Draft — to be reviewed by a lawyer. This text is not final yet.
Privacy Policy
Last updated: · Version 0.1
This is a translation for convenience. If it differs from the Spanish version, the Spanish version prevails. Español
This policy explains what personal data we process when you use RefMe, the iPhone app that finds the clothes in TikTok videos, Instagram Reels and YouTube Shorts, and when you visit this website: why we use it, who we share it with, how long we keep it and what you can do about it. It starts with the essentials; the detail comes afterwards.
The essentials at a glance
- What we collect. Your email and password for your account, the links and photos you analyse, what you save to your wardrobe, your history, and the minimum technical data the app needs to work and to prevent abuse.
- Where the images go. The video frames, or your photo, go to Anthropic, whose AI (Claude) recognises the clothes. The crop of each item you choose to search for goes to Google Lens through SearchAPI. Neither receives your email or your name.
- No selling, no tracking. We don’t sell your data, we don’t do advertising or profiling, and the app has no analytics SDKs. The website only counts visits in aggregate, without cookies.
- Shared analyses. If someone else analyses the same video, we reuse the analysis, but nobody can see who asked for it.
- You’re in control. You can delete your account from the app whenever you like (how) and exercise your rights by writing to [pending: privacy email].
- If you’re not happy with our answer, you can complain to the Spanish Data Protection Agency (aepd.es).
Who is responsible for your data
The controller of your personal data is the owner of RefMe:
- Owner: [pending: owner name or company name]
- Tax ID (NIF): [pending: tax ID (NIF)]
- Address: [pending: registered address]
- Privacy email: [pending: privacy email]
The rest of our details are in the legal notice.
We have not appointed a data protection officer: given our size and what we do, the law does not require one (Art. 37 GDPR and Art. 34 of the Spanish Organic Law 3/2018 on Data Protection and Digital Rights, LOPDGDD). For anything about your data, write to the email above.
What data we process and where it comes from
You give us almost all of it by using the app. When something comes from elsewhere, we say so.
Your account
To create an account we ask for an email address and a password. We store the email, the password protected with a hash (we never store it as it is and cannot see it) and a random internal identifier that links your account to what you save. We don’t ask for your name or phone number.
Your welcome answers
When you start, the app asks you a few questions: where you see the looks you like, how often, what you do when you love one, which styles suit you and what matters most to you when shopping. They are optional: you can skip any of them. They are saved with your account so we can personalise the app later without asking again; today they don’t change your results.
What you analyse
- Links. We store the link you share or paste exactly as it arrives, including the parameters apps add when sharing (such as
?igsh=,?si=or_t). We don’t use them for anything. - Photos and screenshots. You pick the photo in the iOS photo picker: the app only receives that one, not the rest of your library. The original file is not stored: it only passes through the server’s memory while it is analysed. We keep a downsized copy (720 pixels on its longest side) and the crops of each item, without the file’s metadata (EXIF) such as location, phone model or date. To recognise the same photo if it is uploaded again, we keep its fingerprint: a SHA-1 code calculated from the file, which cannot be used to rebuild the image.
- Videos. We don’t keep the video: we download it to a temporary folder that is deleted when the analysis finishes. We keep the cover, a few frames and the crops of the items. We explain it step by step in how an analysis works.
Your activity in the app
- History: for each video or photo you analyse, the link, the cover, the title, the @ of whoever posted it, how many items it had and the date.
- Searches: which items you asked us to search for in shops, so we never count the same one twice.
- Wardrobe: the items you save with the heart, your collections, the ones you mark as already owned, the shop results you pin and, sometimes, a copy of the item’s photo.
- Allowance and plan: when your free search week started and your plan (free or Pro).
Notifications
If you allow notifications (the app asks during your first analysis), we store your iPhone’s notification token, which is the address alerts are sent to, and the fact that your phone runs iOS. We delete it when you sign out.
While an analysis runs, the app can show its progress on the lock screen as a Live Activity. To update it we use a separate token, which only stays in the server’s memory until the analysis finishes. The alert that your free items are back is scheduled by your own iPhone: it doesn’t go through us.
The clipboard
When you come back to the app with something copied, the app checks whether it is a TikTok, Instagram or YouTube link so it can offer it to you; it never pastes it on its own. To read it, iOS asks for your permission to paste. If it is a link from one of those platforms, we send it to our server to show you which platform it’s from and who posted it; the server remembers it in memory for 30 minutes to avoid repeating the lookup, and doesn’t store it. Any other text stays on your iPhone.
