Privacy Policy

Cladwell helps you understand your colors, your style, and the clothes you already own. Doing that well requires personal information. This policy explains what The Cladwell Group, Inc., doing business as Cladwell (“Cladwell,” “we,” “us,” or “our”), collects, why we collect it, who helps us process it, how long we keep it, and the choices you have.

This policy applies to Cladwell’s mobile applications, cladwell.com, app.cladwell.com, our newsletters and support services, and other Cladwell services that link to it (together, the “Services”). It does not govern a third-party service you choose to visit or use under that service’s own privacy policy.

The short version

• We use your information to provide your account, color and style guidance, closet and outfit features, subscriptions, communications, support, and product security.
• A photo used for color analysis is used only for that analysis. We do not use it for facial recognition, identity verification, advertising, or AI training.
• The free color reading on cladwell.com, when offered as a no-storage reading, removes image metadata, analyzes the photo in memory, and does not retain the photo.
• In app onboarding, an unclaimed photo is kept for up to seven days so you can resume. If you create or connect an account, the photo is kept privately with the account until you delete the photo or the account.
• We do not sell personal information for money, and we do not sell, lease, trade, or profit from photo or face-geometry information.
• You can ask to access, correct, export, or delete your information by emailing hello@cladwell.com. You can also delete your account in the app.

1. Information we collect

Information you give us

Depending on how you use Cladwell, you may provide:

• Account and contact information, such as your name, email address, login credentials, social-login details, and communication preferences.
• Profile and style information, such as the types of clothes you wear, sizes, wardrobe preferences, style goals, lifestyle and dress-code answers, color preferences, and other answers you choose to give us.
• Closet and outfit information, such as clothing items, item and outfit photos, item links, notes, prices, capsules, favorites, outfit plans, wear history, and shopping-list information.
• Photos for personal color analysis, along with limited face-location and cheek-region coordinates produced on your device, as described in Section 3.
• AI and stylist content, such as questions, messages, feedback, and the closet, style, weather, and profile context needed to answer them.
• Location choices, including a city, coarse location, or precise device location when you grant permission, so we can provide local weather and weather-aware outfit guidance.
• Purchase and subscription information, such as the product purchased, transaction and subscription identifiers, entitlement status, renewal state, and billing history. Payment-card details are handled by the applicable app store or payment processor and are not stored by Cladwell in full.
• Communications, including support requests, survey or questionnaire answers, newsletter signups, reviews, and feedback.
• Content you choose to share, such as an outfit, report, or closet content sent to a stylist, invited user, social platform, or another recipient.

Information collected automatically

When you use the Services, we and our service providers may collect:

• IP address and approximate location derived from it;
• device, browser, operating-system, app-version, language, and time-zone information;
• app-instance, device, advertising, push-notification, and similar identifiers, subject to device settings;
• pages, screens, links, features, and actions used, along with timestamps and referral information;
• subscription, notification, and communication-delivery events;
• crash reports, diagnostics, security events, and performance data; and
• cookies, pixels, local storage, and similar technologies on web surfaces where they are enabled.

We minimize analytics for the rebuilt onboarding. In particular, its analytics contract excludes photos, face geometry, sampled colors, palette results, answers, free text, names, email addresses, precise location, stable account identifiers, and AI prompts or responses.

Information from other sources

We may receive information from:

• Apple, Google, Facebook, or Pinterest if you choose a supported social sign-in;
• Apple, Google Play, RevenueCat, Stripe, or another payment provider about purchases and entitlements;
• Typeform and connected services for legacy style, color, wardrobe, or styling questionnaires;
• a stylist, client, or other user who invites you to a Cladwell feature; and
• analytics, attribution, communication, and support providers that report interactions with Cladwell.

