Consent to Cross-Border Transfer of Personal Data
Edition of 21 August 2026. The document version is recorded in the database together with a timestamp at the moment you tick the checkbox.
Operator: Individual Entrepreneur MAKSIM POLIKANOV, identification number 304820433, address: Georgia, Tbilisi City 0108, Nino and Ilia Nakashidze Street N 1 (former Avlevi Area), Building N 3, Apartment N 3. Contact: hello@modello.style.
Why this is a separate consent and not a line in the general policy
Transferring data abroad is a distinct action that deserves a distinct, informed consent — not an "I have read everything" checkmark. That is why at registration you tick two different boxes: one for processing under the privacy policy, and this one. It can be withdrawn independently, without deleting the account.
What exactly you consent to
You agree that, for several functions of the service to work, your data will be transferred to processors outside your country:
Colour type determination. The selfie you upload is transferred to Anthropic (USA), where a model determines the tone of your skin, eyes and hair and returns the name of your colour type and a palette.
Outfit try-on. A photo of your figure and an outfit image are transferred to FASHN AI (USA), where an image of you in that outfit is generated.
Submitted outfit analysis. An image you send with the question "will this suit me" is transferred to Anthropic (USA) for clothing analysis. The image is not stored.
Verdict on a wardrobe item. The photo of an item you have added to your wardrobe is transferred to Anthropic (USA): the model answers whether the item suits your body type and how to wear it. Unlike a submitted outfit image, this photo is stored with us — you added it to your wardrobe yourself and can delete it at any time.
Category and colour suggestion. When you add an item to your wardrobe, its photo is transferred to Anthropic (USA) so that the model can suggest a category and a colour — you only confirm or correct them. This happens at the moment of adding, not on a separate request. If the model is unavailable or you have used up the daily limit, the item is added as before: you fill in the fields manually.
This consent is about transfers to the USA. The application and the database with files are hosted in Germany, and no consent is needed for that: Germany provides adequate protection of personal data (it is a party to Council of Europe Convention 108), so transfers there proceed in the ordinary course — to perform the contract with you, with no separate checkbox. Email delivery uses providers in the USA and the EU.
Put simply: the checkbox covers exactly what crosses the ocean.
Recipients and countries
| Recipient | Country | What is transferred | Why |
|---|---|---|---|
| Anthropic, PBC | USA | Selfie; outfit images submitted for analysis; photos of items from your wardrobe; textual portrait data | Colour type determination, outfit analysis, item verdict, category and colour suggestion when adding an item |
| FASHN AI | USA and South-East Asia | Figure photo, outfit image, wardrobe item photo | Try-on |
| Vercel Inc. | Germany (Frankfurt) | Technical request data | Running the application |
| Supabase | Germany (Frankfurt) | Database and files | Storage |
| Resend, Cloudflare | USA, EU | Email address and message text | Email delivery |
| Paddle (Merchant of Record) | EU and USA | Payment data | Accepting payment |
The list may change. When a recipient or a country is added, we will ask for consent again — a new edition of the document means a new consent, not a silent extension of the old one.
Duration and withdrawal
The consent is valid while your account exists, or until withdrawn.
You can withdraw it at any time in the app settings, with one button and no correspondence. The withdrawal is recorded in the database with a timestamp.
What happens immediately after withdrawal. Outfit try-on and colour type determination stop working — these functions are impossible without transferring data abroad, and we will not pretend they are available. Results you already have — your colour type, palette, saved try-ons — remain yours and can be deleted separately. The rest of the service remains usable.
What we do not do on withdrawal. We do not delete the account, do not take away the paid subscription period, and do not block access to anything that does not require the transfer.
What this consent does not cover
It does not give us the right to use your photographs to establish identity, to train models, for advertising, or to show them to other users. We do none of these things, and this consent does not permit them.
Country-specific provisions
Kazakhstan. Cross-border transfer is carried out with regard to the requirements of Law No. 94-V. The consent is separate and specific, as the law requires.
Countries differ in their level of protection, and the basis for transfer depends on it:
| Where | Level of protection | Basis for the transfer |
|---|---|---|
| Germany (Supabase, Vercel) | adequate — party to Convention 108 | Performance of the contract with you, Art. 7 of Law No. 94-V. A separate consent is not required |
| USA (Anthropic, FASHN, Cloudflare) | adequate protection not ensured | Your explicit consent, Art. 16(2) of Law No. 94-V — that is, this checkbox |
| EU and USA (Paddle, Resend) | mixed | Same scheme: the European part — under the contract, the American part — under the consent |
No notification of the authorised body (MCRIAP) is required for this transfer. The notification regime applies to state information systems and integrations with them; our case does not fall under it.
Russia. This section does not apply: the service does not operate in Russia, we have no Russian processing infrastructure, and no personal data is transferred from Russia. When the infrastructure appears, so will the section.
The checkbox text in the app
The wording a person sees at registration must match this document in meaning:
> I consent to the transfer of my photographs and data to processors outside > my country for colour type determination and outfit try-on. I understand > that these two functions will not work without it, and that the consent can > be withdrawn in the settings.