Privacy Policy

Issued: December 01, 2024

1. Introduction

Your style is a reflection of you – unique, bold, and ever-evolving. At Zhoosh, we understand that feeling confident in your look is everything. But shouldn't feeling confident about your privacy be just as easy? That's why we've created this Privacy Policy ("Privacy Policy", "Policy"), your essential guide to how Zhoosh handles your information.

Zhoosh Sp z o.o. (“Zhoosh”, “Company”, “we”, “our”, or “us”) operates the Zhoosh application (“App“) and the website https://www.zhoosh.ai/ and all subdomains (“Website”, collectively with App “Service”). All references to “you” or “your” as applicable, mean the person who accesses, uses, or participates in the Service.

This Privacy Policy helps you understand the information we collect, store, use, transfer and share whenever you use our Service. You are not legally required to provide us with Personal Information, but without it we will not be able to provide you with the full range or with the best experience of using our Service.

The Policy is integrated into and forms part of the Company's Terms of Use. Any term not defined in the Privacy Policy shall have the meaning ascribed to it under the Terms of Use.

We encourage you to take a look at the full Policy below and make sure you fully understand and agree to it. By using our Service, you signify your acceptance of our Policy. If you do not agree to the terms of this Policy, please do not use the Service. Your continued use of the Service following the posting of changes to this Policy will mean that you accept such changes.

2. Data We Receive

To provide the best experience with the Service, we must process information about you. The types of information we collect depend on how you use the Service.

2.1 Data You Provide

Here is a breakdown of the information we receive directly from you:

Account Data: To get started, we'll need some essential details from you. This may include, but not limited to your name, e-mail address and location (for security), birthday (for age verification), a username (for identification within the Service) and other information. You can also choose to share additional information, e.g. profile picture (for visual representation), or some information about you, your style, fashion and other preferences, or social media identifiers (for standing out and enjoying specific content), or other.
Content Data: We receive the content you create on our Service. This may include pictures, photos, videos, texts, comments, chat messages, tags, links and other materials. You own your content, but remember: others might screenshot or share it beyond the Service, so be mindful of what you post.
Communication With Us: We collect information when you interact with us for various reasons, such as reporting a problem, sharing your thoughts in a survey, providing feedback, requesting assistance, exercising your rights, or other. This information may include details from your message, any photos/ pictures you send us, identifiers (name, e-mail address, or other), or other information you provide.

2.2 Data We Collect

Here is a list of the information we may receive through your use of our Service:

Connection Details: We may collect your IP address, account creation date, login history, session duration, terminal equipment and port, operating system, system configuration data, viewed pages and content, mobile advertising IDs (e.g.,Apple IDFA), and device identifiers (e.g., IDFV for iOS).
Device Info: We may track the information, such as your device type, operating system version, language preference, and other.
Device Setting Data And Cookies: You may choose to allow us to receive information through device settings you turn on, camera, or photos, as well as share data from cookies stored on your device, including cookie IDs and settings.
Interaction Data: We may analyze your actions and their timing, such as following/unfollowing, saving/removing from favorites, viewed content, content interactions (reactions, supporting others' comments), content creation (posts, comments, chat messages), other performed actions, deletions, hidings, reports, screenshots, sharing to external platforms, crashes, event logs, and other.
Actions Of Others: We may also receive and analyze content, communications, and information that other people provide when using our platform. This may include information about you, such as when others react, support, or comment on your content, save it to favorites, hide or report it, or send you a chat message.
Transaction Data: We exclusively use Apple Pay for payments, we do not collect or store any of your personal financial information, such as credit card numbers or bank account details. When you make a purchase using Apple Pay, your payment information is processed by Apple. Apple's separate policies apply to your transactions, and the Company does not control such policies. We may only receive limited information about the transaction, such as the date, time, amount of the purchase, and other relevant details.

2.3 Personal Vs Non-Personal Information

Some information we may receive about you is Personal Information, while other information is Non-Personal Information.

Personal Information is any information that can reasonably identify you (e.g., your email address or name). Non-Personal Information does not identify you and might include aggregated usage data or technical device information (e.g., your browser or operating system).

