Revamped Ltd. (“Revamped”, “we”) is committed to maintaining the privacy of its users (“user”, “you”). The following information describes how Revamped collects and processes information about you when you use our Platform and Services (as defined below).
• What information we collect and why we collect it
• How we use that information
• Your rights with regard to the collection of such information
Revamped provides a mobile application (“Platform”) that utilizes artificial intelligence algorithms to offer personalized fashion outfit recommendations. The Platform assists with outfit choices by providing a personalized and optimized customer experience that suggests different clothing items and where you can buy them from, based on the pieces of clothing you choose to scan and upload to the Platform, your body type and measures, skin tone, the event you wish to dress up for and other fashion related preferences you may be asked about (“Services”). The Platform provides information on the Services and enables its users to utilize the Services.
3. Collecting Information
Information from which you can be personally identified may also be collected, including but not limited to your name, email address, photos you choose to upload from your Device or photos you take while using the Platform, your body measures and type, fashion related preferences and the location of the Device through which you used the Platform (hereinafter: “Personal Information”). Personal Information shall be collected only if received voluntarily from you, including, without limitation, via the following ways:
a. Sign up
If you wish to sign up to the Platform, we will collect your Personal Information such as your email address and password, to enable you to join the Platform and Services.
b. Sign up via SSO
If you wish to sign up to the Platform via your Meta, Apple or Google accounts (or any other available platforms), you can sign up via the Single Sign-On (“SSO”) method. Signing in via the SSO will provide us with access to information these SSO services obtain about you, and all in accordance with your specific SSO’s privacy settings.
c. Log in
If you wish to log in to the Platform, we will collect your Personal Information such as your email address and password, to enable you to use the Platform and Services.
d. Suggestions based on your own clothes
If you wish to receive personalized outfit recommendations which are based on your own pieces of clothing, we will collect the picture taken using the Platform, an item tagged through the Platform or alternatively the picture you chose to upload from your Device gallery, in order to provide you with the requested Services.
e. Suggestions based on your body measures, body type and skin tone
If you wish to receive outfit recommendations based on your body measures (shoe size, height, pants size, shirt size, etc.) and type, as well as your skin tone, we will collect your picture taken using the Platform or alternatively the picture you chose to upload from your Device gallery, as well as the body measures you choose to disclose directly , in order to provide you with the requested Services.
f. Contacting us
g. Information collected via targeted advertisement practices
Revamped uses various advertising practices in cooperation with third party services and products. We use certain data about you in order to improve our advertising practices and make the ads we deliver more effective, relevant and enjoyable, including by deploying interest-based advertising, as well as targeting and ad measurement and attribution systems.
Such data includes your Device advertising identifiers (e.g. IDFA or Advertising ID), to the extent available), data related to your connected Meta, Apple, or Google profile (if any, such as your gender, region or country), and other demographic and interests-based information that we or our partners may have received from or about you.
The ads we or our partners deliver may be shown through other channels, such as third party websites and applications. If you wish to prevent the use of your Device’s advertising ID or other identifiers for interest-based advertising, you may change your Device settings to reset such advertising ID or opt out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your Device settings).
Please note that if you reset your advertising ID or opt out of interest based advertising, you may still see advertisements on other channels, but those ads will not be targeted based on the above mentioned identifiers.
4. Use of Information
We use Personal Information we collect from you for a range of different business purposes according to different legal bases of processing. We may use or process your Personal Information for the following purposes. One or more purposes may apply simultaneously.
1. Providing the Requested Services
• We collect Personal Information listed in Section 3 above, to provide you with the Services you contracted to receive.
• Such collection of information will enable us to provide you with technical and professional assistance, with regard to the Services you use or intend to use.
We process the Personal Information where it is necessary for the adequate performance of the contract regarding the provision of the Platform.
2. Improvement and Development of the Services
• We collect Personal Information to improve and develop our Services and understand feedback on Revamped’s Services and Platform and to help provide more information on the use of the Platform and Services quickly and easily.
• We collect Personal Information for ongoing review and improvement of the information provided on our Platform and Services to ensure it is user friendly.
• We collect Personal Information to improve the management and administration of our business and maintain compliancy with our internal policies and procedures.
• We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve our Services, develop new features, and conduct audits and troubleshooting activities.
We process this information in light of our legitimate interest in improving the Services, to allow our users to have the best experience.
3. Maintain a Safe and Secure Environment
We may use your information to detect and prevent fraud, abuse and security incidents in the following ways:
• Verify and authenticate your identity and prevent unauthorized or illegal activity;
• Enhance the safety and security of our Platform;
• Conduct security investigations and risk assessments;
• Prevent or take action against activities that are, or may be, in breach of our terms of service or applicable law.
We process this information in light of our legitimate interest in improving our Services and enabling our users to browse in a secure environment.
4. Personalize Content, Advertising and Marketing
• If you have used Revamped’s Services in the past, we have a legitimate business interest for matching the data we collect with other data we had already collected.
• This enables us to understand your needs and interests, optimize the content we send you and make it more suitable and relevant to your needs.
• This also enables us to improve your experience on the Platform and Services by providing you with personalized content, recommendations, and features.
We process this information in light of our legitimate interest to personalize your experience and customize our content.
