Privacy Policy
1. Who we are
Magnificent Marina is operated by [Legal entity name], a company registered in England and Wales under number [company number], with its registered office at [registered address] ("we", "us", "our"). We are the data controller for the personal data described in this policy. Our data protection contact is [privacy contact email]. Our Information Commissioner's Office registration number is [ICO registration number].
This policy explains what we collect when you use magnificentmarina.com and its account, wardrobe, partner and administration areas (together, the "service"), why we collect it, who we share it with and the choices you have. It should be read with our Terms of Service and Cookie Policy.
2. What we collect
Account information. Your email address, your name if you give it, a hashed version of your password (we never store the password itself), the date you accepted our terms, and the dates you created your account and last signed in.
Style profile. Sizes, preferred colours and materials, budgets by category, shipping country and currency, and your notification and privacy preferences. Everything in the profile is optional.
Wardrobe. Items you record as owned or under consideration, including names, colours, materials, brands, sizes, prices paid, notes, the photographs you upload of those items, outfits you save, and how often you log an item as worn.
Your model. Body measurements you choose to enter (height, shoulders, bust, waist, hips, inside leg), a skin tone and hair colour you select, and a photograph of your face if you upload one. We use the face photograph only to draw your model on your own screen. We do not use facial recognition, we do not extract biometric templates or identifiers from the photograph, we do not use it to identify you, and we do not share it. It is stored privately and is only ever returned to your signed-in session.
Photo try-on. If you choose to switch on photo try-on: a full-length photograph of yourself that you upload, the pictures produced from it, and a record of each picture (which garment, when, and what it cost us). The feature is optional and starts only when you tick the consent box. Each picture is produced by Google Cloud's Vertex AI virtual try-on model: we send your photograph and the garment image to Google, which returns the finished picture (see sections 6 and 7). As with your face photograph, we do not use facial recognition and we do not extract biometric identifiers. The photograph and the pictures are stored privately, shown only to you, and deleted when you ask.
Activity. Searches you make, looks you open, products you click through to, items you save or compare, alerts you set and notifications we send you. When you are signed in we keep a history of searches, looks and clicked products, with a snapshot of each item as it was at the time, so your record survives a product selling out or being delisted. You can switch this history off or clear it at any time in Settings.
Partner applications. If you apply to our partner programme: business name, website, country, contact name and email, positioning, shipping markets, returns policy, catalogue size, commission model, affiliate network details and the product feeds you upload.
Technical information. A one-way hash of your IP address, your browser's user agent string, request identifiers, timestamps and error logs. We keep the hash rather than the address for rate limiting and abuse prevention.
Correspondence. Anything you send us by email or through the service.
We do not knowingly collect payment card details, government identifiers or special category data. Please do not include such information in notes or photographs.
3. How we use it and our lawful bases
| Purpose | Data | Lawful basis |
|---|---|---|
| Providing your account, wardrobe, model, outfits, alerts and notifications | Account, profile, wardrobe, model, alerts | Performance of our contract with you |
| Ranking looks and suggesting outfits to you | Profile, wardrobe, activity | Performance of our contract; our legitimate interest in making the service useful. You can switch personalisation off in Settings. |
| Making photo try-on pictures | Your try-on photograph, the garment image, the pictures produced | Your consent, given when you add the photograph. You can withdraw it at any time by deleting the photograph in your wardrobe. |
| Keeping your history | Searches, looks opened, products clicked | Our legitimate interest in letting you find things again. You can switch it off or clear it. |
| Recording click-outs to merchants and paying commission | Product, look, time, hashed IP, your account id if signed in | Our legitimate interest in operating an affiliate marketplace and reconciling commission |
| Sending service emails (welcome, invitations, password resets, alerts you asked for) | Email address, name, alert details | Performance of our contract; your consent for alerts and digests, which you can withdraw |
| Security, fraud and abuse prevention, rate limiting | Technical information, account information | Our legitimate interest in keeping the service safe; our legal obligations |
| Running the partner programme | Partner applications and feeds | Performance of the partner contract; our legitimate interests |
| Improving the service with aggregate statistics | Activity, in aggregate and without identifying you | Our legitimate interests. You can opt out of analytics in Settings. |
| Complying with the law and defending claims | Any of the above as required | Legal obligation; legitimate interests |
Where we rely on legitimate interests we have balanced them against your rights and interests. You can ask us for that assessment.
4. Automated suggestions
Match scores, suggested outfits and your model are produced automatically from the data above. They are illustrative only. They have no legal or similarly significant effect on you, and we make no decisions about you based on them.
