Refashion Policy

Welcome to Refashion, a Cosmos Oyun Yazilim Danismanlik Sanayi Ticaret Limited Sirketi app. Refashion (“App” / “Refashion”) and all of its associated websites and services (“Services”) are owned and operated by Cosmos Oyun Yazilim Danismanlik Sanayi Ticaret Limited Sirketi (“Cosmos”).

At Cosmos, your privacy is of the utmost importance to us. To provide our users with the highest levels of data protection and assurance that we will not misuse your information, Cosmos is compliant with the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) as stated below.

This Privacy Policy governs the use of Refashion, the Cosmos website, and your use of any of our Services provided through the same. When using or accessing the Cosmos website and Services, you agree to be bound by the terms within this Privacy Policy and the Terms of Use policy. This policy may refer to users as “you” or “user” and may refer to Cosmos as “us,” “we,” or “our.” If you do not agree to the terms within this Privacy Policy and the corresponding Terms of Use, do not access or use Refashion, the Cosmos website, or Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. By accessing or using the Website, the App, and Services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Website, the App, and the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

A small note on how the AI Photo Generator feature works:

1. Refashion uses a pre-trained Neural Network Model to allow users to generate personalized AI photos (“Photos”).
2. Users upload their face data and select their preferred style.
3. The model uses the uploaded face data to generate the Photos.
4. After the Photos are generated, the uploaded face data is permanently deleted from our servers within 14 days.
5. We do not use your Personal Data to generally train and/or create our separate artificial intelligence/products.

We do our best to moderate the parameters of the model, however, it is still possible that you may encounter content that you may see as inappropriate.

We also encourage you to get acquainted with our Terms of Use to understand how we provide services to you.

We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy explains what we do with your Personal Data (as defined below) and allows you to manage your Personal Data effectively.

Information collected and stored by Cosmos

In order to carry out the Services of Cosmos and to provide a great user experience, we will collect and store the following information about you:

Personal Information, that may be used to identify you as an individual

(Personal information is any information related to an identified or identifiable natural person).

• First and Last Name;
• Profile Picture or Avatar;
• Profile Information from Third-Party Social Media and Payment Websites;
• Your Email Address;
• IP Address;
• Anonymous website activity logs

Other information that may be linked to personal information

• Searches Completed through the Website;
• Preference Settings;
• Stored Information or Files Created or Stored on Website or through the Services;
• Any Emails You Send to Cosmos;
• Times of Access to Website;
• Websites that Referred to Cosmos;
• Your Operating System Type

How we collect your personal information

Cosmos collects personal information from you upon your registration for our Services and upon your log-in to or accessing of Refashion, our Website or Services. We collect any additional information about you when you interact with us electronically or in person, when you access Refashion, or our Website and when we provide our Services to you.

It may not be readily apparent to you when such data is being collected. For instance, when you visit our Website or download or use Refashion, your IP address is collected so that we know where to send information you are requesting. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.

How we process your face data

In order to generate AI Photos, you have to upload your face data to Refashion. At this point, your face data is stored on our cloud storage (provided by Cloudflare R2). The model uses the uploaded face data to generate the Photos. After the successful generation of Photos, your original face data is permanently deleted from our servers within 14 days. Your generated Photos are stored on our cloud storage so that they remain accessible only from your device in Refashion until you decide to delete them or until they are automatically deleted after 14 days.

How we process your photos

With regard to your photos, most processing activities take place on your device. However, there are exceptions to this rule when you generate AI photos. When you generate AI photos, the photos that you have uploaded to Refashion or those selected by Refashion from your camera roll/library are stored on our cloud storage (provided by Cloudflare R2). The model uses the uploaded photos to generate the AI Photos. After the successful generation of Photos, your original photos are permanently deleted from our servers within 14 days. Your generated Photos are stored on our cloud storage so that they remain accessible only from your device in Refashion until you decide to delete them or until they are automatically deleted after 14 days.

Notwithstanding anything to the contrary elsewhere in this Privacy Policy:

• We do not use photos and Photos to identify any individual user;
• We do not use your photos, videos, or Photos for authentication, advertising, or marketing purposes and we do not share them with any third parties without your prior consent;
• We do not use your photos and Photos for the purposes of identifying anonymous users and reconstructing their user profiles.

Why we collect your personal information

We process your personal information because we have a contractual obligation with you. When you create an account to use Refashion (required for any paid subscriptions), or our Website and Services, and agree to our Terms of Service, a contract is formed between you and us. In order to carry out our contractual obligations, we need to process the information you provide, which also includes personal information. Even if there is no direct contractual obligation between us, we may process your information based on your explicit consent you have provided (to us or a third-party data controller) for the processing of that information.

How we use your personal information

• To administer your account with us and provide you with our Services;
• To respond to your inquiries and deliver reminder e-mails to you;
• To provide you with information regarding updates and changes to Refashion, our Website, our Terms of Service or any Services we offer or provide through it;
• To improve our products and Services;
• To provide personalized experience for you upon use of our Services;
• Information about your gender: When you use our AI Photos feature, we ask you about your gender. This information is used by the AI model solely to generate the Photos in accordance with the indicated gender: for example, if you choose to identify your gender as female, then you will receive conventionally more feminine-like Photos.

Additionally, we may use anonymized information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of personal information

We will not disclose your personal information to any third parties and we do not share, sell, rent, or trade your personal information with third parties for their commercial purposes. However, we reserve the right to disclose information about you to third parties for assistance in improving the Cosmos products and Services. Additionally, we may disclose personal and non-personally identifiable information with third-party service providers engaged by us to provide technical support, hosting services, testing, network security, or statistical services. Any such disclosure will be subject to confidentiality obligations.

