Privacy Policy

This Privacy Policy describes how MIRROR ("MIRROR", "we", "us", or "our") processes personal data in connection with the provision and operation of the MIRROR platform, an AI-powered suite of size recommendation, virtual try-on, visual content generation, and conversational shopping assistance technology integrated into the websites of fashion and retail brands ("Retailers").

This Privacy Policy applies to individuals who interact with MIRROR technology as visitors or customers of a Retailer's website ("you"), to representatives of Retailers who use MIRROR's administration console, and to visitors of MIRROR's own website.

1. Who We Are

MIRROR is operated by:

2. Two Different Roles: Please Read This Section Carefully

Depending on the type of data and the purpose of processing, MIRROR acts either as a data processor, on behalf of the Retailer, or as an independent data controller. This distinction determines who you should contact to exercise your rights, and it is explained in full in Section 12.

MIRROR acts as a data processor, on the instructions of the Retailer, for the data you provide in order to receive a size recommendation, generate a virtual try-on visualization, or interact with the conversational shopping assistant. The Retailer determines why and how this data is used and is your primary point of contact. We encourage you to also read the Retailer's own privacy notice.

MIRROR acts as an independent data controller for two limited purposes only: (i) the technical operation, security, and fraud prevention of the platform, and (ii) the improvement of our artificial intelligence models using pseudonymized data, as described in Sections 6 and 8 below. MIRROR is also the data controller for the account data of Retailer staff who use our administration console.

3. Categories of Personal Data We Process

3.1 Identification and contact information

Name, email address, phone number, company name, and professional contact information, provided by Retailer staff or by individuals contacting us directly.

3.2 Fit and profile information

To generate a size recommendation, we process information you provide such as your declared sex, height, weight, and usual clothing sizes. This information is processed as a processor on behalf of the Retailer.

3.3 Image data

To generate a virtual try-on visualization, we process an image captured via your device's camera or uploaded by you.

• This image is processed transiently, solely to generate the requested visualization.
• MIRROR does not retain this image in its own systems.
• The visualization is generated primarily using MIRROR's proprietary models, hosted within the European Economic Area. In some cases, generating the visualization requires the involvement of a third-party technology provider; in such cases, the image is used by that provider solely to produce the requested result, under the terms in force with that provider.
• MIRROR does not use this image for identification, biometric recognition, or facial recognition purposes.

3.4 Interaction and technical data

A technical identifier is associated with each size recommendation, together with data on your interaction with the service: recommended sizes, try-on requests, messages exchanged with the conversational assistant, product context, session data, and diagnostic and technical logs (IP address, browser and device type, timestamps).

The correspondence, if any, between this technical identifier and your identity as a known customer of the Retailer is established and held exclusively by the Retailer in its own systems. MIRROR does not access this correspondence for the purpose described in Section 6.

4. Why We Process Your Data

As a processor, on the Retailer's instructions:

• generating size recommendations and virtual try-on visualizations
• operating the conversational shopping assistant
• providing the Retailer with usage statistics

As an independent controller:

• securing the platform and preventing fraud or misuse
• diagnosing technical issues
• improving the accuracy and performance of our artificial intelligence models
• managing our relationship with Retailers and responding to communications
• complying with our legal and regulatory obligations

5. Legal Basis for Processing

6. Automated Processing, Artificial Intelligence, and Model Improvement

MIRROR uses artificial intelligence systems to generate size recommendations, virtual try-on visualizations, and conversational responses. These outputs are probabilistic aids to your shopping experience and are not guarantees of fit or of any purchasing outcome. MIRROR does not carry out automated decision-making producing legal effects concerning you.

Model improvement. MIRROR processes pseudonymized interaction data, such as recommended sizes and conversational session data, to train, refine, and evaluate its artificial intelligence models and to produce aggregate statistics. For this specific purpose, MIRROR acts as an independent data controller on the basis of its legitimate interest in improving the accuracy and reliability of its technology.

This processing:

• never includes the images described in Section 3.3, which are not retained;
• never includes the Retailer's own content, such as product visuals or catalog data, unless the Retailer has expressly authorized such use;
• is carried out on data from which MIRROR cannot identify you, because the correspondence between the technical identifier and your identity, where it exists, is held exclusively by the Retailer as described in Section 3.4.

You may object to this processing, for your future interactions with a given Retailer's website, by contacting privacy@mirrorforfashion.com or the Retailer.

7. Who Receives Your Data

We may share personal data with:

• the Retailer operating the website on which you use MIRROR's technology;
• our hosting providers, which operate infrastructure located within the European Economic Area;
• a limited number of specialized technology providers, which may include providers located outside the European Economic Area, used to help generate certain visualizations or conversational responses;
• our professional advisors;
• competent judicial or regulatory authorities, where required by law.

Third-party technology providers process data solely to deliver the specific result requested and, to MIRROR's knowledge, do not use it to train their own general-purpose models. Retention of data by such providers, where it occurs, follows their own applicable terms and is limited to what is reasonably necessary for service quality and abuse-monitoring purposes.

8. International Data Transfers

Some of the technology providers referred to in Section 7 are located outside the European Economic Area, including in the United States. Where this is the case, the transfer is governed by the European Commission's Standard Contractual Clauses or an equivalent safeguard recognized under Chapter V of the GDPR.

9. How Long We Keep Your Data

• Images used for virtual try-on: not retained by MIRROR; processed transiently only.
• Fit and profile information, and recommendation history: retained for three (3) years from your last interaction.
• Conversational session data: retained for three (3) years from the end of the session.
• Technical and diagnostic logs: retained for twelve (12) months.
• Retailer staff account data: retained for the duration of our contract with the Retailer.

These periods may be shorter where required by our contractual commitments to a specific Retailer.

10. Security Measures

We implement technical and organizational measures designed to protect personal data, including encryption in transit, access controls limiting data access to authorized personnel, and secure hosting infrastructure within the European Economic Area. No system can guarantee absolute security.

11. Children

MIRROR's services are not directed at, and do not knowingly process data relating to, children under the age of fifteen (15). If you believe a child has provided us with personal data, please contact us at privacy@mirrorforfashion.com.

12. Your Rights, and Who to Contact

For data processed as described in Section 3.2 (fit information) and 3.3 (images), and for the interaction data described in Section 3.4 insofar as it relates to a purpose determined by the Retailer: MIRROR acts as a processor. Please contact the relevant Retailer directly, in accordance with its own privacy notice, to exercise your rights of access, rectification, erasure, restriction, objection, and portability. If you contact MIRROR directly regarding such data, we will forward your request to the relevant Retailer without undue delay.

For data processed under Section 6 (model improvement) and for our own technical and security logs: MIRROR acts as an independent controller. You may exercise your rights directly by contacting privacy@mirrorforfashion.com.

You also have the right to lodge a complaint with a competent supervisory authority. In France, this is the Commission Nationale de l'Informatique et des Libertés (CNIL), 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr.

13. Cookies

MIRROR's technology may rely on cookies or similar technologies necessary for the operation of the size recommendation, virtual try-on, and conversational features. Where MIRROR's own website or platform uses non-essential cookies, this is governed by a separate cookie notice presented at the relevant time.

14. Relationship with Retailer Websites

MIRROR's technology is embedded within websites operated by Retailers. Retailers determine certain aspects of data processing relating to their own use of our services and remain responsible for their own privacy practices, including the information they provide to you and, where required, the consents they collect from you.

15. Changes to This Policy

We may update this Privacy Policy to reflect changes in our services, in applicable law, or in our operational practices. The date at the top of this page indicates when it was last revised.