WellStyle Privacy Policy

1. Introduction

Onelabel AI Ltd (“OneLabel”, “Company”, “we”, “us” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, process, share, and protect your personal information when you use WellStyle — our AI personal stylist, available as the WellStyle apps for iOS and Android (each, the “App”), together with any WellStyle website we operate and related services, features, software, and content (collectively, the “Service”). It is an integral part of our Terms of Use, and by accessing or using the Service, you confirm that you have read, understood, and agree to the practices described here. If you do not agree with this Privacy Policy, you must stop using the Service and may delete your account as described in Section 9.

Quick Summary: We collect the information you give us — your account details, your style quiz answers (including body measurements), the photos you upload, photos of your wardrobe, your chat messages with the AI stylist, and your reactions to outfits — and limited technical information. We use it to provide WellStyle: your style profile, outfit feed, color and body analyses, virtual try-on, 28-day plan, stylist chat and closet. To produce AI results, we send the data a feature needs to our AI providers, Google (Gemini) and OpenAI, who process it on our behalf; the App asks your permission before it does so for the first time. Analysis photos are deleted from our systems after the analysis, a saved try-on photo is kept until you remove it, and deleting your account in the App removes your profile, photos, wardrobe, looks and chats. We do not sell your personal data, and the WellStyle iOS app contains no advertising and no third-party tracking.

2. Definitions

“Personal Data” (or “personal information”) means any information relating to an identified or identifiable natural person. “Processing” means any operation performed on Personal Data, such as collection, storage, use, disclosure, or deletion.

“GDPR” refers to the EU General Data Protection Regulation (EU) 2016/679. “UK GDPR” refers to the UK’s data protection law (the UK Data Protection Act 2018 and retained EU GDPR). “EEA” refers to the European Economic Area (EU member states plus Iceland, Liechtenstein, and Norway); for purposes of this Policy, references to the EEA include the United Kingdom as having equivalent data protection principles. “LGPD” refers to the Lei Geral de Proteção de Dados, Brazil’s General Data Protection Law. “PIPEDA” refers to Canada’s Personal Information Protection and Electronic Documents Act. “AI Providers” means the companies whose AI models power WellStyle’s AI features, described in Section 5. Other capitalized terms used but not defined here have the meanings given in our Terms of Use.

3. Data Controller and Contact Information

For the purposes of applicable data protection laws (such as the GDPR and UK GDPR), the controller of your Personal Data is Onelabel AI Ltd, a company incorporated in the Republic of Cyprus (registration number HE 481834), with its registered office at 75 Prodromou, ONEWORLD PARKVIEW HOUSE, Floor 4, 2063 Nicosia, Cyprus. If you have any questions, requests, or concerns regarding your Personal Data or this Privacy Policy, please contact us by email at support@wellstyle.fashion . Please include “Privacy Inquiry” in the subject line so we can route your request to the appropriate team.

4. Information We Collect

We collect information about you in three ways: (1) information you provide directly to us, (2) information collected automatically when you use the Service, and (3) information from third parties. We limit our collection to what WellStyle needs to work.

4.1 Information You Provide Directly.

Account Data: your name, email address and password. Your WellStyle account is created together with your subscription, and you sign in to the App with its email address and password. We use your email address to create and authenticate your account, send important account messages (such as the link to set your password), and respond to your inquiries. We store passwords using secure hashing (we never keep them in plain text). In the WellStyle iOS app, your sign-in session is kept in your device’s secure storage (the iOS Keychain).

Style Quiz and Profile Data: the answers you give in the style quiz and later in the App — your age range, the body shape closest to yours, your body measurements (your height and, if you choose to give it, your weight), the areas you would like to highlight or downplay, your skin tone, eye and hair color and jewelry preference, the colors you love or avoid, your styles and occasions, where you usually shop, your clothing sizes, and the name you would like us to use. From these answers we calculate your style profile: an estimated color season, your body shape, a body-shape avatar of a similar size, and your style preferences. Weight is optional; we use height and weight only to choose your avatar’s proportions.

