Privacy notice
Draft pending legal review
First layer: the essentials
Who handles your data. [RAZÓN SOCIAL] ("Perchia"), [NIF], [DOMICILIO]. Contact: hola@perchia.app.
What for. So Perchia can dress you from your own clothes: keeping the photos of your pieces, reading your colours and, if you want, your measurements, choosing outfits for whatever you ask with the weather and the time, and drawing you wearing them. Also to keep the service safe and to improve it during the beta.
On what basis. The contract (the beta terms) for the basics. Your explicit consent, separate for each and withdrawable at any time, for photos of your face and body, your measurements, needs such as pregnancy or a seated fit, the head covering you wear, and the AI pictures of you. Our legitimate interest for security and for measuring, without your name or photos, how the app works.
Who else sees it. Only the providers that help us run the service, under contract and on our instructions: storage and servers in the EU (Supabase and Google Cloud, Frankfurt), Google's image model that draws you, Anthropic's Claude for the words (it never sees your photos), email sending (Resend) and error reports (Sentry). Some are in the US or keep account data there: we use the safeguards the law requires. We do not sell your data. Nobody trains AI models on your photos.
Your rights. Download all your data, correct it and delete your account in the app (Settings → Your data), withdraw each consent (Settings → Privacy), and write to hola@perchia.app for any other right. You can complain to the Spanish Data Protection Agency (www.aepd.es).
Adults only (18+). Perchia is not for minors.
More. Read on: the second layer explains each point.
Second layer: everything else
1. Controller
[RAZÓN SOCIAL], [NIF], at [DOMICILIO], is the controller of your data in Perchia (the web app, the iPhone app and perchia.app). For anything about privacy: hola@perchia.app. [Data protection officer: not appointed / appointed: contact.]
2. What we process
| What | Examples | From where |
|---|---|---|
| Your account | email, the name you choose, language, that you confirmed you are 18 or over; with Google sign-in, the identifier Google gives us | you, Google |
| Your clothes | photos of your clothes and shoes; their description (kind, colour, cut, fabric); the ones you correct by hand | you; AI describes them |
| Photos of you | three photos (front, angle, face) and any you add | you |
| Your colours | skin tone, hair and eye colour, undertone, your colour season, read from your photos or your answers | worked out by Perchia, or you |
| Your body (if you allow it) | height, measurements (chest, waist, hips, inseam), the build we estimate from full-body photos (e.g. "shoulders wider than the hips"), sizes | you, or worked out by Perchia |
| Your needs (if you allow it) | pregnancy, a seated fit, sensitivity to fabrics or labels, easy fastenings | you |
| Head covering (if you allow it) | whether you wear a hijab, turban, headscarf, kippah or other, to keep it in every outfit and picture | you |
| Your style | what you love and what you'd never wear, how you like clothes to fit, which clothes you wear (men's, women's or both), what you prefer to keep covered (shoulders, arms, legs), your work dress code, your ♥ and ✕ | you; what we learn from your ratings |
| What you ask | your requests ("dinner Saturday at 9"), the conversation with Perchia, what you ask it to remember | you |
| Your city and the weather | the city you give (not your exact location) and the forecast for that hour | you; Open-Meteo |
| AI-drawn pictures | pictures of you in an outfit, with your real face put back | made by Perchia with AI |
| What you tell us | thumbs up or down and what you write in "Tell us" | you |
| Technical data | when each feature is used, how long it took, whether it failed and the kind of error; the app version; never your name, your words or your photos | your device and our servers |
[DRAFT NOTE: the beta edition (edition.py) doesn't let people enter height, measurements, needs or what they prefer to keep covered, and doesn't show the build. If that still holds at publication, remove the rows "Your body" and "Your needs" and the C-BODY and C-NEEDS purposes, unless the build is still estimated from photos (see Part C).]
When you upload a photo we remove where it was taken (the GPS and place names phones store in the photo).
Specially protected data. Photos of your face and body, your skin tone, your measurements, needs such as pregnancy and the head covering you wear can reveal data the law protects specially (health, ethnic origin, beliefs). So we process them only with your explicit consent, each one separately, and only to dress you. We never use your photos to recognise or identify you: your face is used only to read your colours and to put it back in the pictures drawn of you.
Your requests can say more than they seem. If you write "church wedding" or "Eid dinner", Perchia reads it to dress you for that occasion. Write only what you want Perchia to know. You can clear the conversation at any time ("Start over").
