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Email: emea@truefit.com

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True Fit Privacy Notice
for California Residents

Last Modified: June 2, 2020 - This Privacy Policy is effective as of the date last modified. 

This Privacy Notice for California Residents supplements the information contained in the general Privacy Policy of True Fit, Inc. (“True Fit,” “we,” or “us”), which is incorporated in this privacy notice by this reference. This privacy notice applies solely to those who reside in the State of California (“consumers” or “you”), including visitors to www.truefit.com (the “Site”). We adopt this privacy notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this privacy notice.

Information We Collect
This Site collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). In particular, within the last 12 months True Fit’s Site has collected the following categories of personal information from the sources and for the business or commercial purposes described below: 
 
Description of Category What We Collect Source Business or Commercial Purposes for Collection
Identifiers
(“Identity Data”).
An alias, online identifier, internet protocol address, and, to the extent provided by consumers, email addresses. Directly from consumers (e.g., when consumers create an account with True Fit)
 
Indirectly from consumers (e.g., when a consumer interacts with our website)
To provide our True Fit services, including size and style recommendations, to our users and enable our retail customers to provide better service to users.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“Customer Records Data”). An alias, physical characteristics or description.
 
Directly from consumers (e.g., when consumers create an account with True Fit) To provide our True Fit services, including size and style recommendations, to our users and enable our retail customers to provide better service to users.
Protected classification characteristics under California or federal law (“Classification Data”). Age ranges as well as sex, gender identity, gender expression, etc. but only to the extent these would be discernable from consumer-provided preferences (e.g., clothing and fit preferences). Directly from consumers (e.g., when consumers create an account with True Fit) To provide our True Fit services, including size and style recommendations, to our users and enable our retail customers to provide better service to users.
Commercial information (“Commercial Data”). Records of products or services purchased,  or considered, or other purchasing or consuming histories or tendencies. From our retailer partners
 
Indirectly from consumers (e.g., when a consumer interacts with our website)
To provide our True Fit services, including size and style recommendations, to our users and enable our retail customers to provide better service to users.
Internet or other similar network activity (“Internet Use Data”). Browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement. Indirectly from consumers (e.g., when a consumer interacts with our website)
 
From our third-party analytics partners as described in our general Privacy Policy
To improve the True Fit services, including size and style recommendations, to our users and enable our retail customers to provide better service to users.
Inferences drawn from other personal information (“Inferences”). Profile reflecting a person’s preferences, characteristics, behavior. Directly from consumers (e.g., when a consumer identifies preferred styles or clothing sizes, when consumers create an account with True Fit)
 
Indirectly from consumers (e.g., when a consumer interacts with our website)
To provide our True Fit services, including size and style recommendations, to our users and enable our retail customers to provide better service to users.
 

Personal information does not include:
  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In addition to the business or commercial purposes for collection described above, we have in the preceding 12 months collected all categories of personal information described above for the following purposes:
  • To process your requests.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To create, maintain, customize, and secure your account with us.
  • For testing, research, analysis, and product development, including to develop and improve this Site and our products and services.
  • To provide, support, personalize, and develop this Site and our products and services.
  • To help maintain the safety, security, and integrity of this Site and our products, services, databases, other technology assets, and business.
 
We will continue to collect the categories of personal information described above from the sources and for the business or commercial purposes described above.
We may also use or disclose the personal information we collect for one or more of the following purposes:
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of True Fit’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by True Fit about the users of this Site is among the assets transferred.
 
Disclosures of Personal Information for a Business Purpose
We share your personal information for a business purpose to the following categories of third parties:
  • Service providers.
  • Data analytics providers.
 
In the preceding 12 months, we have disclosed to these third parties the following categories of personal information for a business purpose:
  • Identity Data.
  • Customer Records Data.
  • Protected Class Data.
  • Inferences.
Sales of Personal Information
True Fit may sell (as defined by the CCPA) your personal information to those retail partners with whom you shop, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights).
 
In the preceding 12 months, we have sold to these third parties the following categories of personal information:
  • Identity Data.
  • Customer Records Data.
  • Inferences. 
Your Rights and Choices
The CCPA provides you as California residents with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed for a business purpose or sold your personal information, two separate lists disclosing:
    • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
    • Sales, identifying the personal information categories that each category of recipient purchased.

Deletion Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
  • Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
 
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:  
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the personal information requested. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
 
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
 
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will inform you of the reason and extension period in writing.
 
If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
 
Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
 
We do not charge a fee to process or respond to your verifiable consumer request unless the request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.
 
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 years of age and less than 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized agent) may submit a request to us by visiting our “Do Not Sell My Personal Information” webpage, available at: https://www.truefit.com/en/California-Privacy. If your authorized agent submits a request on your behalf, the authorized agent must provide either (1) a copy of your written permission for the authorized agent to submit a request on your behalf and information sufficient to verify the authorized agent’s identity or (2) power of attorney pursuant to California’s Probate Code.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
  • Provide you a different level or quality of goods or services, including denial of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
 
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, levels, or quality of goods or services. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
 
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of this Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information set forth below.

Changes to this Privacy Notice
 True Fit reserves the right to update or change this privacy notice at any time. When we make changes to this privacy notice, we will post the updated notice on this Site and update the date on which this privacy notice was last updated. The date this privacy notice was last updated is at the top of this page. You are responsible for periodically reviewing this Site and this privacy notice to check for any updates or changes. Your continued use of this Site following the posting of changes constitutes your acceptance of such changes.  

Contact Us
If you have any questions or comments about this privacy notice or our privacy practices, your choices and rights regarding use of your personal information, or wish to exercise your rights under California law, please send an email to privacy@truefit.com or submit a request at: www.truefit.com/en/Privacy-Policy.
 


Do Not Sell My Information

Please fill out the following form to request that True Fit not sell your personal information as those terms are defined under California law