5. Disclosure of Information and Transfer of Data
In order to perform our contractual and other legal responsibilities or purposes, we may, from time to time, need to share your Personal Information with third parties. We may as well share your Personal Information with our affiliates, subsidiaries or any third party service providers and individuals to facilitate our Services or any portion thereof, such as marketing, data management or maintenance services. We may also share your information with analytics service providers for analytics services. Such analytics service providers set their own identifiers on your Device, through which they can collect information about your usage of our Platform. This helps us compile aggregated statistics about the effectiveness of our Platform and Services.
We may also transfer your information, including Personal Information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate changes. Furthermore, information about you may also be released in order to comply with any valid legal obligation or inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if you use the Platform to perform an unlawful act or omission or take any act or omission that may damage Revamped, its property and goodwill, or if there is an attempted breach of the security of the Platform or a physical or property threat to you or others. The authority supervising such activities is the Israeli Privacy Protection Authority, and you have the right to file a complaint to it or any other relevant supervisory authority.
6. Roles and Responsibilities
Please note that certain data protection laws and regulations, such as the GDPR or the CCPA typically distinguish between two main roles for parties processing Personal Information: the “Data Controller” (or under the CCPA, “Business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, “Service Provider”), who processes the data on behalf of the Data Controller (or Business). Please see the below explanation where we elaborate on how these roles apply to our Services, to the extent that such laws and regulations apply.
7. Your Rights
In some jurisdictions, in particular those located within the European Union (the “EU”) or within the European Economic Area (the “EEA”), you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:
1. Request a rectification of your Personal Information where the information we hold about you is incorrect or incomplete.
2. Object to the processing of your Personal Information for direct marketing purposes.
3. Object to the processing of your Personal Information where our legal basis for that processing is that such processing is necessary for our legitimate interests.
4. Object to an automated decision-making (including profiling) in certain circumstances.
5. Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it;
6. Receive your Personal Information, or ask us to transfer it to another organization that you have provided to us, which we process by automated means, where our processing is either based on your consent or is necessary for the performance of a contract with you.
If you wish to file a request regarding any of the above, you may contact us at: email@example.com
8. Notice to California Residents
The California Privacy Laws permit some users to request to exercise certain rights. If these rights are applicable to you, you are afforded with the following rights:
a. Right of access
You can request Revamped for certain information about our practices with respect to your Personal Information. In particular, you can request to receive information on the following:
• The categories and specific pieces of your Personal Information that we have collected.
• The categories of sources from which we collected your Personal Information.
• The business or commercial purposes for which we collected or share your Personal Information.
• The categories of third parties with which we shared your Personal Information.
b. Right to Opt Out of Sale of your Personal Information
You can be rest assured that we do not sell your Personal Information.
c. Right to Limit Use and Disclosure of Sensitive Personal Information
We do not share sensitive Personal Information for cross-context behavioral advertising and we do not sell sensitive Personal Information.
d. Exercising your California Law Rights
Please note that we will be required to verify your identity and request before an action is taken to exercise your rights. As a part of this process, government identification may be required. Moreover, you may designate an authorized agent to make a request on your behalf. We make our best efforts to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide, will only cover the 12 months period preceding your verifiable request’s receipt. If, for some reason, we cannot reply within such time frame, our response will include an explanation for our inability to comply. If you wish to exercise your California Privacy Laws rights, please contact us at: firstname.lastname@example.org.
e. Right of No Retaliation Following Opt-Out or Exercise of your Rights
If you choose to exercise your rights, we will not charge you different prices or provide different quality of our Services, unless those differences are related to your provision of your Personal Information. We will not discriminate against you for exercising any of your rights and unless permitted by the California Privacy Laws, we will not:
1. Deny you goods or services.
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
3. Provide you with a different level or quality of goods or services.
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
9. CAN SPAM Act
The CAN-SPAM Act is a Federal US law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out strict penalties for violations.
To be in accordance with CAN-SPAM, Revamped agrees to the following:
• Not use false or misleading subjects or email addresses.
• Identify the commercial message sent to you as an advertisement when required.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can email us at email@example.com and we will promptly remove you from ALL correspondence.
10. Opt In or Opt Out
You are always in control of your data, and if you choose to receive information from us, or others, you can change your mind later. If, at any time, you would like to stop receiving such information or opt out of a feature, you may notify us by writing to firstname.lastname@example.org You should be aware, however, that it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request.
11. Links to Other Websites
12. Data Security
We deploy industry standard measures to ensure the security, confidentiality, integrity and availability of the Personal Information we process. We maintain physical, technical and administrative safeguards, and test and update these periodically. We endeavor to restrict access to Personal Information on a ’need to know’ basis for the provision of Platform and Services to you. No such measures are perfect or impenetrable. In the event of a security breach, we will take all reasonable action to minimize any harm. Although we will do our best to protect Personal Information, we cannot guarantee the security of data transmitted to us and transmission is at the users own risk.
13. Data Retention
Generally, Revamped does not retain information longer than necessary to provide its Services and for its reasonable business and lawful needs. If you withdraw your consent to us processing your Personal Information, we will erase your Personal Information from our systems, unless the Personal Information is required for Revamped to establish, exercise or defend against legal claims or it is necessary for the performance of the requested Services.
14. Children’s Privacy
The Platform is not intended for children under the age of 16. We do not, knowingly or intentionally, collect information about children who are under 16 years of age.
IF YOU ARE UNDER THE AGE OF 16 YOU MAY NOT USE THE PLATFORM, UNLESS PARENTAL CONSENT IS PROVIDED ACCORDINGLY.
17. Governing Law and Jurisdiction
This page was updated on May, 2023.