Technical data
- Your IP address. Our server uses it to limit how many requests can be made per minute and to stop abuse. It only keeps it in memory, for one minute, although it may occasionally appear in an error log. We don’t keep an access log.
- Error logs. If something fails, the technical log may include your user identifier, the analysis identifier or the analysed link.
- Supabase logs. Our database provider logs sign-ins and requests to its service, with the IP address and time, for security.
What stays on your iPhone
Your open session, your appearance settings for the app and the date you accepted sending images to other services. The session is used to identify you to our services; the rest never leaves your phone.
If you get Pro
Pro is not on sale yet. When it is, Apple will handle the payment: we will never see or store your card details. We will store your plan, its dates, the fact that the purchase came from Apple and the transaction identifiers Apple gives us, to activate it, restore purchases and handle claims.
When you write to us
If you write to support or privacy, we process your email address, what you tell us and anything you attach (for example, the link or identifier of an analysis) in order to reply.
What we don’t collect
We don’t access your location, your contacts or your camera, nor your iPhone’s advertising identifier.
Data about people who don’t use the app
When we analyse a public video we also process some data about people who don’t use RefMe. We tell you about it here because it doesn’t come from them (Art. 14 GDPR).
- About whoever posted the video: their username (@), the title or description, the cover and some frames, in which they or other people may appear.
- About commenters: on TikTok and YouTube we read public comments to find shop hints, such as “the jacket is from…”. We store the text, the number of likes and whether it was written by whoever posted the video. We don’t store who commented, although the text may contain @mentions. We don’t read Instagram comments: only the caption and its author.
Where it comes from. The public TikTok, Instagram and YouTube pages of the content someone analyses with the app.
We don’t identify anyone. The AI only recognises clothes. We don’t use facial recognition or try to find out who appears in the images, so we don’t process biometric data (Art. 9 GDPR).
Why, and on what basis. To show whoever analyses the video where the clothes are from, including the shop mentioned by whoever posted it. We rely on our legitimate interest and that of the people who use the app (Art. 6(1)(f) GDPR), and we limit ourselves to what is already public and needed for that. We keep it for the time shown in the retention table.
If it’s your video or your comment, you can object to us processing it or ask us to take down an analysis: how to tell us. You can also exercise the rest of your rights.
Why we use data and on what legal basis
| What for, and with what data | Legal basis (GDPR) |
|---|---|
| Providing the service: creating your account, analysing what you share, showing you the items, searching for them in shops and keeping your wardrobe and history. | Performance of a contract (Art. 6(1)(b)). |
| Recognising and finding the clothes: sending the frames or your downsized photo, the crops and the video’s text to Anthropic and, through SearchAPI, to Google Lens. | Performance of a contract (Art. 6(1)(b)). Before your first analysis, the app explains this and asks you to accept it. |
| Applying your free allowance and your plan, using your allowance week and the items you have searched for. | Performance of a contract (Art. 6(1)(b)). |
| Letting you know when your analysis is ready and showing its progress on the lock screen, using your notification token. | Your consent, through the iOS notification permission (Art. 6(1)(a)). You can withdraw it in Settings. |
| Personalising the app later with your welcome answers. | Your consent (Art. 6(1)(a)): they are optional. |
| Preventing abuse and protecting the service: rate limiting (with your IP address, for one minute), usage caps and technical logs. | Legitimate interest in keeping the service secure and available (Art. 6(1)(f)). |
| Showing you where the clothes are from in a public video, using what its poster and its comments say. | Legitimate interest (Art. 6(1)(f)). |
| Reusing an analysis when someone else analyses the same content, without keeping who asked for it. | Legitimate interest in providing a fast, sustainable service (Art. 6(1)(f)). |
| Answering your questions, using your email and what you tell us. | Performance of a contract (Art. 6(1)(b)) or, if you don’t use the app, legitimate interest (Art. 6(1)(f)). |
| Handling your data protection rights. | Legal obligation (Art. 6(1)(c)). |
| Defending ourselves against claims, with whatever each case requires. | Legitimate interest (Art. 6(1)(f)). |
| Counting website visits, in aggregate only: page views, referrer, browser and country. More in the cookie policy. | Legitimate interest (Art. 6(1)(f)). |
Your account data and what you analyse are necessary to provide the service: without them we can’t. Anything based on your consent you can withdraw whenever you like, without affecting what was done before. And you can object to anything based on legitimate interest (see your rights).
