Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how Formetry LLC, a Wyoming limited liability company doing business as FORMÉ ("FORMÉ," "we," "us," or "our"), collects, uses, shares, retains, and protects personal information when you access or use the FORMÉ platform, website, applications, and all related products and services (collectively, the "Services").

FORMÉ operates an AI-powered creative platform through which: (a) participating human models ("Models") authorize the creation of AI-enabled digital representations of their likeness ("Digital Twins") for use in generating commercial creative assets; (b) brands, advertisers, agencies, and other clients ("Users" or "Clients") engage Digital Twins to generate proposed creative outputs, upload garment and product imagery, and use AI-powered studio tools to produce professional-quality product photography, editorial shots, and outfit compositions; and (c) Users may create and configure AI-generated virtual figures ("Virtual Models") that are not based on any specific real person's likeness.

This Policy applies to all individuals who interact with the Services, including Models, Users, account administrators, website visitors, and any other persons whose personal information we process in connection with the Services. Because Models and Users interact with the Platform in fundamentally different ways, we describe the specific data practices relevant to each where appropriate.

Questions or concerns? Please contact us at privacy@forme.style.

We recommend that you read this Policy in full. If you do not agree with our practices, please do not use the Services. Your use of the Services is also governed by our Terms of Service.

Table of Contents

1. Key Definitions
2. Information We Collect
3. How We Use Your Information
4. Biometric Data: Special Notice
5. AI Processing and Digital Twin Technology
6. When and With Whom We Share Your Information
7. Cookies and Tracking Technologies
8. Data Retention
9. Data Security
10. Your Privacy Rights
11. United States State-Specific Rights
12. International Users (EEA, UK, Switzerland, Canada)
13. Children's Privacy
14. Social Media Logins
15. Do-Not-Track Signals
16. Changes to This Policy
17. Contact Us

1. Key Definitions

The following terms are used throughout this Policy and have the meanings described in our Terms of Service. Key terms include:

2. Information We Collect

We collect different categories of personal information depending on whether you interact with the Platform as a Model, a User/Client, or a website visitor.

2.1 Information Models Provide to Us

When you participate as a Model on the Platform, we may collect:

• Identity and contact information: full legal name, professional/stage name, email address, phone number, mailing address, date of birth, government-issued identification (for identity verification and tax purposes)
• Appearance Data: photographs, videos, digitized images, body measurements, skin texture references, hair characteristics, styling references, pose references, portfolio materials, and similar visual or descriptive information used to create and maintain your Digital Twin
• Biometric Identifiers and Biometric Information: where applicable and with your informed written consent, scans of face geometry and other biometric data as defined under applicable law, used in the creation and operation of your Digital Twin (see Section 4 for detailed biometric disclosures)
• Professional information: agency representation, modeling experience, portfolio, professional references
• Financial and tax information: payment details for compensation, bank account information, tax identification numbers, and related data necessary to process Model payments
• Transaction and approval records: records of Hiring Invitation responses, Model Output Release decisions, approval and rejection histories, and related workflow data
• Communications: messages, support requests, feedback, and other correspondence with FORMÉ

2.2 Information Users/Clients Provide to Us

When you use the Platform as a User or Client, we may collect:

• Account and contact information: name, email address, company name, job title, phone number, mailing address
• Business information: brand identity, agency affiliation, industry, intended use cases
• Billing and payment data: payment method details, billing address, purchase history, credit balances, and transaction records. Payment processing is handled by our third-party payment processors; we do not store full payment card numbers on our systems
• User Materials: Creative Briefs, Garment Content, reference assets, trademarks, logos, campaign copy, product images, and other materials you upload to or provide through the Platform
• Transaction records: Hiring Invitation details, campaign specifications, usage declarations, Order history, Output License records, and Studio License Terms
• Communications: messages, support requests, feedback, and other correspondence with FORMÉ

2.3 Information Collected Automatically

When you visit, access, or use the Services, we automatically collect certain technical and usage information, including:

