Data Protection — With Jacq
Legal

Data Protection

How With Jacq protects your personal data, our obligations as a data controller, and the technical and organisational measures we have in place to keep your information safe.

Last UpdatedApril 2026
Effective DateApril 2026
ControllerWith Jacq Ltd, London
Version1.0

Style Smarter  ·  Rewear Better  ·  Build Confidence

Compliance frameworks:
UK GDPR & ICO Registration
EU GDPR (Regulation 2016/679)
CCPA / CPRA & US State Laws
01

Our Commitment to Data Protection

At With Jacq, data protection is not a legal checkbox — it is a core part of how we build. We are a technology company that handles sensitive personal data including wardrobe information, images, style preferences and body measurements. We take that responsibility seriously.

We are committed to handling your data with transparency, care and the highest applicable legal standards. Our approach is informed by the same values that guide our product: honesty, intentionality and respect for the individual.

Our Data Philosophy

We collect only what we need. We keep it only as long as necessary. We never sell it. We protect it with industry-standard security. And we give you full control over it at all times.

02

Data Controller

With Jacq Ltd is the data controller responsible for all personal data processed through our website and app. As data controller, we determine the purposes and means of processing your personal data and are accountable for compliance with applicable data protection law.

  • Company: With Jacq Ltd
  • Registered in: England and Wales
  • Location: London, United Kingdom
  • ICO Registration: Registered (or pending registration) with the Information Commissioner's Office
  • Contact: info@withjacq.com — subject line: Data Protection
03

Our Data Protection Principles

We process personal data in accordance with the following principles, as required by UK and EU GDPR:

  • Lawfulness, fairness and transparency — we process data lawfully, fairly and openly
  • Purpose limitation — data is collected for specified, explicit and legitimate purposes only
  • Data minimisation — we collect only what is adequate, relevant and necessary
  • Accuracy — we take reasonable steps to ensure data is accurate and kept up to date
  • Storage limitation — data is kept no longer than necessary for its stated purpose
  • Integrity and confidentiality — data is processed securely using appropriate technical and organisational measures
  • Accountability — we are responsible for and can demonstrate compliance with these principles
04

What Data We Hold and Why

We hold personal data across the following categories. Each category is held only for the purpose specified and is subject to appropriate access controls.

Identity and Contact Data

Name, email address and account credentials. Held to create and manage your account and communicate with you. Legal basis: contract performance.

Wardrobe and Style Data

Clothing items, images, style preferences, colour analysis, body measurements and lifestyle information you choose to share. Held to provide personalised styling recommendations. Legal basis: contract performance and consent.

Image Data

Photographs you upload for wardrobe cataloguing or AI Twin Try-On. Held solely to provide the relevant feature. Images are not shared, sold or used to train third-party models without explicit consent. Legal basis: consent.

Usage and Technical Data

Device information, IP address, app usage patterns, session data and crash reports. Held to improve our service and ensure security. Legal basis: legitimate interests.

Financial Data

Transaction records for subscription payments. Card details are processed by our payment provider — we do not store them. Legal basis: contract performance and legal obligation.

Communications Data

Messages you send us via email or contact forms. Held to respond to your enquiries and improve our service. Legal basis: legitimate interests.

05

Security Measures

We implement technical and organisational measures appropriate to the risk posed by the data we hold. Our security approach includes:

Technical Measures

  • Encryption of data in transit using TLS/HTTPS across all platform communications
  • Encryption of sensitive data at rest
  • Secure cloud infrastructure with access controls and audit logging
  • Regular security testing and vulnerability assessments
  • Multi-factor authentication for internal systems
  • Automated monitoring for unusual access patterns or potential breaches

Organisational Measures

  • Data protection training for all team members with access to personal data
  • Role-based access controls — staff access only the data required for their role
  • Data processing agreements with all third-party processors
  • A documented data breach response procedure
  • Regular review of data protection policies and procedures
  • Privacy by design principles applied to all new features and product development

No system is entirely immune to security risks. In the event of a breach, we will notify affected users and the relevant supervisory authority in accordance with legal requirements.

06

AI Technology and Your Data

With Jacq uses AI to power its core features. We believe AI should be transparent, safe and in service of the user — not the other way around.