We don’t use your data for advertising or to train AI models.
How an analysis works, step by step
- You send us a link or a photo. With a link, our server requests the public content from TikTok, Instagram or YouTube, as a browser would, and downloads the video to a temporary folder that is deleted at the end.
- The AI watches the video. The server extracts frames and sends them to Anthropic, whose AI (Claude) picks the moments where the clothes are clearest and recognises each item. With a photo, we send a downsized copy. To find shop hints we also send the title, description and comments. Never your email or your identifier.
- You choose what to search for. Viewing the items sends nothing else. Only when you choose to search for one is its crop published at a private link that expires after 10 minutes; SearchAPI passes it to Google Lens, which downloads the image and looks for similar products. The copy is deleted a minute after the link expires.
- You get links to shops. Sorted by similarity, with the price when the shop provides it. Buying is between you and the shop: we don’t sell anything or earn commission.
Shared analyses
Each video is analysed only once. If someone else analyses the same video (we recognise it by its identifier on the platform) or uploads exactly the same file (identical byte for byte), we show them the existing analysis instead of repeating it. What is reused is the items, their images and the shop results, never who asked for it: nobody can tell who analysed something before. The only things linked to your account are your history and the items you choose to search for.
With one of your photos, this means only someone who uploads that very same file, in other words someone who already has the photo, would see its analysis.
Who we share data with
We don’t sell your data or hand it over for advertising. It only reaches those who help us provide the service and, when you use the app, some companies that act on their own account.
Providers working on our behalf
They process data only to provide their service to us, following our instructions and under a data processing agreement (Art. 28 GDPR). They may not use it for their own purposes.
| Provider | What for | What data it receives | Safeguards |
|---|---|---|---|
| Supabase, Inc.EU: Paris (France), on Amazon Web Services | Database, accounts and sign-in, image storage and, for now, account emails. | Your account (email, hashed password, identifier and welcome answers), your wardrobe, collections, history and searches, your allowance and plan, your notification token, analysis images and sign-in logs, including your IP address. | Data processing agreement and standard contractual clauses. |
| [pending: server provider and country]To be verifiedProvider not chosen yet. | Hosts our analysis server, which downloads videos, prepares images and talks to the other providers. | Everything that goes through the server: the links and photos you send, the images of each analysis while it runs, your user identifier, your IP address (one minute, in memory) and technical logs. | Data processing agreement. |
| Anthropic, PBCUSTo be verifiedData Privacy Framework certification and retention period. | Its AI (Claude) recognises the clothes in the images and reads the title, description and comments to find shop hints. | Video frames or your downsized photo, crops of each item and the text of the title, description and comments. Never your email or your identifier. | The data processing addendum in its commercial terms and standard contractual clauses. |
| SearchAPITo be confirmedTo be verifiedThe company behind it, its country and its contract. | Runs the Google Lens search with the crop of the item you choose and sends us back the shop results. | The crop of the item, through a link that expires after 10 minutes, one word for the type of item, and the search country and language. No account data. | Data processing agreement and, if it processes data outside the EEA, standard contractual clauses. |
| 650 Industries, Inc. (Expo)USTo be verifiedIts processing agreement and Data Privacy Framework certification. | Its notification service delivers the “your analysis is ready” alert to your iPhone, through Apple. | Your iPhone’s notification token, the alert text (with the @ of whoever posted the video and the number of items), the link to the crop image and the analysis identifier. | Data processing agreement and standard contractual clauses. |
| Cloudflare, Inc.Global network; US companyTo be verifiedIts Data Privacy Framework certification. | Serves this website, protects it from attacks and counts visits in aggregate, without cookies. | When you visit the website: your IP address and browser details, to serve and protect it. Analytics only keeps totals: page views, referrer, browser and country. | Data processing addendum and standard contractual clauses. |
| [pending: email provider]To be confirmedPlannedNot in use yet. | Will send your account emails, such as password reset. Until then, Supabase sends them. | Your email address and the content of those emails. | Data processing agreement. |
Companies that receive data on their own account
They decide for themselves about what they receive and apply their own privacy policy:
- Google, for Google Lens: receives the crop of the item you choose to search for, through SearchAPI. In addition, product thumbnails load directly from Google or from the shop, so they receive your iPhone’s IP address. Google privacy policy.
- Apple: runs the App Store and, once available, the Pro payment. It also delivers notifications to your iPhone and the Live Activity updates our server sends to it directly. Apple privacy policy.