Photos You Upload: the photos you choose to take or upload for a color analysis (a photo of your face) or a body analysis (a full-length photo), the photo you save for virtual try-ons (a full-length photo of you, if you choose to try outfits on your own photo rather than on an avatar), and photos you attach to a message to the AI stylist (for example, to ask it to rate a look). Before an analysis photo is uploaded, the WellStyle iOS app checks on your device that it is suitable (for example, that it shows one face and enough light), using Apple’s on-device Vision framework; this check does not send anything to us. We do not use your photos to identify you: we do not perform facial recognition and do not create biometric identifiers.

Wardrobe Data: photos of your own clothes that you add to your closet, the descriptions and tags our AI derives from them (such as category, color and style), the cut-out image we make of each item, the looks you save, and the capsules you build.

Chat Messages: the messages you send to the AI stylist, any photos you attach, and the stylist’s replies, which we keep as your chat history so the stylist can follow the conversation.

Reactions and Progress: the outfits you like, dislike or save, the try-ons you create, your progress through the 28-day plan, and similar activity in the App. We use them to personalize your feed and your plan.

Communications: If you contact us by email or through customer support, we collect the information you provide (such as your name, contact details, and the content of your message) to assist you. A support email you start from the App may include the App’s version, your device model and your account ID, which you can remove before sending.

Payment Information: If you buy a subscription, your payment card details are collected and processed directly by our third-party payment processors (such as Stripe) — we do not receive or store your full card number. We may receive a transaction record (such as your name, the date and amount, and the card type and last four digits) for billing, receipts, and accounting purposes. The App itself has no in-app purchases and processes no payments.

Sensitive Personal Data: We do not seek to collect special categories of data (such as racial or ethnic origin, health, religious beliefs, or sexual orientation). Some information you give us — such as photos of your face and body, your skin tone, and your height and weight — is personal and may be considered sensitive in some places; we use it only to give you style suggestions, never to infer your health, ethnicity or any other special category, and you can delete it at any time. WellStyle is not a health, fitness or medical service; please do not share health information with the AI stylist.

Photos of Your Face and Body, in Plain Words: A selfie is used to estimate your color season from your skin, eye and hair coloring, and a full-length photo is used to estimate your body shape. The photo is sent to our AI provider (Google Gemini, or OpenAI as a backup) and is deleted from our systems as soon as the analysis is done; we keep only the result, such as your color season and body shape, in your profile. We do not create face templates or any other biometric identifiers, and we do not use your photos to identify you.

4.2 Information Collected Automatically.

Device and Technical Information: When the App or any WellStyle website communicates with our servers, we receive technical information such as your IP address, device type, operating system and App version, and the date and time of each request. We use it to operate and secure the Service (for example, to apply rate limits and detect abuse) and to diagnose errors. We do not collect precise geolocation.

Usage Information: We record which features you use and how often (for example, each analysis, try-on or stylist reply), mainly to apply the usage limits of your plan and to understand the reliability and cost of our features. When you delete your account, these records are kept only in anonymized form, without your account ID.

App Analytics and Tracking: The WellStyle iOS app contains no third-party analytics, advertising or tracking software, does not use your device’s advertising identifier, and does not track you across apps or websites owned by other companies. If we add analytics to a future version, we will update this Privacy Policy before we do.

Websites and the Style Quiz: Our website wellstyle.fashion does not use analytics, advertising or other tracking cookies; our hosting provider’s network sets one strictly necessary security cookie on it, described in our Cookie Policy. The style quiz at quiz.wellstyle.fashion, where subscriptions are sold, uses cookies and similar technologies to save your answers, process payments, prevent fraud, measure how the quiz is used and measure our advertising, with partners such as Amplitude, Google and Meta. Our Cookie Policy (https://wellstyle.fashion/legal/en/cookie-policy) lists them and explains your choices. Where the law requires it, we ask for your consent before setting non-essential cookies. We do not respond to browser “Do Not Track” signals, but where required by applicable law we treat recognized opt-out preference signals, such as the Global Privacy Control (GPC), as a request to opt out of the “sale” or “sharing” of personal information and of targeted advertising.

