Privacy Policy

Version 1 | 2022-05-13

1. Introduction

When visiting the mobile Application DressLab (the “Application”), CatchLab AB, company registration number 559294-5397 with its registered address at Husarvikstorget 3, 11547 Stockholm, Sweden (“CatchLab AB”, “we”, “us", “our”) may collect and process personal data (“Personal Data”) about you (“user”, “you”, “your”). This privacy notice (“Privacy Notice”) sets out which Personal Data CatchLab AB collects from the users of the Application, and for which purposes the Personal Data is processed. Throughout this Privacy Notice, the term “processing” is used to cover all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of information. “Applicable Data Protection Laws” includes, in particular, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the “GDPR”).

2. What Personal data do we collect?

Personal Data refers to information which can directly or indirectly identify an individual. It also includes special categories of personal data, which is considered as more sensitive information. Personal Data which CatchLab AB collects and processes includes the following categories: Personal Data refers to information which can directly or indirectly identify an individual. It also includes special categories of personal data, which is considered as more sensitive information. Personal Data which CatchLab AB collects and processes includes the following categories:

• 2.1 Registration and identification data include details provided by you in order to register and/or open an account on our Application. These include first name, last name, username or similar identifier, email, telephone number, date of birth and gender. This also includes user submitted photos that could depict the users facial features.
• 2.2 Contact data includes, email address and telephone number.
• 2.3 Technical/log-in data includes internet protocol (IP) address, log in information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Application.
• 2.4 Usage and analytics data include information on how you use our Application, products and services; such as the username or similar identifier, language, location, browser data, device used and payment provider.
• 2.5 Marketing and Communications data includes information with regards to your preferences in receiving marketing material from us; as well as other various information which is provided by you in your communication to us.
• 2.6 Special categories of data include information processing and storing of digital photos of clothing objects submitted by the user.

3. From where do we collect personal data?

• 3.1 Information collected from you
  We collect Personal Data directly from you when you register an account on our Application, when you interact with us, and when you use our services. This includes information about your visit to our Application, as detailed in Clause 2 above, and information you voluntarily shared with us or made public.
• 3.2 Information collected from third parties
  CatchLab AB works with various third-party data processors when providing its services to customers. These include, for example, business partners and payment service providers. When you register an account on our Application, certain Personal Data will be automatically populated in your customer profile. This refers to the email address, first and last name.

4. For what purposes?

We use the Personal Data collected about you in accordance with applicable laws and only for specified purposes. We use information that we collect for the following main reasons, which are described in more detail below:

• 4.1 Personalize and analyze our interaction with you
  When you visit our Application, we will collect and process your Personal Data in order to better understand you as a user and to personalize our interactions with you, for example, to show you products and services we think you may like and in order to carry out customer profiling segmentation and analysis. We will also collect and process your Personal Data in order to identify usage trends, and for the purpose of statistical analysis. The legal basis for the above processing of your Personal Data is that the processing is necessary in order to fulfil our legitimate interest to better understand you as a user, and to personalize our interactions with you to show you relevant products and services, as per article 6.1 (f) of the GDPR.
• 4.2 Provide you with information such as newsletter and press releases
  If you have opted in to receive or subscribed to our newsletters, press releases and similar information about CatchLab AB and its business and services, or order such information on a one-time basis, we process your Personal Data for the purposes of providing you with the requested subscription or information, in accordance with the article 6.1 (a) of the GDPR (you have given consent to the processing of your personal data for one or more specific purposes).
• 4.3 Answer your questions and handle feedback in general
  Our Application provides functionality for the user to communicate with us, to ask questions and give feedback regarding our services and business. Where you use such functionality, CatchLab AB will process your Personal Data for the purpose of answering your questions and handling your feedback sent to us. The legal basis for the above processing of your Personal Data is that the processing is necessary in order to fulfil our legitimate interest to answer questions and handle feedback from you, as per article 6.1 (f) of the GDPR.
• 4.4 Manage complaints relating to our services and products
  Our Application allows you to send us your complaints relating to our services and products. When you provide us with a complaint, CatchLab AB will process your Personal Data for the purpose of investigating, managing and replying to your complaint. The legal basis for the above processing of your Personal Data is that the processing is necessary in order to comply with a legal obligation to investigate, manage, and reply to your complaint, as per article 6.1 (c) of the GDPR.
• 4.5 Registration of personal user accounts and providing our services
  Our Application allows users to register a personal user account, accessible via one-time password sent to your email. If you create a user account, CatchLab AB will process your personal data for the purpose of creating and managing your personal user account, and providing you with access to your account, including the provision of our services. The legal basis for the above processing of your Personal Data is that the data subject has given consent to the processing of his or her personal data for one or more specific purposes (see section 4: “What Purposes”); as per article 6.1 (a) of the GDPR.
• 4.6 Our Services
  Our Application allows users to create digital outfits by uploading photos of their physical clothes to the Application and digitally organize, explore and share the outfits with other users in the Application.
• 4.7 Establish, exercise and defend legal claims
  CatchLab AB may process your Personal Data for the purpose of ensuring compliance with our Terms and Conditions; and establishing, exercising and defending legal claims in the unlikely event of a dispute. The legal basis for the above processing of your personal data is that the processing is necessary in order to fulfil our legitimate interest to establish, exercise and defend legal claims, as per article 6.1 (f) of the GDPR.

