Privacy Policy

A few key points about our privacy practises

We are an AI-powered platform that provides personal styling, personal shopping, and colour analysis.
We make personalised recommendations of clothes and beauty products by analysing a photo of your face, as well as your figure type, height, and other parameters. To use this service, you provide us information pertaining to your colour style and style personality.
To make sure our services are run smoothly, we use third-party providers – for example, Amazon Web Services for cloud storage. All such providers are bound by our mutual contractual arrangements and are not able to use your data for any purpose except the one misi tells them to.
We use the photographs or any other personal information you provide us only in accordance with this Privacy Policy and the Purposes.
We take reasonable and appropriate measures to protect your Personal Information from loss, theft, misuse, or unauthorised access.
You have full control over your data. You can always access, correct, erase, and update your Personal Information by writing to us at info@misi.app.
We believe in honest and transparent dialogue. You can always contact us at info@misi.app.

Introduction

This Privacy Policy explains how misi LLC (“misi” or “we” or “us”) collects, stores, uses, transfers, and shares Personal Information from our users (“you”) in connection with the www.misi.app including any products and services related to it (“Website”) and the misi mobile applications on iOS and Android designed for the Purpose (“App”) (all collectively, “Services”). misi is the ‘data controller’.

misi is committed to protecting your personal information while you use our Website or App. We may change this Privacy Policy from time to time. If the changes are material, we will notify you. If permitted by law, your continued use of the Services after this policy has been updated indicates your acceptance of changes made.

If you do not accept the terms of the Privacy Policy, please do not use the Services.

CONSENT TO PRIVACY POLICY. BY CONSENTING TO OUR PRIVACY POLICY DURING REGISTRATION, YOU CONSENT TO ITS CONTENTS IN ITS ENTIRETY, INCLUDING THE PROCESSING ACTIVITIES THAT RELY ON CONSENT AS A LEGAL BASIS (INCLUDING BUT NOT LIMITED TO PROCESSING OF YOUR PHOTOS TO IMPROVE OUR RECOMMENDATION ALGORITHMS). FAILURE TO ACCEPT THIS PRIVACY POLICY MEANS THAT YOU ARE NOT ALLOWED TO USE THE SERVICES.

What Personal Information do we collect?

We collect personal information appropriate to the service you choose to sign up for. ‘Personal Information’ refers to information that can be used to identify you (whether alone or in combination with other data).

We may collect the following Personal Information directly from you:

Photographs: via your camera or camera roll (with your direct permission), photos of your face for color analysis, and other information provided by you when using the Service. We access only the specific images you choose to grant us access to using the mobile application; we do not collect or store your photo albums, even if you grant us access to them. During the onboarding process, we collect information about your skin undertone, eye color, and hair color. This information is obtained through an analysis conducted by your device’s camera and is used solely for the purpose of color analysis.
Account registration information: email, phone or social media account log-in details, username, first name, surname, age, gender, and password (if using the email to register).
Onboarding questions: your seasonal colour type, beauty and clothing recommendations, your style, and other relevant data.
Payment details: if you choose to subscribe to our paid service, we may collect your name, ID number, postal address, and financial data such as a bank account, credit card number, or Apple ID if you use in-app payments.
Optional Personal Information that can make the Services more personalised. This may include: profile picture, your location, gender category of clothing, clothing size, favourite colours, price preferences, and other information.

We may also collect certain Personal Information automatically:

Application usage information such as information about how you use and interact with the Services, including your preferred language, the date and time when you first installed the App and the date and time you last used it, your onboarding path (e.g. the source you found us from), certain geolocation data (if permitted on device level).
Data we receive from third parties – websites, services, and products when you interact with Social Features of our application.
Purchase history such as confirmation that you are a paid subscriber of the App.
Social media information, if you choose to log in to the Services via a third-party platform or social media network such as Facebook or Instagram, we may collect information about you from that platform or networks (for example, social media ID) in accordance with their own privacy and/or cookie policies.
Device data, such as your computer and mobile device operating system type and version number, manufacturer and model, device ID, push tokens, Google Advertising ID, IDFA, browser type, screen resolution, IP address, and other information about the device you are using to visit the application. Please note, that on certain platforms we may need to ask your permission to access your device identifiers (e.g. IDFA).
Data associated with the Cookies Policy.

How do We use your Personal Information?

Depending on which features of the Services you use, we will process your Personal Information based on one or more of the following legal bases:

Your consent. For example, on the registration screen when you give us permission to process your Personal Information related to the onboarding questionnaire and provide consent to our Privacy Policy.
To fulfil our contractual obligations to you in order to provide the Services to you. For example, we may process your Personal Information to fulfil our contractual obligation to you such as account management and other administrative purposes.
Legitimate interest. For example, we may process your Personal Information in relation to our interests in providing the Services to you, including our interest in protecting the security and integrity of the Services.
Legal obligation. For example, we may be obligated to process some of your Personal Information to comply with applicable laws and regulations.

Below you can find some examples of our core processing activities, including but not limited to:

privacy-policy-core-processing-activities

If you want to opt-out from this processing activity, email us at info@misi.app.