4.3 Information from Third Parties. When you buy a subscription, we receive from our checkout and payment providers the information needed to create your account and activate your plan (such as your name, email address, the plan, and its billing period and status). If you sign in with Apple where it is offered, we receive the name and email address you choose to share with us (which may be an Apple private relay address). Any information we obtain from third parties is combined with the information you provide and treated according to this Policy.

Advertising Attribution: When you reach the style quiz from an ad, we receive and store information that links your visit and purchase to that ad — such as click identifiers (fbclid, fbc and fbp), your email address, IP address and browser type — to measure our advertising. We keep it on our servers for up to 90 days; a copy of the click identifiers and your IP address stays in your browser until you clear it (see our Cookie Policy).

5. AI Features and Our AI Providers

WellStyle’s AI features — the color and body analyses, virtual try-on, the closet’s item recognition and cut-outs, AI-generated looks, and the AI stylist chat — are powered by third-party AI models. To produce a result, our servers send the data that feature needs to one of our AI Providers:

Google (Gemini API): our main provider. It receives the photos you submit for an analysis, your try-on photo together with images of the outfit’s items, photos of the clothes you add to your closet, descriptions of your wardrobe items when you ask for AI-generated looks, and the stylist conversation (your messages, any photo you attach, and a summary of your style profile such as your color season, body shape, sizes and style preferences). Try-on images and cut-outs are created only with Gemini.

OpenAI (OpenAI API): our backup provider. When Gemini does not answer, it may receive the same kind of data for analyses, the check of your try-on photo, closet item recognition, AI-generated looks and the stylist chat.

What We Send: We send only what the feature needs. We do not send your name, email address or password to the AI Providers (unless you type them into a message yourself). The AI Providers process this data on our behalf, as our processors, to return the result to us, under their API terms and data processing terms; their own handling of the data, including any retention for abuse monitoring, is governed by those terms. We do not sell your data to them.

Your Permission: Before the App first sends your personal data — such as a photo, your style profile or a chat message — to the AI Providers, it asks for your permission, once for your account. If you choose “Not now”, the AI feature does not run and nothing is sent; the rest of WellStyle (your feed, your plan and your profile) keeps working, and the App asks again the next time you start an AI feature. You can withdraw your permission at any time in the App’s Settings; AI features will then ask again before sending anything.

AI Results: AI results (such as a color season, a body shape, a try-on image or a stylist reply) are generated automatically and may be inaccurate. They are style suggestions only, and we do not use them to make decisions that have legal or similarly significant effects on you.

6. How We Use Your Information

We process your Personal Data, relying on the legal bases in Section 7, for the following purposes:

To Provide and Maintain the Service: to create and secure your account, authenticate sign-ins, build your style profile, rank your outfit feed, run the analyses, try-ons, closet features and stylist chat you request, unlock your 28-day plan, and perform routine administrative, backup, and security activities.

To Manage Your Account and Provide Support: to administer your account and plan, respond to your requests and support inquiries (which may involve reviewing your account details and relevant logs), and honor your preferences and settings.

To Communicate With You: to send administrative or transactional messages (such as the link to set your password, security and policy notices, and receipts), which you cannot opt out of while you have an account; and, where you have opted in or as otherwise permitted by law, to send marketing communications, which you can opt out of at any time using the unsubscribe link or by contacting us.

To Personalize WellStyle: to tailor your outfit feed, plan and stylist answers to your style profile, your reactions and your wardrobe. We do not use your data for advertising in the App.

To Improve the Service: to analyze usage, reliability and cost trends, fix errors, and evaluate and improve the quality of our features, generally using aggregated or pseudonymized data where feasible.

To Process Payments: to verify subscription payments made outside the App, activate and update your plan, send receipts and renewal notices, and handle billing inquiries and disputes (much of which is carried out by our payment processors on our behalf).

To Enforce Our Terms and Prevent Fraud or Misuse: to apply usage limits, monitor for and investigate violations of our Terms, prevent abuse of accounts and AI features, detect and prevent fraud or security threats, and protect the rights, property, and safety of OneLabel, our users, and others.

To Comply with Legal Obligations: to respond to lawful requests by public authorities or law enforcement, meet record-keeping, tax, and regulatory requirements, and exercise or defend legal claims. We limit any such processing or disclosure to what is necessary and properly authorized.

