Terms of Use | CLOWOO

Preamble

Purpose and scope

These Terms of Use (hereinafter "Terms") govern access to the CLOWOO mobile application, available on iOS (App Store) and Android (Google Play), published by CLEMS BROADCAST, a company based in Draveil 91210, France (hereinafter "the Company"), as well as all features of the Platform: account creation, content publication, browsing, social interactions, messaging, contests and Premium subscription.

Transactional operations (sales, purchases, service orders, exchanges, donations) are governed by the General Terms of Sale (GTS), a separate document available within the application. These Terms and the GTS together form the complete contract binding the Company to each User.

Strictly national transactionsTransactional interactions are strictly national: the Platform technically requires that the parties to a transaction reside in the same country. Prices are denominated and payments made in the legal currency of the User's country of residence. The applicable law for each transaction is that of the parties' country of residence.

By creating an account on the Platform or accessing it, the User acknowledges having read, understood and accepted these Terms without reservation.

These Terms comply with Regulation (EU) 2016/679 (GDPR), Directive 2000/31/EC (e-commerce), Regulation (EU) 2022/2065 (Digital Services Act, DSA) and French Law No. 2004-575 of 21 June 2004 (LCEN).

Article 1

Definitions

Term	Definition
Platform	The CLOWOO mobile application, available on iOS (App Store) and Android (Google Play). Transactional interactions are strictly national: the Platform requires that the parties to a transaction reside in the same country.
Company	CLEMS BROADCAST, publisher of the Platform, based in Draveil 91210, France.
User	Any adult natural person (18 years or older) who has created an account on the Platform.
Creator	A User whose creator account application has been approved by the Company after manual verification.
Content	Any item published by a User: photos, texts, article descriptions, messages, comments, contest entries.
Personal Data	Any information relating to an identified or identifiable natural person, within the meaning of Article 4.1 of the GDPR.
Account	The User's personal space on the Platform, identified by their email address and secured by a password.
Look Contest	A themed event organised by the Company inviting Users to submit outfit photos.
Premium	An optional paid subscription giving access to advanced Platform features.

Article 2

Platform Access and Account Creation

2.1 Access conditions

Access to the Platform is reserved for adult natural persons (18 years or older). Registration by a minor is strictly prohibited. The Company reserves the right to request proof of age at any time and to delete any account where the User's minority is established.

Registration is free. It requires creating a personal account with a valid email address and a secure password.

2.2 Registration obligations

When creating their account, the User agrees to:

Provide accurate, complete and up-to-date information (first name, last name, username, date of birth, email address);
Not impersonate any other natural or legal person;
Not create multiple accounts for the same individual;
Maintain the confidentiality of their login credentials;
Immediately notify the Company of any unauthorised access to their account at users_support@clowoo.com.

The User is solely responsible for all activity carried out from their account.

2.3 Creator Account

Creator status is subject to a manual verification process described in Article 2.2 of the GTS. Approval grants the User the ability to offer Services on the Platform and access to a dedicated dashboard.

2.4 Verification and security

The Company reserves the right to request identity verification from any User, particularly in cases of suspected fraud or before any first payment to a Creator. In the event of refusal to verify, the Company may suspend the account concerned.

Article 3

Use of the Platform

3.1 Available features

Navigation and discovery: exploration of a personalised home feed, a discover page, User and Creator profiles;
Social interactions: following other Users, likes, comments, content sharing;
Content publishing: uploading outfit and fashion article photos with descriptions and hashtags;
C2C Marketplace: sale, exchange and donation of fashion items between individuals residing in the same country, in the applicable national currency (governed by the GTS);
Creator Services: ordering creative services from qualified Creators residing in the same country as the Client, in national currency (governed by the GTS);
Look Contests: participation in themed style contests organised by the Company;
Messaging: encrypted communication between Users in the context of transactions or social interactions;
Premium subscription: access to advanced features via an optional paid subscription.

3.2 Licence of use

The Company grants the User a personal, non-exclusive, non-transferable, revocable and limited licence to access and use the Platform for their personal needs, in compliance with these Terms. This licence excludes any reproduction, modification, decompilation, reverse engineering or commercial exploitation of the Platform.

