Biometric Data Policy

Effective date: 14 October 2026. Version 1.0.

LOOM is run by Riccardo Pittiglio, trading as LOOM Weather, Strassergasse 8-12/4/10, 1190 Vienna, Austria ([email protected]). This policy says how we handle biometric data. The rest of your data is covered in our Privacy Policy.

1. What we treat as biometric data

If you choose to create an Avatar, we treat all of the following as biometric data:

• the selfie you take or upload;
• the Avatar LOOM makes from it, including the Avatar options you did not choose;
• the try-on pictures that show your Avatar.

We do this whether or not a particular law would call them biometric. LOOM does not compute or keep a face template, face geometry or a "faceprint", and does not use your face to recognise or identify you.

Try-ons on LOOM's generic models, your closet photos and photos you send the stylist are not used for anything biometric.

2. Why we collect it

Only to make your Avatar and to show you how clothes look on it. Nothing else.

3. Who receives it

• FASHN AI (United Kingdom; processing in the UK, the EU and the US) makes the Avatar and the try-ons.
• fal.ai (United States) removes backgrounds and helps make the Avatar.
• Cloudflare stores the pictures.
• Cloudinary holds a few older pictures from before we moved to Cloudflare (garment originals, worn-outfit and try-on pictures and chat thumbnails, about 60 today), and a copy of a new picture only if Cloudflare fails at the moment it is saved.

All of them act only on our instructions, under written contracts. We do not disclose your biometric data to anyone else, except where a law or a valid court order requires it.

4. What we never do

We never sell, lease, trade, license or otherwise profit from your biometric data. We never use it to train any AI model, never share it with brands, and never use it for advertising. This holds whatever you choose in LOOM's data settings.

If you choose "Share anonymous trends with brands", what LOOM records for that is facts about clothes, weather and choices, never a picture, your face or your Avatar. The only Avatar-related fact is that a try-on happened and whether it was on an Avatar or on a generic model, together with the garments. Product emails use only your email address and are not connected to your Avatar or selfie.

5. Your consent comes first

• Before you take or upload a selfie, LOOM shows a separate consent screen. It explains:
  • what is collected;
  • why;
  • who receives it;
  • how long it is kept.
• It has one tick box: "This is a photo of me, and I am 18 or older". The Agree button stays off until you tick it. Without your consent, no selfie is taken.
• We record your consent with its date, time and the version of the wording (bio-1.0). You can withdraw it at any time in Profile.
• If the wording changes, we ask again.
• The Avatar is for people 18 and over. The app asks you to confirm this before you make one.
• Saying no leaves the rest of LOOM working.

6. Where the Avatar is not offered

The Avatar (creating one, and trying on with one) is not available to people in Illinois, Texas or Washington. To check this we use four signals:

• the state you tell us you live in: on a US App Store account, the app asks you once, when you go to create an Avatar;
• your phone's own location check, if you have allowed it. The app sends us only whether the phone is in Illinois, Washington or Texas, never coordinates, and nothing about where you are is kept;
• the country of your App Store account;
• the country your connection comes from.

• If any one of these says Illinois, Texas or Washington, the Avatar is off.
• If a US account gives us no state signal at all, it is off too.

The same check runs each time you try on with an Avatar.

The Avatar is not offered in Quebec before 4 January 2027.

7. How long we keep it, and how we destroy it

The selfie itself is deleted as soon as you have chosen your Avatar. After that, LOOM keeps only the Avatar.

We permanently delete the rest of your biometric data at the earliest of:

1. when you withdraw your face consent (in the app: Profile, Account & Privacy, Withdraw Face Consent), which deletes your selfie, Avatar and try-ons;
2. when you delete your LOOM account;
3. when you withdraw your consent;
4. 12 months after you last used your Avatar (made, tried on or worn an Avatar look). A job runs every day to do this.

These are shorter than every limit we know of:

• Illinois (BIPA): 3 years after the last interaction.
• Texas: 1 year after the purpose ends.
• Colorado: 24 months after the last interaction.

Destruction means:

• the files are deleted from our storage;
• the records are deleted from our database.

Copies at our providers expire by themselves:

• FASHN says it keeps generated pictures for up to 72 hours and does not store the pictures sent to it.
• fal.ai is told to keep nothing for our Avatar requests: every request carries a store-nothing header, and its media expires after one hour.

We keep a log that a deletion happened, and the record of your consent (what you agreed to, which version, when), for the life of your account plus 5 years, as proof. Neither ever contains biometric data.

8. How we protect it

• Encrypted in transit.
• Stored on Cloudflare R2. Each picture has its own long, random web address that cannot be guessed or listed, and it is never shown to other people.
• Protected with at least the care we use for our most sensitive information.

If a security incident affects biometric data:

• we treat it as high risk and tell the people affected;
• we tell the authorities as each country's law requires (in the EU and the UK within 72 hours of learning of it);
• we record what happened and what we did.

This is our written incident procedure.

9. Your rights

You can see, download or delete your biometric data, or withdraw consent, at any time: in the app (Profile, Account & Privacy), or by writing to [email protected]. We answer within one month. Your other privacy rights are in our Privacy Policy.

10. Changes

We will publish changes here before they take effect, and ask for your consent again if what we do changes.