Privacy policy

Effective Date: August 2025

Hello and welcome to Persi’s privacy policy. Persi is a fashion technology solution that sits on the websites of our partner retailers and is designed to enhance the retail experience for customers, including the ability to:

find personalised product and outfit ideas comprising items from our partner retailers that fit your style and wardrobe, to make shopping smarter, faster and tailored to what you actually wear
complete our style quiz (including submitting your measurements, style preferences, feedback, owned wardrobe item and images) to help us understand your profile and style preferences
explore the products of our affiliated retail partners, through a hosted and integrated Persi user interface embedded on the retailer’s own website (whenever you see the Persi icon) and purchase their items if you wish
upload pictures of clothing you already own to help us build a clear picture of your wardrobe and style goals to personalise your product/outfit suggestions
save your style preferences and wardrobe items to get more accurate recommendations over time

This privacy policy gives you information about how Persi collects, uses and protects your personal data through your use of our platform, which refers to all our sites located at or accessible through https://www.yourpersi.com/, any associated domains and any downloadable mobile application or web application, which may be accessible on desktop and mobile devices, including any data you may provide when you register with us, use our services, sign up to our newsletter.

This website is not intended for children (those under 13 for GDPR purposes) and we do not knowingly collect data relating to children. In the event that we become aware that we have collected personal data from a child without parental consent, we will take reasonable steps to delete such information from our records.

This policy supplements (and its terms apply in addition to) any other terms of use or other terms and conditions agreed between you and us from time to time, including but not limited to our Platform Terms of Use.

Controller

We are Your Persi Limited, a company registered in Scotland under company number SC831953, with registered office at 5 South Charlotte Street, Edinburgh, City of Edinburgh, Scotland, EH2 4AN (collectively referred to as "Persi", "we", "us" or "our" in this privacy policy). We are the controller and responsible for your personal data.

We are registered with the Information Commissioner's Office (ICO) as a data controller under registration number ZB887149.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. Our DPO is Matthew Deakins, who can be contacted at matt@yourpersi.com. If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 7), you may also contact us using the information set out in the contact details section (paragraph 8).

Contents of this Privacy Policy:

The types of personal data we collect about you
How is your personal data collected?
How we use your personal data
Disclosure of your personal data
Data security
Data retention
Your legal rights
Contact details
Complaints
Changes to the privacy policy and your duty to inform us of the changes
Third-party links

1. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes your title, first name, last name, username or similar identifier, gender, date of birth, company/employer and role, and your image or likeness (if your face or other identifying features are visible in any photos you choose to upload of your wardrobe).
Contact Data includes email address and telephone numbers.
Transaction Data includes details about products you purchase from our retail partners following our platform-generated recommendations, and your unique checkout ID.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our platform.
Profile Data includes your username and password, photographs, your style quiz answers (including height, clothing size, body shape, fashion interests, preferences and style goals), feedback and other survey responses, and your style profile generated from your quiz responses and uploaded images.
Usage Data includes information about how you interact with and use our platform and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect or process any payment or billing information.

Special category personal data

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific platform feature or feature of our services in order to analyse general trends in how users are interacting with our platform/services to help improve the platform, our service offering and retailer’s offerings.

We do not collect or process any personal information from you that is considered "Sensitive Personal Information" under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- register for our services;
- create an account on our platform;
- complete a style quiz at the time of account registration;
- subscribe to our publications;
- request marketing to be sent to you;
- enter a competition or promotion; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns (such as clicks, sessions logs and viewed products). We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Contact and Transaction Data is collected from our retail partners when you purchase products from them following our recommendations;
- Technical Data is collected from analytics providers such as PostHog (in anonymised form).

3. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

  
      Purpose/Use
      Type of data
      Legal basis
    

  
      To register you as a new customer
      (a) Identity 
(b) Contact
      Performance of a contract with you
    

      To provide you with our services (providing personalised product and outfit recommendations to users)
      (a) Identity 
(b) Contact 
(c) Profile
      (a) Performance of a contract with you (your use of the platform) 
(b) Having obtained your prior consent
    

      To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Dealing with your requests, complaints and queries
      (a) Identity 
(b) Contact 
(c) Profile 
(d) Marketing and Communications
      (a) Performance of a contract with you 
(b) Necessary to comply with a legal obligation 
(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)
    

      To track and process purchase referrals where you purchase products from our retail partners following our recommendations
      (a) Identity 
(b) Transaction 
(c) Technical
      Necessary for our legitimate interests (in tracking referrals and receiving commission from our retail partners)
    

      To build and personalise your style profile
      (a) Identity 
(b) Contact 
(c) Transaction 
(d) Profile 
(e) Usage
      (a) Necessary for our legitimate interests (so that our Services can be more relevant and useful to you and our retail partners) 
(b) Having obtained your prior consent
    

      To enable you to partake in a prize draw, competition or complete a survey
      (a) Identity 
(b) Contact 
(c) Profile 
(d) Usage 
(e) Marketing and Communications
      (a) Performance of a contract with you 
(b) Necessary for our legitimate interests (to study how customers use our products/services)
    

      To administer and protect our business and platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
      (a) Identity 
(b) Contact 
(c) Technical
      (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) 
(b) Necessary to comply with a legal obligation
    

