Privacy Policy

• Account creation data: name, email address, phone number (if used for authentication), password (or passwordless credentials).
• Wardrobe and user content: photos of clothing items, descriptions, sizes, colors, brands, purchase history, tags/categories, outfit combinations.
• Mirror AI inputs: avatar preferences (body type, measurements, skin tone, etc.), clothing selections for visualization.
• Communications: messages sent via in-app chat, support requests, feedback.
• Optional: payment-related info (if we introduce processing in the future).
• For child sub-accounts: additional parent-provided information (child name, date of birth) and parental control settings.

• Device and usage data: IP address, device type/model, operating system, browser type, unique identifiers, app version.
• Usage analytics: features accessed (especially Mirror sessions), time spent, interactions, clicks, scrolls.
• Cookies, pixels, and similar technologies: for functionality, analytics, and personalization.
• Location data: approximate location if enabled (e.g., for weather-based suggestions); you can disable this in device settings.

• If you connect social accounts or import data (e.g., from retailers), we may receive limited profile or wardrobe info.
• Analytics providers, AI service providers (for Mirror processing), or crash reporting tools may share aggregated or technical data.

• Provide, maintain, and improve the Service, including generating accurate real-time visualizations via the Mirror tool.
• Personalize your experience (outfit recommendations, avatar rendering, closet organization).
• Communicate with you (service updates, support responses, optional marketing with opt-out).
• Analyze usage trends and develop new features (including AI model improvements).
• Detect fraud, enforce policies, and protect security.
• Comply with legal obligations or respond to lawful requests.

• Service providers and processors: Cloud storage, analytics, AI/ML providers (e.g., for Mirror rendering), payment processors (if introduced), under strict confidentiality agreements.
• User-to-user features: Limited sharing of wardrobe/item data with other users when you engage in borrowing, renting, or resale connections.
• Business transfers: In connection with merger, acquisition, or asset sale.
• Legal requirements: To comply with laws, respond to subpoenas, court orders, or protect rights/safety.
• Aggregated/de-identified data: For research, marketing, or analytics (non-identifiable to you).

• Outputs are probabilistic and based on algorithms, training data, and your inputs.
• We make no warranty regarding accuracy, realism, appropriateness, or non-infringement of third-party rights in any AI-generated visualization.
• Similar or identical outputs may appear for different users.
• You should not rely on Mirror outputs for critical decisions without verification.

• Access, correction, deletion: Log in to update your data or email support@cluedincloset.com to request access, correction, or deletion (subject to legal exceptions).
• Opt-out of marketing: Use unsubscribe links or contact us.
• Cookies & tracking: Manage via browser/device settings (some features may be limited if disabled).
• Location: Disable in device settings.
• California residents: Rights under CCPA/CPRA (access, deletion, opt-out of sale/sharing). Submit requests to support@cluedincloset.com with “California Privacy Rights” in the subject.

• Parents or legal guardians must create a primary account and complete strong age verification (credit card authorization + government-issued ID with liveness detection via Persona or similar service).
• Verified parents may then create linked child sub-accounts.
• As part of creating a child sub-account, the parent must provide verifiable parental consent, which includes:
  • Strong identity verification (Persona KYC)
  • An electronic signature affirming the following attestation under penalty of perjury

• I am the parent or legal guardian of [Child’s Full Name], born on [Date of Birth];
• I have read and understand the Privacy Policy and Terms of Service, including the parental controls and data practices for child sub-accounts;
• I consent to the collection, use, and disclosure of my child’s personal information as described in this Privacy Policy;
• I understand that I may review, delete, or revoke this consent at any time through the Parental Dashboard.

Consent Acknowledgment

Parents must affirmatively acknowledge key terms through individual checkboxes for material aspects of consent (including data practices, parental controls, monitoring scope, and responsibilities). A final overall confirmation is also required. This layered acknowledgment process is designed to ensure parents make informed decisions.

