Privacy policy
Last updated:
At Looka we take your data seriously, especially your photos. This policy explains clearly what personal data we process when you use the Looka app and this website, what we use it for and what rights you have, under the General Data Protection Regulation (GDPR) and the Spanish Organic Law 3/2018 on Data Protection and Digital Rights (LOPDGDD).
The essentials: your photos are only used to create your try-ons and never to train AI models. We don’t sell your data. You can delete your account and everything in it from the app at any time.
The Spanish version of this policy prevails in case of discrepancy.
1. Data controller
The controller of your data is Cometa Labs:
- Company name: PRAXIS BUNKER, S.L.
- Tax ID (NIF/CIF): B42914226
- Address: Carrer Can Ribera, 4, 07012 Palma, Balearic Islands (Spain)
- Registered in the Commercial Registry of the Balearic Islands.
- Cometa Labs is a trade name of PRAXIS BUNKER, S.L.
- Contact email: hola@cometalabs.io
For any question about your personal data, write to hola@cometalabs.io.
2. What data we process
- Account data: your email address and the one-time sign-in codes we send you (we don’t use passwords). If you use the app as a guest, an anonymous session identifier is created.
- Your photos: the photos of yourself you upload as reference (up to 4) to generate try-ons.
- Garments: the store links you paste, the garment images or screenshots you upload and the stickers we generate from them, along with descriptive garment data (for example type, colour or name).
- Generated images: the try-on photos (“looks”) the AI creates for you.
- Usage and technical data: number of try-ons, language, app preferences, device type and operating system, and technical logs (for example IP addresses and errors) needed to run and secure the service.
- Subscription status: if you have Looka Pro, the plan, renewal date and a purchase customer identifier. We don’t receive or store your card or payment details: payment is handled by Apple or Google.
We don’t ask for special category data and don’t need it to provide the service. Please don’t upload photos that reveal unnecessary sensitive information.
3. Your photos and face detection
Photos in which you appear are personal data. They may show physical features of your face and body, so we treat them with special care:
- We only use them to generate your try-ons and the images you request in the app.
- We do not perform biometric identification: we don’t create facial templates to identify you or verify your identity, and we don’t match your face against databases.
- We use face detection only to frame the image and preserve your face in the generated photo, so the person in the result is you.
- We never use your photos to train AI models, ours or anyone else’s.
4. Why we use your data and on what legal basis
- Providing the service (creating and keeping your account, sending your sign-in code, creating garment stickers, saving your wardrobe and looks, counting your try-ons): performance of the contract you accept through the Terms of use (Art. 6(1)(b) GDPR).
- Processing your photos to generate try-ons: your consent (Art. 6(1)(a) GDPR), which you give by uploading them and can withdraw at any time by deleting your photos or your account. Withdrawal doesn’t affect the lawfulness of prior processing.
- Managing your subscription (checking whether you’re Pro, applying fair-use limits): performance of the contract (Art. 6(1)(b) GDPR).
- Security, preventing abuse and misuse of the AI, and technical improvement of the service using aggregated usage data: our legitimate interest in keeping the service safe and working (Art. 6(1)(f) GDPR).
- Complying with legal obligations (for example tax or requests from authorities): legal obligation (Art. 6(1)(c) GDPR).
- Answering your support requests: your request and our legitimate interest in handling it.
We don’t make automated decisions that produce legal effects on you or similarly significantly affect you. We don’t run personalised advertising and we don’t sell your data.
5. Processors and third parties
To provide the service we rely on providers that process data on our behalf, under data processing agreements and only on our instructions:
- Google (Gemini API): image generation and analysis (creating stickers, analysing garments and generating try-ons). It receives the photos and images needed for each request. According to the terms of Google’s paid service, data sent through the paid API is not used to train Google’s models.
- Resend: sending transactional emails, such as your sign-in code.
- RevenueCat: managing the status of in-app subscriptions.
- Apple (App Store) and Google (Google Play): process subscription payments as independent controllers, under their own privacy policies.
- Hosting and database providers in the European Union and the United States, where your account, images and looks are stored.
Store pages: when you paste a link, our server downloads the public product page and its image to create the sticker. We don’t send any of your account data to the store.
We may also disclose data to authorities and courts when required by law.
6. International transfers
Some of these providers are in the United States or may process data outside the European Economic Area. In those cases transfers rely on appropriate safeguards: the provider’s certification under the EU-US Data Privacy Framework where applicable, and/or the Standard Contractual Clauses approved by the European Commission, together with supplementary measures. You can ask us for more information at hola@cometalabs.io.
7. How long we keep your data
- Account, photos, wardrobe and looks: for as long as you have an account. When you delete it from Profile → Delete my account, your photos, wardrobe and looks are deleted. Technical backups are overwritten in short cycles.
- Individual photos: if you delete a photo it is removed; your saved looks are kept until you delete them or your account.
- Guests: data from a guest session that isn’t turned into an account is deleted after 90 days of inactivity.
- Subscription and billing data: for as long as tax and commercial law requires.
- Technical and security logs: for as long as strictly necessary for their purpose, and no longer than the law allows.
Images the app sends to our providers to process a request are kept only as long as they need to provide the service and meet their obligations, under their terms.
8. Your rights
You can exercise at any time your rights of:
- Access: knowing what data of yours we process.
- Rectification: correcting inaccurate data.
- Erasure: deleting your data. You can do it yourself in the app, under Profile → Delete my account.
- Portability: receiving your data in a structured, commonly used format.
- Objection and restriction of processing, where the law provides.
- Withdrawing your consent at any time, by deleting your photos or your account.
Write to hola@cometalabs.io from your account email stating the right you want to exercise. We’ll reply within one month. If you believe we haven’t handled your data properly, you can lodge a complaint with the Spanish Data Protection Agency (AEPD) or your local supervisory authority.
9. Minors
Looka is intended for people aged 18 and over. We don’t allow minors to use the service or photos of minors to be uploaded. If we detect or are told about an account belonging to a minor or photos of minors, we will delete them.
10. Security
We apply appropriate technical and organisational measures to protect your data: encrypted connections (HTTPS), restricted access to information, access to your images only through your session, and providers with recognised security standards. No system is infallible; if a security breach affected your data, we would act as the law requires and inform you where appropriate.
12. Changes to this policy
We may update this policy, for example if we add features or change providers. We’ll publish the new version here with its date and, if the changes are significant, we’ll let you know in the app or by email.
13. Contact
For any privacy question: hola@cometalabs.io.