7. Legal Basis for Processing (EEA, UK, Brazil, and Canada)

If you are in a jurisdiction that requires a lawful basis for processing (such as under the GDPR, UK GDPR, or similar laws), we process your Personal Data only when we have a valid legal basis:

Contract Performance: where processing is necessary to provide the Service you have requested under our Terms of Use (such as creating your account, building your style profile, providing your plan, and running the AI features you start).

Consent: where we ask for it — for example, before the App first sends your personal data to the AI Providers (Section 5), for certain direct marketing, for non-essential website cookies, and for any sensitive data you choose to provide. You may withdraw consent at any time for future processing, without affecting prior processing.

Legitimate Interests: where we have a genuine interest that is not overridden by your rights — for example, to secure and improve the Service, prevent fraud and abuse, and market to existing customers within legal limits. You may object to processing based on legitimate interests in certain cases (see Section 10).

Legal Obligation: where processing is necessary to comply with a legal obligation, such as retaining records for tax purposes or responding to lawful requests.

For Brazilian users, these bases correspond to LGPD legal bases such as consent, performance of a contract, legitimate interests (balanced against your rights), and compliance with legal obligations. For Canadian users (PIPEDA), we generally obtain consent for collection, use, or disclosure except where otherwise permitted by law, and you may withdraw consent for non-essential uses. If you have any questions about the legal basis for any processing, please contact us.

8. How We Share Your Information

We do not sell your Personal Data, and we do not share it with third parties for their own independent marketing purposes. We share information only with trusted parties and only for the purposes described in this Policy:

Service Providers (Processors): companies that perform services on our behalf under contract and may process Personal Data only on our instructions, including: Cloud Hosting and Infrastructure (such as DigitalOcean, which hosts our servers, database and stored photos); AI Providers (Google and OpenAI, as described in Section 5); Payment Processing (such as Stripe, which receives your payment details directly when you buy a subscription and is PCI-DSS compliant); Email Delivery providers (to send account emails and support responses); and Error Monitoring services (to diagnose server errors). We require these providers to protect your information and use it only for the purposes we specify, and we put in place data processing agreements or rely on their data processing terms (including Standard Contractual Clauses where required for international transfers). For the style quiz on our website, these include our payment processor (Stripe), product analytics (Amplitude and Google Analytics) and advertising measurement (Meta).

Retailers: “Shop similar” opens a search for a similar item on a third-party retailer’s website. We do not share your personal data with retailers, but the retailer receives the search, and your visit is governed by the retailer’s own terms and privacy policy.

Legal Compliance and Safety: we may disclose information to courts, law enforcement, government authorities, or other third parties where we have a good-faith belief that disclosure is required or appropriate to comply with the law, respond to valid legal requests, enforce our Terms, or protect the rights, property, or safety of OneLabel, our users, or others.

Business Transfers: if we are involved in a merger, acquisition, reorganization, sale of assets, or bankruptcy, your Personal Data may be disclosed or transferred as part of that transaction, subject to the receiving party agreeing to protect it consistently with this Policy.

Affiliates: we may share information with our current or future affiliates and subsidiaries (under common ownership or control with Onelabel AI Ltd) for purposes consistent with this Policy and under appropriate confidentiality and security obligations. This includes OneLabel Inc., a Delaware corporation (USA), our affiliated billing entity, which processes payments, billing, and related transaction data for the Service.

With Your Consent or at Your Direction: we will share your Personal Data with third parties when you direct us to or expressly consent to such sharing.

9. Data Retention and Deletion

We keep your Personal Data only as long as we need it to provide WellStyle, or as the law requires. In particular:

Analysis Photos: the photo you submit for a color or body analysis is deleted after the analysis job finishes (if our storage fails at that moment, an hourly cleanup deletes it). We keep the result, such as your color season and body shape, in your profile.

Try-On Photo and Try-Ons: a photo you save for try-ons is kept until you remove or replace it in the App, so you can try on more outfits without uploading it again. The try-on images we generate are kept until you delete them or your account.

Wardrobe Photos: the original photo of a clothing item is deleted once its cut-out image exists (or once its processing fails for good). We keep the cut-out, its tags, your looks and your capsules until you delete them or your account.

