Privacy Notice

Revised 5 October 2026

This Privacy Notice for Driveclick Group Ltd ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://averley.app, or any website of ours that links to this Privacy Notice
• Use our mobile application (Averley), when it launches, or any other application of ours that links to this Privacy Notice
• Engage with us in other related ways, including any marketing or events

Averley is not available yet. This site is a waitlist. Nothing is charged today. Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services.

Summary of key points

This summary provides key points from our Privacy Notice. You can find more detail in the sections linked below.

What personal information do we process? On this site we process the email you submit, optional answers about what you would want first and what is hardest for you, the page language, and which button opened the form. When the app launches, garment photos are stored so outfits can be built, and a colour-analysis selfie is handled only as described in section 1. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We use your email to write when Averley is ready, your optional answers to decide what the app leads with, and — only if you accept — the Meta Pixel to measure advertising. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We share waitlist submissions with Formspark, and Pixel events with Meta only after you accept. Learn more about when and with whom we share your personal information.

What are your rights? Depending on where you are located, you may have rights to access, correct, or delete your personal information. Learn more about your privacy rights.

How do you exercise your rights? Email hello@averley.app. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

Table of contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process your personal information?
4. When and with whom do we share your personal information?
5. Do we use cookies and other tracking technologies?
6. Is your information transferred internationally?
7. How long do we keep your information?
8. What are your privacy rights?
9. Controls for do-not-track features
10. Do we make updates to this notice?
11. How can you contact us about this notice?
12. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In short: we collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you join the waitlist, ask for information about Averley, or otherwise contact us.

On the waitlist form that is:

• your email address
• optional answers: what you would want first (want_first) and what is hardest for you (hardest). Both questions can be skipped
• the page language (locale) and which button opened the form (source)

We do not charge you on this site. We do not sell clothes, and we do not earn commission from shops. You do not have to buy anything Averley suggests.

Sensitive information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Colour-analysis selfie

When the app offers colour analysis, the selfie is cropped on your device at the collarbone. Six colour values are extracted from that crop, and the image is deleted. The photo is not kept.

Garment photos

Once the app stores a wardrobe, garment photos are kept so Averley can build outfits from them. A full wardrobe is photographed about eight items at a time. That is not how the colour selfie works.

Information collected only after you accept

In short: the Meta Pixel does not load until you choose Accept.

If you choose Accept on the cookie banner, we load Meta’s Pixel to measure advertising. Until you accept, that script does not load. Reject leaves it off. Your choice is stored in this browser. You can change it with Cookie settings in the footer. A switch to Reject applies on the next page load.

After Accept, the Pixel can send:

• PageView, when a page loads
• ViewContent, when the price section is on screen
• Lead, after a successful email signup

2. How do we process your information?

In short: we use it to run the waitlist, decide what to build first, and — only with consent — measure ads.

We process your personal information for these reasons:

• To write to you when Averley is ready, using the email you submitted
• To use optional quiz answers to decide what the app leads with
• To measure advertising with the Meta Pixel, only after you accept
• To comply with law, where we are required to

We do not use your information to sell clothes or to take a commission from a shop.

3. What legal bases do we rely on to process your personal information?

In short: we process personal information when we have your consent, or when the law requires it.

The General Data Protection Regulation (GDPR) requires us to explain the valid legal bases we rely on. We rely on the following:

• Consent. We process your waitlist email, optional answers, and Meta Pixel events if you have given permission. You can withdraw consent at any time. Learn more about withdrawing your consent.
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

4. When and with whom do we share your personal information?

In short: we share waitlist data with Formspark, and Pixel events with Meta only after you accept.

• Formspark. Waitlist submissions are sent to Formspark (submit-form.com), which stores them and emails a copy to hello@averley.app. Formspark processes that form for us.
• Meta. If you accept, Meta Platforms Ireland Ltd receives the Pixel events described above, under its own terms.
• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Do we use cookies and other tracking technologies?

In short: advertising measurement runs only after you accept on our banner.

We use a first-party cookie banner on this site. It asks you to accept or reject the Meta Pixel before that script loads. The choice is saved in local storage in your browser under the name averley-consent. We do not publish a separate cookie notice. This section, and the banner, are the description of that technology.

If you accept, Meta may use cookies and similar technologies to receive PageView, ViewContent, and Lead. You can refuse by choosing Reject, or change a previous choice with Cookie settings. Reject means the Pixel script is not loaded on later visits.

6. Is your information transferred internationally?

In short: Formspark and Meta may process information outside Cyprus.

We do not run the waitlist form or the Pixel on our own servers. Formspark stores submissions and can email them to us. If you accept, Meta receives Pixel events. Those providers may store and process information in countries other than Cyprus.

If you are in the European Economic Area (EEA) or Switzerland, those countries may not have data protection laws as comprehensive as those in your country. We share data with these providers only as described in this notice: Formspark for the waitlist, and Meta only after you accept.

7. How long do we keep your information?

In short: we keep waitlist data until we have written to you at launch, or until you ask us to delete it.

We keep your email and optional answers until Averley launches and we have written to you, or until you ask us to delete them, whichever comes first, unless a longer period is required by law (such as tax, accounting, or other legal requirements).

The colour-analysis selfie is not retained. Six colour values are extracted on your device and the image is deleted.

When we have no ongoing need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store it and isolate it from any further processing until deletion is possible.

8. What are your privacy rights?

In short: if you are in the EEA or Switzerland, you can ask to access, correct, or delete your personal information.

In some regions (like the EEA and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us as described in How can you contact us about this notice?

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA and you believe we are unlawfully processing your personal information, you have the right to complain to a supervisory authority. In Cyprus that is the Commissioner for Personal Data Protection. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent. Where we rely on consent, you can withdraw it at any time. Email hello@averley.app, or use Cookie settings to reject the Meta Pixel. Withdrawal does not affect the lawfulness of processing before withdrawal, and it does not affect processing that relies on a legal basis other than consent. A Pixel rejection applies on the next page load.

9. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice. You can still reject the Meta Pixel with the banner on this site.

10. Do we make updates to this notice?

In short: yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

11. How can you contact us about this notice?

If you have questions or comments about this notice, you may email hello@averley.app or write to:

Driveclick Group Ltd
HE470062
Limassol, Cyprus

12. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, email hello@averley.app.