Privacy Policy

Effective Date: October 16, 2025

Contracting Entity / Data Controller: LookSky Pte. Ltd. (“LookSky”, “we”, “our”, “us”)

Address: 250 N Bridge Rd, #12-02, Singapore 179101

This Privacy Policy explains how LookSky collects, uses, discloses, and protects personal data when you use our websites, mobile applications, and related services (collectively, the “Services”).

By using the Services, you agree to this Policy and our [Terms of Service]. If you do not agree, please do not use the Services.

1. Who We Are and What We Do

LookSky operates an AI-enabled fashion discovery and styling platform. We do not manufacture, sell, ship, or accept returns for physical goods. If you purchase a product after leaving our Services, you transact directly with the third-party retailer or brand (“Brand Partner”) under that partner’s own terms and privacy policies.

2. Information We Collect

We collect personal data in three ways: (A) you provide it, (B) we collect it automatically, and (C) we receive it from third parties.

A. Information You Provide

- Account & profile: name, email, username, password (hashed), country or region, and style preferences (e.g., shape, color season, vibe).

- Photos & uploads: images or videos used for Core Style analysis, virtual try-on, or avatar creation.

- Transactions for digital features: purchase of Credits (for digital try-ons only). Payments are processed by PCI-DSS–compliant providers such as Stripe, Apple Pay, or Google Pay; LookSky does not store full card numbers.

- Communications: messages to support, survey responses, or participation in promotions.

- SMS/Calls: we send service or security messages; marketing SMS/calls are sent only with consent and in compliance with Singapore’s Personal Data Protection Act 2012 (PDPA, including Do-Not-Call rules).

B. Information Collected Automatically

- Usage & device data: app interactions, IP address, device identifiers, operating system, browser, crash logs, and referring/exit pages.

- Cookies and similar tech: used for sign-in, preferences, analytics, and advertising (see Section 9).

C. Information from Third Parties

- Brand Partners & affiliate networks: click IDs or attribution data when you buy from a Brand Partner.

- Social/login providers: limited profile information when you sign in with Apple, Google, or another provider.

- Advertising & analytics partners: aggregated insights, audience reach, and campaign performance data.

3. Special Processing: Photos & AI Functions

We use AI/ML (“AI Functions”) to analyze photos you upload for Core Style analysis, virtual try-on, or personalized recommendations.

We and our vetted vendors process this content only to operate, secure, and improve these features.

Model training. We do not use your photos or other personal data to train publicly available AI models.

Our AI vendors are contractually restricted from using your personal data to train their foundation models unless we explicitly state otherwise and obtain your consent.

Photo retention & deletion. Photos remain securely stored in your account to support avatar history.

You can delete photos anytime in the app or by emailing us. They are permanently removed from active systems within 30 days, subject to safety, fraud-prevention, or legal-hold requirements.

LookSky does not sell your images or body data.

4. Location Data

If you enable location services, we may use approximate location to personalize recommendations (for example, seasonal or weather-based outfits).

You can disable location access in your device settings.

5. How We Use Information

We use personal data to:

- Operate, secure, and improve the Services and AI Functions.

- Process one-time Credit purchases (no subscriptions).

- Communicate with you, provide support, and send service updates.

- Send marketing messages (with your consent where required).

- Attribute clicks and commissions with Brand Partners and affiliate networks.

- Detect, prevent, and respond to fraud or abuse.

- Comply with legal obligations and enforce our Terms.

- Generate aggregated or de-identified analytics to understand usage trends.

5A. Sensitive Information

When we process sensitive information (such as body measurements or imagery that may reveal biometric identifiers), we do so only to deliver the Services you request, ensure integrity and security, prevent fraud, or as otherwise permitted by law.

We do not use or disclose sensitive information for unrelated purposes without your consent.

Where applicable, you may exercise a Right to Limit such use by contacting legal@looksky.ai.

6. When We Share Information

We share personal data only as described below:

- Service providers and subprocessors: vetted vendors for hosting, AI processing, analytics, payments, communications, and support.

They act under written contracts limiting use of personal data to providing services for LookSky.

A current list of subprocessor categories is available at [looksky.ai/legal/subprocessors].

- Brand Partners & affiliate networks: to track clicks and purchases for attribution. Each Brand Partner’s own privacy policy governs its site and data collection.

- Advertising & social platforms: for audience matching and performance measurement (e.g., hashed emails).

- Corporate transactions: in case of merger, acquisition, or sale of assets.

