DisegnoSarto
Version 5.1 — Last updated: October 5, 2026 — Effective date: October 5, 2026
What changed in this version: version 5.1 explains how we back up your data and how long recovery copies are kept (Sections 2.3, 7 and 8), and removes references to Google and Apple sign-in, which the App does not offer (Sections 2.1, 5 and 13). Version 5.0: the App can now use your device camera to photograph the fabric of your ties and pocket squares, and it no longer contains any analytics tool. Sections 2.3, 2.4, 2.9, 3, 5, 7, 8 and 10 describe what is captured, where it is stored, who can access it, and how to delete it.
Welcome to DisegnoSarto. This Privacy Policy explains how Maxime Biasiol, operating as DisegnoSarto (a sole proprietorship / micro-entrepreneur under French law), referred to as “we”, “us”, or “our”, collects, uses, stores, and protects your personal information when you use the DisegnoSarto mobile application (the “App”) and the website disegnosarto.com (the “Website”).
We are committed to protecting your privacy and handling your data transparently. This policy applies to all users of the App, regardless of location, and is designed to comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the French Data Protection Act (Loi Informatique et Libertés), and other applicable data protection laws.
By using the App, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the App.
The data controller responsible for your personal data is:
Maxime Biasiol
Operating as: DisegnoSarto (sole proprietorship / micro-entrepreneur)
SIRET: 97791455500015
Address: 24 rue Jeanne d’Arc, Saint-Jean-de-Bournay, France
Email: privacy@disegnosarto.com
As a micro-entrepreneur under French law, the data controller is an individual, not a separate legal entity. For all privacy-related inquiries, please use the contact email above.
Under Article 37 GDPR, we are not required to appoint a Data Protection Officer (DPO), as we are a small-scale operator that does not carry out large-scale processing of special categories of data or systematic monitoring of individuals. If this changes, we will update this policy. For all privacy inquiries, contact us using the email in Section 1.1.
We collect and process the minimum amount of personal data necessary to provide and improve the App, in accordance with the GDPR data-minimisation principle (Article 5(1)(c)).
When you create an account, we collect:
When you use the App, you may create and store the following data, tied to your account:
This content is stored solely to provide the App’s core functionality. We do not access, review, or use your wardrobe data for any purpose other than delivering the service to you.
The App can use your device camera to photograph the fabric of a tie or pocket square, so the accessory appears in your wardrobe with its real fabric instead of a flat colour. This feature is optional, available to premium subscribers, and used only when you start a capture yourself.
What is captured. The camera screen shows a cut-out in the shape of the accessory. When you take the photo, the App crops the image on your device to the area inside that cut-out. The rest of the camera frame is discarded on your device and is never uploaded. Only the cropped fabric image is saved.
What is not captured. The App does not record video or sound, does not run in the background, and does not access your photo library. It does not perform face recognition or any biometric analysis. Because the App does not request location permission, the photo contains no location data. Please avoid capturing people or other personal items inside the cut-out.
Why. The photo is used only to display the accessory in your wardrobe, outfit combinations, and plans.
Where it is stored. The cropped image is uploaded to Cloud Storage for Firebase (Google) in a folder tied to your account, and a copy may be cached on your device for faster display. Storage security rules allow only your own account to read or write your photos.
Who can see it. Only you. Your photos are not visible to other users, are not published, and are never sold or shared with anyone for marketing, advertising, or AI/ML training. Google processes the files solely as our hosting provider (see Section 5). We do not view your photos. Administrative access is limited to the data controller and used only if you ask us for help with a specific item or if the law requires it.
How to delete it. Delete the accessory, or replace its photo, and the image is removed from the App and our storage straight away; a recovery copy is kept for up to 7 days, then permanently erased (see Section 7). Deleting your account removes all your photos (see Section 7).
Permission. Camera access is requested by your device’s operating system the first time you use the feature. You can refuse it, or revoke it at any time in your device settings; all other features keep working, and accessories can still be created with colours.
The App contains no analytics, advertising, or tracking tool. We do not record which screens you visit or how you use the App, we do not collect your device’s advertising identifier, and we do not track you across other apps or websites.
