GLAMIFY ME

PRIVACY AND COOKIES POLICY

Last updated [date] May 2026.

1. Introduction

1.1 We are Glamify Me Ltd, a company registered in England and Wales under company number 16597761 with its registered office at 48 Matlock Way, New Malden, England, KT3 3AY (we, us or our). We are the controller responsible for your personal data.

1.2 We comply with our obligations under the Data Protection Act 2018 and the EU law retained version of the General Data Protection Regulation ((EU) (2016/679) (UK GDPR) (data protection laws). If any of these laws are replaced or superseded, we will also comply with those.

1.3 We are registered with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk), and our registration number is [registration number]. If you have any concerns about data protection, we would appreciate if you contacted us first so we can discuss these with you before you approach the ICO. For data protection matters, please email us at support@glamifyme.beauty.

1.4 We respect your privacy and are committed to protecting your personal data. This policy explains the terms on which we collect and process your personal data, and how we protect your personal data, such as when you:

  • (a) visit our website at https://glamifyme.beauty/,
  • (b) use our GlamifyMe mobile application (App),
  • (c) contact us with any enquiry, or
  • (d) otherwise engage with us.

2. The data we may collect about you

2.1 Personal data/information means any information about an individual from which that person can be identified. It does not include anonymous data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • (a) Identity Data includes your full name, username, date of birth, gender, profile name, profile photo, account identifier, social media account identifier where you choose to sign in using a social media account, and information used to verify your identity and secure your account, including multi-factor authentication information.
  • (b) Contact Data includes home address, billing address, email address and telephone number.
  • (c) Financial Data includes bank account and payment card details, however, please note that is generally collected and processed by a third party payment providers and are not stored by us unless strictly necessary for fraud prevention, refunds or accounting records.
  • (d) Transaction Data includes details about payments to and from you, subscriptions and cancellation history, rewards activity, and details of the products, including details of outfit sets or digital items, you have purchased from us.
  • (e) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website. This may also include approximate or precise location data where enabled for relevant features, such as in-store virtual try-on or location-based functionality.
  • (f) Profile Data includes your username and password (if applicable), purchases or orders made by you, your interests, preferences including authentication settings, purchases or orders made by you, saved items, brand preferences, style preferences, size preferences, calendar-linked outfit preferences, feedback, survey responses loyalty and rewards information, and records of your interactions with our AI stylist and customer support.
  • (g) Usage Data includes information about how you use our website, App and services.
  • (h) User Content Data includes photos, videos, wardrobe images, uploaded clothing images, body scans, body measurements, fit data, sizing information, avatar data, body-shape information, try-on images and videos, user-generated posts, shared looks, comments and other content you choose to upload, create, store, generate or share through the App or connected social media features, together with information derived from your photos, videos or scans, such as clothing size recommendations, fit predictions, colour and tone recommendations and similar styling outputs.
  • (i) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences including recommendation notifications and subscription renewal notices.
  • (j) Aggregated Data such as statistical or demographic data for any purpose, is not considered personal data in law as this data will not directly or indirectly reveal your identity to us. We may aggregate your Usage Data, scan and fit trends, and customer preference data to help improve our services, recommendation tools, analytics and commercial reporting.
  • (k) Special Category Data some features of our App may involve the collection or processing of data that is classed as ‘Special Category Data’ under data protection laws, or that may reveal sensitive information about you. This may include, biometric data, data concerning health, or data from which racial or ethnic original may be inferred. Where we process Special Category Data, we will do so only where permitted by law, will identify the relevant lawful basis and condition for that processing, and will provide any additional notices or obtain any explicit consent required.

Please do not upload or share sensitive personal data with us unless we specifically ask for it or the feature clearly requires it and we have explained how it will be used.

3. How is your personal data collected?

We may use different methods to collect data from and about you including through:

3.1 Direct interactions. You may give us your Identity Data, Contact Data, Profile Data, User Content Data, Transaction Data, Marketing and Communications Data and other personal data by filling in forms, creating an account, completing multi-factor authentication, uploading photos, videos, wardrobe images or body scans, using virtual try-on or styling features, making purchases, entering competitions or challenges, responding to surveys, or by corresponding or engaging with us by post, phone, email, social media or otherwise.