People who are not you. Upload only photos of yourself. If a clothes photo shows someone else, try to keep their face out of it. Do not upload photos of other people to draw them.
3. What for, and on what legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Create and keep your account; let you in with an email link or Google | account | contract (Art. 6(1)(b) GDPR) |
| Keep and describe your clothes; choose outfits for what you ask, with the weather and time; learn your taste from your ♥ and ✕ | clothes, style, requests, city, weather | contract (Art. 6(1)(b)) |
| Keep photos of you and read your colours from them | photos of you, colours | explicit consent C-PHOTOS (Arts. 6(1)(a), 9(2)(a)) |
| Estimate your build and use your measurements to choose cuts | body | explicit consent C-BODY |
| Take your needs into account (pregnancy, a seated fit…) | needs | explicit consent C-NEEDS |
| Keep the head covering you wear and follow the customs of religious occasions you mention | head covering; those requests | explicit consent C-HEAD-COVERINGS |
| Draw you wearing an outfit, with your real face | photos of you, clothes, AI pictures | explicit consent C-FACE-DRAW and C-AI-ENGINES |
| Send you news about Perchia by email | consent C-MARKETING-EMAIL (Art. 6(1)(a) GDPR; Art. 21 LSSI-CE) | |
| Protect the service, prevent abuse, fix errors; measure, without your name or photos, what works | technical data | legitimate interest (Art. 6(1)(f)): a safe service that works; you can object |
| Read and answer what you send in "Tell us" | what you tell us | legitimate interest (Art. 6(1)(f)): improving the beta with your comments |
| Handle your rights, keep proof of your consents, report security breaches | what that needs | legal obligation (Art. 6(1)(c)) |
Without the optional consents Perchia still works, with less: without C-PHOTOS you answer a colour quiz instead of photos; without C-BODY outfits are chosen by occasion, your colours and your taste, not your build; without C-FACE-DRAW and C-AI-ENGINES you see outfits as photos of your clothes, without a picture of you.
Automated decisions. Perchia ranks outfits and learns your taste: that is profiling of your clothing preferences. It takes no decision with legal effects on you or that affects you in a similarly significant way (Art. 22 GDPR). You can always pick another outfit, rate it or ask for something else.
4. AI in Perchia
- Words (understanding what you ask, choosing outfits, the conversation): Claude, by Anthropic. Claude never sees your photos. It receives your request, the name you chose, your clothes' descriptions, your city and the weather, your colour season, your tastes and, if you allowed it, the head covering you wear (and, if those features are on and you allowed it, your build in words and your needs). Never the numbers of your measurements.
- Describing your clothes from their photos: a Google vision model (Gemini 2.5 Flash) on Vertex AI, in the EU (europe-west4, the Netherlands). It receives clothes photos only. If you appear in a clothes photo, it is sent as it is; you can crop yourself out first.
- Reading your colours (skin tone, hair, eyes and contrast) from one close-up photo of your face, and checking the three photos you give (front, angle, face close-up) (only you in it, your face visible, sunglasses, your whole body in view, a plain background): a Google vision model (Gemini) on Vertex AI, in the EU. To read your colours it receives that one photo, without metadata and with nothing else about you; to check a photo, that photo. Only with your "Photos of you" permission and never for anyone under 18. Your build is not read from your photos: it comes from your answers.
- Drawing you in an outfit ("See it on me"): Google's Virtual Try-On (virtual-try-on-001) on Vertex AI, in the EU (europe-west4, the Netherlands). For each picture it receives your main photo and the photos of that outfit's clothes (one garment per call), nothing else. Google does not train models on them.
- AI-drawn pictures carry a visible label ("Made with AI") and a machine-readable mark saying they were made with AI. They are illustrations: they may not show exactly how a piece fits you.
- When you talk to Perchia you are talking to an AI, not a person.