Our service providers (Firebase and RevenueCat) automatically receive limited technical information needed to run the service and prevent abuse: device type and model, operating system and version, app version, and language and locale settings.
The App offers in-app purchases managed through RevenueCat, Inc. We do not collect or store your payment card details, banking information, or billing address. Payment processing is handled entirely by the platform store (Google Play or Apple App Store) and by RevenueCat. We receive only:
We use Firebase App Check to verify that requests to our backend originate from the authentic DisegnoSarto app. This service processes device-attestation tokens to prevent abuse and unauthorized access. No personal data is collected through App Check beyond anonymous device-attestation signals.
We do not collect precise or GPS-based geolocation, and the App does not request location permissions. However, like virtually all internet services, our service providers (Firebase, RevenueCat) automatically process your IP address, from which an approximate, coarse location (typically country level) may be derived for fraud prevention and abuse detection. We do not use this to track or identify your movements.
For transparency, we confirm that we do not collect:
We do not use your data, including your photos, for: selling to third parties; behavioral advertising or ad targeting; automated decision-making or profiling producing legal effects (Article 22 GDPR); or training artificial-intelligence or machine-learning models.
If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we process your personal data on the following grounds:
| Purpose | Legal Basis |
|---|---|
| Account creation and service delivery, including storing and displaying accessory photos you choose to take | Performance of a contract — necessary to provide the service you signed up for (Art. 6(1)(b) GDPR) |
| In-app purchases and subscription management | Performance of a contract — necessary to fulfil your purchase (Art. 6(1)(b) GDPR) |
| Security and fraud prevention | Legitimate interest — to protect our users and our service (Art. 6(1)(f) GDPR) |
| Customer support and handling your requests | Legal obligation for privacy requests (Art. 6(1)(c) GDPR); legitimate interest for other support (Art. 6(1)(f) GDPR) |
| Compliance with legal obligations | Legal obligation — where required by applicable law, e.g. retention of transaction records (Art. 6(1)(c) GDPR) |
Legitimate-interest assessment: Where we rely on legitimate interest, we have conducted a balancing test confirming that our interests do not override your fundamental rights and freedoms. The processing is limited to technical signals and messages needed to keep the service secure and to answer you, and it is never used for advertising or profiling.
We do not sell your personal data, and we do not share it with any party for marketing or advertising. Your photos and wardrobe are never shown to other users. We share data only with the following service providers (“sub-processors”), strictly as necessary to operate the App:
| Service Provider | Purpose | Data Shared | Location |
|---|---|---|---|
| Google Firebase (Authentication) | User login and account management | Email, authentication tokens | EU / US (SCCs) |
| Google Firebase (Cloud Firestore) | Storing designs, wardrobe, app data | User-created content, account IDs | EU / US (SCCs) |
| Google Firebase (Cloud Storage for Firebase) | Storing accessory photos | Cropped fabric images, account IDs | EU / US (SCCs) |
| Google Firebase (App Check) | Preventing abuse and unauthorized access | Device-attestation tokens | EU / US (SCCs) |
| RevenueCat, Inc. | Subscription and in-app purchase management | User identifiers, subscription status | US (SCCs) |
Each provider acts as a data processor on our behalf, may use the data only to provide its service to us, and is bound by data-processing agreements compliant with Article 28 GDPR.
The App integrates the following third-party SDKs: Firebase Authentication, Cloud Firestore, Cloud Storage for Firebase, Firebase App Check, and RevenueCat Purchases. Each may collect and transmit data as described in their respective privacy policies (see Section 13). The App contains no analytics or advertising SDK. It uses your device’s built-in camera interface; no third-party SDK receives camera data.
We may disclose your information where required by law, regulation, legal process, or governmental request; to enforce our Terms of Service; to protect the rights, property, or safety of our users or the public; or in connection with legal proceedings.
