Privacy Policy
Effective as of 01 February 2025
Here are a few key points about our privacy practices:
1. Intro
This Privacy Policy explains how ESPRI Fashion, represented by Anton Rublev (“ESPRI” or “we” or “us”) analyzes, collects, stores, uses, transfers and shares Personal Information from our users (“you”) in connection with the https://espri.fashion/ including any products and services related to it (“Website”) and the ESPRI Fashion mobile applications on iOS and Android designed for the Purpose (“App”) (all collectively, “Services”). ESPRI Fashion is responsible for processing your data as described in this policy.
ESPRI Fashion is committed to protecting your Personal Information while you use our App. We may change this Privacy Policy from time to time. If the changes are material, we will notify you. If permitted by law, your continued use of the Services after this policy has been updated indicates your acceptance of changes made. If you do not accept the terms of the Privacy Policy, please do not use the Services.
CONSENT TO PRIVACY POLICY. CONSENTING TO OUR PRIVACY POLICY DURING REGISTRATION OR OTHERWISE, YOU CONSENT TO ITS CONTENTS IN ITS ENTIRETY, INCLUDING THE PROCESSING ACTIVITIES THAT RELY ON CONSENT AS A LEGAL BASIS. FAILURE TO ACCEPT THIS PRIVACY POLICY MEANS THAT YOU ARE NOT ALLOWED TO USE THE SERVICES SINCE WE MIGHT NOT BE ABLE TO PROVIDE YOU WITH THE SERVICES AS DESCRIBED IN THIS POLICY.
2. What Personal Information do we collect?
We collect personal information appropriate to the service you choose to sign up to. ‘Personal Information’ refers to information that can be used to identify you (whether alone or in combination with other data).
We may collect the following Personal Information directly from you:
We may also collect certain Personal Information automatically:
3. How do we use your Personal Information?
Depending on which features of the Services you use, we will process your Personal Information based on one or more of the following legal bases:
Below you can find some examples:
- Our platform uses AI technology to offer virtual try-on services, allowing users to upload personal photos or images of their own clothing, and explore how different outfits from our collection look on them.
- To use the app and the services it offers, you may need to provide your Personal information as specified in this policy (“Personal Information”) . To use the ‘Virtual Try-on’ service, you can upload any photos of items you have and/or your own photo, and the application will generate outfits incorporating them (all the above together with the ‘Purposes’).
- To operate our Services, we rely on third-party providers such as Google Cloud Platform (for cloud storage), PostHog (for analytics), and Kling AI (for AI-generated outfits). These providers only process your data as required to deliver the requested services and are contractually prohibited from using it for any other purposes
- We use the photographs or any other Personal Information you provide us only in accordance with this Privacy Policy and the Purposes.
- We take reasonable and appropriate measures to protect your Personal Information from loss, theft, misuse, or unauthorized access.
- You have full control over your data. You can always access, correct, erase, and update your Personal Information by writing to us at espri.fashion@gmail.com. We believe in transparency and open dialogue. You can always contact us at espri.fashion@gmail.com
1. Intro
This Privacy Policy explains how ESPRI Fashion, represented by Anton Rublev (“ESPRI” or “we” or “us”) analyzes, collects, stores, uses, transfers and shares Personal Information from our users (“you”) in connection with the https://espri.fashion/ including any products and services related to it (“Website”) and the ESPRI Fashion mobile applications on iOS and Android designed for the Purpose (“App”) (all collectively, “Services”). ESPRI Fashion is responsible for processing your data as described in this policy.
ESPRI Fashion is committed to protecting your Personal Information while you use our App. We may change this Privacy Policy from time to time. If the changes are material, we will notify you. If permitted by law, your continued use of the Services after this policy has been updated indicates your acceptance of changes made. If you do not accept the terms of the Privacy Policy, please do not use the Services.