Data minimisation and purpose limitation. We will not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorised by you or collect any Personal Information that is not needed for the mentioned purposes.

No sale of Personal Information. We will not sell or rent your Personal Information for monetary gain. We will not disclose your Personal Information except as otherwise described in this Privacy Policy.

Advertisement. We can work with advertising partners to display advertisements within the Services. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

Anonymous, aggregated, or de-identified data. We may create anonymous, aggregated, or de-identified data from your Personal Information and Personal Information of other individuals. We may aggregate, anonymise, or de-identify your Personal Information by removing information that makes the data personally identifiable. We may use this anonymous, aggregated, or de-identified data and share it with third parties for our lawful business purposes or use it for internal business improvements.

Communication with you. We may contact you from time to time via email or through other means (like pop-ups or push notifications) to communicate with you about products, services, offers, promotions, and rewards offered by us, and provide news and information that we think will be of interest to you. You can always opt-out of receiving emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting-out of these emails or notifications will not end the transmission of important service-related emails that are necessary for your use of the Services. You may also opt-out of receiving pop-ups or push notifications by adjusting your settings in your device. If applicable laws prescribe so, we may ask some users to provide their additional consent for such communications.

Please note that we may contact you with information about products, services, offers, promotions, and rewards offered by us and others via third-party platforms (like social media).

No automated decision-making. Processing of your Personal Information will not be subject to decisions based on automated processing that may produce legal effects or significantly affect you.

Referrals. Please note that we may introduce certain referral programs that allow you to take selfies of your friends to refer them to the Services. Subject to the Terms of Use, you agree and certify that the party whose selfie you are taking, fully agrees to this Privacy Policy and processing of Personal Information as specified herein. We may request the proof of such consent if we elect to. Please note that we do not store such selfies for more than a month in case your referral to the Services was not accepted (i.e. your friend does not become our user). After this period, such photos are permanently deleted.

How long will we keep your Personal Information?

Your Personal Information shall be stored as long as your contractual relationship with us lasts.

However, we shall store certain personal identification and traffic data for a maximum period of 2 years after your last day of inactivity to make sure you can resume our Services.

We collect face data to personalize styling recommendations, which is essential for accurate colour analysis tailored to your style. This data is stored briefly, for no more than 24 hours, to facilitate processing and is then securely deleted to protect your privacy.

Impact of account deactivation/requests to erase Personal Information. At any time, you can deactivate your account and erase your Personal Information by emailing info@misi.app or by submitting an in-app deletion request. We will address your deletion request within 30 days after receipt. It may take us up to 90 days in some cases to complete full erasure of your Personal Information stored in our backup systems. If you choose to deactivate your account, we will generally delete all your Personal Information and it will not be recoverable should you later create another account.

Will we share your Personal Information?

Your photographs. We exclusively share this data with Claude AI, who adheres to stringent security standards and does not retain the data after processing. Our partnership with Claude AI is strictly governed by robust data protection agreements, ensuring alignment with our commitment to your privacy.

Service providers. In some situations, we engage other companies to process your Personal Information on our behalf. This is normal in the tech industry: even if we wanted, it would be extremely difficult and impractical for us to build our own storage facilities, analytics services, and email providers. We refer to these companies or service providers as “processors.” We prohibit the service providers we engage from using Personal Information for any purpose that is not related to our engagement.

Processors are companies that help us run the Services, support our communication with you, or perform other Services-related activities. They may process certain Personal Information on our behalf to accomplish the goals related to the App functions, deliver the Services, and associated activities. We remain responsible for any acts or omissions of our processors and undertake to execute formal data processing agreements with them to the extent required by applicable law.

Here are some of the main processors we rely on:

AWS (Amazon Web Services Inc): Our storage and infrastructure provider
- AWS Privacy Policy
PostHog: Our analytics provider that helps us analyse usage patterns and activities
- PostHog Privacy Policy
Supabase: Our backend service provider for database and authentication
- Supabase Privacy Policy
Adapty: Our service for managing in-app subscriptions and payments.
- Adapty Privacy Policy

Affiliate Partnerships. In connection with the personalised shopping recommendations, we share limited data with our affiliate partners through Awin and other networks. This data includes information necessary to link the recommended products with your user profile without compromising your identity. We share only non-identifiable data necessary for the affiliate to support the shopping recommendation process, ensuring all shared data adheres to our stringent privacy standards.

Promotion activities. We may collect certain basic technical information, such as IDFA, instals, and subscription status (but never photos or your answers) to analyse your use of the website and the Services, to understand the effectiveness of our promotion efforts and Services (and related content). This data may be shared with certain third parties for the mentioned purposes. Please note that you might need to separately consent to such tracking, if required by applicable laws. Unless a separate consent is required under applicable law, consent to this Privacy Policy shall constitute a consent to such activity.

Third-party platforms and social media networks. If you have enabled features or functionality that connect the Services to a third-party platform or social media network (such as by logging into the App using your account with the third-party, providing your API key or similar access token for the Service to a third-party, or otherwise linking your account with the Service to a third party’s services), we may disclose the Personal Information that you authorised us to share, such as when you elect to upload a photograph from the Services to your social media account. We do not control the third-party platforms’ use of your Personal Information, which is governed by that third party’s privacy policy and terms and conditions.

