Data Processing Agreement

Last updated: September 15, 2026 · Operator: Easturing Limited · For merchant / API customers

1. Roles

Where a merchant (“Controller”) embeds the FullOnMobile SDK or calls our APIs to process end-user portraits and try-on outputs, Easturing Limited (operating FullOnMobile) acts as Processor. For FullOnMobile’s own consumer app accounts, we act as Controller as described in the Privacy Policy.

2. Subject matter

Processing is limited to providing AI try-on, outfit recommendation, logging for security/billing, and optional features expressly enabled by the Controller (e.g. saved looks).

3. Nature of data

Image data depicting the end user (portrait / full-body).
Derived technical features required for rendering (not sold as biometric profiles).
Identifiers tying sessions to the Controller’s product context.

4. Instructions & confidentiality

We process personal data only on documented instructions from the Controller, including configuration of retention (auto-expire), regions, and subprocessors listed in the order form. Personnel are bound by confidentiality.

5. Security measures

We implement API authentication, encryption in transit, access control, abuse detection for batch GPU calls, and optional Cloudflare acceleration. Private deployment customers may define additional controls in the SOW.

6. Subprocessors

Controller authorizes use of infrastructure subprocessors necessary to deliver the service (cloud GPU, object storage, CDN). We will provide notice of material subprocessor changes where legally required.

7. International transfers

Where data is transferred across borders, parties will rely on appropriate safeguards (e.g. contractual clauses) specified in the commercial agreement.

8. Assistance & deletion

We assist with data subject requests, security incidents, and DPIAs reasonably related to the service. Upon termination, we delete or return Controller personal data within the timelines in the order form, except data retained for legal compliance.

9. Governing commercial terms

This DPA supplements the Terms of Service and executed order forms. For a signed PDF DPA, contact Easturing Limited at hello@fullonmobile.com.