3.2 Automated technologies or interactions. As you interact with our website and App, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies such as pixels, device identifiers and in-app analytics tools and third-party technologies integrated into our website and App. We may receive Technical Data and Transaction Data from app store providers, payment processors, analytics providers and other technical service providers. We may also collect information about how you use App features, including virtual try-on, recommendation, notification and saved-item features.

3.3 Third parties and public sources. We may collect personal data about you from third parties and public sources, such as Google, Companies House, or the electoral register. This may also include identity and authentication providers, social media platforms where you choose to sign in or connect your account, payment providers, analytics providers, advertising networks, fraud prevention providers, supported body-scanning or AR/VR technology providers, and other service providers who help us operate our website, App and services.

4. How we use your personal data

We will only use your personal data when we can rely on a legitimate (lawful) basis, and only for the purposes described in this privacy policy, such as:

4.1 Contract: Where we need to perform the contract, we are about to enter into or have entered into with you.

4.2 Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4.3 Legal Obligation: Where we need to comply with a legal obligation.

4.4 Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter or where we use your personal data for personalisation, profiling, recommendations or other AI-enabled features where consent is required.

5. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/activityType of dataLawful basis for processing including basis of legitimate interest
To enable you to submit an enquiry to us, whether via the App, email, or social media.

Identity

Contact

Profile

Contract - where your enquiry relates to the services you have signed up to or steps taken at your request before entering into a contract.

Legitimate Interests - to respond to enquiries, keep our records accurate, improve customer service and demonstrate compliance if challenged.

To create and administer your account, including where you sign in using a social media account, complete multi-factor authentication, and access and use the App and its core functionality.

Identity

Contact

Technical

Profile

Usage

Contract - to create and administer your account, provide access to the App, and deliver its core functionality to you.

Legitimate Interests - to verify users, maintain account security, prevent fraud and unauthorised access, operate, monitor and improve the App, and maintain service performance.

To process your purchase of products, subscriptions, outfit sets, digital items or other in-App purchases, including payments, renewals, cancellations, refunds and rewards activity.

Contact

Transaction

Financial (processed via third party providers)

Profile

Contract - to process payments, cancellations, refunds or reward redemptions, and provide access to paid features.

Legal Obligation - to comply with financial and tax obligations.

Legitimate Interests - to recover sums due to us and keep accurate financial and account records.

To manage our relationship with you which will include (a) notifying you about changes to our terms and conditions or this privacy and cookie policy (b) dealing with your requests, complaints, and queries.

Identity

Contact

Profile

Marketing and Communications

Contract - necessary to provide the services you have signed up to and respond to your enquiries.

Legal Obligation - to provide certain updates under consumer protection and data protection laws.

Legitimate Interests - to keep our records accurate, improve customer service and handle complaints and disputes.

To provide body scan, sizing, fit, virtual try-on, avatar and styling functionality, including generating fit predictions, size recommendations, colour and tone recommendations and similar styling outputs.

Identity

Technical

Profile

Usage

User Content

Special Category Data (where applicable)

Contract - to provide the scan, fit, try-on and styling features you request through the App.

Consent - to provide the scan, fit, try-on and styling features you request through the App.

Legitimate Interests - to improve fit accuracy, recommendation quality and the performance of these features. Where this processing involves Special Category Data, we will also rely on an additional condition required by data protection law and, where required, obtain your explicit consent.

To provide AI stylist, outfit suggestions, personalisation, recommendations and similar AI-enabled features based on your preferences, activity, wardrobe uploads, scans, purchases, calendar-linked preferences, location or other inputs you choose to use.

Identity

Technical

Profile

Usage

User Content

Marketing and Communications

Special Category Data (where applicable)

Contract - where the feature is part of the service you actively request and use through the App.

Legitimate Interests - to personalise your experience, improve relevance, develop our services and grow our business.

Consent - where consent is required by law or where we choose to rely on it for a particular feature. Where relevant, we will explain when recommendations involve profiling or AI-enabled processing and the lawful basis we rely on.