3.3 General obligations of use

The following are notably prohibited:

Publishing unlawful, hateful, defamatory, obscene, pornographic, violent or discriminatory content;
Publishing content infringing the intellectual property rights of third parties;
Publishing content containing third-party personal data without their explicit consent;
Harassing, threatening or intimidating other Users;
Impersonating another person or posing as a representative of the Company;
Using bots, scripts or any automated means to access the Platform or extract data;
Attempting to circumvent the Platform's security measures;
Publishing spam, links to malicious websites or any unsolicited content;
Using the Platform for commercial purposes not authorised by the Company.

Article 4

User-Generated Content

4.1 Ownership of content

The User retains full intellectual property rights over the content they publish on the Platform. Publishing content does not transfer any ownership rights to the Company.

4.2 Licence granted to the Company

By publishing content on the Platform, the User grants the Company a non-exclusive, worldwide, royalty-free and sub-licensable licence, for the duration of publication of the content plus 30 days, for the following purposes:

Displaying, distributing and featuring the content on the Platform;
Indexing the content by search engines;
Promoting the Platform on third-party social networks (with mention of the User's username);
Technical reproduction necessary for the operation and backup of the Platform.

This licence ends automatically when the content is deleted by the User or their account is closed.

4.3 User warranties

By publishing content, the User declares and warrants:

Being the author of the content or holding all rights necessary to publish it;
That the content does not infringe any third-party rights (copyright, neighbouring rights, image rights, trademarks, patents);
Having obtained the express consent of any identifiable person appearing in published photos;
That the content complies with applicable French and European legislation.

Any third-party claim based on content published by the User is the User's sole responsibility.

4.4 Look Contest content

By entering a Look Contest, the User grants the Company a non-exclusive, worldwide and royalty-free licence, for the legal term of copyright protection, to reproduce, distribute, adapt and exploit the photos for communication and promotion of the Platform, with mention of the User's username.

The User certifies having obtained the free, informed and express consent of each identifiable person appearing in submitted photos. Any person concerned may request removal of their image by contacting users_support@clowoo.com.

Article 5

Content Moderation

5.1 Moderation policy

The Company implements a content moderation policy combining automated tools and human moderation, in compliance with Regulation (EU) 2022/2065 (DSA) and French Law No. 2004-575 of 21 June 2004 (LCEN).

5.2 Reporting system

Any User may report unlawful content from each post, profile or message via the built-in reporting mechanism. In accordance with Article 16 of the DSA, the Company processes each report within a reasonable timeframe and notifies the relevant parties of the decision taken.

5.3 Moderation decisions and appeals

If content violates these Terms or the law, the Company may: remove or restrict the content, warn the User, temporarily suspend or permanently delete the account.

In accordance with Article 20 of the DSA, any User may contest a moderation decision within 6 months by sending an email to users_support@clowoo.com (subject: Appeal against moderation decision). The Company processes the appeal within 15 working days.

5.4 Warning system

Level	Designation	Consequences
Level 1	Simple warning	In-app notification. No account restriction.
Level 2	Serious warning	In-app and email notification. Temporary restriction of certain features.
Level 3	Severe warning	Email and notification. Temporary account suspension. DSA information.
Level 4	Ban	Permanent account deletion. Email and notification. DSA information. Possible referral to competent authorities.

Any warning may be contested in accordance with the procedure described in Article 5.3.

Article 6

Personal Data Protection

6.1 Data controller

CLEMS BROADCAST, based in Draveil 91210, France, is the data controller within the meaning of Article 4.7 of Regulation (EU) 2016/679 (GDPR). Contact: users_support@clowoo.com.

6.2 Data collected and purposes

Data category	Purpose	Legal basis	Retention period
Identification data (name, email, username, date of birth)	Account management, identification	Performance of contract (Art. 6.1.b)	Account duration + 3 years
Password (hashed)	Account security	Performance of contract	Account duration
Profile photo (optional)	Profile personalisation	Consent (Art. 6.1.a)	Until withdrawn
Transaction data (address, history)	Transaction processing, accounting	Performance of contract + legal obligation	5 years (accounting obligations)
Published article photos	Displaying listings	Performance of contract	Duration of listing + 30 days
Measurements (if shared)	Fulfilling creator service	Consent	Order duration + 1 year
Contest photos	Contest organisation, promotion	Consent	Contest duration + defined promotional period
Messages between members	Facilitating exchanges, disputes	Performance of contract	1 year after end of transaction
IP address, connection logs	Security, anti-fraud	Legitimate interest (Art. 6.1.f)	12 months

EXIF note: photos uploaded to the Platform may contain geolocation data. The Company systematically removes this metadata upon upload.