• Device and browser information: IP address, browser type and version, operating system, device type, device identifiers, screen resolution, and language preferences
• Usage data: pages viewed, features used, actions taken (such as Hiring Invitations submitted, outputs generated, Studio Features accessed), session duration, referring URLs, and clickstream data
• Log data: server logs, error reports, timestamps, and diagnostic information
• Location data: approximate geographic location derived from IP address (we do not collect precise GPS location)

2.4 Information from Third Parties

We may receive personal information from:

• Social media platforms: if you register or log in using a social media account (see Section 14)
• Payment processors: transaction confirmation, fraud screening results, and payment status
• Identity verification providers: verification results for Model onboarding and account security
• Analytics providers: aggregated usage insights and performance data

3. How We Use Your Information

We process personal information for the following purposes:

3.1 Platform Operations

• Creating, maintaining, and authenticating user accounts
• Processing Model onboarding and Digital Twin creation
• Operating Studio Features, including processing Garment Content uploads, generating Product Shots, and creating Virtual Model compositions
• Facilitating the Hiring Invitation, output generation, Model Output Release, and Output License workflow
• Processing payments, managing credits, and administering billing
• Delivering, maintaining, and improving the Services

3.2 AI Processing and Digital Twin Operations

• Creating, training, maintaining, and updating Digital Twins using authorized Model Appearance Data and, where applicable, Biometric Identifiers and Biometric Information
• Generating Proposed Outputs using Digital Twins in response to User requests
• Operating Studio Features to generate Product Shots and Virtual Model renderings
• Maintaining quality, accuracy, and safety of AI-generated outputs
• Monitoring outputs for compliance with Platform Policies, content standards, and applicable law

3.3 Communications

• Responding to inquiries, support requests, and feedback
• Sending transactional notifications (account activity, payment confirmations, approval requests, license updates)
• Providing service announcements and updates
• Sending marketing communications where you have opted in (you may opt out at any time)

3.4 Safety, Security, and Compliance

• Detecting, preventing, and addressing fraud, abuse, security incidents, and technical issues
• Enforcing our Terms of Service, Platform Policies, and Output License terms
• Protecting the rights, safety, and property of FORMÉ, Models, Users, and the public
• Complying with applicable legal obligations, law enforcement requests, and regulatory requirements
• Conducting audits and maintaining compliance records
• Resolving disputes and enforcing agreements

3.5 Analytics and Improvement

• Analyzing usage patterns to improve Platform features, performance, and user experience
• Conducting internal research and development
• Generating aggregated, de-identified analytics and reporting

4. Biometric Data: Special Notice

This Section provides specific disclosures regarding our collection and processing of biometric data, as required under applicable biometric privacy laws including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and similar state laws.

4.1 What Biometric Data We Collect

In connection with Digital Twin creation, FORMÉ may collect Biometric Identifiers and Biometric Information from participating Models, including scans of face geometry derived from photographs, videos, or other visual data provided during the onboarding process. We do not collect biometric data from Users/Clients, website visitors, or any individuals other than participating Models who have provided informed written consent.

For clarity, Virtual Models are AI-generated figures that are not based on any real person's biometric data.

4.2 Purpose of Collection

We collect and process Model biometric data solely for the following purposes:

• Creating, training, calibrating, and maintaining the Model's Digital Twin
• Generating Proposed Outputs and Approved Outputs that accurately depict the Model's likeness within the Platform
• Ensuring quality, accuracy, and visual fidelity of Digital Twin renderings
• Verifying identity and preventing unauthorized use of a Model's likeness
• Complying with applicable law

We do not use biometric data for purposes unrelated to the Model's authorized Digital Twin or the operation of the Platform.

4.3 Consent

Before collecting any Biometric Identifier or Biometric Information, FORMÉ obtains the Model's informed, written consent through the Model–Platform Agreement, which describes the specific biometric data to be collected, the purposes of collection and use, and the applicable retention and destruction schedule. This consent is separate from and in addition to any general terms of service acceptance. Models may withdraw consent as provided in the Model–Platform Agreement, subject to the notice and wind-down provisions described therein.

