Privacy Policy

1. About this Privacy Policy

This Privacy Policy explains how Asociația Alfabetul Scripor (“we”, “us”, “our” or the “Data Controller”) collects, uses, stores, shares and protects personal data when you use the Touch 'n Match mobile application, also referred to as Touch'n Match or TNM (the “App”), the Touch 'n Match website and the related digital services, accounts and features made available as part of the Touch 'n Match ecosystem (together, the “Services”).

Touch 'n Match is an inclusive connected-fashion platform built around the Scripor Alphabet®️ tactile colour system.

The platform enables users to interact with clothing and fashion products through tactile identification, NFC technology and accessible digital information. Depending on the features used, Touch 'n Match may allow users to:

• identify garment colours through touch;
• scan tactile NFC labels;
• access Digital Product Passport information;
• organise a personal digital wardrobe;
• create and save outfits;
• receive colour-combination and styling recommendations;
• obtain garment-care and stain-treatment guidance;
• access repair, reuse, resale, recycling or other lifecycle services;
• use personalised and AI-assisted features available through Touch 'n Match Plus;
• interact with participating fashion brands and garment-care partners.

This Privacy Policy is intended to comply with Regulation (EU) 2016/679 (“GDPR”), applicable Romanian data-protection legislation and relevant privacy requirements of the Apple App Store and Google Play.

2. Who is responsible for your personal data?

The Data Controller responsible for the processing described in this Privacy Policy is:

If a Data Protection Officer (“DPO”) is appointed in accordance with Article 37 GDPR, the DPO's contact details will be made available through this Privacy Policy and/or the Touch 'n Match website.

For certain services offered together with fashion brands, retailers, technology providers or other partners, another organisation may act as an independent data controller or, where appropriate, as a joint controller. Where this occurs and personal data is involved, users will be informed about the relevant processing before it takes place.

3. What personal data we collect

The personal data we process depends on how you use Touch 'n Match and which features you choose to activate. We follow the principle of data minimisation and seek to process only the information reasonably necessary for the relevant functionality.

3.1 Account information

When you create a Touch 'n Match account, we may process:

• your name, display name or username;
• your email address;
• your account type;
• your unique account identifier;
• authentication information necessary to manage your account;
• authentication tokens when you use Google Sign-In or Sign in with Apple;
• language preferences;
• accessibility and interface preferences;
• subscription or feature-entitlement information;
• account settings.

Where Firebase Authentication, Google Sign-In or Sign in with Apple is used, Touch 'n Match does not need to receive or store your authentication password in plain text.

If you use Sign in with Apple and choose Apple's email relay functionality, we may receive the relay email address provided by Apple instead of your personal email address.

4. Digital wardrobe and styling information

Depending on the features you use, Touch 'n Match may process information concerning:

• garments, footwear and accessories added to your wardrobe;
• garment identifiers associated with Touch 'n Match labels;
• saved Digital Product Passports;
• colour information, garment category, material and fabric composition, texture, size, care information, and season;
• favourite items and outfits you create or save;
• automatically generated outfits and colour-combination preferences;
• sizing and style preferences;
• preferred garment types and occasions for which you request recommendations;
• seasonal context, wardrobe-planning, capsule wardrobe, and travel packing information;
• information necessary to provide personalised styling functionality.

Depending on the feature and your account settings, some wardrobe information may remain on your device while other information may be synchronised with our cloud infrastructure.

5. Smart Stain Assistant and garment-care information

If you use the Smart Stain Assistant or another garment-care feature, Touch 'n Match may process information such as:

• the garment concerned and its fabric/material composition;
• its official care instructions;
• the type of stain described by you and treatments already applied;
• the resulting care recommendation.

The Smart Stain Assistant may combine information supplied by you with information contained in the garment's Digital Product Passport. Commercially sponsored detergent or garment-care recommendations may also appear and will be clearly indicated.

6. Designer, Creator, Brand and professional accounts

If you use Touch 'n Match as a Designer, Creator, fashion brand, retailer or professional partner, we may process:

• your personal or professional name, brand/company name, professional role, and contact info;
• account credentials, garment/product information, descriptions, images, colour, size, material composition, origin, manufacturing, supply-chain, care instructions, sustainability, repair, recycling, and authenticity data;
• Digital Product Passport data, product identifiers, NFC identifiers, publication/modification timestamps;
• information necessary for product-management dashboards and enterprise services.

Information intentionally published in the public Touch 'n Match catalogue may be visible to other users. Information relating exclusively to a product or legal entity and which does not identify a natural person is not personal data under the GDPR.

7. Guest users

Certain Touch 'n Match functionality may be available without creating an account. For Guest users, information such as temporary wardrobe data, preferences, locally created items, and temporary session information may be stored locally on your device.

However, accessing an online Digital Product Passport or requesting information from our catalogue generates standard technical info (IP address, request timestamp, device/network info, security logs). Local data can generally be removed by clearing App storage or uninstalling the App.

8. NFC technology and tactile labels

Touch 'n Match uses NFC technology to connect physical garments with accessible digital information.

When an NFC label is scanned, the App uses the tag's identifier to retrieve product info from our catalogue, identify an item in your wardrobe, or retrieve the Digital Product Passport. A product identifier which is not personal data on its own may become associated with personal data when connected to an identifiable user account.

9. Device permissions

Touch 'n Match may request access to specific device capabilities when necessary:

• NFC: Used to detect and read compatible Touch 'n Match NFC labels.
• Notifications: With your permission, used for account, security, and service communications. Can be disabled via device settings.
• Location — Weather-Aware Style: Optional. Used to retrieve weather conditions to adapt outfit recommendations (temperature, rain, season). Location access is strictly optional and not used for unrelated advertising targeting.
• Camera and Photo Library: Requested only when adding garment photographs or using visual product features.