CONSENT TO PRIVACY POLICY. CONSENTING TO OUR PRIVACY POLICY DURING REGISTRATION OR OTHERWISE, YOU CONSENT TO ITS CONTENTS IN ITS ENTIRETY, INCLUDING THE PROCESSING ACTIVITIES THAT RELY ON CONSENT AS A LEGAL BASIS. FAILURE TO ACCEPT THIS PRIVACY POLICY MEANS THAT YOU ARE NOT ALLOWED TO USE THE SERVICES SINCE WE MIGHT NOT BE ABLE TO PROVIDE YOU WITH THE SERVICES AS DESCRIBED IN THIS POLICY.
2. What Personal Information do we collect?
We collect personal information appropriate to the service you choose to sign up to. ‘Personal Information’ refers to information that can be used to identify you (whether alone or in combination with other data).
We may collect the following Personal Information directly from you:
- Photographs via your camera or camera roll (with your direct permission), gender and other information provided by you when using the Services. We access only the specific images you explicitly select to upload. Even if you grant access to your photo album, we do not scan, collect, or store other photos from your device.
- Account registration information: email, gender, and password (if using the email to register).
We may also collect certain Personal Information automatically:
- Application usage information such as information about how you use and interact with the Services, including your preferred language, the date and time when you first installed the App and the date and time you last used it, your onboarding path (e.g. the source you found us from).
3. How do we use your Personal Information?
Depending on which features of the Services you use, we will process your Personal Information based on one or more of the following legal bases:
- Your consent. For example, on the registration screen when you give us permission to process your Personal Information related to the onboarding questionnaire and provide consent to our Privacy Policy.
- Our contractual obligations to you in order to provide the Services. For example, we may process your Personal Information to fulfill our contractual obligations such as account management and other administrative purposes.
- Legitimate interest. For example, we may process your Personal Information in relation to our interests in providing the Services to you, including our interest in protecting the security and integrity of the Services.
- Legal obligation. For example, we may be obligated to process some of your Personal Information to comply with applicable laws and regulations.
Below you can find some examples:
Data minimization and purpose limitation. We will not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Information that is not needed for the mentioned purposes.
No sale of Personal Information. We will not sell or rent your Personal Information for monetary gain. We will not disclose your Personal Information except as otherwise described in this Privacy Policy.
Anonymous, aggregated, or de-identified data. We may create anonymous, aggregated or de-identified data from your Personal Information and Personal Information of other individuals. We may aggregate, anonymize, or de-identify your Personal Information by removing information that makes the data personally identifiable. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes or use it for internal business improvements.
Communication with you. We may contact you from time to time via email or through other means (like pop-ups or push notifications) to communicate with you about products and services. You may also opt out of receiving pop-ups or push notifications by adjusting your settings on your device. If applicable laws prescribe so, we may ask some users to provide their additional consent for such communications.
No automated decision-making. Our AI processes your images only to generate virtual outfits, and these processes do not involve automated decision-making that impacts your legal rights or personal circumstances
4.How long will we keep your Personal Information?
Your Personal Information shall be stored as long as your contractual relationship with us lasts.
However, we shall store certain personal identification and traffic data for a maximum period of 12 months after your last day of inactivity to make sure you can resume the Services.
To facilitate our Services, we may store the photos you upload for a limited period (normally, up to 12 months from the last activity). This allows users to revisit and refine their virtual try-ons without re-uploading. After this period, all images are permanently deleted unless you choose to erase them earlier.
Impact of account deactivation/requests to erase Personal Information. At any time, you can deactivate your account and erase your Personal Information by emailing espri.fashion@gmail.com or by submitting in-app deletion request. We will address your deletion request within 30 days after receipt. It may take us up to 90 days in some cases, to complete the full erasure of your Personal Information stored in our backup systems. If you choose to deactivate your account, we will generally delete all your Personal Information and it will not be recoverable should you later create another account.
5. Will we share your Personal Information?
Your photographs. We do not share your photographs with third parties, with the exception of uploading encrypted images to our cloud provider, Google Cloud Platform and processing them as specified in this Privacy Policy. You may voluntarily choose to share your outfit photos on your social media platforms, such as Instagram or Facebook; however, we will never share them without your consent or knowledge.
Service providers. We engage other companies to process your Personal Information on our behalf. We refer to these companies or service providers as “processors.” We prohibit the service providers we engage from using Personal Information for any purpose that is not related to our engagement.
