DisegnoSarto
Last updated: June 12, 2026
Effective date: June 12, 2026
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”).
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.
We collect usage data through Firebase Analytics to understand how the App is used and to improve it. This data is pseudonymised (it is linked to a Firebase-generated app-instance identifier rather than directly to your name), and is processed under our legitimate interest (Article 6(1)(f) GDPR). It may include:
Privacy-protective configuration: We have configured Firebase Analytics to truncate / anonymise IP addresses and we do not enable Google Signals, advertising identifiers, or ads-personalisation features. Analytics data is never used for advertising or cross-app tracking.
How to opt out: You can disable analytics collection at any time, with immediate effect, directly in the App via Settings → Privacy → Usage Analytics. No analytics events are sent while this setting is off. This implements your right to object under Article 21 GDPR.
We may automatically collect: device type and model; operating system and version; unique device identifiers generated by Firebase for analytics and crash reporting; language and locale settings; and app version.
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 analytics and security providers (Firebase, RevenueCat) automatically process your IP address, from which an approximate, coarse location (typically country and city level) may be derived for analytics aggregation, 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 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 | 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) |
| Usage analytics and app improvement | Legitimate interest — to understand and improve how the App is used, using pseudonymized data with IP truncation and no advertising features. You may opt out in-app at any time (Art. 6(1)(f) GDPR; see Section 2.3) |
| Security and fraud prevention | Legitimate interest — to protect our users and our service (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 analytics data is pseudonymized, IP-truncated, free of advertising identifiers, proportionate, and you can opt out at any time in-app.
We do not sell your personal data, and we do not share it with any party for marketing or advertising. 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 (Analytics) | Usage analysis and crash reporting | Pseudonymized usage and device data | 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) |
| Google (Google Sign-In) | Third-party authentication (if chosen) | Email, name (as authorized by you) | EU / US (SCCs) |
| Apple (Sign in with Apple) | Third-party authentication (if chosen) | Email or relay email, name (as authorized) | US / Ireland (SCCs) |
Each provider acts as a data processor on our behalf and is bound by data-processing agreements compliant with Article 28 GDPR.
The App integrates the following third-party SDKs: Firebase Authentication, Cloud Firestore, Firebase Analytics, Firebase App Check, RevenueCat Purchases, Google Sign-In, and (on iOS) Apple Authentication Services. Each may collect and transmit data as described in their respective privacy policies (see Section 13).
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 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 |
| User-created content (designs, wardrobe, outfits) | Until you delete your account or remove the content |
| Analytics data | Retained in pseudonymized/aggregated form per Firebase default retention (up to 14 months for user-level data) |
| 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 |
When you delete your account, we delete or anonymize your personal data within 30 days, except where retention is required by law (e.g. transaction records above).
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.
The DisegnoSarto App is a mobile application and does not use cookies. Firebase Analytics may use device identifiers to collect pseudonymized usage data; this is not used for advertising or cross-app tracking, and you can disable it in-app (Section 2.3). If we launch a website in future, we will provide cookie information and obtain consent as required.
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 June 12, 2026. Version 4.0
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