ecomlook privacy policy

Effective Date & Last revised: October 5, 2023

Introduction ans scope

This ecomlook App & website Privacy Policy (“Privacy Policy”) is delivered on behalf of ecomlook AI Lab, Inc. (“ecomlook AI Lab”, “we”, “us”, and “our”) and governs the Personal Data (as defined below) collected from or processed about you when you use the ecomlook mobile application (“ecomlook”, the “app”, or the “application”), including by downloading, installing, registering with, accessing or otherwise using the application (collectively referred to herein as “Use”).
We provide this Privacy Policy to explain our practices for collecting, using, processing, and disclosing the Personal Data we process about ecomlook users (“users”, “you”, or “your”, as applicable), and to tell you about the rights you may have in relation to your Personal Data and choices you may be able to make in relation to it. By Personal Data we mean information that is associated with an identified or identifiable natural person, and protected as personal data under applicable data protection laws.
This Privacy Policy applies to Personal Data we or any third party collects from you e.g., ecomlook.com
Please read this Privacy Policy carefully to understand our privacy practices. We also encourage you to get acquainted with our Terms of Use to understand how we provide services to you. For information on how we process photos in connection with various features of our app, including the Virtual Try-On feature, please see Section 3: How We Process, Share and Retain Your Photos and Image Data.
If you do not want us to process your Personal Data as it is described in this Privacy Policy, please do not Use ecomlook.com
If you have any questions about this Privacy Policy or ecomlook, please contact us at ecomlook@ecomlook.com. For additional contact information, please see Section 15: How to Contact Us.
U.S. State Supplements:

If you are a resident of the U.S. state of California, please see our California Notice at Collection and Privacy Notice.
If you are a resident of the U.S. state of Connecticut or Colorado, or a resident of the U.S. Commonwealth of Virginia please see our U.S. State Privacy Supplement (Non-California).

We process your photos and videos to provide you with the features of the ecomlook application that you choose to use. In doing so, when you upload photos or videos to ecomlook, we process your photos and videos using technology that identifies data that is in the photos and videos and provides us with information, such as information about your facial position, orientation and topology and other elements of your photo (collectively, “Image Data”). The following describes how we process, share, and retain your photos, videos and Image Data in connection with various features of the ecomlook app. Please note, however, that we may retain your data for longer time periods than set forth below where required to do so by law.

Photo & Video Upload. When you upload photos and videos for editing, we will automatically apply technology that generates Image Data. This processing only occurs on our servers.
Virtual Try-on. To generate Virtual Try-on, you must upload one or more photos to ecomlook to perform the Virtual Try-on. The photos you upload are stored on our servers, which are hosted by Google Cloud Platform and Google Firebase (European Union). The Virtual Try-on feature relies on the Stable Diffusion model. We do not Use your Personal Data to train and/or create separate artificial intelligence/products and do not share any content including photos to any third parties.
Your generated Virtual Try-ons are stored on our servers (provided by Google Cloud (European Union)) and are available to you within the ecomlook app at any time, via any device from which you log into the ecomlook application, until you decide to either (i) delete the Virtual Try-ons or, (ii) delete your ecomlook account. If you delete a Virtual Try-on, we will generally process the deletion immediately automatically. If you request to delete your ecomlook account, we will generally delete your account, including the Virtual Try-ons in your account, within 48 hours from the request. Please be aware that deleting the ecomlook application from your device does not result in the deletion of your ecomlook account! To request the account removal please use this form.

When you Use ecomlook, we or third parties we permit to do so, may automatically collect certain information, including Personal Data, from you (this is subject to your consent where this is required by law). The information collected from you automatically when you Use ecomlook may include:

Device information: Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier, operating system and version, mobile network information, device type and device language.
App and country information: Information regarding the version of the app that you are using and the country version of the app store from which you downloaded ecomlook.
Image Data: For more information regarding how we process your photos and videos when you Use various features of the app, please see Section 3: How We Process, Share, and Retain Your Photos, Videos and Image Data.
Usage details: Details of your Use of ecomlook, including frequency of Use, areas and features of the application that you access and information regarding engagement with particular features of the app.
Details about your in-app activities: For example, details regarding the time you did certain activities.
(If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by ecomlook, please follow the instructions below.

If you use an iOS device:

Go to Privacy settings to see a list of apps that request to track your activity. On iPhone or iPad, go to Settings > Privacy > Tracking.
Tap to turn off or turn on permission to track for ecomlook.

If you use an Android device:

Open Settings app
Navigate to “Privacy” > “Ads”
Tap “Delete Advertising ID”
Tap it again on the next page to confirm.