- TikTok, Meta (Instagram) and Google (YouTube): to analyse a link, our server requests the public content from them. They see a request from our server, not your IP address or your account.
- Shops: when you open a result, its website opens in Safari inside the app, and the shop receives what it gets from any visit: your IP address, your browser details and, if you buy, whatever you give it. We don’t use affiliate links.
What happens on shops’ websites and on the platforms is governed by their own policies, which we recommend you read. And if the law requires it, we will share what is necessary with the authorities or courts that ask for it.
Transfers outside the European Economic Area
Our database is in the EU, in Paris. Some providers are in the United States or may access data from there:
| Provider | What leaves the EEA | Safeguards |
|---|---|---|
| Supabase, Inc.EU: Paris (France), on Amazon Web Services | Data is stored in the EU, but its staff may access it from the US to provide support and keep the service running. | Data processing agreement and standard contractual clauses. |
| Anthropic, PBCUSTo be verifiedData Privacy Framework certification and retention period. | The images and text of each analysis are processed in the US. | The data processing addendum in its commercial terms and standard contractual clauses. |
| SearchAPITo be confirmedTo be verifiedThe company behind it, its country and its contract. | The crop of each item you choose to search for. | Data processing agreement and, if it processes data outside the EEA, standard contractual clauses. |
| 650 Industries, Inc. (Expo)USTo be verifiedIts processing agreement and Data Privacy Framework certification. | The token and the content of each notification. | Data processing agreement and standard contractual clauses. |
| Cloudflare, Inc.Global network; US companyTo be verifiedIts Data Privacy Framework certification. | The technical data of your visit to the website. | Data processing addendum and standard contractual clauses. |
For these transfers we use the safeguards provided for in the GDPR: the EU-US Data Privacy Framework where the company is certified (European Commission adequacy decision of 10 July 2023) and, otherwise, the standard contractual clauses approved by the Commission (Art. 46(2)(c) GDPR). You can ask us for a copy of these safeguards at [pending: privacy email].
Google and Apple, which receive data on their own account, apply their own safeguards.
How long we keep data
We keep each piece of data only as long as it is needed for the purpose we collected it for. After that we delete it or anonymise it, meaning we leave it in a form that can no longer be linked to you. If the law requires it, or to deal with a claim, we may keep something for longer, blocked and only until the claim period expires.
| What | How long |
|---|---|
| Your account: email, password (hashed), identifier and welcome answers | Until you delete your account. |
| Wardrobe, collections, history and pinned results | Until you delete them in the app or delete your account. |
| The items you asked us to search for and the start of your allowance week | Until you delete your account. |
| Photos of items saved in your wardrobe | Until you delete the item or your account. |
| Your iPhone’s notification token | Until you sign out on that iPhone or delete your account. |
| Your plan and Apple subscription details | While you have the plan or the account; afterwards, only what is needed to handle claims, kept blocked for the legal period.PlannedPro is not on sale yet. |
| The original file of a photo you upload | Never stored: it only stays in the server’s memory while it is analysed. |
| Downsized copies of the photos you upload (without EXIF), their crops and their analysis | Deleted with your account, unless someone else has uploaded the same file. In that case, after [pending: analysis retention period].To be verifiedDeletion together with the account is being built. |
| The downloaded video | Deleted when each analysis finishes. |
| From analysed public videos: cover, frames, crops, title, description, comments and the @ of whoever posted it | After [pending: analysis retention period], or earlier if the analysis is taken down.To be verifiedThe automatic deletion process is not built yet. |
| The temporary image for Google Lens | About 11 minutes: the link expires after 10 and the copy is deleted a minute later. |
| Shop results (products, prices and links) | Together with the analysis they belong to. They are not personal data. |
| The record of the cost of each call to our providers | When you delete your account it loses your identifier and becomes anonymous, for our bookkeeping. |
| Your IP address, for rate limiting | One minute, in memory only. |
| Server technical logs | Overwritten automatically as they rotate; at most [pending: log retention period].To be verifiedThey currently rotate by size: a time limit is still needed. |
| Supabase logs (sign-ins, with your IP address) | Supabase’s retention periods for our plan.To be verifiedExact period to be confirmed. |
| What Anthropic, SearchAPI and Expo receive for each analysis or alert | As set out in their processor terms, only to provide the service to us.To be verifiedEach provider’s period to be confirmed. |
| Support and privacy emails | [pending: support retention period]. |
| What is stored on your iPhone: your session, your appearance settings and the date you accepted sending images | The session, until you sign out; the rest, until you uninstall the app. The acceptance date is also removed when you delete your account. |
| Visits to this website | Only totals are kept, which do not identify you. |
What happens when you delete your account
You can delete it at any time from the app (how). When you do, we immediately delete your account and your welcome answers, your wardrobe and its photos, your collections, your history, the items you asked us to search for, your pinned results, your allowance, your plan and your notification tokens. We also delete the copies of the photos you uploaded and their analyses, unless someone else has uploaded exactly the same file.
