ITFITS.FIT WEB
SITE PRIVACY POLICY
Effective as of January 15, 2024
This Privacy Policy ("Privacy Policy") explains how CashFlow LLC and its affiliates ("Company" or "we"
or "us") collects, stores, uses, and discloses information from our
users ("you") in connection with your use of the ITFITS.FIT website
(the "Website") and any related content, features, materials,
applications, and/or services.
1. Acceptance of privacy policy. Changes to
privacy policy
This Privacy policy is an integral part of the Terms of Use. By
accepting the Terms of Use, you also accept this Privacy Policy. In
some cases, we may ask you to explicitly accept this Privacy Policy.
We reserve the right to and may periodically change, amend, or update this
Privacy Policy. We will notify you by email, through the Website, or by
presenting you with a new version of Privacy Policy for you to accept if we
make modifications that materially change your rights. Your continued use of
the Website after the effective date of an updated version of this Privacy
Policy will indicate your acceptance of the Privacy Policy as modified. In some
cases, we may ask you to explicitly accept the updated Privacy Policy.
Defined terms used in this Privacy Policy have the same meaning attributed to
them in the Terms of Use.
2. PERSONAL DATA AND INFORMATION WE COLLECT
When you open and use the Website, we may collect the following technical or
(and) personal data ("Data"):
·
Your name (if you voluntarily enter it in order to contact
us);
·
Your e-mail address (if you voluntarily enter it in order
to contact us);
·
Your phone (if you voluntarily enter it in order to
contact us);
·
Your company name (if you voluntarily enter it in order to
contact us);
·
Your job title (if you voluntarily enter it in order to
contact us);
· Location information (country/region);
· Photos of your foots (for building a 3D models and
measuring);
·
Interests/affinities within the Website;
·
Information about your device (description
of a device that is used to access the Website, for example, device ID, type of
OS, its version and language);
·
Sessions (completed Sessions across OS);
·
Information that is gathered about your use
of the Website (frequency of use, experienced problems, etc.) via cookies or
similar technologies (for instance, through third party services like Amplitude).
We need such information in order to improve Website's functionality and
technical stability. This section may include information
about your interaction with Third-Party Services).
We do not collect other personal information which was
not mentioned above if not voluntarily and expressly shared by you, however,
reserve our right to do so in the future granted we amend this Privacy Policy
as stipulated by Section 1. We never collect any sensitive personal data about
you. "Personal Data" is referred to herein as information that
relates to an identified or identifiable individual.
3. YOUR CONSENT
By using the Website, you explicitly consent that:
1. WE MAY STORE AND PROCESS YOUR PERSONAL DATA AND INFORMATION
FOR THE PURPOSE OF PROVIDING SERVICES TO YOU, TO IMPROVE OUR SERVICE FEATURES
AND OTHER PURPOSES INDICATED IN SECTION 4 OF THIS PRIVACY POLICY. SUCH SERVICES
MAY INCLUDE SENDING YOU INFORMATION AND REMINDERS THROUGH THE APP.
2. WE WILL NOT TRANSMIT ANY OF YOUR INFORMATION TO THIRD PARTIES, EXCEPT IF
IT IS REQUIRED TO PROVIDE THE SERVICE TO YOU (E.G. TECHNICAL SERVICE OR ANALYTICS
PROVIDERS), UNLESS WE HAVE ASKED FOR YOUR EXPLICIT CONSENT.
4. HOW WE USE YOUR PERSONAL DATA
We use all collected Data to improve the Website and
deliver a better experience. Among others, we may use your Personal data and
information to:
1. analyze, operate, maintain and improve the Website, to add new features and
services to the Website;
2. provide and received from you commercial information;
3. send you
technical notices, updates, security alerts and support and administrative
messages;
4. monitor and analyze trends, usage and activities in connection with our Website.
5. HOW WE PROCESS YOUR PERSONAL DATA
· Lawfully, fairly and transparently;
·
Only for the purpose stated at the time of collection;
·
Only such Personal Data that is adequate, relevant
and limited to what is necessary for the stated purpose will be collected;
·
It is your responsibility to ensure that any
Personal Data you provide is accurate at the time of collection and if ensure
timely changes to the Personal Data, and we will take every reasonable action
to ensure the data remains accurate;
·
Your Personal Data will not be kept longer
than necessary for the stated purpose except for statistical reasons in which case
appropriate technical and organizational measures will be implemented to safeguard
your data;
·
We will process your data in a manner that ensures
security using appropriate technical or organizational measures;
· We do not sell, lease, rent or otherwise disclose your Personal Data to
third parties, except our group companies or authorized third parties who
process Personal Data for the Company for the purposes described in this
Policy. These authorized third parties are not permitted to use your Personal
Data for any other purposes. We require them to act consistently with this
Privacy Policy and to use appropriate security measures to protect your Personal
Data.
