Privacy Policy

This Privacy Policy applies between you, the User of this Website, ugenie.ai, and Ugenie AI LTD (trading as Ugenie.ai / Ugenie, with registered address at Bartle House, 9 Oxford Court, Manchester, M2 3WQ), the owner and provider of this Website. Ugenie AI LTD takes the privacy of your information very seriously. This policy governs our collection, use, processing, and disclosure of any data you provide or that is automatically collected during your use of the Website. Please read this Privacy Policy carefully.

We reserve the right to make changes to this Privacy Policy at any time for any reason. Changes will be signalled by an update to the "Last Updated" date below, and they become effective immediately upon posting. By continuing to use the Website after changes are made, you are deemed to have accepted the revised Privacy Policy. We encourage you to periodically review this document to stay informed of updates.

1. Definitions and Interpretations

Data: All information that you submit to Ugenie AI LTD via the Website, including definitions provided under the Data Protection Act 2018 and the UK GDPR.

Ugenie AI LTD: Trading as Ugenie.ai / Ugenie; our registered office is at Bartle House, 9 Oxford Court, Manchester, M2 3WQ.

User/You: Any third party who accesses the Website and is not employed by or providing services to Ugenie AI LTD.

Website: The site you are accessing at ugenie.ai, including any sub-domains (unless explicitly excluded by separate terms).

For clarity: a. Singular terms include their plural forms and vice versa; b. References to sub-clauses, clauses, schedules, or appendices are to those parts of this Privacy Policy; c. "Including" is taken to mean "including without limitation"; d. Any reference to statutory provisions includes subsequent amendments; e. Headings are for organisational purposes only.

2. Scope of This Privacy Policy

This Privacy Policy applies solely to the actions of Ugenie AI Limited and its Users with respect to this Website. It does not extend to any websites accessed via links on this Website (such as social media sites), each of which is governed by its own privacy policy. For the purposes of the UK GDPR and the Data Protection Act 2018 (as may be amended by the UK Data Protection and Digital Information Bill), Ugenie AI LTD is the "data controller" for the data we process through the Website.

3. Collection of Your Information

We may collect information about you in various ways, including:

A. Personal Data

Your name, shipping address, email address, telephone number, and other demographic details that you voluntarily provide when registering or engaging with the Website.

B. Social Media Data

When processing screenshots from social media platforms, we collect image data necessary to perform our Visual Matching Attribution™ service.

C. Derivative Data

Information automatically collected by our servers, such as your IP address, browser type, operating system, access times, and the sequence of pages viewed.

D. Financial Data

While we do not currently process payments through our platform, once payment features are active, we will collect only the financial details necessary to facilitate payouts (e.g. bank account details, sort codes). The majority of financial data will be handled by our secure payment processors (such as Stripe Connect, Wise, or PayPal). We advise you to review the privacy policies of these processors for further details.

E. Mobile Device Data

Data about your mobile device (such as device ID, model, manufacturer) and, where permitted, location information when accessing the Website via a mobile device.

F. Third-Party Data

Information from social media or other third-party services that you connect to Ugenie. We will only access information you have explicitly authorised through the respective authentication processes.

G. Data from Contests, Giveaways, and Surveys

Additional personal information that you may provide when participating in promotions, used solely to administer the promotion and deliver prizes.

H. Image and Visual Content Data

When you upload images or screenshots to our platform, we collect and process the visual data to enable our Visual Matching Attribution™ Technology. This includes analysing the image content to identify products, styles, and other visual elements necessary for matching purposes.

4. Our Use of Your Data

We use the data collected to:

• Create and manage your account.
• Process transactions and related communications.
• Maintain internal records.
• Enhance and improve our products and services.
• Send you newsletters and email communications (subject to your consent).
• Manage and administer promotions, contests, and giveaways.
• Compile anonymous statistical data for internal analysis.
• Deliver targeted advertising, coupons, and recommendations.
• Monitor and analyse site usage and trends.
• Notify you of updates to the Website.
• Process visual data through our Visual Matching Attribution™ Technology to match products in images and attribute sales appropriately.

Data is retained according to the following standard periods, unless extended by legal or business requirements:

• Account Information: For the duration of your account plus 12 months post-closure.
• Transaction Data: For 7 years to comply with financial and tax regulations.
• Marketing Preferences: Until you opt-out or request deletion.
• Usage Data: For 26 months for analysis and service improvement.
• Creator Content (including images): For the duration of your participation in our platform plus 12 months, unless specific content is used for demonstration purposes with your explicit consent.

Visual Matching Data:

Product identification data derived from images is retained in an identifiable form for as long as your account remains active to improve our matching algorithms. For deleted accounts, Visual Matching Data is retained in an identifiable form for 36 months from the account deletion date, to comply with legal, regulatory, and business requirements. After this retention period, the data will be permanently deleted or irreversibly anonymised so that it can no longer be linked to any individual, and, once anonymised, may be retained indefinitely for analytical purposes.