We may process, use, or share Non-Personal Information, aggregated data, or Personal Information in a non-human-readable format (like anonymous or aggregated data about how our community uses the Service). This helps us gather statistics for business and marketing analysis, plan and execute marketing campaigns, improve our Service, and enhance your user experience. We may anonymize or de-identify information collected through the Service or other means to prevent it from personally identifying you. We can use or share this anonymized information without restrictions, including for advertising or marketing. If we combine Personal and anonymous information, the combined data will be treated as Personal Information as long as they remain linked.

3. Tracking Technologies

When you visit or access the Service, we may use cookies, pixels, beacons, local storage, and similar technologies ("Tracking Technologies"). These may allow us to automatically collect the information about you, your device, and your online behavior to enhance your navigation, improve the performance, perform analytics, customize your experience, and offer you tailored content and advertisements that better correspond with your interests.

3.1 What Types Of Tracking Technologies We May Use

Strictly Necessary Tracking Technologies: Automatically placed on your device when you access or take certain actions. These Tracking Technologies are essential for navigating and using the features, so we do not need your consent to use these Tracking Technologies.
Tracking and Advertising Tracking Technologies: Information about your browsing habits to make advertising more relevant to you and your interests. They may be also used to limit the number of times you see an advertisement and to measure the effectiveness of an advertising campaign. They may remember the websites you visit, and this information is shared with other parties such as advertisers and/or publishers. Publishers, advertisers, and third-party ad networks may also utilize Tracking Technologies or similar technologies to deliver ads and monitor their performance. The collection of information through Tracking Technologies by such third parties is governed by their own privacy policies/cookies policies and principles, which the Company does not control.
Functionality Tracking Technologies: Remembering choices you make (such as your language) and providing enhanced and personalized features. For example, they may be used for authentication (to remember when you are logged in).
Performance Tracking Technologies: Information about your online activity (for example, the duration of your visit), including behavioral data and content engagement metrics. They may be used for analytics, research, and to perform statistics (based on aggregated information).

3.2 How And By Whom Tracking Technologies Are Stored On Your Device

We may store Tracking Technologies on your device when you visit or access our Service ( "First Party Tracking Technologies"). Additionally, Tracking Technologies may be stored by other third parties, such as our analytics service providers, business partners, and advertisers, who run content on our Service ("Third Party Tracking Technologies"). Both types of Tracking Technologies may be stored either for the duration of your visit or for repeated visits.

You can manage and control your Tracking Technologies settings. For example, you can change your browser settings to send a "Do-Not-Track" signal. In such a case, your browser will send us a special signal to stop tracking your activity. However, please note that certain features of the Service may not work properly or effectively if you delete or disable cookies.

To learn more about how to manage your cookies, below is a list of useful links that can provide you with more information on how to manage your cookies:

You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party web pages:

You can withdraw your consent to personalized advertising experience on your device at any time by using your device settings. On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).

4. Conditions For Processing Personal Information

We would like to outline the purposes and legal grounds for processing your Personal Information.

Purpose
Legal basis
Provision of our Service; support and customer relations. We may use your Personal Information, such as your name and email address, for consumer services purposes. This includes, for example, managing your account, operating the Service, and responding to your inquiries.
The legal bases for processing this data are the performance of our contractual obligation towards you (Art. 6.1(b) GDPR); your consent (Art. 6.1(a) GDPR); compliance with our legal obligations (Art. 6.1ca) GDPR); and our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are enforcing our policies, providing the Service.
Improving our Service. We may collect and analyze information about you and your usage of the Service to improve the usability and effectiveness of the Service.
The legal bases for processing this data are our legitimate interests (Art. 6.1(f) GDPR), in this case – providing and improving our Service.
Marketing, advertising and analytics. We may use your Personal Information in order to provide you with personalized advertisements, to market the Service and to gather aggregate usage information and analytics.
The legal basis for processing this data are your consent (when required) and our legitimate interests (Art. 6.1(a), 6.1(f) GDPR). Our legitimate interests in this case are providing you with tailored services, content and advertisements that better correspond with your interests and to promote our Service.
Dispute resolution and protection of our legal claims. We may collect your Personal Information in order to investigate violations to our policies, enable us to resolve disputes in connection with your use of the Service and to establish and defend our legal claims.
The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are to establish and defend our legal claims.
Corporate transactions. We may share your Personal Information with a potential purchasers, successors or investors in the Company or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to the Company.
The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR), in expanding and building our business.
Prevention of fraud. We may process your Personal Information to detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Service, including by identifying risks associated with your activity on our Service.
The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are to protect our Company and customer against fraud.
Compliance with applicable laws. We may process your Personal Information to comply with our various legal obligations.
The legal basis for processing this data is to comply with our various legal obligations and our legitimate interests (Art. 6.1(f) GDPR).