6.3 Rights of data subjects

In accordance with the GDPR, the User has the following rights, exercisable at users_support@clowoo.com:

Right of access (Art. 15): obtain confirmation of data processing and receive a copy;
Right to rectification (Art. 16): correct inaccurate or incomplete data;
Right to erasure (Art. 17): obtain deletion of data, subject to legal retention obligations;
Right to restriction (Art. 18): suspend data processing in certain cases;
Right to data portability (Art. 20): receive data in a structured, machine-readable format;
Right to object (Art. 21): object to processing based on legitimate interest;
Rights regarding automated decisions (Art. 22): request human intervention;
Right to withdraw consent at any time, without retroactive effect.

The Company responds within one month. The User may lodge a complaint with the relevant data protection authority.

6.4 Sharing data with third parties

The Company does not sell Users' personal data. It shares data only in the following cases:

Technical service providers (GDPR sub-processors) bound by contracts compliant with Article 28 of the GDPR;
Other Users: username, listings, reviews and profile photo are publicly visible. The full postal address is only shared with the co-contractor for shipping purposes;
Legal authorities: in response to a valid judicial or administrative requisition;
DAC7 obligations: automatic reporting to tax authorities for Users exceeding legal thresholds.

6.5 Transfers outside the European Union

If the Company's sub-processors process data outside the EU, the Company ensures appropriate safeguards are in place (European Commission standard contractual clauses or adequacy decision). The list of transfers is available on request.

6.6 Data security

The Company implements appropriate technical and organisational measures to protect personal data: encrypted communications (HTTPS/TLS), encrypted messaging (AES-256-GCM), password hashing, internal access controls, regular security audits, protection against bots and intrusion attempts.

In the event of a personal data breach, the Company notifies the relevant supervisory authority within 72 hours and directly informs affected Users if the risk is high, in accordance with Article 34 of the GDPR.

Article 7

Messaging and User Communications

The Platform provides an encrypted messaging system (AES-256-GCM) between Users, activated in the context of authorised transactions and social interactions. Messages exchanged are:

End-to-end encrypted and not read by the Company under normal conditions;
Accessible to the Company only in the context of legal proceedings, a valid administrative requisition, or a dispute intervention expressly requested;
Retained for 1 year after the end of the relevant transaction.

It is prohibited to use the messaging system to bypass payment systems, harass other Users, send spam or share third-party personal data without their consent.

Article 8

Look Contest

8.1 Organisation

The Company organises periodic Look Contests inviting Users to submit photos of their outfits based on a defined theme published in a specific set of rules for each edition. Contests are organised without any obligation to purchase.

8.2 Participation

By submitting a contest photo, the User:

Declares being the author or rights holder of the submitted photograph;
Certifies having obtained the express consent of any identifiable person appearing in the photo, including for its use for promotional purposes;
Warrants that the photo does not infringe third-party rights and does not contain unlawful content;
Grants the Company the licence described in Article 4.4.

8.3 Selection and rewards

Winners are selected according to the terms specified in each edition's rules. Rewards (gift vouchers, credits, items, features) are described in each edition's rules. No compensation is owed to unselected participants.

Article 9

Intellectual Property

9.1 Company rights

All elements of the Platform (logo, graphical interface, source code, algorithms, database, editorial content) are the exclusive property of CLEMS BROADCAST and are protected by French and international intellectual property laws, including the French Intellectual Property Code and Directive 2001/29/EC.

It is prohibited to reproduce, copy, sell, rent, sub-license, modify, decompile or attempt to extract the source code of all or part of the Platform without prior written authorisation from the Company.

9.2 Users' rights over their content

Users retain full ownership of their content published on the Platform. The licence granted to the Company (Article 4.2) is limited to the described purposes and ends under the conditions defined. The Company may not exploit Users' content for purposes other than those provided in these Terms without their consent.

Article 10

Service Availability

The Company uses all reasonable means to ensure Platform availability 7 days a week, 24 hours a day. However, access may be interrupted for:

Scheduled maintenance operations, announced with 24 hours' notice except in emergencies;
Technical failures beyond the Company's control (hosting outages, cyberattacks, force majeure);
Security updates or urgent fixes requiring immediate interruption.