2. How we use information

We use personal information to:

• create, authenticate, maintain, and secure accounts;
• build and manage a digital closet, capsules, outfits, schedules, wear history, and wardrobe insights;
• provide color analysis, a Style Baseline, personalized styling, weather-aware recommendations, and AI-assisted features;
• process purchases, confirm entitlements, administer trials and subscriptions, and provide billing support;
• send requested newsletters, product messages, service notices, and push notifications;
• respond to support, privacy, safety, and account requests;
• operate, debug, protect, measure, and improve the Services;
• prevent fraud, abuse, unauthorized access, and violations of our terms;
• comply with law and enforce or defend legal rights; and
• create aggregated or deidentified statistics that are not reasonably capable of identifying you. We do not attempt to reidentify data we maintain as deidentified.

We do not use your photos, closet content, messages, or other personal content to train Cladwell or third-party AI models. Model providers may process content only to provide the requested feature and under the provider controls applicable to that feature.

3. Photos, color analysis, and face geometry

This section is also Cladwell’s public retention and destruction policy for photo-derived face-geometry information. Some jurisdictions may define a record or scan of face geometry as a biometric identifier or biometric information even when it is not used to identify a person.

What the feature does

For personal color analysis, the app checks on your device that one usable face is present. It may create a face bounding box, pose measurements, and two small cheek-region polygons so the service can sample color consistently. Cladwell receives only that limited geometry, not the full set of facial landmarks detected by the device.

We use the photo and limited geometry to check photo quality, measure coloring, create a color palette and related Style Baseline, and let you resume or review the result. We may send the photo and bounded analysis inputs to an approved model provider acting for Cladwell. We do not create a reusable face-recognition template or compare the photo with an identity database.

The disclosure shown in the app is a product rule as well as a privacy promise:

Your photo is used only to read your coloring.

Never to judge how you look, or to infer your identity, age, gender, body, or health.

Cladwell also prohibits using the feature to infer or score attractiveness, race or ethnicity, disability, gender identity, wealth, or body desirability. We do not send the photo, face geometry, sampled facial colors, or color result to product analytics or ordinary AI observability systems.

Retention and destruction schedule

• No-storage web color reading: When a cladwell.com color reading is expressly presented as a no-storage reading, we remove embedded image metadata, process the image in memory, and discard the image after returning the result. We do not write the source photo to Cladwell’s application storage. Separate security logs may record an IP address, request time, response status, and abuse-control outcome, but not the photo.
• Unclaimed in-app onboarding: We keep the private source photo and its limited geometry for no more than seven days so you can resume an interrupted session. If the session is not connected to an account, the photo and geometry are automatically deleted when that period expires.
• Claimed account: If you create or connect a Cladwell account, the private source photo and limited geometry are kept with the account so the reading can be reviewed and adjusted. We delete them when you delete the photo or your account, when the information is no longer needed for the disclosed purpose, or earlier if applicable law requires it.
• Color result and Style Baseline: Your derived palette, qualities, confidence values, and version history may remain after the source photo is deleted so your Cladwell experience continues to work. They are deleted when your account is deleted, subject to limited legal or backup exceptions described in Section 8.
• Other photos: Profile, closet-item, and outfit photos remain until you delete the content or account, subject to the same limited exceptions.

When a source color-analysis photo is deleted, Cladwell also deletes its linked face geometry from active systems. Backup copies are isolated from ordinary use and expire under our backup cycle unless we must preserve a copy for a legal reason.

No sale, unrelated use, or training

Cladwell does not sell, lease, trade, or otherwise profit from a color-analysis photo, face geometry, or information derived from it. We do not disclose that information except to service providers that need it to provide the requested analysis, when you direct us to, or when disclosure is required by law. We do not use it for advertising or to train an AI model.

You can skip photo analysis and still use a reduced onboarding path. You can request deletion or withdraw consent for future processing at any time. Withdrawal does not make earlier lawful processing unlawful, but we will stop any processing based solely on that consent and delete the covered information unless another legal basis requires retention.

4. AI-assisted features

Cladwell uses model providers for features such as stylist conversations, conversation summaries, style reviews, item import, moderation, and color analysis. The information sent depends on the feature. It can include your question, recent conversation, name, wardrobe type, selected closet items, rounded location, weather, or an image you ask us to analyze.