4.4 Retention and Destruction

FORMÉ maintains a written biometric data retention and destruction policy. Biometric Identifiers and Biometric Information are retained only for as long as necessary to fulfill the purposes described in Section 4.2, or as required by law. Specifically:

• Upon termination of a Model's participation in the Platform (following the applicable notice period set forth in the Model–Platform Agreement), FORMÉ will permanently destroy the Model's Biometric Identifiers and Biometric Information within a commercially reasonable timeframe, and in no event later than three (3) years after the Model's last interaction with the Platform, unless a longer retention period is required by law or necessary to fulfill surviving contractual obligations
• Destruction will be carried out using industry-standard methods appropriate for the type of data

4.5 Disclosure and Security

FORMÉ does not sell, lease, trade, or otherwise disclose Biometric Identifiers or Biometric Information to third parties, except:

• With the Model's prior informed consent
• To service providers and processors bound by contractual obligations to protect such data and use it only for the purposes we specify
• As required by law, regulation, court order, or valid legal process
• To complete a transaction specifically authorized by the Model

Biometric data is protected using reasonable security measures at least as protective as those used for other confidential and sensitive personal information (see Section 9).

4.6 Model Rights Regarding Biometric Data

Models have the right to:

• Receive written notice before any biometric data collection occurs
• Provide or withhold informed written consent
• Request information about what biometric data has been collected and how it is used
• Request deletion of biometric data, subject to the retention and wind-down provisions in the Model–Platform Agreement and applicable law
• File a complaint with FORMÉ or applicable regulatory authorities

To exercise biometric data rights, contact us at privacy@forme.style.

5. AI Processing and Digital Twin Technology

5.1 How AI Is Used on the Platform

FORMÉ uses artificial intelligence, machine learning, and related technologies ("AI Technologies") to power several core functions of the Platform:

• Digital Twin creation and operation: AI Technologies process authorized Model Appearance Data and, where applicable, Biometric Identifiers to create Digital Twins capable of generating realistic visual outputs depicting the Model's likeness
• Output generation: When a User submits a Creative Brief or generation request, AI Technologies use the applicable Digital Twin to generate Proposed Outputs
• Studio Features: AI Technologies process uploaded Garment Content to generate Product Shots, create and render Virtual Models, and produce outfit compositions and editorial visuals
• Quality and safety: AI Technologies assist in monitoring output quality, detecting content policy violations, and maintaining platform integrity

5.2 Third-Party AI Service Providers

We use third-party AI infrastructure and model providers ("AI Service Providers") to operate certain AI Technologies on the Platform. Your inputs (including Creative Briefs, Garment Content, and generation parameters) and the resulting outputs are shared with and processed by AI Service Providers as necessary to deliver the Services. We require AI Service Providers to handle data in accordance with this Policy and applicable contractual safeguards.

We do not authorize AI Service Providers to use your personal information, Appearance Data, Biometric Identifiers, Garment Content, or outputs for their own independent purposes, including for training their own general-purpose AI models. AI Service Providers may process your data only as necessary to provide the specific services we contract for, subject to contractual restrictions that prohibit independent use, retention beyond the processing period, and onward disclosure.

FORMÉ may use aggregated, de-identified usage data and output quality metrics derived from Studio Features to improve the performance and accuracy of its own Platform AI systems. This internal improvement does not involve sharing identifiable Garment Content, personal information, or Biometric Identifiers with third parties for training purposes.

5.3 What AI Processing Does Not Do

• FORMÉ does not use AI Technologies to make automated decisions that produce legal or similarly significant effects on you without human involvement and the opportunity for review
• Virtual Models are AI-generated figures and do not incorporate or reflect any real person's biometric data, likeness rights, or identity
• Studio Features process Garment Content to generate visual assets; they do not extract, retain, or reverse-engineer proprietary garment design data for any purpose beyond generating the requested outputs

5.4 Your Obligations

You must not use AI-powered features of the Platform in any way that violates the terms or policies of our AI Service Providers, this Policy, or our Terms of Service.