Cosmos may also disclose information about you to third-parties where we have a good faith belief that such disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Cosmos, our affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the Cosmos employees, owners, or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.

Cosmos may use third-party payment processors including Stripe or other credit card provider platforms for payment transactions. Wherever you designate a payment source for transaction processing with us through any platform, you are responsible for visiting, understanding, and abiding by all terms of such platforms and such payment sources.

When you choose to use the AI Photos feature, you provide your gender identification, which is used to retrain the separate copy of the model to generate Photos based on your particular face data. It is our contractual obligation to ensure that we provide you with the requested service. This data is deleted immediately after the Photos are successfully generated.

How long we keep your information

We will keep your personal information for as long as you use Refashion, our Website, and our Services. You have the right to request that your personal information is permanently removed from our system and database at any time. We will accommodate such requests within 45 (forty-five) days or less. You can e-mail such requests for permanent removal to [email protected].

Right to access and control your data

We provide you with many choices about the collection, use, and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts and communication controls. We will provide you with access to your personal information that we store and allow you to:

1. Delete your data — you can request that we erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you);
2. Change or correct your data — you have the option to edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate;
3. Object to, or limit or restrict, use of data — you can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held);
4. Right to access and/or take your data — you can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
5. We provide our California consumers with detailed information about the categories of personal information you have collected in the past 12 months.

You may send us an e-mail at [email protected] to request any or all of the above.

Cookies and tracking technologies

We collect information about you using “cookies.” Cookies are small data files stored on your hard drive by a Website. The cookies that we use are for authentication purposes (to facilitate your log-in) and session cookies (to recognize your preferences while navigating through the Website).

Usually the information that we collect automatically through cookies is statistical data and cannot be used to identify you as an individual. It helps us to improve our App(s), Website and Services and to deliver a better and more personalized service.

Additionally, there might be third-party cookies used on our Website by third-party advertisers. Those cookies are not related to your profile, they cannot identify who you are and therefore are not linked to your personal data.

When you first visit our Website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose. If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our Website or Services.

Security of your personal information

Cosmos is committed to ensuring that the information you provide to us is secure from accidental loss and from unauthorized access, use, alteration, and disclosure. We have implemented suitable physical, electronic, and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss, and unauthorized access, modification, and disclosure.

• All information you provide to us is stored, if at all, on a secure database behind a Virtual Private Network;
• We restrict access to personal information to employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations;
• We back up all client data in multiple data centers enabling speedy recovery in case of a disaster;
• Whenever possible we will make sure we pseudonymize all personal or related data.

The safety and security of your information also depends on you. Where we have given you a password for access to certain parts of our App, Website, or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website or our Apps or platforms that support or make them available or usable, including chats or message boards. The information you share in public areas may be viewed by any user of the Website or our Apps or Services.

Commercial and non-commercial communication

By providing information to the Website or through our App(s) or Services, such as signing up for a newsletter or an account, you have agreed to receive e-mail communication from us. However, you may unsubscribe from certain communications by notifying Cosmos that you no longer wish to receive solicitations or commercial information. Cosmos will remove you from the database, where you have the right to request this under the Privacy Policy, Terms of Use, or applicable law, or where Cosmos voluntarily decides to grant the request.

Children’s online privacy protection act

The Cosmos Website, App(s), and Services are directed to persons over the age of 13. Cosmos does not knowingly collect information from children under 13 years of age or have any reasonable grounds for believing that persons under the age of 13 are accessing the Website, or our Services or App(s). If Cosmos discovers any inadvertently collected Personal Information of a person under the age of 13, that information will be swiftly deleted from its’ records. If you believe that Cosmos may have any information from a person under age 13, please contact Cosmos at: [email protected]

Your california privacy rights

Cosmos welcomes residents of the State of California to use its App(s), Website, and Services, and complies with the California Business and Professions Code §§ 22575-22579. If you are a California resident you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes. Please send a written request to Cosmos Oyun Yazilim Danismanlik Sanayi Ticaret Limited Sirketi, Manavkuyu Mah. 278/5 Sk. Basari 1000 Yil Basari No: 14 Ic Kapi No: 10, 35535 Bayrakli, Izmir Turkey.

Changes to this privacy policy

We reserve the right to make changes to this privacy policy at any time. If we change our privacy policy, we will notify you via email sent to the email address you provide at the time of registration as well as post an updated version of this Privacy Policy on our Website, App pages/platforms or where Services under our control are otherwise made available, so that you and other users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Changes will not apply retroactively and changes addressing new functions for a service or changes made for legal reasons will be effective immediately. If you do not agree to the modified terms, you should discontinue your use of the Website and our App(s) and Services. Your continued use of the after any such changes constitutes your acceptance of the new Privacy Policy. You should also check back from time to time to ensure you are aware of any changes. Under California Consumer Privacy Act we will be reviewing this Privacy Policy every 12 months.

Contact information

If you have any questions, comments, complaints or concerns regarding this Privacy Policy, you can contact us anytime through the following address: Manavkuyu Mah. 278/5 Sk. Basari 1000 Yil Basari No: 14 Ic Kapi No: 10, 35535 Bayrakli, Izmir Turkey, and/or

[email protected]

We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

Last Updated: 27 July 2024