5. Lawful Basis for Processing

We process your data based on one or more of the following lawful bases under UK GDPR:

• Consent: When you have explicitly agreed to the processing of your data for specific purposes.
• Contract: Where processing is necessary for the performance of our contractual obligations to you.
• Legal Obligation: Where processing is required to comply with the law.
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided these do not override your fundamental rights and freedoms.

The lawful basis for specific processing activities is as follows:

• Account Creation and Management: Contract
• Processing Transactions: Contract and Legal Obligation
• Service Improvement and Analytics: Legitimate Interests
• Marketing Communications: Consent
• Visual Matching Attribution™ Technology: Consent and Legitimate Interests
• Social Media Data Analysis: Consent
• Third-Party Data Sharing: Contract and Legitimate Interests

6. User Consent

By accessing and using Ugenie.ai, you confirm that you have read, understood, and consent to the collection, use, and processing of your personal data in accordance with this Privacy Policy. This consent includes:

• Processing of your social media content and engagement data for attribution and monetisation purposes.
• Analysing your public content to facilitate the "shop from screenshot" functionality.
• Delivering personalised recommendations and improving our Visual Matching Attribution™ technology.
• Sharing necessary data with our payment processors for payouts.

You may withdraw your consent or request deletion of your data at any time by contacting us at privacy[at]ugenie.ai. Please note that withdrawing consent may affect the availability of certain services.

7. Automated Decision-Making and Your Rights

Our Visual Matching Attribution™ technology involves automated processing to match products from screenshots, attribute sales, and distribute commissions. When automated decision-making is utilised, you have the following rights:

• Human Intervention: You can request a review by a human operator.
• Explanation: You can ask for a clear explanation of how the automated decision was reached.
• Contestation: You have the right to contest decisions that significantly affect you.

Review Process: To initiate this process, please contact us at privacy[at]ugenie.ai. We will provide guidance on the review procedure and ensure that you are supported throughout the process.

8. Disclosure of Your Information

Your data may be disclosed in the following circumstances:

A. Third-Party Service Providers

We share your information with third parties that provide services on our behalf (such as payment processing, data analysis, email delivery, hosting, customer service, and marketing). We require these providers to adhere to strict data protection standards.

When sharing data for personalised recommendations, any third-party platforms (e.g., OpenAI, Instagram, YouTube, LinkedIn, Facebook, TikTok, Snapchat, X/Twitter, Twitch) will only use your data to optimise monetisation strategies for your account.

B. By Law or to Protect Rights

If required by law or necessary to protect our rights, property, or safety, we may disclose your information. This includes situations involving legal process, fraud protection, or credit risk reduction.

C. Marketing Communications

With your consent, or when you are provided with an option to withdraw consent, your data may be shared with third parties for marketing purposes, in accordance with applicable law.

D. Interactions with Other Users and Online Postings

If you interact with other users on the Website (e.g. via comments or public posts), your profile information (such as your name and profile photo) may be visible to other users and publicly available.

E. Business Transfers

Should our business undergo a merger, acquisition, or sale, your data may be transferred to the new controlling entity under the same privacy terms.

For all disclosures, we endeavour to ensure that appropriate safeguards are in place, including Standard Contractual Clauses, Binding Corporate Rules, and where applicable, obtaining your consent.

9. Tracking Technologies and Cookies

A. Cookies and Web Beacons

We use cookies, web beacons, tracking pixels, and similar technologies to improve your experience on our Website. Cookies help us:

• Recognise and count visitors.
• Analyse site usage.
• Remember your preferences.
• Deliver targeted advertising and personalised content.

B. Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the operation of the Website.
• Analytical/Performance Cookies: Help us understand how visitors interact with the Website (typically retained for 30–90 days).
• Functionality Cookies: Remember your preferences and choices (duration varies by setting).
• Targeting Cookies: Record your visit and browsing patterns for personalised advertising (retention periods may vary).

C. Cookie Management

Our website uses cookies and similar technologies to provide functionality, personalise content, analyse traffic, and improve your experience. You can learn more about how we use cookies by visiting our Cookie Policy.

You have the right to manage your cookie preferences at any time. Click the button below to access your cookie settings:

10. International Data Transfers

We may transfer your personal data to countries outside the UK and European Economic Area (EEA). When doing so, we ensure that appropriate safeguards are implemented, such as:

• Standard Contractual Clauses approved by the relevant authorities.
• Binding Corporate Rules within our corporate group.
• Obtaining your explicit consent where necessary.

For further information about these safeguards, please contact privacy[at]ugenie.ai.

11. Data Security

We take the security of your data very seriously. To protect your personal information, we have implemented suitable technical and organisational measures including, but not limited to:

• Encryption of sensitive data during transmission and at rest.
• Secure storage solutions and regular security audits.
• Access control measures and, where applicable, two-factor authentication.
• Ongoing training and assessments for staff handling your data.

