Privacy Policy

Protecting your privacy is really important to us. Accordingly, we’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive through the DressUp Club mobile application known from now on as the DressUp Club app. This Privacy Policy doesn’t apply to any third-party websites, services or applications, even if they are accessible through our DressUp Club app. Also, please note that, unless we define a term in this Privacy Policy, all capitalised words used in this Privacy Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service.

1. General Information

Bitello Studio SRL, Salacz Gyula Nr. 3 , Arad 310022, Romania (“Bitello Studio“). We, the team of Bitello Studio, email address: [email protected] (“Email Address”), process your personal data when you use our app (“App”) or website (“Website” and, together with the Apps, “Products”). The processing of your personal data takes place in compliance with applicable local data privacy laws, e.g. the EU General Data Protection Regulation (“GDPR“) or the Romanian data protection act in its current form.

In this privacy policy (“Privacy Policy”) we want to provide you with information about us, the nature, scope and purposes of the data processing, e.g collection and use, giving you insights into the processing of your personal data.

2. Data Controller

The controller under data protection law is:

  • Bitello Studio S.R.L.
  • Salacz Gyula nr. 3, 310022 Arad, Romania
  • +40 746 918 775
  • Commercial register entry number: ROONRCJ2/143/2020
  • Data Protection Officer contact: [email protected]

3. Access and activity logs (“server logs”)

Each access to this website automatically causes general protocol data, so-called server logs, to be collected. As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual.

Without this data, it would, in some cases, be technically impossible to deliver or display the contents of the software. In addition, processing this data is absolutely necessary under security aspects, in particular for access, input, transfer, and storage control. Furthermore, this anonymous information can be used for statistical purposes and for optimizing services and technology. In addition, the log files can be checked and analyzed retrospectively when unlawful use of the software is suspected. Article 6 (1) f of the GDPR.

Generally, data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp of the access to the software is collected. The scope of this log process does not exceed the common log scope of any other site on the web.

These access logs are stored for a period of up to 7 days. There is no right to object to this.

4. Error logs

So-called error logs are generated for the purpose of identifying and fixing bugs. This is absolutely necessary to ensure we can react as quickly as possible to possible problems with displaying and implementing content (legitimate interest). As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. The legal basis for this is article 6 (1) f) of the GDPR.

When an error message occurs, general data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp upon occurrence of the respective error message and/or specification is collected.

These error logs are stored for a period of up to 7 days. There is no right to object to this.

5. Use of third-party provider tools

In order to provide and continuously improve our services, we are using the services of the following third-party providers which may also process personal data. These third-party providers have been selected diligently and in line with the requirements of the GDPR.

a. Mixpanel

The operator of all Mixpanel services is Mixpanel Inc. One Front Street, 28th Floor, San Francisco, CA 94111, Attn: Legal Department.

All stored data makes use of their EU compliant data storage.

6. Forms

Please note: If you contact us via contact forms, personal data may be transferred to service providers in third countries. These third countries do not have an adequate level of data protection. If the data is transferred to the USA, there is a risk that your data may be processed by US authorities for control and monitoring purposes, without you possibly being entitled to legal remedies. If the standard contractual clauses and binding corporate rules are not sufficient to establish an adequate level of security, your approval of this privacy policy will be deemed to be consent within the meaning of Art. 49 (1)(a)  GDPR, which justifies data transfer to unsafe third countries.

7. Forms

If the company Bitello Studio S.R.L. processes personal data as data controller, then you as the data subject have certain rights derived from Chapter III GDPR, which depend on the legal basis and purpose of the processing. These rights include when relevant especially the right to information (Art. 15 GDPR), the right to rectification (Art. 16 GDPR), the right to cancellation (Art. 17 GDPR), the right to restriction of processing (Art. 18 GDPR), the right to data portability (Art. 20 GDPR), and the right to objection (Art. 21 GDPR).  If the processing of personal data is based on your consent, then you have the right pursuant to Art. 7 III GDPR to revoke this consent granted under data protection law.

Please contact the Data Protection Officer of Bitello Studio S.R.L. (see Section 2) in order to assert you rights as data subject regarding the data processed for the operation of this website. Please be aware that you must contact the data controller directly to assert your rights as data subject derived from the processing by us, as data processor of our customers. We reserve the right not to respond to corresponding queries or to redirect them to the corresponding companies.

If Bitello Studio S.R.L. as the controller processes personal data, you as the data subject have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and the purpose of the processing, in particular the right of access (article 15 of the GDPR) and the rights to rectification (article 16 of the GDPR), erasure (article 17 of the GDPR), restriction of processing (article 18 of the GDPR), and data portability (article 20 of the GDPR), as well as the right to object (article 21 of the GDPR). If the personal data is processed with your consent, you have the right to withdraw this consent under article 7 III of the GDPR.

Please contact the data protection officer of Bitello Studio S.R.L. to assert your rights with regards to the data processed for the operation of this software (see section 2). Please note that you must address yourself exclusively to the controller in order to assert your rights as a data subject from the processing of personal data by DressUp Club as subprocessor on behalf of our customers. We reserve the right not to answer such questions or to pass them on to the controller of this data processing.

8. Right to lodge a complaint

We would hereby like to inform you that pursuant to article 77 GDPR you have the right to lodge a complaint with the supervisory authority if you believe that your personal data have been processed illegitimately by us. 

9. Right to object

You can object to the use of your data by using the appropriate opt-out or by making the appropriate adjustments in the Mixpanel consent management system.

10. Final clauses

DressUp Club reserves the right to adjust this data privacy policy at any point in time to ensure that it is in line with the current legal requirements at all times, or in order to accommodate changes in the services offered, for example when new services are introduced or modifications are made on the website. In this case, the new data privacy statement applies to any later visit of this software.

Version 01-11-2021