Chat History: your messages to the AI stylist, attached photos and its replies are kept until you delete your account.

Private Files: your photos, cut-outs, try-on images and chat photos are stored privately and are never public. The App shows them through signed links that expire after 15 minutes.

Account Deletion: You can delete your account at any time in the App (Settings › Delete account, or Delete account on the “No active plan” screen). Deletion removes your account, your style profile and quiz answers, reactions, plan progress, try-ons, analyses, wardrobe, looks, capsules, chats and all your stored photos, and anonymizes your usage records (they are kept without your account ID). Because a photo upload link handed out just before the deletion stays valid for a few minutes, a second sweep deletes any file that reached your account’s storage, about 11 minutes later. Deleting your account does not cancel a subscription bought outside the App; see Section 5 of our Terms of Use.

Other Records: support communications may be retained for up to 2 years; financial transaction records are kept as required by accounting and tax laws (often around 7 years); records of finished background jobs are deleted automatically after 14 days; and server logs are kept only for a short time. Personal Data removed from our live systems may persist briefly in secure backups until those backups are cycled out. If you have questions about retention for a particular type of data, please contact us.

10. Your Privacy Rights

Depending on your location and applicable law, you may have the following rights regarding your Personal Data: the Right to Access a copy of the data we hold about you; the Right to Rectification of inaccurate or incomplete data; the Right to Erasure (deletion), subject to data we must retain for legal or legitimate business reasons; the Right to Restrict Processing in certain circumstances; the Right to Object to processing based on legitimate interests or for direct marketing; the Right to Data Portability (to receive data you provided in a structured, machine-readable format); the Right to Withdraw Consent where processing is based on consent; and the Right to Lodge a Complaint with a data protection supervisory authority (such as your local EU authority, the UK ICO, Brazil’s ANPD, or Canada’s OPC). These rights are not absolute and may be subject to conditions under applicable law.

Exercising Your Rights: you can delete your account and its data yourself in the App (Settings › Delete account, or Delete account on the “No active plan” screen), remove your try-on photo, try-ons, wardrobe items and looks, and withdraw your permission for the AI Providers in Settings. For any other request, contact us at support@wellstyle.fashion and clearly describe your request. For your security, we may need to verify your identity before fulfilling certain requests. We will respond within the timeframe required by law (generally within 30 days, with the possibility of extension). There is no fee unless a request is manifestly unfounded or excessive. You may, where permitted, use an authorized agent, subject to verification. Additional rights apply to users in Brazil under the LGPD (including confirmation of processing, anonymization, blocking, or deletion of unnecessary data, and information about sharing) and to users in Canada under PIPEDA (including access and correction). Even if you are not in a region with specific privacy laws, we will endeavor to honor reasonable requests about your Personal Data.

11. Age Requirements

The Service is intended for adults and is not directed to children. You must be at least 18 years old to use the Service, and we do not knowingly collect personal information from anyone under 18. Do not upload photos of children. If we become aware that we have inadvertently collected Personal Data from a person under 18, we will take steps to delete it. If you believe a minor has provided us with personal information, please contact us at support@wellstyle.fashion and we will investigate and promptly remove the data. We comply with the Children’s Online Privacy Protection Act (COPPA) (which generally applies to children under 13) and similar laws, and we do not sell the personal data of minors.

12. International Data Transfers

Onelabel AI Ltd is established in the Republic of Cyprus, and WellStyle’s servers are hosted in the United States: your Personal Data will be transferred to, stored in, and processed in the United States, as well as other countries where our service providers, including the AI Providers, process data. This means your information may be subject to data protection laws different from those in your home country. When we transfer Personal Data from the EEA, UK, or Switzerland to countries not recognized as providing an adequate level of protection, we rely on appropriate safeguards, such as the European Commission–approved Standard Contractual Clauses (and the UK International Data Transfer Addendum, as applicable), approved frameworks where available, or other lawful bases such as your consent or the necessity of the transfer to perform a contract. By using the Service, you acknowledge that your data may be transferred across borders as described here.