5. Data Retention

CatchLab AB will only retain your information for as long as is reasonably necessary for the purposes of this Privacy Policy and in order to comply with our legal obligations. We retain your information as long as you are a customer and 2 years from the date your account is closed.

6. Disclosure and transfer of personal data

CatchLab AB does not share Personal Data with external parties.

7. Your Rights

• 7.1 Right to rectification
  CatchLab AB takes steps in accordance with Applicable Data Protection Laws to keep your Personal Data accurate, complete and up-to-date. If you identify that any Personal Data related to you is inadequate, incomplete or incorrect, you are entitled to have the Personal Data corrected. We reserve the right to verify the accuracy of the new data you provide to us.
• 7.2 Right of access
  You may request us to confirm whether or not we are processing your Personal Data. You can access most Personal Data we hold about you by emailing a request to hello@catchlab.se. Any additional information regarding the processing of your Personal Data can be requested by contacting us on hello@catchlab.se.
• 7.3 Right to object
  You have the right to object to the processing of your personal data for direct marketing purposes. If you have opted in to receive email newsletters from us, each email will include an easily accessible opt-out function where you may unsubscribe from further direct marketing communications.
• 7.4 Right of erasure
  You have the right to request us to delete your Personal Data under certain circumstances, such as when your Personal Data is no longer required for the purposes for which it was originally collected.
• 7.5 Right to restrict processing
  You may ask us to restrict the processing of your Personal Data to only comprise the storage of your Personal Data under certain circumstances and as such, we will not use your Personal Data further.
• 7.6 Right to withdraw consent
  You have the right to withdraw your consent to the processing of your Personal Data at any time to the extent that the processing is based on your consent. As also stated in section 7.3, you can easily withdraw your consent from direct marketing received from us by using the unsubscribe option which is found in every communication.
• 7.7 Right to data portability
  You have the right to request to receive a machine-readable copy of your Personal Data which was processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you. Our Terms and Conditions, which you have accepted at registration, set out the terms of the contract and the services we will provide. You will receive your Personal Data in a structured and commonly used format. This right refers to Personal Data which has been provided to CatchLab AB by you (data portability) and allows you to ask for the information to be transferred to another data controller (where possible).

8. Complaints to the supervisory authority

You always have the right to lodge complaints pertaining to the processing of your Personal Data by CatchLab AB to the competent data protection authority, if so, provided under Applicable Data Protection Laws. Our main data protection authority is the Integritetsskyddsmyndigheten (‘IMY’).

9. Data Security

We have implemented appropriate technical, physical and organizational measures to protect your Personal Data against unauthorized or accidental destruction; alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorized access. This is complemented by internal policies and ensuring that our employees are properly trained on Data Protection and Information Security.

10. Cookies

CatchLab AB does not use cookies and other technologies to collect information about you when you visit our Application.

11. Contact Information

If you have any questions or concerns regarding the processing of your Personal Data or wish to exercise any of your rights, please contact CatchLab AB using the contact details set forth below. You can contact our Data Protection Officer (“DPO”) by emailing hello@catchlab.se. The data controller for Personal Data is CatchLab AB, a company registered under the laws of Sweden with registration number 559294-5397, and registered address in Husarvikstorget 3, 11547 Stockholm.