Professional advisors. We may disclose your Personal Information to professional advisors, such as lawyers, bankers, IT developers, auditors, and insurers, where it is necessary in the course of the professional services that they render to us.

For compliance, fraud prevention, and safety. We may share your Personal Information for the compliance, fraud prevention, and safety purposes described.

Business transfers. We may sell, transfer, or otherwise share some or all of our business or assets, including your Personal Information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganisation, or sale of assets, or in the event of bankruptcy or dissolution.

Compliance with Law. We may be required to use and share your Personal Information to comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities.

Security and Data Usage. All personal data used to generate shopping recommendations is processed securely. We store this information on encrypted servers and only share data with third parties (e.g., affiliate networks, and data analytics firms) to the extent necessary to provide you with tailored shopping recommendations. We ensure that all third parties are contractually bound to maintain the confidentiality and security of data.

Your Rights

We believe privacy is a human right. Therefore, all our users have the following universal rights:

You have a right to request information about what Personal Information we process about you, to access all your Personal Information (‘Access right’).
You may ask us to erase your Personal Information if you withdraw your consent to processing or if you believe such processing is unlawful (‘Deletion right’). Please be aware that erasing some Personal Information may affect your experience using certain features of the Services that rely on historical data. You can exercise your Deletion right from within the App.
In some cases, you can object to the processing of your Personal Information, for example, if we process it under the legitimate interest basis, by contacting us at info@misi.app (‘Objection right’).
If you believe your Personal Information is inaccurate or incomplete, you can request to correct or, in some cases, correct it yourself from within the App (‘Correction right’).

How to exercise your rights. Contact us at info@misi.app to exercise your Access right, Deletion right, Objection right, and Correction right.

We will address your request within 30 days after receipt. It can take us up to 90 days in some cases, for example for full erasure of your Personal Information stored in our backup systems. We will let you know if we need more time and explain the reasons for the delay.

Opt-out of marketing communications and other push notifications. You may opt-out of marketing-related communications and other push notifications we may send you by changing the settings on your mobile device or the website.

Device permissions. You may revoke any permissions you previously granted to us, such as permission to access your camera or camera roll, through the settings on your device.

Cookies & Web Browser Storage. Please read our Cookies Policy for more information.

Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Services may be members of organisations or programs that provide choices to individuals regarding the use of their browsing behaviour or mobile Service usage for purposes of targeted advertising. So you can always adjust your settings. In addition, your mobile device settings may provide functionality to limit ours or our partners’ ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Service ID for Advertising associated with your mobile device.

Proof of identity. We might also require you to prove your identity in some cases. Normally, we make sure to verify that the request is coming from a legit persona. In some cases, we may ask you to undergo additional verification measures in an effort to ensure we are appropriately responding to requests.

National laws. Please note, that if your local laws provide for additional rights and protection otherwise not specified in this Privacy Policy, we undertake to comply with such additional requirements, if misi is obligated to do so in accordance with the applicable laws.

Other Sites, Mobile Applications, and Services

The Services may contain links to other websites, mobile applications, and online services operated by third parties. These links are not an endorsement of, or indication that we are affiliated with, any third party. In addition, our content may be included on webpages or in mobile applications or online services that are not associated with us. We do not control third-party websites, mobile applications, or online services and we are not responsible for their actions. Other websites, mobile applications, and online services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Data Security and Retention

We implement technical and organisational measures in an effort to protect Personal Information from loss, theft, misuse, and unauthorised access, disclosure, alteration, and destruction, taking into account the nature of the Personal Information that we process and risks associated with special categories of Personal Information we collect.

Specifically, we implemented the following measures to protect your Personal Information:

Encryption: We use an industry-standard security protocol (Secure Sockets Layer – SSL) to help ensure that the information is encrypted and protected from third parties. SSL helps ensure that the communication between your browser and our servers is private and that the information contained therein is safe and delivered only to our computers.
Firewall: Once your information reaches our servers, we protect it in many ways, including storing the information on secure servers and using a device known as a firewall which protects your information by detecting and preventing unauthorised access to the information.
Authorised access: Using our firewalls and other mechanisms, we also protect your information by only allowing access to it by employees and authorised parties who have a legitimate and verified need to access the information in order to service your requests and administer policies and claims.

Cross-Border Data Transfers

misi is based in the United States of America. Personal Information we collect is transferred to and processed in the U.S. (where it is governed by U.S. law) and to other countries (where it is governed by the laws of those countries). The laws of the U.S. and the laws of other countries may not offer the same protections as the laws of your jurisdiction.

Personal Information in the European Union (EU), the EEA, and the United Kingdom (UK) is protected by the General Data Protection Regulation (GDPR) and Data Protection Act 2018, but some other countries may not necessarily have the same standard of protection for your Personal Information. When transferring Personal Information outside the EU, EEA, and UK we either implement standard contractual clauses or rely on current European Commission adequacy decisions. For further information please contact info@misi.app.

How to Contact Us

Please direct any questions or comments regarding this Policy or our privacy practices to info@misi.app.