Privacy Policy
Last updated: 15 February 2026
Operated by: The Vibe Circle Ltd (trading as “TVC Threads”) | Company No.: 16418815
Registered Office: 167–169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom
Contact: hello@tvcthreads.com
1. Introduction and Data Controller
This Privacy Policy (the "Policy") describes how The Vibe Circle Ltd (trading as "TVC Threads"), a company incorporated in England and Wales (Company No. 16418815), collects, uses, and protects your personal data.
For the purposes of the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018, we act as the Data Controller.
2. Scope and Status
This Policy applies to our website (tvcthreads.com), mobile applications, and any associated services (collectively, the "Platform").
Current Operations Note
At the date of this Policy, the Platform is in an "Early Access & Preview" phase. Commercial transactions and payment processing are currently disabled. Provisions in this Policy relating to "Transaction Data" or "Fulfilment" are included for transparency regarding the Platform's upcoming full launch.
3. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:
Identity Data: Includes first name, last name, username or similar identifier, title, and date of birth (for age verification).
Contact Data: Includes billing address, delivery address, email address, and telephone numbers.
Fit & Measurement Data: Includes numerical physical dimensions (e.g., height, chest, waist, hip, inseam) and preferred garment silhouettes.
Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Platform.
Usage Data: Includes information about how you use our website, products, and services.
Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.1 Camera and Image Data (Privacy-First Architecture)
Our Platform utilizes proprietary camera-assisted measurement technology to provide custom-fit garments.
On-Device Processing: All image and video frame processing occurs locally on your device’s hardware.
No Central Storage: We do not transmit, upload, or store raw images, video frames, or snapshots on our servers.
Extracted Data Only: We only collect the resulting numerical output (e.g., "Waist: 32 inches") generated by the local processing.
Non-Identification: This technology is utilized solely for garment fitting. We do not process this data for the purpose of unique identification (biometric ID) or facial recognition.
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Performance of Contract: Where we need to perform the contract we are about to enter into or have entered into with you (e.g., delivering a garment).
Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., system security and platform improvement).
Comply with a Legal Obligation: Where we need to comply with a legal or regulatory obligation.
5. Disclosures of Your Personal Data
We may share your personal data with the parties set out below:
Service Providers: IT and system administration services (e.g., hosting, analytics).
Artisan Partners: Independent tailors and manufacturers who require specific measurement data to produce your order (Identity data is restricted to what is necessary for fulfilment).
Professional Advisers: Including lawyers, bankers, auditors, and insurers.
HM Revenue & Customs: Regulators and other authorities who require reporting of processing activities in certain circumstances.
6. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Encryption: All data in transit is encrypted via SSL/TLS.
Access Control: We limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.
Hashing: User credentials are stored using industry-standard salted hashing algorithms.
7. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Waitlist/Account Data: Retained until you request deletion or opt-out.
Transaction Data: (Post-launch) Retained for 6 years following the end of the tax year in which the transaction occurred to comply with UK tax laws.
8. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of these rights, please contact us at hello@tvcthreads.com.
9. Complaints
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO.
Trade mark: UK00004341050 | ICO registration reference: ICO:00013173461