6. When and With Whom We Share Your Information

We do not sell personal information as that term is commonly understood. We may share personal information in the following circumstances:

6.1 Within the Platform Ecosystem

• Model–User limited disclosures: When a User submits a Hiring Invitation, the applicable Model may receive limited information about the campaign, brand, and intended use to make an informed approval decision. Users do not receive Models' personal contact information, Biometric Identifiers, or Biometric Information. FORMÉ acts as the intermediary in all transactions
• Transaction records: Certain transaction-related information (such as Approved Usage Package details) is shared between Models and Users as necessary to administer Output Licenses

6.2 Service Providers and Processors

We share personal information with third-party service providers who perform functions on our behalf, including:

• Payment processing and billing
• Cloud hosting and data storage
• AI infrastructure and model hosting (see Section 5.2)
• Identity verification
• Analytics and performance monitoring
• Customer support tools
• Email and notification delivery

Service providers are contractually bound to use personal information only for the purposes we specify and to maintain appropriate security measures.

6.3 Legal and Compliance

We may disclose personal information when we believe in good faith that disclosure is necessary to:

• Comply with applicable law, regulation, legal process, or governmental request
• Enforce our Terms of Service, Output Licenses, or other agreements
• Protect the rights, safety, or property of FORMÉ, our Models, Users, or the public
• Detect, prevent, or address fraud, security, or technical issues
• Respond to a valid subpoena, court order, or similar legal process

6.4 Business Transfers

We may share or transfer personal information in connection with, or during negotiations of, any merger, acquisition, sale of assets, financing, reorganization, bankruptcy, or similar transaction. If such a transaction occurs, we will require the acquiring entity to honor the commitments made in this Policy, or we will provide notice and, where required, obtain consent before personal information is transferred to a new entity under different privacy practices.

6.5 With Your Consent

We may share personal information with third parties when you have given us specific consent to do so.

6.6 Aggregated and De-Identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you for analytics, research, industry benchmarking, and similar purposes.

7. Cookies and Tracking Technologies

7.1 What We Use

We may use cookies, web beacons, pixels, and similar tracking technologies to collect information when you interact with the Services. These technologies help us:

• Maintain the security of the Services and your account
• Remember your preferences and settings
• Understand how you use the Services
• Measure the effectiveness of our communications

7.2 Third-Party Analytics

We may use third-party analytics services (such as Google Analytics) to help us understand usage patterns and improve the Services. These services may collect information about your interactions with the Services using cookies and similar technologies. For Google Analytics, you may opt out by visiting https://tools.google.com/dlpage/gaoptout.

7.3 Advertising and Targeted Content

To the extent we use online tracking technologies for targeted advertising, and such use constitutes a "sale" or "sharing" under applicable US state laws, you may opt out as described in Section 11 below.

7.4 Managing Cookies

Most browsers allow you to control cookies through their settings. You may also use industry opt-out tools such as https://optout.networkadvertising.org/. Disabling cookies may affect the functionality of certain features of the Services.

8. Data Retention

8.1 General Retention Principles

We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. Retention periods vary depending on the type of information and the purpose for which it was collected:

