Privacy Notice
Effective Date: 24 June 2026
Your style identity, your data, your control
Privacy at KinraLab
Your Style Identity is personal, and we treat it that way. KinraLab exists to help you understand and express your personal style, and the data we hold about you is what helps us do that. We are open about what we collect, why we collect it, and what choices you have, because we want you to feel confident in the choice to share.
This Privacy Notice aims to provide a clear understanding of the personal information we collect and how we use it.
By using KinraLab, you agree to the practices and policies outlined in our Privacy Notice. Please note that your use of our services is always subject to our Terms of Service which includes this Privacy Notice.
1. Who we are
KinraLab is the styling intelligence platform that creates a persistent Style Identity for each person, connecting who you are to what you wear, own, and shop.
This Privacy Notice is provided by KinraLab (referred to as "we," "us," or "KinraLab" throughout this document). KinraLab is a Free Zone LLC licensed by Dubai Internet City (DIC), part of the Dubai Development Authority (DDA), based in Dubai, United Arab Emirates. KinraLab is the data controller for personal data described in this Privacy Notice.
KinraLab is based in the UAE and primarily serves users in the United Arab Emirates. Our website is open and people from other countries, including the EEA and the UK, may also use KinraLab. Wherever you access KinraLab from, we apply data protection standards consistent with the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), and where applicable, the EU GDPR and the UK GDPR.
For any privacy-related questions or requests, contact us at privacy@kinralab.com. We respond to all requests within 30 days.
2. Who this notice applies to
This notice applies to everyone who uses KinraLab: registered users, people who complete our Discovery experience without registering, and visitors who simply browse our website.
KinraLab also serves business customers (brands, retailers, and stylists) whose data is governed by separate agreements with those partners. This Privacy Notice applies to consumer data and individual users.
Minimum Age
KinraLab is for users aged 18 and older. We may ask you to confirm your age when you create an account or start Discovery. Upon discovery that an account is registered to or used by a minor, KinraLab will suspend and close such account without notice and will process the associated personal data solely as required to fulfil its obligations under applicable data protection law.
Parents or guardians who believe a minor has registered should contact us at privacy@kinralab.com.
3. What personal data we collect
We collect personal data in the categories below. We collect only what we need to deliver KinraLab and improve our service. Providing your account data is necessary to use KinraLab. Providing Discovery responses is necessary to generate a Style Identity. You may decline, but you will not be able to use those features.
Account information
When you create an account, we collect your email address, name, and a securely hashed version of your password.
Discovery information
When you go through Discovery, we collect your first name (which you provide and define however you choose), the responses you give through the AI-guided conversation, and the resulting Style Identity. Discovery can be completed before you create an account; if you don't register within a limited period, your Discovery session is deleted.
Wardrobe Information
When you add items to your wardrobe, we collect the photographs you upload and the details you provide for each item: name, category, wear frequency, brand, and any optional comments you choose to add. Our machine learning models analyse your wardrobe photos to tag each item with its style attributes, which feeds your personalised experience. We ask you to upload photos of the garment alone, without yourself in the frame. The models work best with clean garment photos, and uploading garment-only photos also keeps the personal data we hold about you to a minimum.
Activity and signals
As you use KinraLab, we record which items you view, like, dislike, or click through to, along with similar interactions with the product. These signals power your personalised experience and aggregate analytics.
Communications
If you send us feedback through our website form or email us directly, we retain the content of your message. We also store your preferences for marketing communications.
Technical information
When you visit our website, we automatically collect technical information such as your device type, browser, traffic source, and (at the infrastructure layer) your IP address. We use this for security, debugging, and understanding how the Platform is used.
What we do not collect
At this time, we do not collect biometric data, financial information, identity documents, or special-category data as defined under data protection law. If we introduce features that involve any of these categories in the future, we will ask for your explicit consent at the moment you first use the feature.
4. How we collect personal data
We collect personal data from three sources:
- Directly from you, when you create an account, complete Discovery, add to your wardrobe, send us feedback, or interact with the product in any way.
- Automatically, as you use KinraLab; for example, when you view content, react to items, or browse the website.
- From third parties: currently only when our brand partners report aggregate engagement counts back to us. We do not receive individual-level data about you from any third party.
5. Why we process your data
Every use of personal data must have a lawful basis. KinraLab relies on four.
To deliver the services (contract performance)
When you Processing your account data, your Discovery responses, wardrobe, your Style Identity, and interactions is necessary to provide KinraLab Services. If you do not want this processing, you will need to stop using the Platform.
To improve KinraLab and operate the Platform (legitimate interest)
We use aggregate analytics to understand how the Platform is used; we use activities of the user base (including your wardrobe data, discovery data and interactions) to train and improve our AI models and further personalise the services; we maintain security and infrastructure logs; and we provide brand partners with aggregate engagement reporting. We have a legitimate business interest in each of these uses, balanced against your right to object. You can exercise your right to object through the privacy controls in your account or by contacting us.
To send marketing communications and to deliver optional features (consent)
We send marketing communications only if you opt in. Every marketing email we send includes an unsubscribe link, and you can withdraw your consent at any time. Non-essential cookies are used only if you accept them. For any future features that may involve sensitive data, we will ask for separate explicit consent before you first use the feature.
To comply with legal obligations
We retain records that we are legally required to keep, such as evidence that we have honoured deletion requests.
6. Automated processing and AI
KinraLab uses AI to deliver Discovery, wardrobe analysis, and your personalised feed. The AI follows a styling methodology designed and overseen by humans. It guides and suggests while you make the meaningful choices.
KinraLab does not make decisions about you that produce legal or similarly significant effects by automated means. Your Style Identity is something you arrive at actively: the AI offers options, you choose, reject, or refine them.
AI training and improvement
Our AI models are trained on the styling methodology behind KinraLab. To keep them accurate and to improve them over time, we use data from our user base, including wardrobe images, behavioural signals, and Discovery responses under legitimate interest in improving the Services we provide to all our users.
You can object to your data being used for AI improvement by contacting us at privacy@kinralab.com. Objection stops your data being used in future training rounds; it cannot reverse training already carried out, as model weights cannot be surgically unwound once trained.the feature.
AI partners
Some of our AI capabilities are delivered by third-party AI service providers. When you use Discovery, your responses are processed by these providers under written agreements that include standard data protection clauses for cross border transfers. To know which AI providers we currently use, email us at privacy@kinralab.com.
7. Who we share your personal data with
We do not sell your personal data. We share it only with the recipients below, for the purposes described.
Service providers
We use third-party service providers for essential functions such as hosting and infrastructure, AI processing, email delivery, customer support, and error monitoring. Each service provider acts under a written agreement that includes data protection commitments and processes data only on our instructions. For the current named list of our sub-processors and what each one does, email us at privacy@kinralab.com.
Brand partners
By default, brand partners see aggregate engagement information about their products on KinraLab, for example total counts of impressions, likes, and clicks on their products, broken down by general Style Identity patterns. They do not see who you are or which specific items you liked. We share individually identifying information with a partner only when you explicitly ask us to, for a specific purpose, in the moment (for example, asking us to share your interest with a store so you can try items in person).
We may also publish or share aggregate insights reports derived from our user base, such as patterns in style preferences, engagement, or wardrobe trends. These insights never include data that identifies any individual user.
Legal disclosures
We may share personal data when legally compelled to do so. For example, in response to a valid legal request from a court or regulator. We push back on requests we believe to be improper and aim to notify you when we are legally able to.
Business transfer
If KinraLab is acquired, merged, or otherwise transferred, your data may be transferred as part of that transaction. We will notify you in advance and ensure that any new operator is bound by privacy commitments equivalent at least to this Privacy Notice.
8. Where your data is processed and transferred
We host our primary infrastructure within the European Economic Area, with data stored in Ireland. This is true for most of the personal data we process.
Some processing happens outside the EEA, in particular when your data is processed by our AI partners or other service providers based in another jurisdiction, or when data is processed within the UAE in connection with KinraLab's own operations. When data is transferred outside the EEA or the UK, we put appropriate safeguards in place, including the Standard Contractual Clauses approved by the European Commission and the UK International Data Transfer Agreement (or the UK Addendum to the EU SCCs) for transfers from the UK.
KinraLab is established in the Dubai Internet City free zone and is subject to the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021). Where we transfer your personal data outside the UAE, we do so on the bases permitted under Articles 22 and 23 of the PDPL: transfer to a jurisdiction recognised as providing an adequate level of protection, transfer under contractual safeguards consistent with the PDPL, or, where applicable, transfer that is necessary to perform our contract with you or that you have explicitly consented to.
9. How long we keep your data
We keep your personal data only for as long as needed to provide KinraLab, operate the Platform, meet legal obligations, and protect the security of the Services.
- Account data, Discovery responses, Style Identity data, wardrobe images, wardrobe metadata, and interaction signals are kept while your account is active. If you delete your account, we delete or anonymise this data within 30 days, unless we are legally required to keep a limited record for compliance or dispute purposes.
- If you complete Discovery without creating an account, we retain that Discovery session for up to 60 days and then delete it.
- Support messages and feedback are kept for up to 24 months, then deleted or anonymised. Technical and security logs are kept for up to 90 days, unless needed to investigate fraud, abuse, violation of Terms, or a security incident. Minimal records of deletion requests may be kept for up to 3 years to evidence that we complied with the request. Anonymous aggregate data that no longer identifies you may be retained indefinitely.
If you have a specific question about data deletion or retention, contact us at privacy@kinralab.com.
10. Your rights
Under data protection law, you have a set of rights over your personal data. KinraLab supports all of them. You can exercise any of these rights by contacting us at privacy@kinralab.com, or by using the controls in your account where available.
Your rights in detail
- Right of access: you can request a copy of the personal data we hold about you.
- Right to rectification: you can ask us to correct inaccurate or incomplete data. You can update most of your data directly in your account.
- Right to erasure: you can ask us to delete your personal data, subject to any legal retention obligations described in Section 9. You can delete your account at any time through your profile.
- Right to restriction of processing: you can ask us to temporarily limit how we process your data while a question or dispute is resolved.
- Right to data portability: you can ask us to provide your data in a structured, commonly used, machine-readable format. Email privacy@kinralab.com to request this, and we will deliver it within 30 days.
- Right to object: for processing we base on legitimate interest, you can object at any time. Where applicable, we provide in-product controls to exercise this right.
- Right to withdraw consent: where you have given consent (for marketing, cookies, or specific features), you can withdraw it at any time. Withdrawal does not affect processing that took place before the withdrawal.
- Right to lodge a complaint: you can file a complaint with a data protection supervisory authority: your local authority if you are in the EU, the Information Commissioner’s Office if you are in the UK, or the UAE Data Office if you are in the UAE.
We respond to all rights requests within 30 days, free of charge. If your request is unusually complex, we may extend this by a further period of up to two months. In that case, we'll let you know within the first 30 days and explain why.
11. Cookies and similar technologies
KinraLab uses cookies and similar storage technologies to make our website work, to understand how people use it, and to remember your preferences.
We use two categories of cookies:
- Functional cookies, which are always active because they are necessary for the website to work.
- Performance and analytics cookies, off by default. They help us understand how people use KinraLab. When you first visit KinraLab, we ask for your consent via a cookie banner before any analytics cookie is set. You can accept, decline, or change your choice at any time.
If you have a KinraLab account, your cookie choices are saved to your account, and you can change them anytime in your profile preferences. If you are using KinraLab without an account, your choices are saved on your device, and you can change them by clearing your cookies in your browser. If you would like the specific names, purposes, and lifespans of cookies we set, email us at privacy@kinralab.com.
Separately, your preference to receive non-essential communications from us (such as marketing emails) is stored as a setting in your account, not as a cookie. You can change it in your profile.
We do not currently use third-party analytics SDKs (such as Google Analytics or Mixpanel) for behavioural tracking. If we add any in the future, we will update this notice and obtain your prior consent before they are activated.
12. How we keep your data secure
We take security seriously and apply industry-standard practices to protect your data.
- All data we hold is encrypted at rest. All data in transit between your device and our servers is encrypted using HTTPS.
- Our infrastructure is hosted on a major cloud provider in the European Economic Area, with network isolation between our application layer and our databases.
- Access to user data within KinraLab is restricted to authorised personnel and reviewed regularly.
- Passwords are stored using industry-standard cryptographic hashing. We never store your password in a recoverable form.
- We maintain audit logs of administrative activity and have a defined process for responding to security incidents.
- Where third-party providers process your data on our behalf (see Section 7), each operates under a written data-protection agreement that requires them to maintain appropriate security measures. We choose providers whose security posture we have reviewed.
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. If we ever discover a personal data breach that is likely to affect your rights, we will notify you and the relevant supervisory authority without undue delay (and, where required, within 72 hours of becoming aware) and notify you directly where the breach poses a high risk to your rights.
13. Minors' data
KinraLab is intended for users aged 18 and older. We ask you to confirm your age when you create an account or start Discovery.
We do not knowingly collect personal data from anyone under the age of 18. If we discover that an account belongs to or has been used by a minor, we will suspend and close the account and delete the associated personal data within 30 days, processing it only as necessary to comply with our legal obligations in the meantime. If you are a parent or guardian and believe that a minor has provided personal data to us, please contact us at privacy@kinralab.com.
14. Changes to this notice
Our service will evolve and so will this notice. When we make material changes to how we handle your personal data, we will update this notice and notify you by email for significant changes and through prominent notice on the Platform before the change takes effect. For minor updates (clarifications or corrections), we may update this notice without separate notification.
The effective date at the top of this notice tells you when the current version came into effect. Earlier versions are available on request.
15. How to contact us
For any question, request, or concern about how we handle your personal data, contact us:
By email: privacy@kinralab.com
By post: KinraLab FZ-LLC, HD26C at In5 Tech, Dubai Internet City, Dubai, United Arab Emirates
If you are not satisfied with our response, you have the right to lodge a complaint with a data protection supervisory authority - your local authority if you are in the EU, the Information Commissioner's Office if you are in the UK, or the UAE Data Office if you are in the UAE.