Smart Dress privacy policy

SMARTDRESS, a Société Anonyme Monégasque with share capital of 150 000 €, registered with Monaco's Trade and Industry Register under number 25S09972, with its registered office at c/o MBC2, 1 rue du Gabian, 98000 Monaco, Monaco, is the controller of the data described below.

For any question about your data: contact@smartdress.fr.

The Smart Dress application may collect the following data:

• •Information provided by the user while using the application
• •Photos or images imported by the user as part of the application's features
• •Data relating to use of the application (screens viewed, features used)
• •Anonymous technical data (device type, operating system)

No sensitive data is collected without the user's explicit consent.

The data collected is used solely to:

• •Provide and improve the application's features
• •Offer personalised recommendations
• •Improve the user experience
• •Ensure the application functions correctly

The data is neither sold, rented, nor shared for commercial purposes.

Each processing operation rests on one of the legal bases set out in the GDPR:

• •Performance of the contract: providing the features of the application you request.
• •Explicit consent: processing your photos and the data sent to the AI to analyse your outfits. This consent may be withdrawn at any time.
• •Legitimate interest: keeping the service secure, fixing faults and improving the application.
• •Legal obligation: retaining accounting records and responding to requests from the competent authorities.

Data is stored securely and protected against unauthorised access.

Appropriate technical and organisational measures are in place to ensure the security of the data.

In the event of a data breach likely to create a risk to your rights, you and Monaco's Personal Data Protection Authority (APDP) will be informed.

Data may be processed by third-party technical services solely in order to operate the application (hosting, maintenance).

No sharing for advertising purposes takes place.

Smart Dress uses Google Gemini artificial intelligence for its outfit recommendation and analysis features.

Data sent to Google Gemini:

• •Photos of your clothes (items in your wardrobe, images imported or photographed)
• •Your style, colour preferences and text descriptions
• •Weather data (conditions, temperature) for suitable recommendations
• •Location data (latitude, longitude) solely to obtain the local weather

This data is used exclusively to generate personalised outfit suggestions and to analyse your clothes. No data is shared with Gemini without your prior consent. Google Gemini applies data protection measures equivalent to industry standards.

You can read Google's privacy policy at: policies.google.com/privacy

The publisher is established in the Principality of Monaco, recognised by the European Commission as providing an adequate level of data protection. Using Google Gemini may involve a transfer outside the European Economic Area; such transfers are covered by the standard contractual clauses adopted by the European Commission.

In accordance with applicable regulations, users have the following rights:

• •Right of access to their data
• •Right of rectification
• •Right to erasure
• •Right to object to processing
• •Right to restriction of processing
• •Right to data portability
• •Right to withdraw consent at any time, without affecting processing already carried out

Any request may be sent to the contact address given below. We will respond within one month.

You also have the right to lodge a complaint with the Personal Data Protection Authority (APDP), 12 avenue de Fontvieille, 98000 Monaco — apdp.mc. If you reside in the European Union, you may contact the supervisory authority of your country of residence.

You can delete your account at any time from within the app: Settings → Account → Delete my account.

Deletion erases your profile, your photos and your preferences within 30 days, except for data the law requires us to keep.

You may also send us your deletion request by email and we will handle it.

Data is kept only for as long as necessary to use the application or in accordance with legal obligations.

In practice: account data and imported content are kept for as long as the account is active, then erased within 30 days of its deletion. Accounting records are kept in accordance with the legal obligations applicable in the Principality of Monaco.

The application is not intended for anyone under the age of 15. No data concerning them is knowingly collected. Should such data reach us, it would be deleted as soon as we became aware of it.

Any subscriptions are managed by Apple's App Store. We have no access to payment details: payments, renewals and refunds are handled by Apple under its own privacy policy.

This policy may be amended. Any material change will be brought to your attention in the application or by email before it takes effect.

For any question regarding this Privacy Policy, you can contact us at:

contact@smartdress.fr

Postal address: c/o MBC2, 1 rue du Gabian, 98000 Monaco, Monaco