To enable you to upload, store, create, generate, share or publish photos, videos, wardrobe images, try-on looks, comments and other user content, and to let you choose who can view that content.

Identity

Profile

Usage

User Content

Contract - to provide the sharing, storage and social features you choose to use.

Legitimate Interests - to operate these features, apply your sharing preferences, investigate misuse and keep the platform/App safe.

Consent - where we ask for your permission for a particular use, such as optional sharing or connected social media functionality.

To allow you to save favourite items, receive sale alerts, recommendation notifications, subscription renewal notices and other service messages.

Identity

Contact

Transaction

Profile

Usage

Marketing and Communications

Contract - to provide service features you request.

Legitimate Interests - to send relevant service-related updates, maintain engagement and improve your user experience.

Consent - where required by law for particular notifications or marketing channels.

To administer loyalty, rewards, competitions, fashion challenges, badges, discounts and similar promotional features.

Identity

Contact

Transaction

Profile

Usage

User Content

Marketing and Communications

Contract - where necessary to administer the reward, competition or challenge you choose to enter or use.

Legitimate Interests - to encourage engagement, measure participation, promote our services and improve our offerings.

Legal Obligation - where required to administer promotions fairly and keep legally required records.

To send you direct marketing and maintain our mailing list.

Identity

Contact

Technical

Profile

Usage

Marketing and Communications

Consent - where you actively opt in to receive email, SMS or other electronic marketing.

Legitimate Interests - to promote relevant products and services to existing customers where the soft-opt-in applies (existing customers who have not opted out).

Legal Obligation - to maintain a suppression list of people who have opted out.

To administer and protect the App, our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Identity

Contact

Technical

Legitimate Interests - to run our business efficiently, ensure IT security, prevent fraud and support any corporate reorganisation.

Legal Obligation - to comply with statutory data-security duties and cooperate with lawful requests from regulators or law-enforcement.

To deliver relevant in-App content and, where permitted, personalised promotions or advertising, and to measure their effectiveness.

Identity

Contact

Profile

Usage

Marketing and Communications

Technical

Legitimate Interests - to study how users use the App, develop our services, grow our business and inform our content and marketing strategy.

Consent - where required for direct marketing or use of non-essential technologies.

To use data analytics to improve the App, user experience and functionality.

Technical

Profile

Usage

User Content

Aggregated

Legitimate Interests - to analyse how users interact with the App, fix issues, improve performance and develop new features. Where possible, we use aggregated or de-identified information for these purposes.

6. Direct marketing

6.1 You will receive marketing communications from us if you have provided your consent to receive such communications or, where permitted under applicable law (including the Privacy and Electronic Communications Regulations 2003), where you have previously purchased products or services from us, we are marketing similar products or services, and you have not opted out at the time of collection or in any subsequent communication.

6.2 We may also use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to assess which products, services and offers may be of interest to you and to send you relevant marketing communications, where permitted by law.

7. Third party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

8. Opting out of marketing

8.1 You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at support@glamifyme.beauty.

8.2 If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates to our terms and conditions and checking that your contact details are correct.

9. Cookies

9.1 We use cookies and similar technologies (including third-party tracking technologies) to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and to display advertisements according to your interests, and also allows us to improve our website services.

9.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer where required by law and subject to your consent for non-essential cookies. Cookies contain information that is transferred to your computer's hard drive. Some emails and pages contain a tiny graphic file that lets us see when you open a message or visit a page. Web beacons work together with cookies; if you disable cookies, they may stop working.

9.3 We display a cookie banner when you first visit our website which allows you to accept, reject or customise your preferences for non-essential cookies. Strictly necessary cookies are always active as they are required for the operation of the website.

9.4 We use the following cookies:

  • (a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • (b) Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • (c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

9.5 The App currently uses mobile SDKs, authentication/session tools, analytics and crash-reporting technologies provided by third party providers (including providers such as Firebase Analytics and Google Analytics for Firebase) to support functionality, authentication, performance monitoring, analytics and security.

