Section 01
Who We Are and How to Contact Us
Re-wear (“Re-wear”, “we”, “us”, or “our”) operates the Re-wear application and website (the “Service”), a wardrobe management tool that helps you rediscover and make better use of the clothes you already own.
Data Controller: Re-wear (pending formal incorporation; contact details below)
Email: privacy@re-wear.app
This Privacy Policy explains how we collect, use, store, and share your personal data, and describes your rights under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable data protection laws.
Section 02
What Personal Data We Collect
We collect the following categories of personal data:
2.1 Account Data
- Email address (provided at registration or when joining the waitlist)
- Display name (provided during onboarding)
- Password (optional; stored in hashed, non-recoverable form if set)
- Account creation date and last login date
- Notification preferences (e.g. whether you have opted in to email updates)
2.2 Wardrobe and Clothing Data
- Photographs of clothing items you upload
- Item attributes (type, colour, brand, category, tags)
- Item purchase price and estimated cost-per-wear (if you choose to enter these)
- Notes or descriptions you add to items
2.3 Usage and Activity Data
- Outfit selections and wear logs
- Feature interactions (which features you use and how often)
2.4 Sustainability Data
- Sustainability metrics derived from your wear and relisting activity
2.5 Technical and Device Data
- Device type and operating system
- App version
- IP address (collected temporarily during connections)
- Crash and error logs
2.6 Communications Data
- Any messages or emails you send to us
Section 03
How We Collect Your Data
- Directly from you when you register, join the waitlist, upload clothing items, log outfit choices, or contact us.
- Automatically when you use the Service, through technical logs and usage analytics.
- From third-party platforms — If you use the relisting feature, those platforms process your data under their own privacy policies. We do not receive your personal data from those platforms.
Section 04
Lawful Basis for Processing
Under the GDPR, we must have a valid lawful basis for each processing activity.
| Processing Activity | Data Involved | Lawful Basis |
|---|---|---|
| Creating and managing your account | Account data | Contract (Art. 6(1)(b)) |
| Storing and displaying your wardrobe | Photos, item attributes | Contract (Art. 6(1)(b)) |
| Generating outfit suggestions | Wardrobe and wear data | Contract (Art. 6(1)(b)) |
| Tracking cost-per-wear and wear logs | Activity data | Contract (Art. 6(1)(b)) |
| Sustainability tracking | Sustainability data | Contract (Art. 6(1)(b)) |
| Relisting assistance (Vinted, Depop) | Item attributes | Contract (Art. 6(1)(b)) |
| Automated image processing / AI tagging | Photos | Contract (Art. 6(1)(b)) |
| Sending service-related communications | Email address | Contract (Art. 6(1)(b)) |
| Onboarding profile (display name, notification preferences) | Account data | Contract (Art. 6(1)(b)) |
| Sending marketing or product updates | Email address, notification preferences | Consent (Art. 6(1)(a)) |
| Improving the Service via analytics | Technical and usage data | Legitimate interests (Art. 6(1)(f)) |
| Maintaining security and preventing fraud | Technical data, logs | Legitimate interests (Art. 6(1)(f)) |
| Responding to enquiries | Communications data | Legitimate interests (Art. 6(1)(f)) |
You may withdraw consent for marketing communications at any time by clicking “unsubscribe” in any email or by contacting us.
Section 05
How We Use Your Data
- Operate and provide the Service, including your digital wardrobe and outfit suggestions
- Process and store photographs of your clothing items
- Enable the relisting feature to send pre-filled item information to supported third-party resale platforms
- Send you service-related communications (e.g. account notifications, security alerts)
- Send you product updates or news, only where you have consented
- Improve the Service through usage analytics and error monitoring
- Detect and prevent fraud, abuse, or other harmful activity
- Comply with applicable legal obligations
We do not use your personal data for automated decision-making that produces legal or similarly significant effects without your involvement.
Section 06
Photographs and Automated Image Processing
When you upload photographs to Re-wear, those images are stored on secure servers in Western Europe. Where automated image recognition or AI-assisted tagging is used:
- Processing is performed solely to organise your wardrobe within the Service.
- Your photographs are not used to train third-party AI models, and are not shared with third parties for purposes other than storage and processing as described in this policy.
- Any third-party AI service used for image processing will be listed in Section 7 as a sub-processor.
- You can edit or delete any automatically generated tags or descriptions at any time within the app.