Processors are companies that help us run the Services, support our communication with you, or perform other Services-related activities. They may process certain Personal Information on our behalf to accomplish the goals related to the App functions, deliver the Services and associated activities. We remain responsible for any acts or omissions of our processors and undertake to execute formal data processing agreements with them to the extent required by applicable law.
Here are some of the main processors we rely on:
Google Cloud - our storage and infrastructure provider;
Posthog - our analytics provider that helps us analyze usage patterns and activities. Please note that Posthog will never record your photographs, selfies or pictures;
Kling AI - our image provider which helps to generate images by combining a user’s uploaded photo with a desired clothing item to create a virtual outfit
Professional advisors. We may disclose your Personal Information to professional advisors, such as lawyers, bankers, IT developers and auditors, where it is necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your Personal Information for the compliance, fraud prevention and safety purposes described.
Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Compliance with Law. We may be required to use and share your Personal Information to comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities.
6. Your Rights
We believe privacy is a fundamental human right. Therefore, all our users have the following universal rights:
How to exercise your rights. Сontact us at espri.fashion@gmail.com to exercise your Access right, Deletion right, Objection right, and Correction right.
Opt out of marketing communications and other push notifications. You may opt out of marketing-related communications and other push notifications we may send you by changing the settings on your mobile device or the website.
Device permissions. You may revoke any permissions you previously granted to us, such as permission to access your camera or camera roll, through the settings on your device.
Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Services may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile Service usage for purposes of targeted advertising. So you can always adjust your settings. In addition, your mobile device settings may provide functionality to limit ours or our partners’ ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Service ID for Advertising associated with your mobile device.
Proof of identity. We might also require you to prove your identity in some cases. Normally, we make sure to verify that the request is coming from a legit persona. In some cases, we may ask you to undergo additional verification measures in an effort to ensure we are appropriately responding to requests.
National laws. Please note, that if your local laws provide for additional rights and protection otherwise not specified in this Privacy Policy, we undertake to comply with such additional requirements, if ESPRI Fashion is obligated to do so in accordance with the applicable laws.
7. Other Sites, Mobile Applications and Services
The Services may contain links to other websites, mobile applications and online services operated by third parties. These links are not an endorsement of, or indication that we are affiliated with, any third party. In addition, our content may be included on webpages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services and we are not responsible for their actions. Other websites, mobile applications and online services follow different rules regarding the collection, use and sharing of your personal information.
We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
8. Data Security and Retention
We implement technical and organizational measures in an effort to protect Personal Information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Information that we process, and risks associated with special categories of Personal Information we collect.
9.Cross-Border Data Transfers
ESPRI Fashion operates globally, and the personal information we collect may be transferred to and processed in different countries. The data protection laws in these countries may differ from those in your jurisdiction and may not offer the same level of protection. By using our services, you acknowledge and agree that your data may be processed in locations outside your country of residence.
We take appropriate measures to ensure that your data remains protected in accordance with applicable privacy laws.
Personal Information in the European Union (EU), the EEA and the United Kingdom (UK) is protected by the General Data Protection Regulation (GDPR) and Data Protection Act 2018, but some other countries may not necessarily have the same standard of protection for your Personal Information. When transferring Personal Information outside the EU, EEA, and UK we either implement standard contractual clauses or rely on current European Commission adequacy decisions. For further information, please contact espri.fashion@gmail.com
10. Children
Minors under 18 years of age are not able to contractually agree to the terms of use required by this and its paid edition. For this reason, for the protection of minors, the application is not directed at minors under the age of 18, and our Тerms of Use do not allow minors under 18 years of age to use the Service. If we learn that we have collected the personal information of a child under the age of 18, we will delete it. We encourage parents with concerns to contact us. We do not store or process Personal data of anyone below 18.
11. How to Contact Us
Please direct any questions or comments regarding this Policy or our privacy practices to espri.fashion@gmail.com
12. Notice to California and Virginia Residents
As a matter of principle and commitment to our users, we never sell Personal iInformation. Under certain US state laws, for example, California and Virginia, if we disclose Personal Information to a third party for any benefit, this might formally qualify as a “sale” or “share” of Personal Information, even if the third party does not use the Personal Information for any commercial or alike purpose. We may “share”, as defined in such laws, Personal Information if we disclose personal information to a company for purposes of cross-context behavioral advertising.