5. Data Sharing

We may only share your Personal information when it's absolutely necessary: either when it is essential to operate the Service or when required by law. Here are the limited situations where we might share your Personal Information:

Zhoosh Team: Authorized team members may access your information for limited purposes, e.g. analyzing performance, addressing issues, providing support, and other, which helps keep the Service running smoothly for you.
Other Users: When you share profile information (username, name, gender, location, profile picture, description, and other) and content (posts, texts, tags, comments, reactions, supporting comments, and other) on the platform, it becomes visible to the entire community.
Service Providers: We may engage with subcontractors and third-party service providers, including (but not limited to) those for cloud computing, hosting, technical support, payments, notifications, publishing, content sharing, user analytics, research, marketing, security management, and fraud prevention, so we share data with them only to the extent necessary to fulfill their specific tasks.
Auditors, legal, financial and other advisors: We may share your information with professional advisors who assist us in running our business, including legal, compliance, audit, business analysis, and other related areas.
Governmental and regulatory bodies: We may be required to share information with authorities in response to legal requests, security concerns, or users protection in accordance with applicable laws and regulations.
New business owners: In the event of a corporate transaction (e.g. sale of substantial part of business, merger, reorganization, bankruptcy, consolidation, asset sale or transfer in the operation), your information may be shared with potential purchasers, successors or investors, but this Privacy Policy will still apply.

6. International Data Transfers

We may transfer or disclose your Personal Information to our subsidiaries, affiliates, subcontractors, or other trusted third-party service providers located in various jurisdictions worldwide to fulfill the purposes described in this Policy. Your Personal Information may be stored and processed in any location where we or our partner have facilities.

When transferring data, we ensure that appropriate measures are in place to protect your information in accordance with this Policy and applicable laws.

7. Third Party Collection Of Data

This Policy only addresses the use and disclosure of information we receive about you. If you share information with any third parties through our Service or other sites, different privacy rules may apply. For example, when making a payment through Apple Pay, Apple may collect your information according to its separate policies. Apple may also provide certain of your details to us.

This Policy does not cover the practices of companies we don't own or control, or individuals we don't employ or manage, including any third parties we might share information with under this Policy. The Service may connect you to third-party websites, apps, or services (directly or indirectly), but we are not responsible for their privacy practices or content. These third-party services might collect Personal Information from you, so we recommend reviewing their privacy policies carefully.

8. Retention of Personal Information

If you have an account with our Service, we will retain your Personal Information for the duration of its active status (i.e., that your account has not been deleted by you or terminated by us). Additionally, we may keep your information for extended periods if required for legal reasons, fraud prevention, or record-keeping purposes.

9. Children's Privacy

We never knowingly or willingly collect Personal Information from children under thirteen (13) years old. Depending on where you live, if you are under the Age of Consent in your jurisdiction, a parent or guardian must consent to your use of the Service. Children under thirteen (13) should not use our Service.

If we discover that we have collected Personal Information from someone below the Age of Consent without parental or guardian consent, the Company will take appropriate steps to delete this information, unless required by law to retain it. If you are a parent or guardian of a child under the Age of Consent, please contact us at support@zhoosh.ai to have that child’s account terminated and the Personal Information deleted.

10. Your Rights

If you reside in the EU or in other locations that provide you with the below rights, you may:

Access or delete any Personal Information relating to you;
Update or correct your Personal Information if you believe it is incorrect;
Request restrictions on further use of your Personal Information;
Receive the Personal Information you provided to us in a machine-readable format;
Object to the processing of your Personal Information (such as for marketing purposes);
Withdraw your consent for processing activities that rely solely on your consent, not on other legal grounds;
Avoid being subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significant affects you, except where such processing is needed to provide the Service to you, or based on your explicit consent.

To exercise these rights, you may contact us at support@zhoosh.ai. Please note that these rights are not absolute and requests are subject to applicable legal requirements. We may also correct, complete, or remove incomplete or inaccurate information at any time and at our discretion.