The Company does not guarantee a contractual availability rate and cannot be held liable for damages resulting from a service interruption, except in cases of gross negligence or wilful misconduct by the Company.

Article 11

Account Suspension and Closure

11.1 Closure at the User's initiative

The User may request deletion of their account from the application settings. Deletion is irreversible and results in:

Cascading erasure of all personal data, subject to legal retention obligations;
Loss of access to all Platform features;
Cancellation of current Premium subscriptions;
Closure of all current orders in accordance with the procedures defined in the GTS.

11.2 Suspension or deletion at the Company's initiative

The Company may suspend or delete an account in the event of a breach of these Terms (see Article 5.4) or the GTS. In the event of suspension for proven fraud, the Company may block pending funds during the investigation period.

Article 12

Hyperlinks and Third-Party Applications

The Platform may contain links to third-party websites or applications. These links are provided for information purposes only. The Company exercises no control over these third-party sites and accepts no responsibility for their content, privacy practices or availability.

Use of the login feature via third-party social networks is subject to the terms and conditions and privacy policies of those networks. The Company is not responsible for data collected directly by those third parties.

Article 13

Company Liability

The Company acts as a content host within the meaning of the LCEN and the DSA. It cannot be held liable for content published by Users, subject to its obligations to promptly remove manifestly unlawful content upon notification.

The Company's liability towards a User is limited, in any event, to the amount actually paid by that User to the Company in the 12 months preceding the event giving rise to the damage, to the exclusion of any indirect, consequential, immaterial damages or loss of opportunity.

This limitation of liability does not apply in cases of personal injury, gross negligence or wilful misconduct attributable to the Company, nor in cases where applicable law prohibits any limitation of liability.

Article 14

Company DSA Obligations

In accordance with Regulation (EU) 2022/2065 (Digital Services Act), the Company undertakes to:

Publish an annual transparency report on its moderation activities;
Maintain an accessible and easy-to-use illegal content reporting mechanism;
Process reports relating to content threatening life, human dignity or physical integrity as a priority;
Not target advertising communications based on profiling using sensitive data within the meaning of Article 9 of the GDPR;
Cooperate with Digital Services Coordinators and competent authorities of Member States.

If the Platform reaches the monthly active user thresholds defined by the DSA (Very Large Online Platform), the enhanced obligations provided by the DSA will be fully applicable.

Article 15

Amendment of Terms

The Company reserves the right to modify these Terms at any time. Any substantial modification affecting Users' rights will be notified by email and/or in-app notification with a minimum notice of 15 calendar days before it takes effect.

Continued use of the Platform after the new Terms take effect constitutes acceptance. In case of disagreement, the User may close their account free of charge before the effective date.

The current version of the Terms is always accessible in the application and on the Company's website. A version history is maintained and available on request.

Article 16

Applicable Law and Jurisdiction

These Terms are governed by French law. In the event of a dispute, and in the absence of an amicable resolution, the competent courts are:

For professional Users: courts in the jurisdiction of CLEMS BROADCAST's registered office, located in Draveil, Essonne (91210);
For Consumer Users: courts of the Consumer's place of domicile, in accordance with applicable consumer law.

In accordance with applicable consumer law, the Consumer may have free recourse to consumer mediation.

As transactions are strictly national, disputes between Users are governed by the law of the country where the transaction was concluded. For disputes involving the Company, Users residing in the EU may use the European Online Dispute Resolution platform: https://ec.europa.eu/consumers/odr

Article 17

Contact and Data Protection Officer

Channel	Contact details
User support (general)	users_support@clowoo.com (response time: 48 to 72 business hours)
Data protection (GDPR)	privacy@clowoo.com
Moderation / Appeal	users_support@clowoo.com (subject: Moderation appeal)
Administrative / Legal	privacy@clowoo.com
Postal address	CLEMS BROADCAST, Draveil 91210, France
Data protection authority	Contact your national supervisory authority

The Company is examining the need to appoint a Data Protection Officer (DPO) in accordance with Article 37 of the GDPR. If the appointment of a DPO is required, their contact details will be published in this section.

Document established on 10 June 2026, Version 1.1. CLEMS BROADCAST, Draveil 91210, France.