Other than with respect to Image Data, we and third-parties we engage may use cookies, Software Development Kits (SDKs), and other tracking technologies to automatically collect the Personal Data set forth above. For more information regarding our use of these technologies, please see Section 7: Cookies, Software Development Kits, and Other Tracking Technologies.

We may use your Personal Data for a variety of purposes depending on the category of Personal Data and the way you Use and interact with the ecomlook app, including the following:

To present to you and others with ecomlook and its contents and any other information, products or services that you request from us, including to provide various features of the app (e.g., Photo and Video Upload; Virtual Try-on) and its functionality. We do so to provide you with the services subject to your explicit consent and according to our contractual obligation.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to ecomlook (e.g., the Terms of Use). This is for the performance of our contract with you and for our legitimate interests in performing and enforcing our contracts with you and/or to defend our rights in case of claims.
To customize our product and service offerings to you. In doing so, we make automated decisions using device type and device language data. Where required by law, we rely on your consent to offer such personalization and/or offer you the opportunity to opt-out. Please see Section 7: Cookies, Software Development Kits, and Other Tracking Technologies for more information.
To provide you with customer and technical support, investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other users’ inquiries in relation to ecomlook. It is our legitimate interest to provide you with high-quality support.
To communicate with you, such as to notify you about changes to ecomlook or any products or services we offer or provide through ecomlook, including by sending you technical notices, notices about your account, updates, security alerts and support and administrative messages, which we may send through an in-app or a push notification (you may opt-out of push notifications by changing the settings on your mobile device). It is our legal obligation to keep you informed about your account and otherwise in our legitimate interests of keeping you informed about your ecomlook account.
To conduct research, analytics and monitor performance and other metrics regarding ecomlook and your Use of ecomlook. This may include data regarding the total number of users of our app, traffic, and demographic patterns related to the use of our app. Where this data is collected through the technologies described in Section 7 and where required by law, we rely on your consent; otherwise, it is our legitimate interest to conduct analytics as it helps us understand our business metrics and improve our product.
To improve, test, and monitor the effectiveness of ecomlook. It is our legitimate interest to conduct such analyses to understand our product and business metrics.
To provide personalized content and information to you in relation to ecomlook and so that we, and third parties on which we rely, can advertise to you. This may include using your Personal Data to build advertising audiences that we believe are similar to our user base, serving online ads to you, or engaging in other forms of advertising. Where required by law, we rely on your consent to engage in such activities and/or offer you the opportunity to opt-out. Please see Section 7: Cookies, Software Development Kits, and Other Tracking Technologies for more information.
To send marketing and promotional communications to you, such as via email, push notification or in-app messaging either with your consent or as otherwise permitted by law. Please see Section 9: Your Choices About Our Communications With You for more information.
In any other way as we may describe when you provide the information or otherwise at your direction or with your consent.
As permitted or required by law, including for auditing, fraud and security monitoring purposes.

We may disclose the information we process about you, including any Personal Data, as follows:

We may share your Personal Data with businesses that are legally part of the same group of companies that we are part of, including our subsidiaries (“Affiliates”). The Affiliates act as our data processors and may perform data processing on our behalf (e.g., providing technical support or conducting analytics). Such Affiliates are bound by appropriate contractual safeguards. Currently there are no affiliates and we oblige to notify you as soon as it changes.
We may disclose your Personal Data, and other collected information to third-party organizations such as contractors, business partners, service providers, and vendors that we use to support our business and who assist us in providing ecomlook. Such service providers may include:
cloud provider Amazon Web Services (European Union, USA);
cloud provider Google Cloud Platform (European Union), which we use to host analytics data and which we use to store your Personal Data, photos, and Image Data when you apply or generate Virtual Try-on; and
email delivery providers.
We may disclose your Personal Data to third-party analytics providers and advertising partners or otherwise permit them to collect or access it. For more information, please see Section 7: Cookies, Software Development Kits, and Other Tracking Technologies.
We may disclose your Personal Data in the event that we or any of our affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including in the course of a transaction like a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, liquidation. In such cases, your Personal Data and any other collected information may be among the items sold, transferred, or otherwise disclosed as part of that transaction or proceeding.
We may disclose your Personal Data in response to legal requests and for purposes of preventing harm. We may access, preserve and share your information in response to a legal (like a search warrant, court order or subpoena), government or regulatory request if we have a good faith belief that the law requires us to do so. This may include responding to legal, government or regulatory requests from jurisdictions where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: (i) detect, prevent and address fraud and other illegal activity; (ii) protect ourselves, you and others, including as part of investigations; and (iii) prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

