Privacy Policy - Body Measurement Solution

‍Last updated: 5 April 2022

With this Privacy Policy we inform you about how we process your personal data when you use our sizing and fitting solution and your rights in this respect.

This solution is operated by us (controller): presize GmbH, Kaufingerstraße 24, 80331 München (Germany), info@presize.ai. For further details please see our imprint.

1.       Purpose of the data processing

1.1       Accessing the solution

Each time you access our solution, for example under https://www.find-size.com or through a website of a vendor (hereinafter "Vendor") which gives access to our solution, your device transfers a couple of data points to us which we store in our logfiles. This data may include:

·      browser type and browser version

·      operating system used

·      internet service provider 

·      the IP address 

·      hostname of the accessing computer

·      time of the server inquiry

·      websites from which you reach our solution (so-called referrer)

·      websites accessed by the user's system via our solution

·      bytes transfered

·      access status

We process such data to provide you with the requested content in accordance with our contract with you (Art. 6 (1) lit. (b) GDPR). Thereafter, we store and process such data for a period of seven days (unless an unusual incident requires a longer storage period (e.g. after a hacker attack)) for security reasons as it is in our legitimate interests to identify potential attacks on our systems and optimize our systems (Art. 6 (1) lit. (f) GDPR). Thereafter, this data is anonymized as it is in our legitimate interests to anonymize the data to optimize our systems (Art. 6 (1) lit. (f) GDPR).

The collection of data is required for the provision of the solution and the storage of the data in logfiles is mandatory for the operation of the solution.If you do not provide this data, you will not be able to use our solution.

1.2       Using the solution

When you use our solution, you are asked to provide the following data points so we can recommend your ideal size based on predicted body measurements (including height, neck, shoulder width, chest, waist, upper hips and sleeve length):

·            your age

·            your sex

·            your height

·            your weight

·            your “fit” preferences (on a scale from tight to loose) as selected by you

·            your “body shape” (i.e. “H-Shape”,“O-Shape”) as selected by you

·            your belly and bottom proportions (on a scale from smaller to larger) as selected by you

·            a video of yourself

We collect and process this information as it is necessary to provide you with our solution in accordance with the contract with you (Art. 6(1) lit. (b) GDPR). We store the above data together with a generated “Size-ID”. We store your Size-ID in your local storage so that when you shop with any Vendor, our solution automatically applies its predictions of what size you should select using the measurements linked to your Size-ID.

Your data is deleted or anonymized 3 months (90 days) after you use the Size-ID the last time, unless you have voluntarily created an account with us.

If you create an account with us, we will additionally collect your email address and a password, and we will store the above data and your Size-ID together with your account details until you request a deletion by sending an email to dpo@presize.ai (see section 4 for further information on your rights).

Note that providing a video is optional. As soon as the video is uploaded, we obfuscate the video so that your face is blurred; we then extract certain obfuscated frames to provide the solution and delete the video footage.

When you make a purchase on a Vendor’s website, the Vendor may also send us:

·            the details of the product ordered (including the size you ordered)

·            any returns data (i.e. whether or not the item was returned and the reasons for return)

We link these details to a Size-ID and use the information to train our solutions, because it is in our legitimate interests to improve our solutions and provide users with more accurate future size recommendations (Art. 6 (1) lit. (f) GDPR). Once we delete the Size-ID (in accordance with the time periods set out above), all of the aforementioned data may be used by us to further train our solution or to run anonymized analyses.

1.3       Analytics

We process data when certain events on the Vendor's website (only where our solution is shown) and in our solution itself are triggered. For example, if you click a link or use a function, we store information about that link or that function, together with other information, like the size or the region you likely come from. This data does not allow us to re-identify you and does not allow us to link different visits with each other. The purpose of the data analysis is to pursue our legitimate interest of improving our solution by learning about how users use our solution (Art. 6 (1) lit. (f) GDPR). You may object to this analytics purposes by emailing dpo@presize.ai.

1.4       Cookies and local storage

We use a so-called functional cookie and a functional local storage for Size-ID. Both consist of information which are temporarily stored on your device. They are strictly necessary for the Presize solution to function.  

For example, if you have used our solution to calculate your body measurements, we store the Size-ID as described in section 1.2 above to help us re-identify you during your visit in order to show you size recommendations for other products.  

1.5       Other

We also process your personal data insofar as it is necessary for the fulfillment of a legal obligation to which our company is subject (e.g. accounting, commercial and tax law), court orders or other binding decisions of public authorities (Art. 6 (1) lit. (c) GDPR).

If necessary, we process your personal data to satisfy our legitimate interests (Art. 6 (1) lit. (f) GDPR), including the following: 

·      to complete a corporate transaction (e.g., corporate restructuring, sale or assignment of assets, merger), 

.       to protect, enforce and defend our rights, property and interests.

2.          Data transfers

We share personal information with third parties. 

2.1       Reporting obligations

In order to protect our rights or the rights of third parties, we disclose data to rights holders, consultants, courts and authorities in accordance with legal provisions.  

2.2       Vendors

We do not share your body measurements, any size recommendations, the Size-ID or even the video with any Vendor. Instead, the integration of our solution ensures that the size recommendations are shown only to you in your browser and you are free to choose another size.

2.3       Service providers (processors)

We work with service providers who assist us in providing our solution (e.g., hosting providers). These service providers process data solely on behalf of and under the control of us and only for the purposes described in this Privacy Policy.

2.4       With our affiliates or otherwise within our corporate group

We share your personal data globally, internally within our corporate group. These data transfers are necessary to provide you with our services and to globally operate (see section 2.6 for further information on international transfers).

2.5 Other scenarios

If the ownership or control of all or part of our solution or their assets changes, we may transfer your personal data to the new owner, as it is in our legitimate interests to fulfil such transaction and ensure the success of our business.

2.6       Transfer to recipients outside the EEA

We share personal data globally, both internally within our corporate group (see 2.4 above) and externally (see 2.2, 2.3 and 2.5 above). Personal data controlled by us will be transferred or transmitted to, or stored and processed in, the United States or other countries outside of where you live, for the purposes described in this Privacy Policy. These transfers are necessary to operate globally and to provide our solution to you. We utilise standard contractual clauses approved by the European Commission and rely on the European Commission’s adequacy decisions about certain countries, as applicable, for data transfers from the EEA to the United States and other countries.

3.          Retention of personal data

We will store your personal data as long as it is necessary for the respective purposes, which is usually to provide the services you have requested.  In some cases, we are obliged to store your data for longer in order to comply with statutory retention periods or any other legal obligations or to resolve disputes and enforce our policies.  

4.          Your rights

4.1       General rights

You can request information about your stored personal data. If you have provided personal data based on a contract, you have the right to receive this data in a commonly used and machine-readable format and request that we transfer it to a third party, in certain cases. 

In addition, you can also request the deletion, rectification or restriction of the processing of your data in certain cases. 

If your personal data are transferred to a country outside the EU that does not offer adequate protection, you can request a copy of the contract or other means that ensure adequate protection of personal data.  

You also have a general right to complain to us or a supervisory authority in particular in the member state of your residence, place of work or place of suspected infringement about our data processing. The supervisory authority responsible for Presize is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)  
Promenade 18  
91522 Ansbach

4.2       Right to object

To the extent we base the processing of your personal data on our legitimate interests (Art. 6 (1) lit. (f) GDPR), you may object to such processing at any time. In this case, we will not process such personal data any longer, unless our interests prevail.

4.3       Contacting us or our data protection officer

In order to exercise the aforementioned rights, please contact us directly in writing or via e-mail or contact our data protection officer under dpo@presize.ai.

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