11. How to Delete Your Information

You can request account deletion within your Profile Menu by clicking the 'Delete Account' button. When you submit an account deletion request, we will completely delete your account along with all Personal Information. Information that others have shared about you isn't part of your account and won't be deleted.

Please note that all account deletion requests are subject to information retention policy, and the Company reserves the right to retain certain Personal Information for the purpose of meeting its legal obligations, for fraud prevention or record keeping purposes.

Deletion requests are processed within thirty (30) days. You can reactivate your account within this period. After thirty days, your account and Personal Information will be permanently removed. If you choose to delete your data now, your account and associated Personal Information will be permanently removed. In such a case, account reactivation will not be possible.

12. How We Keep Your Information Secure

We take great care in implementing and maintaining the security of the Service and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to correctly use the information we collect. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Service, and we make no warranty, express, implied or otherwise, that we will prevent such access.

13. Changes to the Privacy Policy

We reserve the right to change this Policy at any time, so please re-visit this page frequently. Zhoosh may provide you with notices regarding changes to the Privacy Policy by email, via the Service or postings on our Website: https://www.zhoosh.ai/. Notice will be deemed given twenty-four (24) hours after the email is sent. Updated Privacy Policy posted on the Website or notice sent via the Service is deemed given ten (10) days following the initial posting. Zhoosh reserves the right to determine the form and means of providing notifications to our users. Your express acceptance or continued use of the Service after the applicable notice period shall constitute your acceptance to the changes.

14. Contact Us

If you have any questions about the Privacy Policy or the Service, please contact us via email at support@zhoosh.ai.

You may also send us a letter to:
Zhoosh Sp z o.o.
Adama Branickiego 21/U3
02-972 Warsaw
Poland

We will respond to inquiries within a reasonable timeframe. Feel free to reach out at any time.

15. California Residents

This part of the Policy supplements the information contained in the above Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, “CCPA“ ).

15.1 What Information We Process

In the preceding 12 months, we have collected and/ or disclosed the following categories of Personal Information:

Category of Personal Information Collected
Personal Information Collected
Categories of recipients to whom Personal Information was disclosed
Identifiers
Full name, alias, email address, username, birthdate, IP address, MAC, UDID
Cloud service providers
Analytics providers
Other service providers
Protected classification characteristics under California or federal law.
Sex (gender)
Cloud service providers
Analytics providers
Other service providers
Internet or Other Electronic Network Activity Information
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Cloud service providers
Analytics providers
Other service providers
Geolocation Data
Geolocation
Cloud service providers
Analytics providers
Other service providers
‍

15.2 Sources of Personal Information

In the 12 preceding months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

Consumer directly;
Payment processors.

15.3 Sale of Personal Information

We do not "sell" Personal Information about our users as most people would typically understand that term. However, we may share your Personal Information by disclosing it to a third party for a business purpose.

15.4 Your Rights under the CCPA

The CCPA provides consumers with specific rights regarding their Personal Information. We would like to describe your CCPA rights and explain how to exercise those rights:

Request to know/ access: You may request, up to twice every twelve (12) months, that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business or commercial purpose for selling your Personal Information, if applicable.
Request deletion: You have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.
Request Opt-Out: In the event that we sell your Personal Information, you have the right to submit a request to opt-out of the sale of your Personal Information. You may change your decision at any time and permit us to sell your Personal Information. After you opt-out, we may continue to share some Personal Information with our partners (who will function as our service providers in such instance) to help us perform business-related functions such as, but not limited to, providing the Service, ensuring that the Service is working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud.
Have right to non-discrimination: You have the right to be free from any discrimination for exercising your rights under the CCPA. Should you exercise any of your rights under the CCPA, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request. However, in some circumstances we may not be able to provide a service if you choose to delete your Personal Information.

15.5 Exercising Your Rights

You can exercise your rights by submitting a verifiable consumer request to our physical address (as written above in the "How to contact us" section). You can also contact us via email: support@zhoosh.ai. You will need to specify “California Privacy Rights Request” in the subject line of the email, and also include your name, street address, city, state, and ZIP code.

Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.

The request must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. It also must describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

15.6 Designating Agents

You can designate an authorized agent to make a request under the CCPA on your behalf if the authorized agent is a natural person or a business entity registered with the Secretary of State of California and if you sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your rights, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information above.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.