Our AI Data Commitment

We do not use your personal data — including your images, wardrobe content or style preferences — to train general-purpose AI models or to share data with third-party AI providers for training purposes. Your data serves you, not our models.

How AI Processes Your Data

  • Style recommendations are generated using your wardrobe and preference data, processed in a secure environment
  • AI Twin Try-On imagery is processed transiently — images are not permanently stored beyond the session unless you explicitly save them
  • Anonymised, aggregated data may be used to improve our own models — never in a form that identifies you personally
  • You can opt out of contributing to model improvement at any time in your account settings

AI Safety and Fairness

Our AI systems are designed to avoid harmful outputs. We do not build systems that generate content designed to create body insecurity, promote disordered relationships with clothing, or exploit emotional vulnerability. We actively monitor our AI outputs for bias and work to ensure recommendations are inclusive, respectful and genuinely useful across all body types, skin tones and personal styles.

Human Oversight

Significant decisions that may affect your account or service experience are not made by automated systems alone. Where automated processing has a meaningful impact on you, you have the right to request human review. Please contact us at info@withjacq.com.

07

Behavioural Intelligence and Wellness Personalisation

With Jacq goes beyond wardrobe organisation. We use behavioural intelligence — the analysis of how you interact with clothing, shopping behaviour, return patterns and lifestyle context — to deliver recommendations that are genuinely personal to you.

Our Approach

With Jacq is inclusive by design, not by categorisation. We do not label users or make assumptions. Instead, our AI learns through your behaviour, preferences and the context you choose to share — returning recommendations that serve your whole life, not just your wardrobe.

What Behavioural Intelligence Means at With Jacq

Our AI analyses patterns in how you dress, what you reach for, what you avoid, and how your needs change across different contexts — work, social occasions, home, travel. Over time, this builds a genuinely personalised understanding of what works for you that no manual style quiz can replicate.

  • Shopping and return behaviour — understanding what you buy, keep and return to surface better recommendations
  • Wardrobe usage patterns — identifying what you wear, what you overlook, and what combinations work for your life
  • Lifestyle context — work environment, family commitments, travel frequency and social occasions
  • Style evolution — how your preferences and needs change over time

Wellness and Health Context — Your Choice

With Jacq operates at the intersection of fashion and wellness. Users may choose to share health and wellness context that allows us to make more meaningful recommendations. This is entirely optional and always consent-based.

Examples of how wellness context improves recommendations include fabric and material guidance for users managing skin sensitivities or conditions affected by certain chemicals, comfort and adaptive styling suggestions informed by physical needs, and dressing strategies that support confidence during significant life stages such as pregnancy, postpartum recovery or menopause.

Health and wellness information is classified as special category data under UK and EU GDPR. We process it only with your explicit, informed consent. You can withdraw consent and request deletion of this data at any time. It is never shared with third parties, used for profiling beyond your own personalisation, or referenced in any aggregated or anonymised dataset.

The Affirmations Feature

With Jacq includes a daily affirmations and confidence feature designed to support how women see themselves, not just how they dress. If you engage with this feature, the inputs you provide help personalise the tone and nature of style guidance you receive. This data is used solely to serve your experience within the app. It is not analysed for emotional state, shared externally or used for any purpose beyond your personalisation.

Community and Social Features

With Jacq includes a style community where users can share, save and engage with looks. Participation is entirely optional. When you share content in the community, you control what is visible. Community engagement data — looks you save, styles you engage with — is used to improve your personal recommendations. It is not used to build social comparison metrics, influence your feed through anxiety-driven algorithms, or sold to advertisers.

Our community is designed to be a space of self-expression and self-discovery. Not comparison. Not performance.

Inclusive by Design

With Jacq is built to serve every woman equally — across all body types, skin tones, ages, backgrounds and lifestyles. We do not require users to disclose protected characteristics. Our AI learns what works for each individual through behaviour and preference, not through labelling. Inclusivity at With Jacq is a design principle, not a data category.

Your Rights Over Behavioural Data

  • You can opt out of behavioural profiling at any time in your account settings
  • You can withdraw consent for wellness and health context data at any time
  • You can request a summary of what behavioural insights With Jacq holds about you
  • You can request full deletion of all behavioural and wellness data

To exercise any of these rights, contact us at info@withjacq.com with the subject line Behavioural Data Request.