• Account data: Retained for the duration of your account and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce agreements
• Model Appearance Data and Digital Twin data: Retained for the duration of the Model's participation on the Platform, plus the wind-down period specified in the Model–Platform Agreement. Existing Output Licenses that survive Model termination may require limited continued retention of approved outputs, as described in the Model–Platform Agreement
• Biometric Identifiers and Biometric Information: Retained in accordance with the schedule described in Section 4.4
• Transaction and billing records: Retained for the period required by applicable tax, accounting, and financial regulations (typically seven years)
• User Materials and Garment Content: Retained for the duration of your account and active transactions. Following account termination, User Materials and Garment Content may be deleted in accordance with our Terms of Service; FORMÉ is not obligated to retain these materials after termination, and you are responsible for maintaining your own copies
• Proposed Outputs and Studio Outputs: Proposed Outputs that are not approved may be retained for a limited period for audit, compliance, and dispute resolution purposes, after which they are deleted or anonymized. Studio Outputs and Approved Outputs may be retained by FORMÉ for record-keeping, compliance, and enforcement purposes for the duration of the applicable Output License and a reasonable period thereafter. You are responsible for downloading and maintaining your own copies of outputs you wish to retain
• Virtual Models: Virtual Models created through Studio Features are Platform-generated assets. FORMÉ retains all right, title, and interest in Virtual Model technology and may retain, modify, or make Virtual Models available to other users. Virtual Models are not guaranteed to be unique to you. FORMÉ is not obligated to retain or make available any specific Virtual Model configuration following account termination
• Automatically collected data: Retained for up to twenty-four (24) months for analytics and security purposes, unless a longer period is required for a specific investigation or legal matter

8.2 Deletion and Anonymization

When personal information is no longer needed for any legitimate purpose, we will delete or anonymize it. Where deletion is not immediately feasible (for example, because information is stored in backup archives), we will securely isolate the information from further processing until deletion is possible.

9. Data Security

We implement appropriate technical and organizational security measures designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive data in transit and at rest
• Access controls limiting personnel access to personal information on a need-to-know basis
• Regular security assessments and monitoring
• Incident response procedures for potential data breaches
• Contractual security requirements for service providers

Biometric Identifiers and Biometric Information are protected using security measures at least as protective as those used for other confidential and sensitive personal information maintained by FORMÉ.

Despite these safeguards, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, and transmission of personal information to and from the Services is at your own risk. You should access the Services only within a secure environment.

In the event of a data breach involving personal information, we will notify affected individuals and applicable authorities as required by law.

10. Your Privacy Rights

Depending on your location and applicable law, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete personal information
• Deletion: Request deletion of your personal information, subject to applicable legal exceptions
• Restriction: Request that we restrict the processing of your personal information in certain circumstances
• Portability: Request a copy of your personal information in a structured, commonly used, machine-readable format
• Objection: Object to certain types of processing, including processing based on legitimate interests
• Withdrawal of consent: Where processing is based on your consent, withdraw that consent at any time (without affecting the lawfulness of processing performed before withdrawal)
• Non-discrimination: Exercise your rights without receiving discriminatory treatment

How to Exercise Your Rights

To exercise any of these rights, please contact us at privacy@forme.style. We will verify your identity before processing your request and respond within the timeframes required by applicable law.

If you are a Model seeking to exercise rights related to Biometric Identifiers or Biometric Information, please see Section 4.6.

Account Termination

If you wish to terminate your account, you may do so through your account settings or by contacting us. Upon termination, we will deactivate your account and process your personal information in accordance with Section 8 and our Terms of Service. We may retain certain information as necessary to comply with legal obligations, resolve disputes, prevent fraud, and enforce agreements.

11. United States State-Specific Rights

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, or another state with applicable data protection legislation, you may have additional rights under your state's laws.

11.1 Categories of Personal Information Collected

The following table summarizes the categories of personal information we have collected in the past twelve (12) months:

We only collect and process sensitive personal information for the purposes permitted by applicable law or with your consent.

11.2 Your State-Specific Rights

Depending on your state of residence, you may have the right to:

• Know whether we are processing your personal data and access it
• Correct inaccuracies in your personal data
• Request deletion of your personal data
• Obtain a copy of your personal data in a portable format
• Opt out of the sale of personal data, targeted advertising, or profiling
• Limit the use or disclosure of sensitive personal information
• Non-discrimination for exercising your rights

11.3 How to Exercise State-Specific Rights

To exercise your rights, contact us at usprivacy@forme.style. We will verify your identity and respond within the timeframe required by your state's law.

11.4 Appeals

If we decline to take action on your request, you may appeal our decision by emailing us at privacy@forme.style. We will respond to your appeal within the timeframe required by applicable law.