Your data, including your accessory photos, is processed and stored using Google Cloud infrastructure, which may process data outside the EEA, including in the United States. RevenueCat processes subscription data in the United States. Where data is transferred outside the EEA, we rely on:
Learn more at policies.google.com/privacy and revenuecat.com/privacy.
| Data Type | Retention Period |
|---|---|
| Account information | Until you delete your account, or until inactivity deletion (see below) |
| User-created content (designs, wardrobe, accessories, outfits) | Until you delete the content or your account, or until inactivity deletion |
| Accessory photos | Deleted from our storage when you delete the accessory or replace its photo (a recovery copy is kept for up to 7 days); otherwise kept until you delete your account, or until inactivity deletion |
| Photo cache on your device | Removed when you delete the accessory or uninstall the App |
| Support and privacy-request emails | 3 years after our last exchange |
| Payment / subscription records | 10 years after the transaction, as required by French law (Art. L123-22 Code de commerce) |
| Firebase App Check attestation tokens | Transient — not retained beyond the verification request |
| Backups (recovery copies) | Up to 30 days for your account and content; up to 7 days for deleted photos. Then permanently erased. |
Account deletion. When you delete your account, we delete or anonymize your personal data, including all your accessory photos, within 30 days, including from our backups, except where retention is required by law (e.g. transaction records above).
Backups. To protect your data against loss or technical failure, we keep encrypted backups of the App’s database for up to 30 days, and deleted photos stay recoverable for up to 7 days. Backups are hosted by Google like the live data, are used only to recover the service after an incident, and are never browsed or used for any other purpose. Data you delete disappears from backups as they expire, at the latest 30 days after deletion. If we ever restore a backup, we first delete again everything you deleted after it was taken.
Inactive accounts. If you have not signed in for 24 months and have no active subscription, we will email you at least 30 days before deleting your account. If you do not sign in during that period, your account and all associated data, including photos, are deleted under the same rules as an account deletion.
End of a subscription. If your premium subscription ends, your existing photos are kept and remain visible to you; you only lose the ability to take new ones. We never delete content because of a downgrade.
While we take reasonable technical and organizational measures, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.
In the event of a personal-data breach likely to result in a risk to your rights and freedoms, we will:
If you are located in the EEA, UK, or Switzerland, you have the following rights:
To exercise any right, contact us at the email in Section 1.1. We respond within 30 days, extendable by up to 60 days for complex requests, in which case we will inform you within the initial period.
Supervisory authority: the lead authority for our processing is the CNIL: www.cnil.fr — Tel: +33 (0)1 53 73 22 22. You may also contact the authority in your EU/EEA member state of residence.
In the App. The DisegnoSarto App does not use cookies and contains no analytics, advertising, or tracking SDK.
On the Website. The Website is hosted by Webflow, Inc., which processes technical data such as your IP address to deliver the pages. The Website does not use advertising or cross-site tracking cookies. If we add analytics or other non-essential cookies, we will ask for your consent first.
DisegnoSarto is intended for adults and is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected such data without verified parental consent, we will delete it within 72 hours. If you believe a child under 16 has provided us with personal data, contact us immediately at the email in Section 1.1.
The App integrates with third-party services that have their own privacy policies, which we encourage you to review:
We are not responsible for the privacy practices of these services.
We do not engage in automated decision-making or profiling producing legal effects concerning you or similarly significantly affecting you, within the meaning of Article 22 GDPR. No decisions about your access, pricing, or service level are made by automated means without human involvement.
We may update this Privacy Policy to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will update the “Last updated” date and notify you through the App or via the email associated with your account. Your continued use of the App after changes constitutes acceptance of the updated policy.
This Privacy Policy is governed by the laws of France, without regard to conflict-of-law principles, and in compliance with the GDPR.
Any disputes that cannot be resolved amicably shall be submitted to the competent French courts of Vienne, without prejudice to your right to lodge a complaint with a supervisory authority or, as a consumer, to bring proceedings before the courts of the EU/EEA member state in which you are habitually resident.
Maxime Biasiol — DisegnoSarto
Email: privacy@disegnosarto.com
Address: 24 rue Jeanne d’Arc, Saint-Jean-de-Bournay, France
For complaints about data handling, you may also contact the CNIL: www.cnil.fr — Tel: +33 (0)1 53 73 22 22.
This Privacy Policy was last reviewed on October 5, 2026. Version 5.1
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