ITFITS APPLICATION
PRIVACY POLICY
Effective as of September 27, 2024
This Privacy Policy ("Privacy Policy") explains how itFits 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
application (the "Application") 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, 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 itFits 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 Application, 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);
· Location information (country/region);
·
Information about your device (description
of a device that is used to access the Application, for example, device ID,
type of OS, its version and language);
· Photos of your foots (for building a 3D models and measuring);
·
Sessions (completed Sessions across OS);
·
Information that is gathered about your
use of the Application (frequency of use, experienced problems, etc.) via
cookies or similar technologies (for instance, through third party services
like MyTarget). We need such information in order to
improve Application'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 Application, 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 Application and
deliver a better experience. Among others, we may use your Personal data and
information to:
1. analyze, operate, maintain and improve the Application, to add new features and
services to the Application;
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 Application.
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 share some of your Personal Data to MyTarget. We use MyTarget tools
to track installs of our App and receive general statistics about the use of
the App.
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 Application,
in order to protect the security of the Application, 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.
7. DATA RETENTION AND SECURITY
If you choose to not use the Application 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 Application, 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 Application
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 Application. 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
Application 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 Application.
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:
Email: info@itfits.fit