5. Who receives your data
Providers that process data on our behalf, under contract (Art. 28 GDPR), only to run the service:
| Provider | What for | Where |
|---|---|---|
| Supabase | database and private storage of your photos | EU (Frankfurt) |
| Google Cloud (Cloud Run, Vertex AI, Secret Manager) | servers; describing clothes; drawing pictures | EU (Frankfurt; Vertex AI in europe-west4, the Netherlands) |
| Anthropic (Claude) | words: reading requests, choosing outfits, the conversation | US [or EU if used through Vertex AI: PENDING] |
| Resend | sending sign-in emails and service notices | sent from Ireland; account data and sending logs in the US |
| Sentry | recording app errors, with no personal data on purpose | EU (Frankfurt); our account data in the US |
| Cloudflare | the domain and the perchia.app site; forwarding mail to hola@perchia.app | global network |
| Open-Meteo | the weather forecast for your city (it receives only the city's coordinates) | Switzerland |
Others acting on their own account, under their own policies: Google, if you sign in with your Google account; Apple, if you test the iPhone app with TestFlight (Apple may share with us your tester email, crash reports and the screenshots and comments you send from TestFlight). And authorities, where the law requires it.
We don't sell your data or use it for advertising. Nobody trains AI models on your photos or on what you write: Google Cloud's and Anthropic's contracts forbid it for their customers' data.
6. Transfers outside the EU
Some providers are in the US or keep part of the data there (Anthropic; Resend's sending logs; Sentry's account data). We do this with the GDPR's safeguards: the European Commission's standard contractual clauses and, where the provider has joined it, the EU-US Data Privacy Framework. Open-Meteo is in Switzerland, which has an adequacy decision of the Commission. You can ask us for a copy of these safeguards at hola@perchia.app.
7. How long we keep your data
| Data | How long |
|---|---|
| Your account | while it is open |
| Clothes photos, photos of you, drawn pictures, your profile | until you delete them or your account |
| What you delete (a piece, a photo, a picture) | goes to a bin for 30 days, then is erased for good |
| Your build, measurements, needs, head covering | until you withdraw that consent or delete them: withdrawing deletes them |
| Your requests | the latest 200 |
| The conversation with Perchia | the latest 60 messages; "Start over" clears it |
| What Perchia remembers about you | until you make it forget (You → What Perchia remembers); 100 things at most |
| Drawn pictures | the latest 1,000 |
| What you tell us ("Tell us") | 1 year at most |
| Technical usage data | 90 days |
| Error records | 30 days [PENDING: set in Sentry and Google Cloud] |
| The "Download my data" file | 24 hours |
| Proof of your consents | while you have an account and [PENDING: period after deletion, to be able to prove them] |
| Database backups | 7 days; photos are not in those backups. On a household's Mac, the local backups (up to 7 daily and 4 weekly copies) do keep the photos |
If you delete your account: you can't sign in from that moment; your photos and data go to a bin nobody uses and are erased for good 30 days later; what remains in backups is gone within the following 7 days. Anthropic deletes what it received within 30 days. [PENDING: blocking under Art. 32 LOPDGDD; see Part C.]
8. Your rights and how to use them
| Right | How |
|---|---|
| Access and portability: get a copy | Settings → Your data → Download my data: a ZIP of your records (JSON) and photos, ready in minutes, available 24 hours |
| Rectification: correct | in the app: You (your details, colours, measurements), each piece (name, colour), Settings; or write to us |
| Erasure: delete | each piece, photo or picture in the app; everything: Settings → Your data → Delete my account |
| Withdraw a consent | Settings → Privacy: each has its own switch; what depended on it is deleted or no longer used |
| Objection | to technical measurement or to "Tell us": write to us |
| Restriction | write to us |
| Not to be subject to automated decisions | Perchia takes none (point 3) |
Write to hola@perchia.app from your account's email. We answer within one month at most (Art. 12(3) GDPR), free of charge. If you think we have not handled your data properly, you can complain to the Spanish Data Protection Agency (AEPD, www.aepd.es, C/ Jorge Juan 6, 28001 Madrid).
9. Minors
Perchia is for people aged 18 and over only. When you sign up you confirm you are. Perchia never measures or comments on the body of a minor and does not draw minors. If we learn an account belongs to a minor, we delete it.
10. Security
Your photos are kept in private, encrypted storage in the EU; only your account can see them and we show them through temporary links. Connections are encrypted. We keep no photos, names or what you write in error records or technical measurement. If a security breach puts you at risk, we will tell you.
11. Cookies
The app uses only what it needs to work: keeping you signed in. We use no advertising cookies and no third-party analytics. The perchia.app site uses no cookies. [PENDING: confirm against the Cloudflare configuration.]
12. Changes
If we change this notice in an important way, we will tell you in the app before it applies. If a change needs your consent, we will ask again.
Last updated: [DATE].