disclosed depends on the Service and feature you use.

When we process personal information on behalf of a business customer, the relevant providers are identified in our Subprocessor List. The categories below instead describe FASHN's own Controller processing.

• Authentication and account providers: Receive account and profile identifiers to manage accounts and provide secure sign-in.
• Payment, app-store, and subscription providers: Receive account, transaction, billing, and subscription information to process purchases and manage subscriptions. These providers may process information they collect directly under their own privacy notices. FASHN does not store full payment card numbers.
• AI and media-processing providers: Receive the direct-user content needed to perform a requested generation, editing, or media-processing operation and return the result.
• Hosting, storage, database, and content-delivery providers: Host and deliver account information, direct-user content, technical records, and other data needed to operate the Services. This may include temporary caching where required for delivery and performance.
• Analytics and product-measurement providers: Receive identifiers, device and usage information, product events, and session-replay information to help us understand and improve the Services, as described under Cookies and Tracking Technologies.
• Advertising partners: Receive website activity, identifiers, including hashed contact identifiers, and signup or purchase events to measure and improve our advertising, as described under Cookies and Tracking Technologies.
• Support and communications providers: Receive contact details, relevant account information, communications, and attachments to provide support and send service or permitted marketing communications.
• Reliability, security, and operational providers: Receive identifiers, request information, technical diagnostics, and error context to monitor performance, investigate incidents, prevent abuse, and maintain the Services.
• Organization owners and members: When you use the Services through an Organization, its owners and members may access information and content associated with that Organization according to their roles and permissions. Organization owners also manage membership, billing, and Organization-level settings.

We may also disclose personal information:

• To legal, accounting, audit, and insurance advisers where necessary for them to provide professional services to FASHN.
• To courts, regulators, law-enforcement authorities, and other parties where required or permitted by law or legal process.
• Where reasonably necessary to protect the rights, property, or safety of FASHN, our users, or others, or to investigate violations of our Terms of Service.
• In connection with a proposed or completed financing, merger, acquisition, restructuring, bankruptcy, or sale of some or all of our business or assets.
• At your direction, with your consent, or when you intentionally make information available to another person or service.

Cookies and Tracking Technologies

We use cookies, pixels, local storage, software development kits, and similar technologies in our websites and applications. Some are operated by FASHN and others are provided by third parties.

Essential Technologies: We use technologies that are necessary for authentication, session management, security, fraud prevention, and core Service functionality. These cannot be disabled through our cookie-preference controls.

Analytics and Product Measurement: We use analytics services to understand how people use and interact with the Services, improve functionality and user experience, troubleshoot problems, and measure performance. These services may collect or receive account or device identifiers, usage and product events, and session-replay information.

Advertising Measurement: We use advertising technologies to attribute signups and purchases, measure and optimise campaigns, and create advertising audiences. We may share website or application activity, signup, purchase, subscription, or upgrade events, transaction information, and hashed contact identifiers with advertising partners.

Application Analytics and Advertising: We also use analytics and advertising measurement in our signed-in web application, including product analytics, session replay, and conversion measurement.

Your Choices: On our marketing website, you can manage optional analytics and advertising technologies at any time through Cookie Preferences in the footer. Depending on where you live, we may ask for your consent before enabling these technologies. Browser, device, and advertising-provider controls may provide additional ways to limit cookies or personalised advertising. Blocking some technologies may affect how the Services function.

Data Retention

We retain personal information only for as long as necessary for the purposes described in this Policy. The retention period depends on the type of information, how it is used, the Service involved, and applicable legal requirements.

• Account and relationship data: Retained while your account or business relationship is active and afterwards where reasonably needed for support, security, or legal compliance.
• Direct-user content and history: Content saved in your Gallery or Agent conversation history is retained until you delete it or the relevant account or Organization is deleted. Content associated with an Organization that remains active after you close your account may remain available to that Organization.
• Usage, support, and security records: Retained for as long as reasonably needed to operate, troubleshoot, and protect the Services, after which they are deleted or anonymised.
• Payment and legal records: Retained for as long as required for accounting, tax, legal compliance, and resolving disputes.
• Analytics, advertising, and cookie data: Retained for periods appropriate to the relevant measurement purpose, taking account of your choices and applicable law.

Customer Personal Data processed on behalf of a business customer is retained and deleted under our DPAand that customer's instructions rather than the Controller retention periods above.

When you delete your account, we delete or anonymise personal information that we no longer need, subject to the exceptions described above. Deleted information may remain in access-restricted backups until it is overwritten through the ordinary backup cycle, or may be retained where required by law.

Data Security

We use appropriate technical and organisational measures designed to protect personal information from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. These measures include safeguards relating to encryption, authentication, access controls, separation between Organizations, monitoring, and incident response.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

Where applicable law requires us to notify you of a personal data breach, we will do so in accordance with that law.

International Data Transfers

Personal information covered by this Policy may be transferred to and processed in countries other than the country where you live, including the United Kingdom, European Economic Area, and United States. Data protection laws in those countries may differ from those in your country.

Where required by applicable law, we use recognised safeguards such as adequacy decisions or approved standard contractual clauses. You may contact us at [email protected] for more information about these safeguards or to request a copy. Transfers of Customer Personal Data are addressed separately in our DPA.

Your Rights

Depending on where you live and subject to legal exceptions, you may have the right to:

• Access your personal information and receive a portable copy.
• Correct inaccurate personal information.
• Delete your personal information.
• Restrict or object to certain processing.
• Withdraw consent you previously gave.
• Appeal or complain about our response to your request.

Your controls in the product: You can review available account information and direct-user content in the application, delete specific or all of your Gallery media and Agent conversations, and close your account from account settings. You can unsubscribe from marketing email in your account settings or through the unsubscribe link in those emails, and manage website cookie choices from the footer.

Advertising choices: Depending on where you live, you may also have the right to opt out of certain uses or disclosures of personal information for advertising measurement, attribution, or audience building. You can use the website cookie choices described above, or contact us at [email protected] with any other opt-out request.

Making a request: To exercise a right concerning data covered by this Policy, contact [email protected]. We may need to verify your identity and authority. We will not discriminate against you for exercising a privacy right.

Content submitted by a business customer:If a business customer submitted your information, contact that customer first. FASHN acts on the customer's authenticated instructions and assists it under the DPA.

Complaints: EEA, UK, and Swiss individuals may lodge a complaint with their local supervisory authority. In the UK, this is the Information Commissioner's Office.

Automated decisions

FASHN's media-generation Services create outputs in response to user instructions. FASHN does not use those outputs to make decisions about individuals that produce legal or similarly significant effects.

Children's Privacy

FASHN accounts and Services offered directly to users are not intended for anyone under 18, or under the age of legal majority where they live if higher, as explained in the User Eligibility section of our Terms of Service. We do not knowingly allow an individual below that age to create a FASHN account or use the Services directly.

This direct-use restriction does not prevent a business customer from making the Services available to younger end users through a permitted API integration. When FASHN processes their personal information on the customer's behalf, that processing is governed by our DPAand the customer's own privacy notice. The customer is responsible for ensuring that the processing is lawful, including obtaining parental or guardian consent where required.

If we learn that we collected personal information from an ineligible direct user outside that business customer context, we will take reasonable steps to delete it. If you believe this has occurred, please contact us at [email protected].

Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated date. Where required by applicable law, we will provide additional notice of a material change through an appropriate account, email, or in-Service channel.

Contact Us

If you have questions or concerns about this Privacy Policy, wish to exercise your rights, or need to report a data protection issue, contact us at [email protected], or write to: