Privacy Policy

Who we are

This Privacy Policy explains how ilé collects and uses personal data. ilé is owned and operated by ILE GROUP LTD, a company registered in England and Wales (company number 17405689), whose registered office is at 20 Wenlock Road, London, England, N1 7GU.

For data protection purposes, ILE GROUP LTD is the controller of your personal data.

Privacy contact: ade@ileapp.co.uk.

Who can use ilé

ilé is intended for users aged 16 or over. We do not knowingly allow users under 16 to create accounts. If we discover that we have collected personal data from someone under 16, we will delete or anonymise it unless we need to keep limited information for legal, safety or security reasons.

Because 16 and 17 year olds are still children under UK data protection law, we aim to write our privacy information in clear language and avoid using their data in ways they would not reasonably expect.

Personal data we collect

Depending on how you use ilé, we may collect:

• Account data: name, email address, login identifiers, authentication provider ID, account settings and login metadata.
• Age and onboarding data: age range, fragrance experience level, fragrance preferences, chosen advisor, preferred price range, favourite fragrance, last-bought fragrance, taste preferences and other onboarding answers.
• Fragrance data: wardrobe, wishlist, tried, passed or saved fragrances, ratings, wear logs, scent memories, diary entries, notes, purchase intentions and recommendations.
• Photos and uploads: fragrance shelf photos, bottle photos, profile photo if you add one, and any images you choose to upload.
• Chat and advisor data: messages you send, AI responses, feedback, recommendation history, prompts, conversation history and, if voice features are enabled, audio recordings and transcripts.
• Location data: approximate location, town, city or device location only where you provide it or grant permission for features such as weather-based recommendations or local stores.
• Device and usage data: device type, operating system, app version, IP address, crash logs, diagnostic data, app events, session data and analytics identifiers.
• Subscription and transaction data: subscription status, plan type, trial status, renewal status and limited payment records from Apple, Google or another payment provider. We do not store full card numbers.
• Communications: messages you send to us, support requests, feedback, survey responses and legal/privacy requests.

How we use personal data and our lawful bases

We use personal data for the following purposes:

• To create and manage your account: contract.
• To provide the app, save your wardrobe, remember preferences and deliver recommendations: contract.
• To personalise AI fragrance advice, "scent DNA", daily picks and advisor responses: contract and legitimate interests.
• To process subscriptions and manage access to paid features: contract and legal obligation.
• To provide optional location, microphone, photo upload or voice features: consent or contract, depending on the feature and permission.
• To improve, test, debug, secure and monitor the Service: legitimate interests.
• To send service messages, updates and support replies: contract and legitimate interests.
• To send marketing messages where required by law: consent or soft opt-in, with an unsubscribe option.
• To comply with legal, accounting, tax, dispute, fraud prevention and regulatory obligations: legal obligation and legitimate interests.

Where we rely on consent, you can withdraw consent at any time through device settings, in-app controls or by contacting us. Some features may not work without the relevant permission.

AI processing

ilé uses third-party AI providers and related tools to generate responses and recommendations. When you ask the AI advisor a question, we may send relevant information to an AI provider, such as your message, fragrance preferences, wardrobe items, chosen advisor style, recommendation history and other context needed to answer.

We aim to minimise the personal data sent to AI providers and use service providers under appropriate terms. AI outputs are generated automatically and may be inaccurate, incomplete or unsuitable. ilé does not use AI to make decisions that produce legal or similarly significant effects about you.

Photos, voice and location

Photos: if you upload photos, we use them to provide features such as wardrobe recognition, profile display, shelf review or fragrance matching. Avoid uploading images that contain other people, private documents, addresses or sensitive information unless you are comfortable doing so.

Voice: if voice features are enabled, we may process audio and transcripts to provide speech-to-text, voice replies or advisor interaction. We do not intend to create voiceprints to uniquely identify users. You can choose not to use voice features.

Location: if location features are enabled, we use approximate location or permission-based device location for features such as weather-based recommendations or local stores. You can disable location permission in your device settings.

Cookies and analytics on our website

Our landing page may use strictly necessary cookies to make the site work. If we use analytics, advertising pixels, affiliate tracking or non-essential cookies, we will provide appropriate cookie information and, where required, ask for consent before setting those cookies.

You can control cookies through your browser settings. Blocking cookies may affect some website features.

