1. Introduction

Palantrix LLC ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website, use our styling services, purchase subscriptions or consultations, and tell you about your privacy rights and how the law protects you.

This policy applies to all users of our services, including those in the European Union (GDPR), California (CCPA/CPRA), and other jurisdictions with applicable data protection laws.

2. Data Controller

Palantrix LLC is the data controller responsible for your personal data.

• Email: contactnaacloset@gmail.com
• Website: naacloset.com

3. Data We Collect

We collect, use, store and transfer different kinds of personal data about you, grouped as follows:

Categories of Personal Information (CCPA)

Detailed Data Types

• Identity Data includes first name, last name, username or similar identifier. We also collect authentication data when you sign in using Google Sign-In.
• Contact Data includes email address and telephone number.
• Financial Data includes payment card details and billing information. Note that we do not store sensitive payment information directly on our servers. All payment transactions are processed through third-party payment providers (Stripe, Apple Pay, PayPal, Google Pay).
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Wardrobe Data includes photographs of your clothing, accessories, shoes, and other personal items you upload to the platform.
• Styling Data includes notes, style preferences, body measurements, sizes, budget constraints, and feedback you provide for styling sessions.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
• Usage Data includes information about how you use our website, upload frequency, and interactions with stylists.

4. Legal Basis for Processing (GDPR)

We process your personal data under the following legal bases:

• Contract Performance (Art. 6(1)(b)): Processing necessary to provide you with our styling services, manage your account, and fulfill subscription obligations.
• Legitimate Interests (Art. 6(1)(f)): Processing necessary for our legitimate business interests, such as improving our services, fraud prevention, and marketing (where you haven't opted out).
• Consent (Art. 6(1)(a)): Where you have given explicit consent, such as for marketing communications, analytics cookies, and sharing data with stylists.
• Legal Obligation (Art. 6(1)(c)): Processing necessary to comply with legal requirements, such as tax and financial regulations.

5. How We Use Your Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To provide the styling services you requested, including sharing your Wardrobe Data and Styling Data with assigned stylists to generate outfit recommendations.
• To process your payments for subscriptions or one-time consultation fees.
• To manage your account and relationship with us.
• To improve our website and services through analytics (Google Analytics, Vercel Analytics).
• 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.
• Where we need to comply with a legal or regulatory obligation.

6. Sharing of Data

With Stylists: By using our services, you explicitly consent to the sharing of your uploaded photographs, notes, and profile information with stylists utilizing our platform. These stylists require access to this data to create outfit collages, provide shopping links, and offer styling advice.

With Third-Party Service Providers: We may share your data with third-party service providers who perform services on our behalf, such as:

• Payment Processors: Stripe, Apple Pay, PayPal, and Google Pay to facilitate secure payments.
• Authentication Services: Google Sign-In for secure user authentication.
• Cloud Infrastructure: Supabase (database), Vercel (hosting) for data storage and website operation.
• Analytics Providers: Google Analytics and Vercel Analytics to help us understand how our website is used and improve user experience.

We Do Not Sell Your Personal Information: We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:

• Account Data: Retained while your account is active and for 30 days after deletion request.
• Wardrobe & Styling Data: Retained while your account is active.
• Transaction Data: Retained for 7 years for tax and legal compliance.
• Analytics Data: Aggregated data may be retained indefinitely; individual tracking data is deleted after 26 months.
• Communication Records: Retained for 3 years for customer service purposes.

8. International Data Transfers

Your data may be transferred to and processed in countries outside of your home country, including the United States. When we transfer data internationally, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data processing agreements with all third-party providers
• Compliance with EU-US Data Privacy Framework where applicable

9. Your Privacy Rights

GDPR Rights (EU/EEA Residents)

• Right to Access (Art. 15): Request a copy of your personal data.
• Right to Rectification (Art. 16): Correct inaccurate personal data.
• Right to Erasure (Art. 17): Request deletion of your data ("right to be forgotten").
• Right to Restriction (Art. 18): Restrict processing of your data.
• Right to Data Portability (Art. 20): Receive your data in a machine-readable format.
• Right to Object (Art. 21): Object to processing based on legitimate interests.
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.
• Right to Lodge a Complaint: File a complaint with your local supervisory authority.

CCPA/CPRA Rights (California Residents)

• Right to Know: Request disclosure of personal information collected, used, and shared.
• Right to Delete: Request deletion of your personal information.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt-Out: Opt out of the sale or sharing of personal information.
• Right to Limit Use: Limit use of sensitive personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights.

How to Exercise Your Rights

You can exercise your privacy rights through our Privacy Rights Center or by contacting us at contactnaacloset@gmail.com.

Response Time: We will respond to GDPR requests within 30 days and CCPA requests within 45 days. Complex requests may require an additional 30-45 days with notice.

Verification: We may need to verify your identity before processing your request. For CCPA requests, you may designate an authorized agent by providing written authorization.

10. Cookies and Tracking

We use cookies and similar technologies to enhance your experience. You can manage your cookie preferences through our cookie consent banner or in your browser settings.

• Strictly Necessary: Required for website functionality (always active).
• Analytics: Help us understand how visitors use our site.
• Marketing: Used for personalized advertising.
• Functional: Remember your preferences and settings.

Do Not Track: We honor browser Do Not Track signals when enabled.

11. Children's Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If we discover that a child under 16 has provided us with personal information, we will delete such information from our systems immediately.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at contactnaacloset@gmail.com.

12. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. These measures include:

• Encryption of data in transit (TLS/SSL) and at rest
• Row Level Security (RLS) policies for database access control
• Regular security audits and vulnerability assessments
• Access controls limiting employee access to personal data
• Secure authentication through established providers (Google Sign-In)

13. Automated Decision Making

We may use automated processes to help stylists understand your preferences based on your uploaded wardrobe and stated preferences. However, final styling decisions are made by human stylists, not automated systems. You have the right to request human review of any automated processing that significantly affects you.

14. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. For significant changes, we will provide additional notice through our cookie consent mechanism, which will prompt you to review and accept the updated terms.

15. Contact Us

If you have any questions about this privacy policy or our privacy practices, please contact us:

• Email: contactnaacloset@gmail.com
• Privacy Rights Center: naacloset.com/privacy-rights

For EU residents: You have the right to lodge a complaint with your local data protection authority if you believe we have not handled your data appropriately.