Privacy Policy
Last updated: February 2026
1. Who We Are
FashionSpyder is a service developed under the Flence ecosystem, owned and operated by Influentive Ltd, Malta. FashionSpyder is an AI-powered HR intelligence platform that connects fashion brand HR teams with verified creative professionals sourced through Flence.
For the purposes of data protection law, Influentive Ltd (trading as Flence / FashionSpyder) acts as the data controller in respect of the personal data processed through this platform.
Contact for data protection matters: privacy@fashionspyder.com
2. Data We Collect
We collect and process the following categories of personal data:
HR Users (platform subscribers)
- Identity: full name, job title
- Contact: work email address, company name
- Account: hashed password, session tokens, 2FA codes
- Payment: subscription plan, billing status (payment details handled by Stripe — we do not store card numbers)
- Usage: search queries, match history, pipeline activity, viewed profiles
- Technical: IP address, browser type, device information, access logs
Fashion Professionals (candidate profiles)
- Profile data received via the Flence platform webhook (name, photo, role, skills, portfolio, location, availability)
- FashionSpyder does not directly collect data from candidates — all candidate data originates from Flence, where professionals have agreed to Flence's own terms and privacy policy
- Candidates may request removal of their profile by contacting Flence or emailing us at privacy@fashionspyder.com
Waitlist Entries
- Name, work email, company name, role type
- Used solely to notify you at launch and manage access eligibility
3. Legal Basis for Processing (GDPR Art. 6)
- Contract performance (Art. 6(1)(b)): Processing necessary to provide the platform service to subscribers — account management, authentication, AI matching, pipeline tools.
- Legitimate interests (Art. 6(1)(f)): Platform security, fraud prevention, service improvement, usage analytics.
- Consent (Art. 6(1)(a)): Optional/analytics cookies, marketing communications (where separately opted in).
- Legal obligation (Art. 6(1)(c)): Tax records, financial transaction logs (Stripe).
4. How We Use Your Data
- Providing and operating the FashionSpyder platform (gallery, AI Matchmaker, pipeline)
- Authenticating users and maintaining secure sessions
- Processing subscription payments via Stripe
- Running the AI Matchmaker algorithm (candidate data is processed by OpenAI GPT via the Emergent integrations layer — no candidate PII is used for model training)
- Sending transactional emails: OTP codes, password resets, subscription notifications (via Resend)
- Improving platform features through anonymous usage analytics
- Marketing and advertising on Meta and Pinterest (with your cookie consent)
- Preventing fraud, abuse, and unauthorised access
- Complying with legal obligations
5. Third-Party Processors
We share your data only with trusted processors under appropriate data processing agreements:
| Processor | Purpose | Location |
|---|---|---|
| Supabase | Database hosting (PostgreSQL + pgvector) | EU (AWS Frankfurt) |
| Stripe | Payment processing | USA (SCCs apply) |
| Resend | Transactional email delivery | USA (SCCs apply) |
| OpenAI via Emergent | AI matching & text generation | USA (SCCs apply) |
| Google Analytics 4 | Aggregated usage analytics (IP anonymised) | USA (SCCs apply) |
| Meta (Facebook Pixel) | Conversion tracking & ad optimisation (with consent) | USA (SCCs apply) |
| Pinterest Tag | Conversion tracking & trend audience research (with consent) | USA (SCCs apply) |
| Flence | Candidate profile data source | EU |
Where data is transferred outside the EEA, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission.
6. Data Retention
- HR user accounts: Retained for the duration of the subscription plus 2 years, then deleted unless required by law.
- Candidate profiles: Retained while the candidate maintains an active Flence profile. Profiles are removed within 30 days of deletion from Flence.
- Waitlist entries: Retained until the platform launches and invitations are sent, or until you request deletion.
- Payment records: Retained for 7 years to comply with Italian and EU tax law.
- Access logs: Retained for 90 days for security purposes.
7. Cookies
We use cookies and similar technologies. See our full Cookie Policy for details. You can manage your preferences at any time via the consent banner.
8. Your Rights Under GDPR
As a data subject in the EU/EEA, you have the following rights:
Right of access
Request a copy of all personal data we hold about you.
Right to rectification
Request correction of inaccurate or incomplete data.
Right to erasure
Request deletion of your personal data ("right to be forgotten").
Right to restriction
Request that we limit how we use your data.
Right to portability
Receive your data in a machine-readable format.
Right to object
Object to processing based on legitimate interests or direct marketing.
Right to withdraw consent
Withdraw any previously given consent at any time.
Right to lodge a complaint
Contact your national supervisory authority (in Italy: Garante Privacy — www.garanteprivacy.it).
To exercise any of these rights, email privacy@fashionspyder.com. We will respond within 30 days.
9. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. These include:
- All data transmitted over HTTPS/TLS encryption
- Passwords stored using bcrypt hashing — never in plain text
- Authentication sessions managed via secure, httpOnly cookies
- Two-factor authentication (2FA) available for all accounts
- Database hosted on SOC 2-certified infrastructure (Supabase / AWS)
- Access to production systems restricted to the development team
10. Children
FashionSpyder is a professional B2B platform intended exclusively for HR professionals and is not directed at or intended for use by anyone under the age of 18. We do not knowingly collect personal data from minors.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify active subscribers of material changes by email. The "Last updated" date at the top of this page will always reflect the most recent revision. Continued use of the platform after changes constitutes acceptance of the updated policy.
12. Contact
For any privacy-related questions, requests, or complaints:
FashionSpyder / Flence
Milan, Italy
Email: privacy@fashionspyder.com