08

International Data Transfers

With Jacq is based in the United Kingdom. Some of our service providers and infrastructure partners are based outside the UK and European Economic Area. Where data is transferred internationally, we ensure appropriate safeguards are in place.

Transfer Mechanisms

  • UK: International Data Transfer Agreements (IDTAs) approved by the ICO
  • EU: Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions: Transfers to countries with a UK or EU adequacy decision where applicable
🇬🇧 UK Post-Brexit

Following Brexit, the UK operates its own data protection regime under the UK GDPR. We maintain separate transfer mechanisms for UK-to-EU and UK-to-rest-of-world transfers, reviewed in line with ICO guidance.

🇺🇸 US Data Transfers

Where data is transferred to the United States, we rely on Standard Contractual Clauses supplemented by additional technical safeguards. We conduct transfer impact assessments for US-based processors handling significant volumes of personal data.

As With Jacq expands globally, this section will be updated to reflect the transfer mechanisms in place for each new market. We are committed to maintaining lawful, documented transfer mechanisms in every jurisdiction we operate in.

09

Data Breach Response

Despite our security measures, no system can guarantee absolute protection. We have a documented data breach response procedure to ensure any incidents are handled quickly and responsibly.

Our Response Process

  • Identification and containment of the breach as quickly as possible
  • Assessment of the scope, nature and risk to affected individuals
  • Notification to the ICO within 72 hours where the breach is likely to result in risk to individuals (as required by UK GDPR)
  • Direct notification to affected users without undue delay where the breach poses a high risk to their rights and freedoms
  • Documentation of all breaches, including those not requiring notification
  • Post-incident review and implementation of measures to prevent recurrence
🇪🇺 EU GDPR — Breach Notification

For users in the EU, breach notification obligations are governed by Article 33 and 34 of the EU GDPR. We will notify the relevant EU supervisory authority and affected EU data subjects in accordance with these obligations.

10

Your Data Rights

You have the following rights in relation to your personal data. These rights apply regardless of where you are located, subject to applicable local law.

  • Access: Request a copy of the personal data we hold about you (Subject Access Request)
  • Rectification: Request correction of inaccurate or incomplete data
  • Erasure: Request deletion of your data where there is no legitimate reason to continue processing it
  • Restriction: Request that we pause processing of your data in certain circumstances
  • Portability: Receive your data in a structured, commonly used, machine-readable format
  • Object: Object to processing based on legitimate interests or for direct marketing
  • Automated decisions: Request human review of any significant automated decision made about you
  • Withdraw consent: Withdraw consent at any time where processing is based on consent

To exercise any of these rights, email info@withjacq.com with the subject line Data Rights Request. We will respond within 30 days. We may need to verify your identity before processing your request.

If you are not satisfied with our response, you have the right to lodge a complaint with the ICO (uk — ico.org.uk), your national data protection authority (EU), or the California Privacy Protection Agency (US — California residents).

11

Children and Data Protection

With Jacq is not directed at children under the age of 16. We do not knowingly collect or process personal data from anyone under 16.

In the United States, we comply with the Children's Online Privacy Protection Act (COPPA) and do not knowingly collect data from children under 13.

If you believe a child has created an account or provided us with personal data, please contact us immediately at info@withjacq.com and we will delete the data promptly.

12

Updates to This Policy

We review and update this Data Protection Policy regularly to reflect changes in our practices, technology or applicable law. The version number and effective date at the top of this page will be updated with every revision.

We will notify users of material changes by email and will post a summary of key changes alongside any update. As With Jacq expands into new markets, this policy will be updated to reflect the applicable data protection frameworks in those regions.

13

Contact Us

For all data protection enquiries, requests or concerns, please contact us directly:

Data Protection Enquiries

With Jacq Ltd
London, United Kingdom

Email: info@withjacq.com
Subject line: Data Protection

We aim to respond to all data protection requests within 30 days. If you are unsatisfied with our response you may escalate to the ICO (ico.org.uk) in the UK, your national supervisory authority in the EU, or the California Privacy Protection Agency if you are a California resident.

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