- Legal requests: see Section 12 below.

- Affiliates: companies under common ownership that follow this Policy.

We do not sell personal data as commonly defined under privacy laws. Some ad-tech sharing may be considered a “sale,” “share,” or “targeted advertising”; users have opt-out rights described in Section 14.

7. Payments and Credits

- Credits are one-time, non-refundable (unless required by law), non-transferable, and have no cash value.

- There are no subscriptions; you’re charged only when you authorize a purchase.

- Payments are processed by compliant third-party processors. LookSky never stores full card details.

8. Children

The Services are for users 13 and older (or the minimum age of digital consent in your country).

Users 13–17 must have parental permission, and their parent/guardian is responsible for their use.

We do not knowingly collect data from children under 13.

If you believe we have such data, contact legal@looksky.ai and we’ll delete it.

9. Tracking Technologies (Cookies & SDKs)

We use cookies, mobile SDKs, pixels, and similar technologies (“tracking technologies”) to operate, analyze, and improve the Services.

These technologies collect information such as device identifiers (for example, IDFA or GAID), app usage data, and interaction metrics to:

- Keep you signed in and secure your session

- Measure performance and fix issues

- Personalize recommendations and content

- Attribute affiliate clicks or ad conversions

Where required, we obtain your consent through your device or app-store privacy settings (for example, Apple’s App Tracking Transparency framework).

You can control these settings on your device at any time:

- iOS: Settings → Privacy → Tracking

- Android: Settings → Privacy → Ads → Delete or reset advertising ID

Disabling tracking may limit personalization and measurement features but won’t affect core functionality.

10. Retention and Deletion

We retain data only as long as necessary to provide the Services and for legitimate business, legal, or security purposes, then delete or de-identify it.

To delete your account:

1. Go to the “Me” tab in the LookSky app.

2. Tap the Settings (⚙️) icon.

Select My Account → Delete Account, and confirm.

Your account and associated data will be permanently deleted from active systems within 30 days, subject to legal or safety retention requirements.

11. Security

We use technical and organizational measures—encryption in transit, access controls, firewalls, and monitoring—to protect personal data.

No system is 100% secure; please use a strong, unique password and keep it confidential.

12. Lawful Requests

We may disclose personal data in response to valid and proportionate legal requests (for example, court orders or government investigations) after internal review.

Where permitted by law, we will notify affected users before disclosure.

13. Singapore PDPA

We collect, use, and disclose personal data in accordance with the Personal Data Protection Act 2012 (PDPA).

You may request access to or correction of your personal data by emailing legal@looksky.ai.

We retain data only as long as reasonably necessary for the purposes described in this Policy and applicable law.

14. Your U.S. State Privacy Rights

Residents of certain U.S. states (including California, Colorado, Connecticut, and Virginia) may have rights to:

- access, correct, delete, or obtain a portable copy of personal data; and

- opt out of (i) the “sale” of personal data, (ii) “sharing” for cross-context behavioral advertising, and (iii) targeted advertising.

LookSky does not sell personal data for money.

Some audience-matching and ad measurement may be treated as a “sale,” “share,” or “targeted advertising” under certain laws.

You can exercise these rights via our [Privacy Choices] page, recognize Global Privacy Control (GPC) signals in supported browsers, or email legal@looksky.ai.

We will not discriminate against you for exercising these rights.

15. Automated Decisions

We use automated processing to personalize recommendations and styling results.

These automated processes do not produce legal or similarly significant effects.

You can adjust preferences or contact support if you disagree with a recommendation; where required by law, you may request human review.

16. International Transfers

We operate globally using reputable cloud providers and service partners.

Your data may be transferred to and processed in countries other than where you reside.

We implement appropriate safeguards consistent with applicable law to protect such transfers.

17. Third-Party Sites and Social Features

Our Services may contain links to Brand Partners or other third-party websites.

We do not control those sites and are not responsible for their privacy practices.

Your use of third-party sites is governed by their own policies.

18. Governing Law and Dispute Resolution

This Policy is governed by the laws of Singapore and follows the dispute-resolution process in our Terms of Service (including SIAC arbitration and individual-only proceedings).

19. Changes to This Policy

We may update this Policy from time to time.

If we make material changes, we’ll notify you by email or in-app notice.

Your continued use after the effective date means you accept the updated Policy.

20. Contact Us

LookSky Pte. Ltd.

250 N Bridge Rd, #12-02, Singapore 179101

Email: legal@looksky.ai