California and Virginia laws grant its residents the following additional rights.
No sale of Personal Information. We will not sell or rent your Personal Information for monetary gain. We will not disclose your Personal Information except as otherwise described in this Privacy Policy.
Anonymous, aggregated, or de-identified data. We may create anonymous, aggregated or de-identified data from your Personal Information and Personal Information of other individuals. We may aggregate, anonymize, or de-identify your Personal Information by removing information that makes the data personally identifiable. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes or use it for internal business improvements.
Communication with you. We may contact you from time to time via email or through other means (like pop-ups or push notifications) to communicate with you about products and services. You may also opt out of receiving pop-ups or push notifications by adjusting your settings on your device. If applicable laws prescribe so, we may ask some users to provide their additional consent for such communications.
No automated decision-making. Our AI processes your images only to generate virtual outfits, and these processes do not involve automated decision-making that impacts your legal rights or personal circumstances
4.How long will we keep your Personal Information?
Your Personal Information shall be stored as long as your contractual relationship with us lasts.
However, we shall store certain personal identification and traffic data for a maximum period of 12 months after your last day of inactivity to make sure you can resume the Services.
To facilitate our Services, we may store the photos you upload for a limited period (normally, up to 12 months from the last activity). This allows users to revisit and refine their virtual try-ons without re-uploading. After this period, all images are permanently deleted unless you choose to erase them earlier.
Impact of account deactivation/requests to erase Personal Information. At any time, you can deactivate your account and erase your Personal Information by emailing espri.fashion@gmail.com or by submitting in-app deletion request. We will address your deletion request within 30 days after receipt. It may take us up to 90 days in some cases, to complete the full erasure of your Personal Information stored in our backup systems. If you choose to deactivate your account, we will generally delete all your Personal Information and it will not be recoverable should you later create another account.
5. Will we share your Personal Information?
Your photographs. We do not share your photographs with third parties, with the exception of uploading encrypted images to our cloud provider, Google Cloud Platform and processing them as specified in this Privacy Policy. You may voluntarily choose to share your outfit photos on your social media platforms, such as Instagram or Facebook; however, we will never share them without your consent or knowledge.
Service providers. We engage other companies to process your Personal Information on our behalf. We refer to these companies or service providers as “processors.” We prohibit the service providers we engage from using Personal Information for any purpose that is not related to our engagement.
Processors are companies that help us run the Services, support our communication with you, or perform other Services-related activities. They may process certain Personal Information on our behalf to accomplish the goals related to the App functions, deliver the Services and associated activities. We remain responsible for any acts or omissions of our processors and undertake to execute formal data processing agreements with them to the extent required by applicable law.
Here are some of the main processors we rely on:
Google Cloud - our storage and infrastructure provider;
Posthog - our analytics provider that helps us analyze usage patterns and activities. Please note that Posthog will never record your photographs, selfies or pictures;
Kling AI - our image provider which helps to generate images by combining a user’s uploaded photo with a desired clothing item to create a virtual outfit
Professional advisors. We may disclose your Personal Information to professional advisors, such as lawyers, bankers, IT developers and auditors, where it is necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your Personal Information for the compliance, fraud prevention and safety purposes described.
Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Compliance with Law. We may be required to use and share your Personal Information to comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities.
6. Your Rights
We believe privacy is a fundamental human right. Therefore, all our users have the following universal rights:
- You have a right to request information about what Personal Information we process about you, to access all your Personal Information (‘Access right’)
- You may ask us to erase your Personal Information if you withdraw your consent to processing or if you believe such processing is unlawful (‘Deletion right’). Please be aware that erasing some Personal Information may affect your experience using certain features of the Services that rely on historical data. You can exercise your Deletion right from within the App.