10. Accessibility information and sensitive personal data

Touch 'n Match is designed to be accessible to blind and visually impaired individuals, but is open to everyone. You are not required to provide a medical diagnosis or prove a disability to use the App.

Where possible, we collect accessibility preferences (e.g., interface settings, screen-reader compatibility, voice interaction) rather than health data. If information voluntarily provided directly reveals special category data under Article 9 GDPR, it is processed only under valid legal grounds (such as explicit consent). Disability/health info is never used for advertising targeting.

11. Technical and usage data

When using online Touch 'n Match services, technical information (IP address, device model, operating system, App version, language, security logs, error reports, session tokens) is processed automatically for security, fraud prevention, troubleshooting, debugging, and performance/accessibility improvements.

12. Local storage and cloud storage

Local storage

Items stored locally on your device (using technology such as Hive) include wardrobe items, locally created garments, outfits, accessibility settings, and App preferences for faster access and offline accessibility.

Cloud storage

For accounts with cloud features enabled, Google Cloud Firestore / Firebase infrastructure processes account info, public catalogue data, synchronised wardrobes, outfits, preferences, and entitlement status for cross-device synchronisation.

13. Purposes and legal bases for processing

• Providing Account & Service: Article 6(1)(b) GDPR — performance of a contract.
• Digital Wardrobe & Outfit Functionality: Article 6(1)(b) GDPR — performance of a contract.
• Personal Style Consultant: Article 6(1)(b) GDPR (contract) or Article 6(1)(a) GDPR (consent for optional features).
• Weather-Aware Style: Article 6(1)(a) GDPR — consent.
• Notifications & Marketing: Article 6(1)(a) GDPR — consent. Service/security notices are sent independently.
• Security & Fraud Prevention: Article 6(1)(f) GDPR — legitimate interests.
• Service Improvement & Analytics: Article 6(1)(f) GDPR — legitimate interests.
• Legal Obligations: Article 6(1)(c) GDPR — legal obligation compliance.
• Special-Category Data: Articles 6(1)(a) & 9(2)(a) GDPR — explicit consent.

14. AI-assisted and personalised recommendations

Certain features (Personal Style Consultant, outfit generation, weekly outfit planning, Smart Stain Assistant) use automated or AI-assisted systems to assist users.

15. Sponsored recommendations and Care Partner Network

Touch 'n Match may collaborate with care product companies, brands, and recycling partners. Paid or sponsored recommendations are clearly marked as commercial content. Sponsorship arrangements do NOT grant partners access to your name, email, account, or private wardrobe.

16. Brand and enterprise analytics

Participating brands receive aggregated or de-identified metrics regarding NFC label scans and Digital Product Passport views. Adding a brand's garment to your wardrobe does not share your personal account details with that brand.

17. Third-party technology and service providers

We work with trusted service providers to operate Touch 'n Match:

• Google Firebase / Google Cloud: Infrastructure, authentication, Firestore database.
• Google Sign-In & Sign in with Apple: Authentication providers.
• Apple App Store & Google Play: In-app payment and subscription processing.
• DeepL: Catalogue text translation (without identifiable user data).

18. International transfers of personal data

Where personal data is transferred outside the European Economic Area (EEA), we rely on appropriate safeguards including European Commission Adequacy Decisions, the EU-U.S. Data Privacy Framework, and Standard Contractual Clauses (Articles 44–49 GDPR).

19. Data retention

We retain personal data only for as long as necessary. Local device data remains until cleared or uninstalled. Account data is deleted or anonymised upon account deletion, except where limited retention is required by tax, accounting, security, or legal obligations.

20. Account deletion

You may request account deletion at any time directly in the App via:
Settings → My Account → Delete Account

You can also request web-based account deletion at touchnmatch.com/delete-account or by emailing touchnmatch@gmail.com.

21. Your rights under the GDPR

Under the GDPR, you have the following rights:

• Right of Access: Obtain confirmation and copy of your data.
• Right to Rectification: Correct inaccurate information.
• Right to Erasure: Request deletion of your personal data.
• Right to Restriction & Object: Restrict processing or object to legitimate interest processing.
• Right to Data Portability: Receive your data in a structured format.
• Right to Withdraw Consent: Withdraw consent at any time without affecting past lawfulness.

To exercise your rights, email us at touchnmatch@gmail.com. We respond within 1 month.

22. Children

In Romania, minors aged 16 or above may provide consent under Article 8 GDPR. For children under 16, parental/guardian authorisation is required where consent is the legal basis.

23. Marketing and service communications

Service and security communications (account updates, password recovery, privacy changes) are sent as required. Promotional marketing is optional and requires explicit consent which can be withdrawn at any time.

24. Data security

We employ technical and organizational measures (encryption in transit, secure cloud configuration, access controls, database rules, security logging) to protect your information.

25. Third-party websites, services and partner ecosystems

Links or services to third-party repair, resale, or retail partners are governed by their respective privacy policies once you leave Touch 'n Match.

26. No sale of personal data

Touch 'n Match does NOT sell personal data to data brokers. Commercial partnerships or sponsorships do not grant partners access to identifiable user data.

27. Changes to this Privacy Policy

Material updates to this Privacy Policy will be notified via in-App notifications, website updates, or email. The current version will always remain available at touchnmatch.com/privacy-policy.

28. Contact us