For color analysis, Cladwell requires approved models and privacy-restricted routing designed to prevent provider training and storage. For other AI features, a provider may retain inputs and outputs for a limited period for security and abuse monitoring under its business-service terms. Cladwell may keep conversations in your account so the feature has context and you can revisit them.

AI output can be incomplete or wrong. Your feedback helps Cladwell correct your experience, but it does not authorize model training on your personal content.

5. When we disclose information

We disclose personal information only as described below.

Service providers and subprocessors

Providers process information for Cladwell under contractual or platform terms. The providers used by a particular person depend on the platform, feature, location, and purchase method.

• Hosting, storage, delivery, and search: Amazon Web Services, Vercel, Cloudinary for legacy images, and Typesense.
• AI and photo analysis: OpenAI; OpenRouter and approved routed providers, including Microsoft Azure and Google Cloud Vertex AI, where configured.
• Payments and subscriptions: Apple App Store, Google Play, RevenueCat, Stripe, and legacy Squarespace Commerce.
• Communications and support: OneSignal, Postmark, Cladwell’s self-hosted Listmonk service, Zendesk, and Google Workspace.
• Analytics and reliability: Google Analytics, Firebase Analytics, Firebase Crashlytics, Segment, and PostHog where enabled. The providers used differ by platform and environment.
• Questionnaires and legacy integrations: Typeform and, for particular historical forms, Zapier, Google Sheets, and Mailchimp.
• Sign-in and platform services: Apple, Google, Facebook, and Pinterest when you choose the corresponding service.
• Location and weather: Google Maps, Apple WeatherKit, and Open-Meteo.

We may change providers as the Services evolve. When a change materially affects how personal information is processed, we will update this policy or provide another appropriate notice.

Other disclosures

We may also disclose information:

• At your direction, such as when you share an outfit, report, or closet with a stylist or another person;
• For legal and safety reasons, when reasonably necessary to comply with law or legal process, protect rights and safety, investigate abuse, or secure the Services;
• In a business transaction, such as a merger, financing, reorganization, bankruptcy, or sale of assets, subject to appropriate confidentiality and notice requirements; and
• In aggregated or deidentified form that is not reasonably capable of identifying you.

Cladwell does not sell personal information for money. Some privacy laws define “sale,” “sharing,” or “targeted advertising” more broadly than an ordinary sale. Legacy and current surfaces may use analytics or advertising technologies from Google, Meta/Facebook, or Pinterest. Where applicable law gives you an opt-out right, you may exercise it as described in Section 9.

6. Cookies, analytics, advertising, and device choices

Cladwell web services may use cookies, pixels, local storage, and similar technologies to keep you signed in, remember settings, understand use, measure campaigns, and protect the Services. Mobile apps use SDKs for similar purposes and for crash reporting, subscriptions, notifications, and attribution.

You can limit cookies through your browser and reset or limit advertising identifiers through device settings. You can also use provider controls such as the Google Analytics opt-out. Blocking necessary storage may prevent some account features from working.

Because browser “Do Not Track” signals do not have a consistent legal or technical meaning, the Services may not respond to them. Where legally required, we treat a supported opt-out preference signal, such as Global Privacy Control, as a request to opt out of sale or sharing.

7. Communications

We send service communications needed to operate an account, such as security, billing, and material policy notices. You cannot opt out of these while keeping the relevant service.

We send marketing email, including the From the Founder newsletter, only as permitted by law. You can unsubscribe using the link in the message or by contacting us. We may retain a minimal suppression record so we do not add an unsubscribed address back to a marketing list. You can control push notifications in the app or device settings.

8. How long we keep information

In addition to the photo schedule in Section 3:

• account, profile, closet, outfit, Style Baseline, and AI-conversation data generally remain while the account is active and until deleted;
• newsletter information remains until you unsubscribe or ask us to delete it, after which a minimal suppression record may remain;
• support records remain while needed to resolve the request, maintain an appropriate business record, and protect legal rights;
• transaction, tax, fraud-prevention, and legal records remain for the period required by law or reasonably needed for those purposes;
• analytics and diagnostic data remain according to the configured provider and Cladwell retention settings; and
• deleted information may remain temporarily in encrypted or access-restricted backups until those backups expire.