- In some cases, you can object to the processing of your Personal Information, for example, if we process it under the legitimate interest basis (‘Objection right’)
- If you believe your Personal Information is inaccurate or incomplete, you can request to correct or, in some cases, correct it yourself from within the App. (‘Correction right’)
How to exercise your rights. Сontact us at espri.fashion@gmail.com to exercise your Access right, Deletion right, Objection right, and Correction right.
Opt out of marketing communications and other push notifications. You may opt out of marketing-related communications and other push notifications we may send you by changing the settings on your mobile device or the website.
Device permissions. You may revoke any permissions you previously granted to us, such as permission to access your camera or camera roll, through the settings on your device.
Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Services may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile Service usage for purposes of targeted advertising. So you can always adjust your settings. In addition, your mobile device settings may provide functionality to limit ours or our partners’ ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Service ID for Advertising associated with your mobile device.
Proof of identity. We might also require you to prove your identity in some cases. Normally, we make sure to verify that the request is coming from a legit persona. In some cases, we may ask you to undergo additional verification measures in an effort to ensure we are appropriately responding to requests.
National laws. Please note, that if your local laws provide for additional rights and protection otherwise not specified in this Privacy Policy, we undertake to comply with such additional requirements, if ESPRI Fashion is obligated to do so in accordance with the applicable laws.
7. Other Sites, Mobile Applications and Services
The Services may contain links to other websites, mobile applications and online services operated by third parties. These links are not an endorsement of, or indication that we are affiliated with, any third party. In addition, our content may be included on webpages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services and we are not responsible for their actions. Other websites, mobile applications and online services follow different rules regarding the collection, use and sharing of your personal information.
We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
8. Data Security and Retention
We implement technical and organizational measures in an effort to protect Personal Information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Information that we process, and risks associated with special categories of Personal Information we collect.
9.Cross-Border Data Transfers
ESPRI Fashion operates globally, and the personal information we collect may be transferred to and processed in different countries. The data protection laws in these countries may differ from those in your jurisdiction and may not offer the same level of protection. By using our services, you acknowledge and agree that your data may be processed in locations outside your country of residence.
We take appropriate measures to ensure that your data remains protected in accordance with applicable privacy laws.
Personal Information in the European Union (EU), the EEA and the United Kingdom (UK) is protected by the General Data Protection Regulation (GDPR) and Data Protection Act 2018, but some other countries may not necessarily have the same standard of protection for your Personal Information. When transferring Personal Information outside the EU, EEA, and UK we either implement standard contractual clauses or rely on current European Commission adequacy decisions. For further information, please contact espri.fashion@gmail.com
10. Children
Minors under 18 years of age are not able to contractually agree to the terms of use required by this and its paid edition. For this reason, for the protection of minors, the application is not directed at minors under the age of 18, and our Тerms of Use do not allow minors under 18 years of age to use the Service. If we learn that we have collected the personal information of a child under the age of 18, we will delete it. We encourage parents with concerns to contact us. We do not store or process Personal data of anyone below 18.
11. How to Contact Us
Please direct any questions or comments regarding this Policy or our privacy practices to espri.fashion@gmail.com
12. Notice to California and Virginia Residents
As a matter of principle and commitment to our users, we never sell Personal iInformation. Under certain US state laws, for example, California and Virginia, if we disclose Personal Information to a third party for any benefit, this might formally qualify as a “sale” or “share” of Personal Information, even if the third party does not use the Personal Information for any commercial or alike purpose. We may “share”, as defined in such laws, Personal Information if we disclose personal information to a company for purposes of cross-context behavioral advertising.
California and Virginia laws grant its residents the following additional rights.
- Request to opt out: While we do not sell your Personal Information for monetary gain, you have the right to opt out of our “sale” or “sharing” of your personal information to our analytics and advertising partners. To exercise this right, you can adjust your browser or device settings, or contact us.
- Request to know/access: In addition to the other rights mentioned in this policy, you have the right to request to know: (i) the personal and sensitive information we have collected about you and our purposes of use; and (ii) the categories, sources and third parties involved in Personal Information we have collected about you or ‘sold’ or disclosed in the past 12 months. You may exercise your right to request to know twice a year, free of charge.