We may preserve and share your Personal Data in response
to a legal request from a competent authority (search warrant, subpoena, court
order). We may also preserve and share your Personal Data when we have a good
belief that that is necessary for a legitimate purpose, e.g., detecting
fraudulent behavior, to protect security, and in other cases.
6. HOW WE STORE AND SHARE YOUR PERSONAL DATA
All your Personal Data is stored and processed only by us.
We do not share your Information with any third parties except as specified by
this Privacy Policy.
We may preserve and share your Personal Data in response to a legal request
from a competent authority (search warrant, subpoena, court order). We may also
preserve and share your Personal Data when we have a good belief that that is
necessary for a legitimate purpose: like detecting fraudulent behavior at the
Website, in order to protect the security of the Website, and in other cases.
You may choose to share your content (for example your photos with applied
footwear masks) using our proprietary or Third-Party Services. Please note that
any such Third-Party Services are not governed by this Privacy Policy. For
instance, if you choose to send an email to share your photo using your Google
account, then all applicable Google privacy policies will apply. When you
access and use Third-Party Services via the Website, we are not responsible for
these Third-Party Services and we do not endorse or make any warranties and
representations about such Third-Party Services.
7. DATA RETENTION AND SECURITY
If you choose to not use the Website again, we may retain your Information for
as long as you are active and within a reasonable period, but normally no
longer than 2 years.
We take all reasonable and appropriate measures to protect all collected
Personal Data and information from loss, theft, misuse and unauthorized access,
disclosure, alteration and destruction. Among others, we utilize the following
information security measures to protect your Personal Data:
1. Pseudominization and tokenization of certain categories of your Personal Data;
2. Encryption of your Information in transit and in rest;
3. Systematic vulnerability scanning and penetration testing;
4. Protection of data integrity.
Please keep in mind that no security system is perfect
and, as such, we cannot guarantee the absolute security of the Website, or that
your Personal Data won't be intercepted while being
transmitted to us. If we learn of a security systems breach, we may post a
notice, and will take reasonable steps to remedy the breach.
8. YOUR RIGHTS
Modification, correction and erasure. You have a right to modify, correct,
erase, and update your Personal Data by contacting us at support@itfits.fit.
Access. You have a right to access your Personal Data you submit to the Website
and ask us about what kind of Personal Data we have about you. You can do this
by contacting us at support@itfits.fit.
EEA residents. Individuals residing in the countries of the European Economic
Area have certain statutory rights in relation to their personal data
introduced by the General Data Protection Regulation (the "GDPR").
Subject to any exemptions provided by law, you have the following rights:
1. Rectification of Personal Data and Restriction of Processing.
You are responsible for ensuring the accuracy of your Personal Data that you
submit to the Website. If you believe that your Personal Data is inaccurate,
you have the right to ask us to correct such Personal Data by contacting us at support@itfits.fit. You shall also have the right to
request restriction of processing of your Personal Data, if you contest the
accuracy of the Personal Data and we need some time to verify its accuracy.
2. Access to your Personal Data and Data Portability. You
have the right to request information about whether we have any Personal Data about
you, to access your Personal Data (including in a structured and portable form)
by contacting us at support@itfits.fit.
3. Erasure of your Personal Data. If you believe that your
Personal Data is no longer necessary in relation to the purposes for which it
was collected or otherwise processed, or in cases where you have withdrawn your
consent or object to the processing of your Personal Data, or in cases where
the processing of your Personal Data does not otherwise comply with the GDPR,
you have right to contact us at support@itfits.fit
and ask us to erase such Personal Data. Please be aware that erasing some
Personal Data submitted by you may affect your possibility to utilize the
Website and its features. Erasure of some Personal Data may also take some time
due to technical reasons.
4. Notification requirements. We commit to notify you within
a reasonable period of time and your data protection authority within the
timeframe specified in applicable law and, where feasible, not later than 72 hours
after having become aware of it, about any personal data breaches in the
Website.
5. Data Protection Authorities. Subject to GDPR, you also
have the right to (i) restrict our use of Personal
Data and (ii) lodge a complaint with your local data protection authority about
any of our activities that you deem are not compliant with GDPR.
Please keep in mind that in case of a vague
access, erasure, objection request or any other request in exercise of the
mentioned rights we may engage you in a dialogue so as to better understand the
motivation for the request and to locate respective information. In case this
is impossible, we reserve the right to refuse granting your request.
Please note that we will grant your request within 30 days after receiving it,
but it may take us up to 90 days in some cases, for example, for full erasure
of your Personal Data stored in our backup systems - this is due to the size
and complexity of the systems we use to store data.
9. CHILDREN'S PRIVACY
We are committed to protecting the privacy of children
under COPPA, GDPR or any other applicable law.
10. DATA PROTECTION OFFICER
To communicate with our Data Protection Officer on any
privacy matters, please email at support@itfits.fit.
11. CONTACT US
If you have any questions or concerns about your privacy, any provisions of
this Privacy Policy or any of your rights, you may contact us at:
CashFlow LLC
Email: support@itfits.fit