We use the shortest period reasonably necessary for the disclosed purpose, taking into account the nature and sensitivity of the information, security needs, legal obligations, and your choices. When retention is no longer justified, we delete, deidentify, or isolate the information from further use.

9. Your privacy choices and rights

Depending on where you live, you may have the right to:

• know whether we process your personal information and access a copy;
• correct inaccurate information;
• delete information;
• receive a portable copy of information you provided;
• object to or restrict certain processing;
• withdraw consent;
• opt out of sale, sharing, targeted advertising, or certain profiling;
• limit certain uses of sensitive personal information;
• appeal a decision we make about your privacy request; and
• receive equal service and pricing without discrimination for exercising a privacy right.

You can edit some information or delete your account in the app. For any request, email hello@cladwell.com with “Privacy Request” in the subject line. Tell us the right you want to exercise and the email address associated with your account. We may ask for information reasonably necessary to verify your identity and protect the account. An authorized agent may submit a request where law permits, but we may require proof of authority and identity.

If we deny a request, you may appeal by replying to our decision with “Privacy Appeal.” You may also complain to your local privacy or data-protection authority.

10. California notice at collection

In the preceding 12 months, Cladwell may have collected the following California categories of personal information: identifiers; customer-record information; characteristics you choose to provide; commercial and subscription information; internet or other electronic activity; approximate or precise geolocation with permission; audio, electronic, visual, or similar information; professional or employment-related context included in style answers; and inferences used to provide color, style, and outfit guidance. Precise geolocation and some account, communication, or photo-derived information may be sensitive personal information under California law.

We collect these categories from you, your device, service providers, and partners described in Section 1. We use them for the purposes in Section 2 and retain them as described in Sections 3 and 8. We may disclose them for business purposes to the provider categories in Section 5. We do not knowingly sell or share the personal information of anyone under 16.

Cladwell does not use sensitive personal information to infer characteristics about you beyond what is reasonably necessary to provide the feature you requested. The color-analysis prohibitions in Section 3 apply everywhere, not only in California.

11. Legal bases for EEA, UK, and similar jurisdictions

Where a legal basis is required, Cladwell processes personal information:

• to perform a contract with you, including providing an account, requested features, purchases, and support;
• with your consent, such as for optional precise location, optional photo analysis where required, or marketing communications;
• for legitimate interests, such as securing, debugging, measuring, and improving the Services, provided those interests are not overridden by your rights; and
• to comply with legal obligations and establish, exercise, or defend legal claims.

Cladwell’s color analysis is not designed to identify a person uniquely. We do not use the photo or geometry for biometric identification or authentication. If applicable law nevertheless treats particular photo-derived information as specially protected or biometric information, we rely on the notice, consent, safeguards, and rights required by that law.

12. International transfers

Cladwell is based in the United States, and personal information may be processed in the United States and other countries where our providers operate. Those countries may have different privacy laws. Where required, we use approved contractual safeguards or another lawful transfer mechanism and make additional information available on request.

13. Security

We use administrative, technical, and physical safeguards designed to protect personal information. Color-analysis photos are kept in private, access-controlled storage and are not served from a public image URL. No storage or transmission method is completely secure, so we cannot guarantee absolute security.

If you believe your account or information has been compromised, contact us promptly at hello@cladwell.com.

14. Children

The Services are not directed to children under 13, and we do not knowingly collect personal information from a child under 13. A person who is not old enough to enter a binding agreement in their location may use the Services only with the involvement of a parent or legal guardian. If you believe a child has provided information contrary to this section, contact us so we can investigate and delete it as appropriate.

15. Changes to this policy

We may update this policy as the Services, providers, or law change. We will update the date above and, when a change is material, provide notice through the Services, email, or another appropriate channel before the change takes effect where required.

16. Contact us

The Cladwell Group, Inc., doing business as Cladwell, is the controller of the personal information covered by this policy unless another notice says otherwise.

Email: hello@cladwell.com
Mail: The Cladwell Group, Inc., 5050 Ridge Avenue, Cincinnati, Ohio 45209, United States