      To carry out research and analytics of aggregated and anonymised data to enhance our services, comprehend usage patterns, and to optimise and improve the functionality of our platform
      (a) Transaction 
(b) Technical 
(c) Profile 
(d) Usage
      (a) Necessary for our legitimate interests (to develop our services, grow our business, and to enable trend analysis and anonymised reporting)
    

      To improve our platform, services, recommendation algorithms, customer relationships and experiences and to measure the effectiveness of our communications and marketing
      (a) Identity 
(b) Contact 
(c) Profile 
(d) Usage 
(e) Marketing and Communications 
(f) Technical
      Necessary for our legitimate interests (to study how customers use our products/services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
    

      We use artificial intelligence (AI) and automated data analysis tools to generate insights to help us better understand your style preferences, and support tailored recommendations aimed at improving your overall platform experience
      (a) Identity 
(b) Profile 
(c) Transaction 
(d) Technical 
(e) Usage
      Having obtained your explicit consent
    

      To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you
      (a) Identity 
(b) Contact 
(c) Technical 
(d) Usage 
(e) Profile 
(f) Marketing and Communications
      Consent, having obtained your prior consent to receiving direct marketing communications
    

      To carry out market research through your voluntary participation in surveys
      (a) Identity 
(b) Contact 
(c) Transaction 
(d) Technical 
(e) Profile 
(f) Usage
      Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services)
    

Direct marketing

We want to ensure that you are informed and aware of the best services and promotions that we can offer you. During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Persi via email, SMS or Telephone.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out/unsubscribe links within any marketing communication sent to you or by contacting us at privacy@yourpersi.com.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to service availability notifications, updates to our terms and conditions, and checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy.

4. Disclosure of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above. We may sometimes contract with the following third parties to supply certain products and services:

Shopify, which powers our online platform and facilitates integration with our retail partners
Amazon Web Services (AWS), which provides infrastructure and hosting support to help us maintain the security, availability, and performance of our platform
Google Cloud Platform, which we use for cloud hosting, model training, data storage, data processing and computing services to host and manage our systems and customer data on our behalf
Neo4J, which we use for storing knowledge to provide style recommendations and provide our services
Posthog Analytics, which we use for understanding our platform and making improvements

In relation to purchase and recommendation data generated through our platform, we may act as joint controllers together with our retail partners. This means that we jointly determine the purposes and means of processing certain personal data related to your transactions and interactions. Where we act as joint controllers, we will cooperate with our retail partners to ensure compliance with data protection laws and provide transparent information about how your data is used. You can contact us or the relevant retail partner to exercise your data protection rights concerning such data.

When you make a purchase through one of our retail partners’ websites following a recommendation from our platform, we share a unique checkout ID with the relevant retailer. This checkout ID allows us to track purchases and receive commission, but it does not identify you directly. The retailer may combine this checkout ID with information they hold about you in order to complete your purchase and manage their relationship with you. We recommend reviewing the retailer’s privacy policy for details of how they handle your personal data.

Other than the checkout ID described above, we do not share your personal data with retail partners. Only aggregated and anonymised data insights and recommendations (not your full profile) may be shared with our retail partners to enhance discovery or analytics, for example to assist them in informing future product design. This data does not identify you, and we will not otherwise share any of your personal data with retailers, for marketing purposes or otherwise. Images and quiz responses you provide are used solely to personalise your recommendations and improve the quality of our services (including training our AI systems and improving our recommendation models/algorithms).

We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. All third-party providers we use are vetted for compliance with industry security standards and data protection regulations. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

All personal data under our control is stored and processed using cloud infrastructure located within the European Economic Area (EEA), and we have configured our services to restrict data transfers outside the EEA.

5. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These include (but are not necessarily limited to) end-to-end encryption (both in transit (using TLS) and at rest), system monitoring for unusual activity with alerts are in place to detect and respond quickly to potential security threats, access controls, regular software updates and patching, firewalls and anti-malware software, data backup and recovery plans.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. If you have an account with us, we retain your data for as long as you have an active account with us. If you do not use your account for a prolonged period (e.g. 3 years), we may delete or anonymise your data, unless we are required to retain it longer for legal reasons. You may request deletion of your data at any time (see paragraph 7 below). We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 7 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of Marketing’ in paragraph 3 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 3 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details in paragraph 8).

Automated decision making and profiling

We may carry out profiling as part of our services to analyse or predict your fashion preferences. We may use Transaction, Technical, Profile and Usage Data generated via the platform to help us better understand your style preferences, and support tailored recommendations aimed at improving your overall platform experience.

This processing does not involve automated decision-making that has legal or similarly significant effects on you. All insights are used solely to offer you product/outfit options, not to make binding decisions about individuals

The use of AI is subject to strict oversight, and we ensure that the processing is transparent and explainable, appropriate safeguards are in place to protect your rights and freedoms, and the outputs are used responsibly and proportionately. The use of such profiling is necessary in order for us to deliver our services. If you choose to object to this processing, we may not be able to provide our services to you.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us via email at privacy@yourpersi.com or via post at 5 South Charlotte Street, Edinburgh, City of Edinburgh, Scotland, EH2 4AN.

9. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

10. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in August 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

11. Third-party links

This website may include links to third-party websites, plug-ins and applications (including third party retail websites). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.