Clonly Privacy Policy

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Last updated: October 10, 2026

This policy explains what data the Clonly app (iPhone and Android) and the clonly.app website collect, why we use it, who we share it with, and how you can exercise your rights. It complies with Colombian Statutory Law 1581 of 2012, Decree 1377 of 2013 (compiled in Decree 1074 of 2015) and other Colombian data protection rules. If you use Clonly from another country, you also have the rights your local law gives you (see section 12).

If there is any difference between this English version and the Spanish version, the Spanish version prevails.

1. Data controller

• Controller: José Mariano Arcila Londoño (individual)
• Address: Carrera 23A # 31-12, Guatapé, Antioquia, Colombia
• Email: soporte@clonly.app
• Phone: +57 311 644 4592

In this policy, "Clonly", "we" or "us" means the controller above.

2. Data we collect

a) Account data

• Your email address (to sign in with a code), or the identifier Apple provides if you use "Continue with Apple". In that case Apple may also give us your name the first time.
• The name you show in the app, username, profile initial, styles you choose, language, your invite code and, if you used one, the code you were invited with.
• Your phone's time zone and the time you choose for the daily notification.

b) Content you upload or create

• Photos of your clothes, the versions we create from them (product image and cutout), and the automatic description of each item (type, colors and style).
• Looks, your look calendar, worn items and look settings.
• Messages you exchange with Clo, the style assistant, and any photos you send her.

c) Avatar images (sensitive data) If you choose to create an avatar, you upload a selfie and a full-body photo. An image of your face is sensitive data (biometric) under Colombian law. Therefore:

• We only process it with your express consent, given on the avatar screen. Giving it is optional: you can use Clonly with the mannequins we provide, without uploading your face.
• We use the selfie and full-body photo only to create your avatar. The original photos are deleted as soon as the process ends, whether it succeeds or not.
• We keep the generated avatar image and the images of your looks on it until you delete your avatar or your account.
• We do not use your face to identify you, for facial recognition, or to train artificial intelligence models.

d) Purchases Payments are processed by Apple (App Store) or Google (Google Play). We never receive or store your card details. Through Adapty we receive what we need to give you your plan and credits: product purchased, dates, subscription status, store and transaction ID.

e) Technical and usage data

• App usage events (for example, "an item was cloned" or "a notification was opened"), device type, operating system and app version, to understand how the app is used and improve it.
• Error reports to fix bugs. They are set up not to send your IP address, email or screenshots.
• Your device's push token, to send you notifications if you allow them.

We do not collect your precise location, your contacts or other data from your phone.

3. How we use your data

1. To create and manage your account and let you sign in.
2. To provide the service: create digital versions of your clothes, build and save looks, create your avatar, show you how looks fit you, and answer your messages to Clo.
3. To manage your subscription, credits and the invite program.
4. To send the notifications you allowed (item ready, today's look, your plan and credits). You can turn them off in Profile → Notifications or in your phone settings.
5. To send required service emails, such as your sign-in code.
6. To answer support requests and handle your rights.
7. To measure app usage, find errors, prevent abuse and keep the service secure.
8. To comply with legal obligations.

We do not sell your personal data. We do not use it for third-party advertising.

4. Artificial intelligence

Clonly uses artificial intelligence models to create images of your clothes, describe them, create your avatar, dress it, and chat with you through Clo. To do this we send the necessary images and text to AI model providers (for example, Microsoft, Meta, OpenAI and Google) through OpenRouter, Inc. We configure it to use only providers that do not store or use your data to train their models.

AI results may not be exact (colors, sizes, fit or details). They are a visual reference, not an exact representation.

5. Who we share your data with

We only share data with providers that help us run the service. They act as processors and follow our instructions:

We may also share data when a competent authority requires it under the law.

6. International transfers

The providers in section 5 are mainly in the United States. By accepting this policy you authorize the transfer of your data to those countries for the purposes described. We choose providers with appropriate security measures and confidentiality commitments.

7. How long we keep your data

• Your account data and content are kept while you have an account.
• The selfie and full-body photo are deleted as soon as the avatar is created (or the attempt fails).
• If you delete your avatar, its image and the look images made with it are deleted.
• If you delete your account (Profile → Delete my account), we delete your photos, content, account data and your Adapty profile.
  • Technical backups are removed in their normal cycles.
  • Deleting your account does not cancel your subscription: you do that in the store.
• We may keep the minimum information a law requires us to keep, only for as long as it requires.

8. Your rights

As the owner of your data, you have the right to:

1. Know, update and correct your data.
2. Request proof of the consent you gave us.
3. Be informed of how we have used your data.
4. Revoke your consent and ask us to delete your data, unless there is a legal or contractual duty to keep it.
5. Access your data free of charge.
6. File complaints with Colombia's Superintendence of Industry and Commerce (SIC) about violations of the law, after making your request or complaint to us.

You can do many of these things yourself in the app: edit your profile, delete items, looks or your avatar, and delete your account.

9. How to make requests and complaints

Email soporte@clonly.app from your account's email address. Include your name, what you are requesting and, for a complaint, the facts and any documents you want to provide.

• Requests: we answer within 10 business days. If that is not possible, we explain why and answer within 5 more business days.
• Complaints (correction, update, deletion or non-compliance): we answer within 15 business days. If that is not possible, we explain why and answer within 8 more business days. If a complaint is incomplete, we ask for what is missing within 5 days; if it is not sent within 2 months, we consider it withdrawn.

José Mariano Arcila Londoño handles these requests, using the contact details in section 1.

10. Minors

Clonly is only for people aged 18 or older. We do not knowingly collect data from minors. If you believe a minor has given us their data, email us and we will delete it.

11. Security

We protect your data with reasonable measures:

• encrypted connections;
• private storage that only your account can access;
• restricted server access;
• deletion of the original avatar photos.

No system is 100% secure. If an incident affects your data, we will notify you, and the authorities when the law requires it.

12. Users outside Colombia

If you live in the European Union, the United Kingdom, the United States (including California) or another country with data protection laws, you have the rights those laws give you. For example: access, portability, correction, deletion, objection and restriction of processing, and complaints to your local authority.

Our legal bases for processing your data are:

• the contract (providing the service);
• your consent (avatar, notifications and analytics);
• our legitimate interest (security and improvements).

To exercise your rights, email soporte@clonly.app. We do not sell or "share" your personal information as those terms are defined under California law (CCPA/CPRA).

13. Changes to this policy

If we change this policy, we will publish the new version on clonly.app with its date. If the change is significant, we will let you know in the app or by email before it applies.

14. Consent

By creating an account and using Clonly, you authorize the processing of your data under this policy. Processing images of your face also requires your separate, express consent on the avatar screen.

Effective: October 10, 2026.