Privacy Policy

The kind of personal information we collect depends on how you use Cycl. It may include:

• your name and email address;
• photographs and images you upload of your wardrobe items, together with any descriptions, tags or details you add;
• items you list for lending, borrowing or swapping;
• wardrobe circle membership details;
• messages you exchange with other circle members;
• device and usage data, such as IP address, browser type, and app interactions; and
• any other information you voluntarily provide when creating or using your Cycl account.

Images and automated tagging

When image indexing is enabled for your account, we may send uploaded wardrobe images to Anthropic, PBC through its Claude API so that an automated model can generate descriptive tags, for example the type, colour, pattern or material of an item, so that you can search and organise your wardrobe. This means your uploaded images may be processed by Anthropic outside Australia, including in the United States, for the limited purpose of providing the image-indexing feature.

We store uploaded wardrobe images securely on our infrastructure in Australia, currently Supabase in Sydney. Anthropic processes images on our behalf under its commercial and data-processing terms, and Anthropic states that it does not train its models on customer content submitted through the Claude API.

You can turn image indexing off in your account settings. If you do, Cycl will store and display your uploaded wardrobe images, but will not send those images to Anthropic for indexing. Features that rely on automated image metadata may not be available or may work less well.

Automated tagging is used only to operate features of Cycl. It is not used to make any decision that produces a legal or similarly significant effect on you.

Please do not upload photographs or details that reveal sensitive information, as Cycl is not intended to collect it.

The Privacy Act 1988 (Cth) defines types of information, including personal information and sensitive information.

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true and whether or not it is recorded in a material form. If information does not disclose your identity or enable it to be ascertained, it will in most cases not be personal information and will not be subject to this policy.

Sensitive information is defined in the Privacy Act as including information or opinion about such things as an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union or professional memberships, criminal record, or health information. We do not seek sensitive information. Where we do collect it, we will use it only:

• for the primary purpose for which it was obtained;
• for a secondary purpose directly related to the primary purpose; and
• with your consent, or where required or authorised by law.

• We collect personal information from you whenever you input it into Cycl or provide it to us in any other way.
• We may collect cookies from your device that let us recognise when you use Cycl and help customise your experience. As a general rule, you cannot be personally identified from our use of cookies.
• We generally do not collect sensitive information; when we do, we comply with section 2.
• Where reasonable and practicable, we collect personal information only from you. If a third party provides us with information about you, we will take reasonable steps to make you aware of it.

• We collect personal information to provide you with the best possible experience on Cycl and to keep in touch with you about our business.
• We disclose personal information to service providers who help us operate Cycl, for example hosting, email delivery, and optional image processing through Anthropic. Your personal information may also be accessed by maintenance and support personnel in the normal course of their duties.
• Other members of a wardrobe circle you join can view your listed items and profile information, in line with your circle's settings.
• We will only send you direct marketing where you have opted in - see section 5.

We will only send you direct marketing material, such as product updates or newsletters, if you have expressly opted in to receive it. You can withdraw your consent at any time using the unsubscribe link in our messages, or by contacting us using the details below. We do not use sensitive information for direct marketing.

• We store your personal information in a way that reasonably protects it from unauthorised access, misuse, modification or disclosure.
• Retention: We keep your personal information only for as long as we need it for the purposes described in this policy, or for as long as we are required to keep it by law. When we no longer need it, we take reasonable steps to destroy, anonymise or de-identify it. You may ask us to delete your account and associated information at any time, and we will do so except where we are required to retain certain records by law.
• The Australian Privacy Principles permit you to obtain access to the personal information we hold about you in certain circumstances (APP 12), and to correct inaccurate personal information subject to certain exceptions (APP 13). To request access or correction, please contact us in writing using the details below.

• In Australia: We store personal information on secure infrastructure located in Australia, currently hosted with Supabase in Sydney.
• International users: If you access Cycl from outside Australia, your personal information will be transferred to and stored in Australia. By using Cycl, you consent to that transfer and to the handling of your information as described in this policy.
• Overseas service providers: Some of our service providers may be located, or may store or process limited data, outside Australia, for example Anthropic in the United States when image indexing is enabled, and our email-delivery provider. Where we disclose personal information to an overseas recipient, we take reasonable steps to ensure they handle it consistently with the Australian Privacy Principles, and by using Cycl you consent to those disclosures.

If you are located in the European Union or the United Kingdom, the General Data Protection Regulation (GDPR) may provide you with additional rights, including rights to access, correct, erase, restrict or port your personal information, and to object to certain processing. To exercise these rights, please contact us using the details below.

Cycl is intended for people aged 16 years and over. We do not knowingly collect personal information from anyone under 16. If you are under 16, please do not use Cycl or provide us with your information. If we become aware that we have collected personal information from a person under 16, we will take reasonable steps to delete it.

If you have a complaint about how we handle the privacy of your personal information, please contact us using the details below. All complaints are considered by Sarah Vaughan, and we may seek further information to clarify your concerns. If we agree your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied, you may refer the matter to the Office of the Australian Information Commissioner (OAIC).