Marketing and notifications

We may send service messages about your account, subscriptions, security, legal updates or important app changes. These are not marketing.

We will send marketing emails, push notifications or promotional messages only where we have the right to do so. You can unsubscribe from marketing emails or change notification settings at any time.

Who we share data with

We may share personal data with trusted providers who help us run ilé, including:

• cloud hosting, database, storage and authentication providers;
• AI, voice and image-processing providers;
• analytics, crash reporting and security providers;
• email, support and communication providers;
• Apple, Google and payment processors;
• map, weather, geocoding or local store providers where those features are used;
• professional advisers, insurers, accountants and legal advisers;
• authorities, regulators or courts where required by law;
• a future ilé company, buyer, investor or successor if the business is incorporated, reorganised, sold or transferred.

We do not sell your personal data. If affiliate or advertising technologies are used, they will be described in this policy or our cookie information.

Payments

In-app payments are normally processed by Apple App Store or Google Play. We receive limited information needed to confirm subscription status and provide access. Apple or Google may process payment and billing data under their own privacy terms.

If ilé later offers web payments, we may use Stripe or another payment provider. We do not intend to store full card details.

International transfers

Some providers may process personal data outside the UK. Where required, we use appropriate safeguards such as adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to Standard Contractual Clauses or other lawful transfer mechanisms.

How long we keep data

We keep personal data for as long as needed to provide ilé, maintain your account, comply with law, resolve disputes, prevent fraud and improve the Service.

As a guide:

• Account and profile data: while your account is active.
• Fragrance wardrobe, notes, photos and chat history: while your account is active, unless you delete them earlier or settings allow shorter retention.
• Support messages: normally up to 6 years where needed for records or disputes.
• Subscription and transaction records: as required for tax, accounting, fraud prevention and legal purposes.
• Analytics and diagnostics: normally kept in identifiable or pseudonymous form only as long as needed, then aggregated or deleted.

When you request account deletion, we will delete or anonymise personal data linked to your account within a reasonable period, usually within 30 days where technically possible, except for backups and limited records we must or may keep for legal, security, accounting, fraud prevention or dispute reasons.

Security

We use reasonable technical and organisational measures to protect personal data, such as access controls, secure authentication, encryption in transit, provider security controls, limited access to production systems and monitoring for misuse. No app, website or cloud system is completely secure, so you should also keep your login details safe and tell us promptly if you suspect unauthorised access.

Your rights

Under UK data protection law, you may have the right to:

• access a copy of your personal data;
• correct inaccurate or incomplete data;
• ask us to delete data;
• restrict how we use data;
• object to certain uses, including direct marketing;
• receive certain data in a portable format;
• withdraw consent where processing is based on consent; and
• complain to the UK Information Commissioner's Office (ICO).

To exercise rights, contact ade@ileapp.co.uk. We may need to verify your identity before responding. We aim to respond within one month, unless the law allows more time.

Account deletion and data deletion requests

If ilé allows account creation, we will provide a way to request account deletion in the app and/or through www.ileapp.co.uk. You can also contact ade@ileapp.co.uk.

Account deletion is different from subscription cancellation. If you have an Apple or Google subscription, you must cancel it through your Apple or Google account settings unless we tell you otherwise.

Special category data

ilé is not designed to collect special category data such as health, religion, political views, sex life or biometric identifiers. Please avoid including highly sensitive information in chats, photos, notes or uploads.

If you choose to tell the AI advisor about allergies, skin conditions, pregnancy, religious preferences, lifestyle restrictions or other sensitive matters, we will use that information only to provide the Service, improve safety and respect your request, unless we have another lawful basis. You should not treat ilé as medical, allergy, dermatology or safety advice.

Changes to this policy

We may update this Privacy Policy as ilé develops, including when we add new features, providers, subscriptions, creator advisors, voice tools, shopping links or when ilé is transferred to an incorporated company. We will update the "Last updated" date and notify users of material changes where required.

Contact

Data controller: ILE GROUP LTD, a company registered in England and Wales (company number 17405689), whose registered office is at 20 Wenlock Road, London, England, N1 7GU

Privacy email: ade@ileapp.co.uk

Support email: ade@ileapp.co.uk

Website: www.ileapp.co.uk

You can also complain to the UK Information Commissioner's Office at ico.org.uk if you are unhappy with how we handle your personal data. We would appreciate the chance to deal with your concern first.