Parents can toggle the following restrictions for each child sub-account at any time:

• Private account only (not discoverable in search or feed)
• Participation in P2P Marketplace
• Access to Social / Community Feed
• Direct messaging with other users
• Marketing data collection and personalized advertising
• Use of the child’s data for AI training or model improvement
• Photo / wardrobe item uploads (approval required)
• Screen time / daily usage limits
• Content and safety filters
• Activity monitoring and reports
• Notification settings

Activity Monitoring Scope

For child sub-accounts, activity monitoring is limited to feature usage, session duration, toggle settings, and high-level interactions with permitted features (e.g., number of Mirror sessions or closet organization actions).

We do not monitor, access, or provide parents with private messages, individual photos, specific wardrobe items, chat content, or any other private user-generated content unless explicitly required by applicable law and with additional verifiable consent.

This approach is designed to balance parental supervision with the child’s reasonable expectation of privacy.

Per-State Configuration

We may apply additional monitoring, logging, or parental control features on a per-state basis to comply with applicable state laws (such as the Utah Social Media Regulation Act or other current and future regulations). Any state-specific differences will be applied transparently and documented in our Privacy Policy or in-app notices.

• Review all data associated with the child sub-account
• Delete specific items or all data
• Export the child’s data
• Revoke consent and suspend or delete the sub-account at any time

• Transfers wardrobe items, outfits, avatar data, Mirror history, and other user-generated content without loss.
• Decouples the account from the parent’s supervision.
• Removes all parental restrictions and oversight.
• Converts the account to standard 18+ terms and controls.

Legacy / Grandfathered Accounts

For child accounts created prior to the implementation of our current family sub-account system, we may have relied on a combination of verification methods available at the time (including email confirmation, electronic signature, identity document upload, and card microcharge).

We are in the process of transitioning these legacy accounts to our current strong verification standards (Persona KYC + parental attestation). During this transition, affected accounts will have enhanced restrictions applied until stronger verifiable parental consent is obtained. Accounts that do not complete the required verification within the communicated timeframe will be suspended and the associated personal information deleted or de-identified in accordance with applicable law.

Non-Compliant Accounts

If we discover that a user is under 18 without a properly verified parent-linked sub-account, is under 13 without COPPA-compliant verifiable parental consent, or if parental consent is revoked, we will promptly suspend the account and quarantine the child’s personal information (making it inaccessible in the Service).

We will handle the data in accordance with applicable law (including COPPA) as follows:

• For users under 13, we will proceed with deletion or de-identification as soon as reasonably practicable, typically within 7 days.
• For users aged 13–17, we may provide a limited grace period of up to 30 days to allow the verified parent or guardian an opportunity to remedy the compliance issue (e.g., re-verification or updated consent).

If verifiable parental consent is obtained and the issue is resolved during the grace period, the account and associated data may be reactivated. If the issue is not resolved within this period, we will permanently delete or irreversibly de-identify the personal information.

Account Restoration

Following suspension and the applicable grace period, a child sub-account may be restored only upon verified parental appeal. Restoration requires:

• Confirmation from the originally verified parent or legal guardian;
• Reasonable evidence that the compliance issue has been resolved; and
• Internal dual-control approval by authorized administrators.

We reserve the right to deny restoration in cases where we reasonably believe there is ongoing risk to the child or a violation of law exists. All restoration decisions will be documented for compliance purposes.

Jurisdiction Determination

We determine applicable privacy laws using a combination of factors, including IP address geolocation and user interaction with our cookie consent banner. When a user is detected as being in the European Economic Area (EEA) or interacts with our EEA-specific cookie consent banner, we apply GDPR requirements to their data processing. Users can also self-indicate their location through account settings or consent choices.

• Performance of a contract (providing the Service, including AI Mirror features).
• Legitimate interests (improving the Service, analytics, security, fraud prevention, and AI model training).
• Your consent (where required, e.g., for certain marketing, non-essential tracking, or specific AI processing). For child sub-accounts, we rely on verified parental consent.

• Access, rectify, or erase your personal data.
• Restrict or object to processing.
• Receive your data in a portable format (data portability).
• Withdraw consent at any time (where processing is based on consent).
• Lodge a complaint with your local data protection supervisory authority.

                                                                 Contact Us

                                                      Email: info@cluedincloset.com

                                                                DOTMatrix Inc, LLC

                                                            7956 Vaughn Road, 123

                                                             Montgomery, AL 36116

                                                                     United States