When you use ecomlook, we and our service providers, vendors, and partners, including third parties, may use cookies (a small text file placed on your computer or mobile device to identify your computer and web browser) and other similar technologies to collect or receive certain information about you and/or your use of ecomlook. We also use third-party analytics tools like Google Firebase, Facebook Analytics (Meta) to help us measure traffic and usage trends for ecomlook and for other purposes. Such analytics tools collect information via third-party SDKs incorporated into ecomlook, which includes information about features of ecomlook you visit or Use, your actions in ecomlook, and information about your subscription. Such information may be used to provide content, advertising, or functionality or to measure and analyze ad performance on ecomlook or other websites or platforms. Third parties may also use such information for their own purposes. For the avoidance of doubt, we do not use Image Data for advertising purposes.
Interest-based Advertising. We may partner with ad networks and other ad-serving providers that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information ad networks and ad serving providers collect about your Use of the app over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.
Your Choices. Most browsers and devices are configured to accept cookies and similar tracking technologies automatically. You may be able to set your browser and device options so to limit such technologies. You can also opt out of receiving interest-based ads from members of the Network Advertising Initiative (“NAI”) by visiting the NAI consumer opt-out page at http://optout.networkadvertising.org/?c=1#!/. Opting out of receiving interest-based ads does not mean that you will no longer receive ads from us, but rather that the ads will not be tailored to your perceived interests.

For users in the European Economic Area, United Kingdom and United States. You can opt-out from processing of Personal Data via cookies, SDKs and other tracking technologies by clicking sending a request to ecomlook@ecomlook.com.

You may find that some parts of the app may not function properly if you have refused cookies or similar tracking technologies, and you should be aware that disabling cookies or similar tracking technologies may prevent you from accessing some of our content. Your choices are typically device and browser specific

Access, modification, correction and erasure. You can send us an email at ecomlook@ecomlook.com to request access to, modification, correction, update, erasure or portability of any Personal Data that you have provided to us and that we have about you. You can also request deletion of your account inside the app, both for iOS and Android users. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
EEA/UK individuals. Individuals in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain statutory rights in relation to their Personal Data including under the General Data Protection Regulation (Regulation (EU) 2016/679) (“EEA GDPR”) and the UK version of the EEA GDPR (“UK GDPR”) (collectively, the “GDPR”), including the rights specified below. You can exercise these rights by contacting us (for contact information, please see Section 15: How to Contact Us). We will do our best to accommodate your request or objection but please note that not all rights are absolute.

Access to your Personal Data: You have a right to request information about whether we have any Personal Data about you, and to receive a copy of such Personal Data.
Rectification of your Personal Data: You are responsible for ensuring the accuracy of your Personal Data that you provide to us. Inaccurate information may affect your experience when Using ecomlook features and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is incomplete or inaccurate, you have a right to contact us and ask us to correct such Personal Data.
Restriction of processing: You also have the right to demand restriction of processing of your Personal Data, for example, if you contest the accuracy of the Personal Data which inaccuracy is verified by us.
Erasure of your Personal Data: In certain circumstances, you may ask us to erase your Personal Data. Please be aware that erasing some Personal Data may affect your ability to Use ecomlook.
Right to portability of your Personal Data: In certain circumstances, you have the right to request us to receive any Personal Data you provided us in a structured, commonly used and machine-readable format. You may further ask us to give that Personal Data to another party.
Right to object to processing or otherwise using your Personal Data: Where we are processing your Personal Data based on our legitimate interest, you may object to the processing or otherwise using your Personal Data. Please be aware that our inability to process or otherwise use some of your Personal Data may affect your ability to Use ecomlook. If you have opted in to receiving marketing communications, you have the right to opt out of those at any time.
Right to withdraw your consent at any time: Where you may have provided your consent to the processing of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. The withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.
Right to lodge a complaint with a supervisory authority: Subject to the GDPR, you have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authority here, and check for the UK’s supervisory authority (ICO).

Please keep in mind that in case of a vague request to exercise any of the aforementioned rights we may engage with you in a dialogue to ask for more details if so needed to complete your request. In case this is impossible, we reserve the right to refuse granting your request. Following the provisions of the applicable law, we might also ask you to prove your identity (for example, by requesting your username or some other proof of your identity) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties is violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.
Please note that we will process your request within one month after receiving it. We may extend this period by up to two months where necessary, taking into account the complexity and number of the requests. If we extend the response period, we will let you know within one month from your request. We will not discriminate against you for exercising your rights under the law.