5. Click-outs, merchants and affiliate networks
When you press Buy we record the click and send you to the merchant's site, sometimes through an affiliate network such as Awin, Rakuten or CJ. We pass a click reference, not your name or email. The merchant and the network are independent controllers of anything you do on their sites, including any purchase, and their own privacy policies apply. We may receive a commission on purchases you make after a click-out; this does not change the price you pay.
6. Who we share data with
- Our hosting and infrastructure provider, [hosting provider], which stores our database and backups.
- Our email delivery provider, [email provider], which sends service emails on our behalf.
- Google Cloud ([Google Cloud EMEA Limited or Google Ireland Limited: confirm the contracting entity for a UK customer]), which runs the Vertex AI virtual try-on model that produces photo try-on pictures. Google acts as our processor under [the Google Cloud Data Processing Addendum: confirm], processes the images in [europe-west4, Netherlands], does not use them to train its models, and does not keep them beyond the request, except that Google may keep a copy of a request flagged by its abuse monitoring for up to 90 days. Only shoppers who switch photo try-on on are affected, and only when they ask for a picture.
- Affiliate networks and merchants, which receive click references as described above.
- Partners in the partner programme, which see aggregate click counts for their own products. They do not see who you are.
- Professional advisers, insurers and auditors where necessary.
- Courts, regulators, law enforcement and other authorities where the law requires it or to protect our rights, property or safety or those of others.
- A buyer or successor if we sell or transfer the business or its assets, in which case this policy continues to apply.
We do not sell personal data. We do not share your wardrobe, model, measurements or face photograph with anyone. Your photo try-on photograph goes only to Google Cloud, only when you ask for a picture, and only if you have switched photo try-on on.
7. International transfers
Our providers may process data outside the United Kingdom, including in [countries, for example the European Economic Area and the United States]. Where they do, we rely on UK adequacy regulations, the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with technical safeguards. Details are available on request. Photo try-on pictures are processed by Google Cloud in [europe-west4, Netherlands], inside the European Economic Area, which the United Kingdom recognises as providing adequate protection.
8. How long we keep it
- Account, profile, wardrobe, model and outfit data: for as long as your account exists. You can delete individual items in your wardrobe, clear your history from your account, or delete your whole account in Settings at any time.
- History: until you clear it or delete your account.
- Photo try-on: your photograph and the pictures made from it, until you delete them in your wardrobe or delete your account. The record of each picture (garment, date and cost, with no image) stays with your account so that the monthly allowance can be worked out.
- Deleted accounts: removed from the live database immediately, and any click or search records are kept without a link to you. Copies may persist in encrypted backups for up to [30 days] before being overwritten.
- Click records: kept for up to [24 months] for commission reconciliation, after which they are anonymised.
- Server logs and security records: up to [12 months].
- Partner records: for the life of the partnership and [6 years] afterwards for tax and contractual purposes.
9. Your rights
Under the UK General Data Protection Regulation and the Data Protection Act 2018 you can ask us to: give you access to your data (you can download a copy yourself from Settings; the photographs you uploaded are not in that file but can be viewed and saved from your wardrobe); correct it; erase it (you can delete your account yourself from Settings); restrict or object to how we use it; give it to you or another provider in a portable format; and withdraw any consent you have given. Switching off personalisation, history, analytics and marketing emails in Settings exercises several of these rights directly.
To exercise any other right, email [privacy contact email]. We may ask you to confirm your identity. We will respond within one month, or tell you if we need longer. You can also complain to the Information Commissioner's Office at ico.org.uk, although we would welcome the chance to address your concern first.
10. Security
Passwords are hashed with scrypt. Sessions use signed, HttpOnly cookies. All traffic is encrypted in transit. Images you upload are stored privately and served only to your signed-in session. Access to production systems is limited to the people who need it. No system is perfectly secure, and you are responsible for keeping your password confidential and for the devices you use.
11. Children
The service is for adults aged 18 and over. We do not knowingly collect data from anyone under 18. If you believe a child has created an account, contact us and we will remove it.
12. Cookies and local storage
We use one strictly necessary cookie to keep you signed in and a small amount of local storage for your theme, your place in the guided tour and your life-size screen calibration. Details are in our Cookie Policy.
13. Changes to this policy
We may update this policy. We will change the version and date above and, for material changes, tell you by email or by a notice in the service. If you continue to use the service after a change takes effect, the updated policy applies.
14. Contact
[Legal entity name], [registered address]. Email: [privacy contact email].