9.6 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

9.7 When you first visit, a cookie banner lets you accept, reject or customise non-essential cookies. You can change your choices at any time by clicking "Cookie Settings" in the website footer. Most browsers also let you block or delete cookies through their settings; see www.allaboutcookies.org for instructions.

10. Disclosures of your personal data

10.1 We may disclose your information in the following cases:

  • (a) to our employees, workers, and subcontractors in order to facilitate the provision of services to you
  • (b) to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy and cookies policy
  • (c) to other companies in our group, as defined in the UK Companies Act 2006
  • (d) to third-party service providers as further explained below, who support our business and the operation of our website and App
  • (e) to our professional advisers, including auditors, legal advisers, insurers and accountants
  • (f) where we have a legal obligation to do so, or in order to protect other people's property, safety, or rights
  • (g) to protect against fraud or credit risks

10.2 We use a variety of third party services providers (sub-processors) as part of our business activities and may share your personal data them where necessary. The types of sub-processors we might use fall into different categories, as follows:

  • (a) payment processing services
  • (b) authentication, hosting and storage providers
  • (c) analytics service providers
  • (d) event or campaign management service providers
  • (e) website and App management service providers
  • (f) information technology and related infrastructure providers
  • (g) email delivery and communications service providers
  • (h) our auditors, legal advisors and other professional advisers.

10.3 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where third parties process personal data on our behalf, we require them to do so only for specified purposes and in accordance with our instructions. Some third parties may, however, process your personal data as independent controllers where permitted or required by law.

11. Data security

11.1 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data we collect. In particular, we use the following measures:

  • (a) storing data on secure infrastructure and cloud hosting platforms;
  • (b) using password protected accounts, authentication and session management controls, and encrypted HTTPS communications; and
  • (c) applying role-based access controls, restricted internal access permissions and contractual protections with third party hosting and AI service providers.

11.2 In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11.3 If there is a personal data breach, we will take appropriate steps to respond to it and will notify the ICO and affected individuals where we are legally required to do so. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further recurrence.

11.4 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website and App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

11.5 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our website and App; any transmission is at your own risk.

12. International transfers

12.1 We may transfer your personal data outside of the UK or the European Economic Area (EEA) where we engage third parties to provide services on our behalf, such as to receive services or deal with payment. Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • (a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • (b) We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Addendum to the European Commission's standard contractual clauses for international data transfers.

12.2 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

13. Data retention

13.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including to provide the App and its features, and for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

13.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

13.3 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

13.4 Where deletion is not possible due to legal, regulatory or contractual obligations, we will explain the reason and, where appropriate, restrict further processing of the data.

13.5 After the relevant retention periods have expired, personal data will be securely erased or anonymised. We may retain anonymised data for research, statistical or product improvement purposes. Anonymised data is not personal data and may be used indefinitely.

13.6 Some content, such as images, scans, try-on content or other uploaded materials, may be deleted automatically after a limited retention period unless you choose to save them to your user profile, in which case we may retain them for longer in line with this policy and our legal, operational and security requirements. Temporary processing assets which are not saved to a user account may be deleted automatically once they are no longer needed for the relevant processing activity.

14. Your legal rights

14.1 You have a number of rights under Data Protection Laws in relation to your personal data. You have the right to:

  • (a) Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • (b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • (c) Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • (d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • (e) You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of marketing’ in section 8 for details of how to object to receiving direct marketing communications).
  • (f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • (g) Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 5 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • (h) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
    • i. If you want us to establish the data's accuracy;
    • ii. Where our use of the data is unlawful but you do not want us to erase it;
    • iii. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • iv. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

14.2 If you wish to exercise any of the rights set out above, please contact us at support@glamifyme.beauty.

14.3 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

14.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

14.5 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

15. Children

We do not knowingly collect personal data from children. The App is intended for users aged 18 or over. If we become aware that we have collected personal data from a child, we will take appropriate steps to delete it.

16. Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

17. Changes to this privacy and cookies policy and your duty to inform us of changes.

17.1 We keep our privacy and cookies policy under regular review. This version was last updated on the date at the header of this policy.

17.2 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.