Despite these measures, please be aware that no method of transmission over the Internet is completely secure. Should a data breach occur, we have a detailed protocol in place.

12. Data Breach Protocol

In the unlikely event of a data breach, we will:

• Notify the relevant supervisory authority within 72 hours of becoming aware of the breach.
• Inform affected users without undue delay, providing clear guidance on steps to protect themselves.
• Document the breach, its effects, and remedial actions taken.
• Offer assistance and advice to mitigate any potential negative consequences.

13. Policy for Children

We do not knowingly collect personal data from children under the age of 13. Our registration and monitoring processes include age verification measures, such as prompts during sign-up and regular monitoring of user content.

Where there is any possibility that data from a child under 13 has been collected inadvertently, we will promptly remove such data upon verification and, where appropriate, notify the relevant authorities. In some jurisdictions, additional parental consent measures may be required, and we will comply with any such applicable legal requirements.

14. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

15. Controlling Use of Your Data

You have choices regarding how we use your data, particularly with respect to direct marketing and third-party sharing. Options include:

• Adjusting your preferences during account registration or via your account settings.
• Using opt-out links provided in marketing communications.
• Contacting us directly at privacy[at]ugenie.ai to request restrictions on processing.

16. Your Rights and How to Access Your Data

Under the UK GDPR, you have a number of rights regarding your personal data, including the rights to:

• Rectification: Correct any inaccurate data.
• Erasure: Request deletion of your personal data.
• Restriction: Limit how your data is processed.
• Data Portability: Receive your data in a machine-readable format.
• Object: Object to certain data processing activities, such as direct marketing.
• Automated Decision-Making: Request human intervention where decisions significantly affect you.

To exercise any of these rights, you may:

• Log into your account settings and use the available online tools.
• Submit a formal request by contacting privacy[at]ugenie.ai.

We endeavour to respond to all requests within one month.

Additional Privacy Rights for California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:

• The right to know what personal information we collect about you.
• The right to delete personal information.
• The right to opt-out of the sale or sharing of your personal information.
• The right to limit the use and disclosure of sensitive personal information.
• The right to non-discrimination for exercising your privacy rights.

To exercise these rights, please contact us at privacy[at]ugenie.ai with "California Privacy Rights" in the subject line.

17. Emails and Other Communications

If you wish to stop receiving emails, newsletters, or other communications from us, you can:

• Update your preferences during registration or via your account settings.
• Use the opt-out links provided in our emails.
• Contact us directly at privacy[at]ugenie.ai.

For communications from third parties, please contact them directly.

18. External Shopping Links and Third-Party Services

As part of our platform's functionality, ugenie.ai may direct you to external websites for purchasing products. Please note:

• We do our utmost to select retail partners with robust data practices, but we cannot control how these third-party sites manage your data.
• Each external site operates under its own privacy policy, and your transaction data is processed by the respective retailer or marketplace.
• Affiliate commissions or attribution data may be received, maintaining the connection between content creators and purchases.

We recommend that you review the privacy policies of these external sites before making any transactions.

19. Special Category Data and Biometric Data Processing

Our Visual Matching Attribution™ Technology is designed to identify products and fashion items in images. It does not intentionally process special category data as defined under UK GDPR, such as data revealing racial or ethnic origin, political opinions, religious beliefs, or data concerning health.

Our technology may process visual characteristics that could indirectly relate to ethnicity or other protected characteristics for the sole purpose of product matching. This processing is not used for profiling or targeting based on these characteristics and is conducted with appropriate safeguards.

We do not process biometric data for the purpose of uniquely identifying natural persons. Our visual recognition technology focuses solely on product identification and matching, not on identifying individuals.

20. Data Processing Agreements (DPA)

For business users (brands, retailers, and creators) that process personal data through our platform in a manner that may designate them as data processors under applicable law, we offer a Data Processing Agreement (DPA) that complies with UK GDPR requirements. This agreement outlines the terms under which personal data is processed and the responsibilities of each party.

To request a DPA, please contact us at privacy[at]ugenie.ai.

21. Screenshot Uploads and Visual Search

When using Ugenie.ai's visual search functionality:

• We recognise users may upload screenshots of social media content to find products
• Our service is designed for product identification, not for collecting personal data
• We process these images primarily to identify and match products
• We implement technical measures to focus on product recognition while minimising processing of personal identifiers
• Similar to other visual search tools, our system is designed to respect intellectual property while enabling users to discover products they're interested in

22. Data Protection Officer (DPO)

Although not legally required for our current processing activities, we have voluntarily appointed a Data Protection Officer to oversee our privacy practices.

You may contact our DPO via email at dpo[at]ugenie.ai. If you prefer, you can also reach out through our main contact email at privacy[at]ugenie.ai for any data protection queries.

23. Contact Us

If you have any questions or comments regarding this Privacy Policy, please contact us using the following details:

Ugenie AI LTD t/a Ugenie
Bartle House, 9 Oxford Court
Manchester, M2 3WQ
Email: hello[at]ugenie.ai