PRIVACY POLICY

1 April 2021

Who is efitter?

EFITTER LTD is a registered company in England and Wales.

Company number: 12013895

Registered address: 85 Great Portland Street, First Floor, Great Portland Street, London, England, W1W 7LT

efitter is dedicated to ensuring our customer's privacy. Your information will not be sold, distributed, or used for any other purpose than the use of our application. efitter only uses your email address to communicate directly with you the user.

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact Elizabeth Blege at hello@efitter.com.

What does efitter do?

efitter is a Google Chrome plugin that predicts a user’s size when shopping online based on their previous purchases. efitter will request your email address to ensure that you can use and access our Chrome extension for your Google account. Your email address is required to parse your past order receipts and collect your sizing data. efitter also requests your email address to communicate with you, the user, directly. Your email address and any other profile data you submitted via efitter is kept private and confidential and are only used for the use of our application.

Changes to the privacy policy

• We keep our privacy policy under regular review.
• This version was last updated on 1 April 2021. You should regularly check our privacy policy for any changes. Changes will be posted on this page and, where appropriate, notified to you when you next start efitter. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of efitter or the Service.
• It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

What data do you hold about me?

We may hold the following personal data about you:​

• Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
• Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
• Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
• Transactional Data: This is the information of details and records of all payments you have made for our services or products.
• Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
• Customer Support Data: This includes feedback and survey responses.
• Usage Data: information about how you use our website, products and services.

As is true of most websites, we also automatically gather information about your computer such as your IP address, browser type, referring/exit pages and operating system. For more information on the cookies we use, why we use them and more information about cookies generally, please see our Cookie Policy under “Manage Cookie Policies”.

Aggregated Data

We also collect, use and share Aggregated Data such as how often you return items when shopping using our browser extension. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also use aggregated data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Why are you requesting Google user data?

You can log in/sign up to our site using single sign-on (SSO) services such as Google. This service will allow the third party to authenticate your identity and provide you with the option to share certain personal information with us such as your name, email address, and scan your emails for your shopping receipts to personalise your shopping experience. You must volunteer this information. We will not extract it from you without your consent.

What do you do with my data?

• We use your location to determine whether you are eligible to use our product based on your location.
• We use the information on your operating system/browser to improve the effectiveness of the efitter Chrome extension and resolve technical issues.
• We use your personal data to create a profile that is linked to your account. We need this information for the extension to be effective in providing personalised recommendations. This is necessary for our legitimate interests (to provide personalised size recommendations).
• We use your email address to facilitate communications between us for operational purposes. You can opt-out of receiving these emails by clicking on the unsubscribe link at the footer of any email you receive from us or emailing hello@efitter.com.

• You will receive marketing and new content communications from us if you have created an account and chosen to opt in to receiving those communications. From time to time, we may make suggestions and recommendations to you about goods or services that may be of interest to you.
• We use analytics data to ensure that our marketing and website content is relevant to our audience.
• We will retain any records of your previous shopping receipts to inform you of your sizing information for your future purchases. We will also retain records of where you have shopped whilst using our browser extension to inform your future sizing recommendations.
• We retain data from our live chat support (including when an email address is voluntarily shared) for diagnostic purposes to ensure that any issues raised are resolved.

Limited Use Disclosure

efitter's use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

How long do you hold my data?

efitter will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

efitter will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

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When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Who do you share my data with?

In the ordinary course, we will only ever share your data with our own carefully selected sub-processors who are directly involved in delivering our product and services. Our sub-processors are primarily used for the purposes of hosting our platform and assisting with sending service emails to our users. We only allow our sub-processors to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on sub-processors relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, accreditation and the audit of our accounts.

We do not sell or give your personal information to third parties to use for their own purposes.

In exceptional circumstances, we may disclose or transfer your personal information:

• as required by law.
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the rights and safety of other third parties (including other efitter users), investigate fraud, or respond to a government request.
• to a third-party buyer or seller in the event that efitter is involved in a merger, acquisition, or sale of all or a portion of its assets.
• to interested parties in connection with the licensing of our technology.
• to any other third party with your prior consent to do so.

Use of third-party tools

• We allow certain third parties to use cookies or similar technologies on this Website. These third parties include analytics, advertising networks and other service providers that assist us in providing, evaluating, and improving this Website and our services and to provide targeted advertising based on your browsing activities and interests.
• These third parties may use cookies or similar technologies and collect data about your use of this Website and your interaction with its content and functions, including the total number of visitors to this Website, the websites our visitors have come from, the pages you visit, date, time and duration of your visit, frequency, clicked banners/links as well as information about the type of device, browser version, language settings and geographic location (including country, city, region). They may also collect online-identifiers (e.g. User-ID) and/or IP-addresses.
• Some of the service providers are based in a country outside the EU/EEA. However, we exclusively work with companies that offer an appropriate data protection level in line with the stipulations of the GDPR.

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

Where is my data stored?

Information we hold about you is stored and hosted in a secure data centre within the European Economic Area (EEA). Your information may be shared with our carefully selected sub-processors who are directly involved with the delivery of our services but such sub-processors shall only process personal information in the EEA and otherwise in countries that have an adequate level of protection from a data protection perspective.

In the event that the processing of your personal information at any time requires it to be transferred to and/or stored at or accessed from a destination outside the EEA, we will take all steps reasonably necessary to ensure that your data is treated securely, in accordance with this policy and safeguarded in accordance with all applicable legislation.

How do you keep my data secure?

• All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
• Once we have received your information, we will use strict procedures and security features to try to prevent data from being accidentally lost, used or accessed in an unauthorised way. We use industry-standard encryption technologies to store all data, both at rest and in transit. We log all access to data and monitor activity to detect any suspicious behaviour to seek to prevent any data breaches.
• We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.
• We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Your Rights

• You have the right to object at any time to the processing of your personal information
• You have the right to access any information we hold about you. Any request which is manifestly unfounded or excessive may be subject to a reasonable fee to cover our administrative costs in providing you with the necessary details.
• You have the right to ensure the personal information we hold about you is up to date and accurate.
• If you have given direct consent to us to process any of your personal information you may withdraw that consent at any time.
• You have the right to opt-out of receiving emails from us at any time. You can do this by managing your privacy settings in the link contained in the footer of any email you may receive from us. You can also opt-out by emailing hello@efitter.com.
• You have the right to request that the personal information we hold about you be erased and/or request that the processing of that data be restricted.

Sweepstakes and Contests

• From time to time you may have the opportunity to participate in sweepstakes, contests, raffles or similar promotional activities (“Promotional Activities”) through this Website:
• We typically ask you for certain personal data in order for you to participate in such Promotional Activities, such as your name, surname, age, address, phone number, social media account, consumer behaviour and/or email address.
• We collect this information solely to administer the respective Promotional Activity (e.g. to verify your eligibility, to determine the winner and to present the award) unless you have given your explicit consent to use such data for specified other purposes.
• All Promotional Activities conducted via this Website are subject to the terms and conditions of each individual Promotional Activity. Such terms and conditions may provide additional information related to the processing of your personal data.
• Unless expressly otherwise specified, personal data collected by us in respect of Promotional Activities will not be stored any longer than is required to fulfil the purpose of the respective Promotional Activity.

Terms of Use

Please also see our Terms of Use (www.efitter.com/terms-of-use) which set out the terms, disclaimers, and limitations of liability governing your use of EFITTER Ltd.

Cookie Policy

Please also see our Cookie Policy (www.efitter.com/cookie-policy).