13. California Privacy Rights (CCPA/CPRA and “Shine the Light”)

This section supplements the rest of this Policy and applies to residents of California. In the 12 months preceding the Last Updated date, we have collected the following categories of personal information (as defined by the CCPA, as amended by the CPRA): identifiers (such as name, email address, and IP address); customer records (such as transactional payment records, since we do not store card numbers); characteristics such as your age range; commercial information (such as subscription details); internet or other electronic network activity (device and usage data); audio, electronic, visual or similar information (the photos you upload); physical characteristics you provide (such as your height, weight, body shape and coloring); and inferences (such as your style profile). We collect this information from the sources and for the purposes described in Sections 4 to 6, and we may disclose it to service providers for the business purposes described in Section 8.

Sale and Sharing: We do not “sell” personal information for monetary consideration, and we do not “share” personal information for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA. We do not have actual knowledge that we sell or share the personal information of consumers under 16. California residents have the rights to know, to delete, and to correct their personal information, the right to opt out of any sale or sharing (which we do not engage in; if that changes, we will provide a “Do Not Sell or Share My Personal Information” mechanism), the right to limit the use of sensitive personal information, and the right to non-discrimination for exercising these rights. To exercise your rights, contact us at support@wellstyle.fashion ; we may need to verify your identity, and you may use an authorized agent with proof of authorization. Under California’s “Shine the Light” law (Civil Code § 1798.83), California residents may request information about disclosures of personal information to third parties for their direct marketing purposes; we do not share personal information with unaffiliated third parties for their own direct marketing.

14. Other U.S. State Privacy Rights

Residents of U.S. states that have enacted comprehensive consumer privacy laws — including, among others, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, and Maryland, as well as additional states as their laws take effect — may have rights similar to those described for California in Section 13. Depending on your state, these may include the right to confirm whether we process your personal information and to access it, the right to correct inaccuracies, the right to delete your personal information, the right to obtain a portable copy of your data, and the right to opt out of targeted advertising, the sale of personal information, and certain profiling. As noted above, we do not sell your personal information or use it for cross-context behavioral advertising / targeted advertising as those terms are defined under these laws. To exercise any of these rights, contact us using the information in Section 18; we will respond in accordance with applicable state law, including any right to appeal a denial of your request where your state provides one.

15. Security

We implement industry-standard technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit (TLS); private storage of your photos, reachable only through signed links that expire after 15 minutes; hashed passwords; access controls that limit access to authorized personnel and providers who need it; secure cloud infrastructure with monitoring; and incident-response procedures. However, no method of transmission over the Internet or electronic storage is completely secure, so while we strive to protect your information, we cannot guarantee absolute security. If you have reason to believe your interaction with us is no longer secure, please notify us immediately at support@wellstyle.fashion .

16. Data Breach Notification

In the event of a data breach that compromises your personal information, we will notify you and the relevant authorities as required by applicable law. We will notify you by email to the address associated with your account, or by other reasonable means, within the timeframes required by law (for example, within 72 hours where required), and our notification will describe the nature of the breach, the types of information that may have been affected, and steps you can take to protect yourself.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or operations. If we make material changes to how we handle your Personal Data, we will provide notice before the change takes effect, as required by law (for example, by an in-app notice or an email to the address associated with your account), and we will update the “Last Updated” date above. If any change requires your consent under applicable law, we will obtain it. Your continued use of the Service after the updated Policy takes effect constitutes acceptance of the changes; if you do not agree, you should stop using the Service and may delete your account.

18. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your Personal Data, please contact us. When reaching out by email, please include a clear subject line (such as “Privacy Inquiry” or “Data Subject Request”) and as much detail as possible about your request, along with your contact information. We may need to verify your identity for certain requests.

Data Controller: Onelabel AI Ltd (Registration No. HE 481834)

Address: 75 Prodromou, ONEWORLD PARKVIEW HOUSE, Floor 4, 2063 Nicosia, Cyprus

Email: support@wellstyle.fashion

Billing entity for card payments: OneLabel Inc., a Delaware corporation (USA).

We will respond to your inquiries as soon as reasonably possible, generally within 30 days or sooner if required by law. Thank you for reading our Privacy Policy, and for trusting WellStyle.