We keep, with nothing that identifies you:
- the record of the cost of each call to our providers, no longer linked to your identifier;
- the analyses of public videos, which are shared and don’t record who asked for them.
If you ever have Pro, deleting your account doesn’t cancel your Apple subscription: cancel it first in Settings.
Your rights and how to exercise them
You have the right to:
- Access your data: find out whether we process it and get a copy.
- Rectify it if it is wrong or incomplete.
- Erase it. The quickest way is to delete your account from the app.
- Restrict its processing, for example while we look into a complaint of yours.
- Take it with you (portability): receive the data you gave us under the contract or with your consent in a structured, commonly used format (JSON), or have us send it to another controller where technically feasible.
- Object to what we do on the basis of legitimate interest, including if you posted a video or wrote a comment.
- Withdraw your consent at any time: for notifications, in iOS Settings; for your welcome answers, by writing to us or deleting your account.
- Not be subject to automated decisions with legal or similarly significant effects. We don’t make any (see automated decisions).
How to make a request
Write to [pending: privacy email] from your account email: that way we can confirm it’s you without asking for documents. If you write from another address or don’t use the app, we may ask for a little more information to confirm your identity, only what is necessary. If it concerns a specific analysis, include its link or identifier (how to find it).
We will reply within one month at the latest. If the request is complex or we receive many, we may extend this by two more months; if so, we will tell you within the first month. It is free, unless requests are manifestly unfounded or excessive.
If you disagree
You can lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, C/ Jorge Juan 6, 28001 Madrid, Spain, www.aepd.es) or with the data protection authority of your EU country. If you like, write to us first: almost everything can be sorted out by talking.
Children and teenagers
RefMe is for people aged 14 or over. In Spain, from that age you can consent to the processing of your data yourself (Art. 7 LOPDGDD); below it, your parents’ or guardians’ consent would be needed, and the app isn’t designed for that. If we learn that an account belongs to someone under 14, we delete it. If you are a parent or guardian and think your child has signed up, write to us at [pending: privacy email].
Automated decisions and profiling
We don’t make decisions based solely on automated processing that have legal effects on you or similarly significant effects (Art. 22 GDPR). The AI only recognises clothes and sorts results by similarity. We don’t build profiles, for advertising or anything else. The free allowance and usage limits are applied automatically and in the same way to everyone on the same plan.
How we protect your data
- Connections between the app, our server and our providers are encrypted (HTTPS).
- The database has row-level access rules: each account can only read and change its own data.
- Analysis images are kept in private storage, and the ones we send to Google Lens go out through signed links that expire after 10 minutes.
- Our providers’ secret keys are only on the server, never in the app.
- Passwords are stored hashed.
We’d rather be clear about the limits. The app receives an analysis’s images (cover, frames and crops) from addresses that contain the analysis identifier, a random code that in practice cannot be guessed; anyone who has that identifier can see them without signing in. Your wardrobe photos are in a folder named with your identifier, also random, and in the same way anyone who has their address can see them.
No system is infallible. If we suffered a security breach that put you at risk, we would notify the AEPD and, where the law requires it, you too (Arts. 33 and 34 GDPR).
What shows on the lock screen
Notifications and the Live Activity can be seen while your iPhone is locked. They include the @ of whoever posted the video and the number of items, for example “3 prendas del vídeo de @creadora.demo” (“3 items from @creadora.demo’s video”). If you’d rather they weren’t visible, go to Settings > Notifications > RefMe to hide previews or turn them off.
Changes to this policy and contact
If we change this policy, we will update the date and version at the top and note it in the change history at the bottom. If the change is significant, such as a new use of your data or a new provider outside the EU, we will let you know in the app or by email before it applies. If you’d like a previous version, just ask.
For any question about this policy or your data: [pending: privacy email]. For everything else, there’s the support page.
Change history
- 0.1 · 10 October 2026 — First draft.