Section 07
Who We Share Your Data With
We do not sell your personal data to third parties, and we do not share your personal data for advertising purposes.
7.1 Service Providers (Sub-processors)
| Provider | Purpose | Data Location |
|---|---|---|
| Cloudflare, Inc. (R2 Object Storage) | Storage of clothing photographs and associated data | Western Europe (WEUR region) |
| AI image processing provider — TBD | Automated tagging and categorisation of clothing photos | To be confirmed |
| Authentication / infrastructure — TBD | Account management and app infrastructure | To be confirmed |
7.2 Third-Party Resale Platforms
When you choose to relist an item on Vinted or Depop, you are directing us to send information about that item to that platform. Once data is passed to the third-party platform, their own privacy policy applies and they become an independent data controller.
- Vinted: vinted.com/privacy-policy
- Depop: depop.com/privacy
7.3 Legal Requirements
We may disclose your personal data if required to do so by law, court order, or governmental authority.
7.4 Business Transfers
If Re-wear is acquired or undergoes a restructuring, your personal data may be transferred as part of that process. We will notify you before your data is transferred and becomes subject to a different privacy policy.
Section 08
International Data Transfers
Re-wear stores clothing photographs on Cloudflare R2 infrastructure located in the Western Europe (WEUR) region, within the European Economic Area.
Where any other personal data is processed by sub-processors outside the EEA, we ensure appropriate safeguards are in place — such as the European Commission's Standard Contractual Clauses (SCCs) or an applicable adequacy decision.
Section 09
Data Retention
| Data Type | Retention Period |
|---|---|
| Account data (email, display name, password hash, notification preferences) | Until account deletion |
| Clothing photographs | Until you delete the item or your account |
| Item attributes and wardrobe data | Until you delete the item or your account |
| Wear logs and activity data | Until account deletion |
| Technical logs (IP addresses, error logs) | Up to 90 days from collection |
| Communications data (support emails) | Up to 3 years from last contact |
| Waitlist email addresses | Until you unsubscribe or the waitlist closes |
When you delete your account, we will delete or anonymise your personal data within 30 days, except where we are required by law to retain it for longer.
Section 10
Data Security
We implement appropriate technical and organisational measures to protect your personal data. These include:
- Encryption of data in transit (TLS) and at rest
- Secure, access-controlled cloud storage
- Password hashing using industry-standard algorithms
- Regular review of our security practices
In the event of a personal data breach likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and report to the relevant supervisory authority within 72 hours, as required by the GDPR.
Section 11
Your Rights
| Right | What it means |
|---|---|
| Right of access | You can request a copy of the personal data we hold about you. |
| Right to rectification | You can ask us to correct inaccurate or incomplete data. |
| Right to erasure | You can ask us to delete your personal data ("right to be forgotten"), subject to certain legal exceptions. |
| Right to restriction | You can ask us to limit how we process your data in certain circumstances. |
| Right to data portability | You can request your personal data in a structured, machine-readable format. |
| Right to object | You can object to processing based on legitimate interests, including for direct marketing purposes. |
| Right to withdraw consent | Where processing is based on consent, you can withdraw at any time. |
| Rights related to automated decision-making | You have the right not to be subject to decisions based solely on automated processing that significantly affect you. |
How to exercise your rights: Contact us at privacy@re-wear.app. We will respond within 30 days.
Section 12
Cookies and Similar Technologies
Re-wear may use cookies and similar tracking technologies for purposes such as:
- Keeping you logged in to your account (strictly necessary)
- Remembering your preferences
- Understanding how the Service is used (analytics)
For cookies that are not strictly necessary, we will ask for your consent before placing them.
Section 13
Children's Privacy
The Service is not directed at children under 13. We do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe your child has provided personal data to Re-wear, please contact us and we will delete it promptly.
For users between 13 and 16 in the EEA, certain processing activities may require parental or guardian consent under Article 8 of the GDPR.
Section 14
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will:
- Notify you by email at the address associated with your account; or
- Display a prominent notice within the app.
Section 15
Right to Lodge a Complaint
If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with a supervisory authority. The lead supervisory authority for Re-wear (once incorporated in the Netherlands) is:
Autoriteit Persoonsgegevens (AP)
Website: autoriteitpersoonsgegevens.nl
Phone: +31 70 888 8500
You may also lodge a complaint with the supervisory authority in the EU member state where you live or work.