Privacy Policy

Effective Date: Last updated + 7days
Last Updated: 2026-1-5

1. INTRODUCTION

Clbak ("we," "us," or "our") values your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and AI-powered styling services (the "Service").

By accessing or using the Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy.

2. INFORMATION WE COLLECT

We collect the minimum amount of information necessary to provide our AI styling services.

2.1. Information You Provide to Us

  • Account Information: When you register, we collect your email address, password, nickname, and (if applicable) Social Media login credentials (e.g., Google/Apple User ID).
  • User Content (Images): To utilize features like "Fit Check", "Try-on" or "Get ideas", you upload photos of yourself or your clothing ("User Content"). We do not collect any text prompts or style keywords from users.
  • Customer Support: Information you provide when contacting us for support.

2.2. Information Collected Automatically

  • Device Information: Device ID, device model, operating system (OS) version, and language settings.
  • Usage Data: Access logs, session time, and interaction history within the App.
  • Transaction Data: Purchase history of Subscriptions or Credits (e.g., transaction ID, date). We do not store your credit card numbers; payment processing is handled solely by the App Store (Apple) or Google Play.

3. BIOMETRIC INFORMATION DISCLAIMER IMPORTANT

While our Service analyzes your photos to provide styling advice or generate virtual try-on images, we do NOT use facial recognition technology for the purpose of uniquely identifying you.

  • We process facial features solely for image synthesis and style analysis.
  • We do not create or store "biometric templates" or "faceprints" for identification or security authentication.
  • The processed data is used specifically for the requested service and is not shared with third parties for their own identification purposes.

4. HOW WE USE YOUR INFORMATION

We use the collected information for the following purposes:

  • Service Delivery: To generate AI outputs (Fit Check, Get Ideas, Try-on), manage your "Digital Wardrobe," and process Credit usage.
  • Service Improvement: To analyze usage trends and optimize our AI algorithms (using de-identified or aggregated data).
  • Account Management: To verify your identity, manage subscriptions, and prevent fraud.
  • Legal Compliance: To comply with applicable laws and regulations.

5. LEGAL BASIS FOR PROCESSING (EEA/UK Users)

If you are from the European Economic Area (EEA) or the UK, our legal basis for collecting and using your personal information is as follows:

  • Performance of Contract: To provide the Service you subscribed to or the features you unlocked with Credits.
  • Consent: We ask for your explicit consent to process your photos for AI generation. You may withdraw this consent at any time.
  • Legitimate Interests: To improve our App security, prevent fraud, and analyze service performance.

6. SHARING OF INFORMATION

We do not sell your personal information. We strictly limit data sharing to the following categories:

  • Service Providers (Sub-processors): We use third-party cloud services to operate the App.
    • Google LLC (Google Cloud & Gemini API): Used for AI image processing and cloud storage.
    • Location: United States.
    • Safeguards: Data transfer is protected via encryption and standard contractual clauses.
  • Legal Requirements: We may disclose information if required by law, court order, or government regulation.

7. INTERNATIONAL DATA TRANSFERS

Clbak is headquartered in South Korea. Your information will be transferred to, stored, and processed in South Korea and the United States (where our AI servers are located).

  • Transferred Data: User Content (Images only).
  • By using the Service, you acknowledge that these countries may have data protection laws different from your jurisdiction. We take appropriate measures, such as encryption and strict access controls, to protect your data during transfer.

8. YOUR PRIVACY RIGHTS

Depending on your location, you may have the following rights:

8.1. EEA/UK Rights (GDPR)

  • Right to Access: Request a copy of your personal data.
  • Right to Rectification: Correct inaccurate data.
  • Right to Erasure ("Right to be Forgotten"): Request deletion of your data.
  • Right to Restrict/Object: Object to processing based on legitimate interests.
  • Right to Portability: Request transfer of your data to another service.

8.2. US State Rights (California/CCPA & Others)

  • Right to Know: Request details about the categories of personal information we collect.
  • Right to Delete: Request deletion of your personal information.
  • Do Not Sell/Share My Personal Info: We do not sell your personal information to third parties for monetary value.

9. DATA RETENTION

We retain your personal information only as long as necessary to fulfill the purposes outlined in this policy.

  • Account Data: Retained until you delete your account (plus a 30-day grace period for fraud prevention).
  • Saved Data (Style Log & AI Results):
    • User Content (Uploads): Images you upload to your "Style Log" or "Digital Wardrobe" (e.g., outfit records).
    • AI Generated Results: Images created by the Service (e.g., Fit Check, Virtual Try-on) that are saved to your gallery/history.
    • Retention Period: Both types of data are retained as part of your account until you delete specific items or delete your account.
  • Temporary Inputs: Images uploaded solely for immediate AI processing (and not saved to your Log) are retained only for the duration necessary to generate results or improve services, after which they are deleted or anonymized.

10. CHILDREN’S PRIVACY

The Service is not intended for children under 13 (or 16 in certain EU jurisdictions). We do not knowingly collect data from children. If we become aware that we have collected such data without parental consent, we will delete it immediately.

11. DATA SECURITY

We implement industry-standard security measures, including SSL encryption for data in transit and restricted access to our servers, to protect your personal information.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of any significant changes via the App or email.

13. CONTACT US

If you have questions about this Privacy Policy or wish to exercise your rights, please contact our Data Protection Officer (DPO) at:

  • Email: contact@clbak.com
  • Address: 81, Neungdong-ro, Gwangjin-gu, Seoul, Republic of Korea