11.5 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require verification of the agent's authority, such as a signed authorization letter or power of attorney.

12. International Users (EEA, UK, Switzerland, Canada)

12.1 Legal Bases for Processing (GDPR / UK GDPR)

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we process your personal information only when we have a valid legal basis:

• Consent: Where you have given explicit consent, such as for biometric data processing (Models) or marketing communications. You may withdraw consent at any time
• Performance of a contract: Where processing is necessary to fulfill our contractual obligations to you, such as providing the Services under our Terms of Service or Model–Platform Agreement
• Legal obligation: Where processing is required to comply with applicable law
• Legitimate interests: Where processing is necessary for our legitimate business interests (such as security, fraud prevention, and service improvement), provided those interests are not overridden by your rights and freedoms

Biometric Identifiers and Biometric Information are classified as "special category data" under the GDPR and UK GDPR. We process such data only with the Model's explicit consent or where another Article 9(2) exception applies.

12.2 Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence, including the United States. Where required by applicable law, we use appropriate safeguards for international transfers, such as Standard Contractual Clauses approved by the European Commission or other legally recognized mechanisms.

12.3 Data Protection Impact Assessments

Where required under the GDPR or UK GDPR, we conduct Data Protection Impact Assessments for processing activities that pose high risks to individuals' rights and freedoms, including large-scale processing of biometric data and AI-based profiling.

12.4 Your Rights Under GDPR / UK GDPR

In addition to the rights described in Section 10, you may have the right to:

• Lodge a complaint with your local data protection supervisory authority
• Object to processing based on legitimate interests
• Request restriction of processing while a dispute is resolved
• Not be subject to solely automated decision-making that produces legal or similarly significant effects. If such a decision is made, we will inform you, explain the main factors involved, and offer a simple way to request human review

12.5 Canadian Users

If you are located in Canada, we process your personal information only with your express or implied consent, except in the limited circumstances permitted by applicable law (such as fraud investigation, legal compliance, or emergency situations). You may withdraw consent at any time, subject to legal and contractual limitations, by contacting us at privacy@forme.style.

13. Children's Privacy

The Services are not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from minors. If we become aware that we have collected personal information from someone under 18, we will take steps to delete that information promptly. If you believe a minor has provided us with personal information, please contact us at privacy@forme.style.

14. Social Media Logins

The Services may offer you the option to register or log in using third-party social media accounts (such as Google, Facebook, or Apple). If you choose this option, we will receive certain profile information from the social media provider, which may include your name, email address, profile picture, and other information you have made public on that platform.

We use this information only for the purposes described in this Policy. We do not control, and are not responsible for, the privacy practices of third-party social media providers. We recommend reviewing their privacy policies to understand how they handle your personal information.

15. Do-Not-Track Signals

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature. Because no uniform technology standard for recognizing or implementing DNT signals has been finalized, we do not currently respond to DNT browser signals. If a standard for online tracking is adopted that we must follow, we will inform you in a revised version of this Policy.

Where required by California law or other applicable state laws, we disclose that we do not currently respond to DNT signals at this time.

16. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, the Services, or applicable law. The updated version will be indicated by a revised "Last Updated" date at the top of this Policy.

If we make material changes, we may notify you by: prominently posting a notice on the Platform; sending a notification to your registered email address; or providing an in-product alert. We encourage you to review this Policy periodically.

Your continued use of the Services after the effective date of a revised Policy constitutes acceptance of the changes. If you do not agree with the revised Policy, you should discontinue use of the Services.

17. Contact Us

If you have questions or concerns about this Policy, our data practices, or your privacy rights, please contact us:

Formetry LLC d/b/a FORMÉ

• General privacy inquiries: privacy@forme.style
• US state-specific privacy rights: usprivacy@forme.style
• General support: support@forme.style

If you are located in the EEA, UK, or Switzerland and have unresolved concerns about our handling of your personal information, you have the right to lodge a complaint with your local data protection supervisory authority.