True Fit Privacy Principles
True Fit follows these principles in order to protect your privacy:
- We do not collect any more Personal Information about you than is necessary;
- We do not keep your Personal Information if it is no longer needed; and
- What is the Personal Information that we collect?
- Why do we collect Personal Impersonal Information?
- How do we use Personal Information?
- With whom do we share Personal Information?
- How do we secure Personal Information?
- How do we respect your choices about your Personal Information?
- How do we use third-party advertising and analytics services?
- Whom do I contact if I have questions or concerns?
- Additional Terms.
1. What is the Personal Information that we collect and how is it collected?
(b) Personal Information automatically collected. While you use the True Fit Service, we automatically record information that your browser sends whenever you visit a website. For example, we may receive: the name of the domain and host from which you access the Internet, the Internet Protocol (IP) address of the computer you are using, the date and time you access our Service, which apparel items you view and/or purchase, and the Internet address of the website from which you accessed the Service. For clarity, we do not store the IP address of the computer you are using. We use this information to measure the usage of our Service, and to understand how to serve you better. The most common sources of this Personal Information include:
- Service Analytics;
- Pixel tags or clear graphics interchange format files, known as GIFs; and
- Retail partners, business partners, contractors, shared databases, and other third parties.
We provide a summary description of each of these circumstances below. Please note that we permit certain service providers to use these technologies on our Services as well. For more information about these service providers and their activities, please see Section 6, below.
Cookies: Cookies are small files that are sent to your computer's hard drive to tell us who you are when you are using our Service. We use them when you use our Service, including on our Partner Sites so that we can provide you our Service on our Partner Sites. Cookies help us to: (1) associate you with your True Fit Profile and enable you to update and modify your True Fit Profile; (2) speed navigation and provide you with personalized fit recommendations; (3) remember Personal Information you gave so you don't have to re-enter it; (4) determine the effectiveness of some of our marketing efforts and communications; and (5) count the total number of visitors, pages viewed, and the total number of banners displayed.
Upon your first visit to our website, we offer you the ability to accept or decline cookies that are not essential to the use of the Services (e.g., marketing or analytics cookies). You may also choose to have your browser notify you when cookies are being written to your computer or accessed, or you can disable cookies entirely. If you disable cookies entirely, you will not be able to create a True Fit Profile, and therefore you will not be able to receive the benefit of the True Fit Service. Also, by not using cookies, features within our Service or a Partner Site may not function properly.
Pixel tags or clear GIFs: To help us understand the effectiveness of select communications and marketing efforts, we may use "message format" and "message open" sensing technologies that use pixel tags or clear GIFs (which are also called web beacons). These technologies allow us to know if your e-mail program is able to accept HTML e-mails and, if it is, to: (1) send you e-mails in that format; and (2) determine if you have opened our e-mail messages.
2. Why do we collect Personal Information?
We collect your Personal Information to provide you with the True Fit Service and to administer our business. It allows us to provide you with easy access to our products and services, with a particular focus on the items and programs that may be of most interest to you. Your Personal Information also allows us to communicate with you about special offers, promotions, and other marketing programs and news that may be of interest to you.
3. How do we use Personal Information?
True Fit uses your Personal Information to provide you with the True Fit Service through our Partner Sites, to provide you with a superior customer experience, and to administer our business. We use your Personal Information to:
- Create and provide recommendations on size, fit, and style of apparel items;
- Analyze the fit, style, and fashion of apparel items;
- Create a True Fit Profile (personal account) you can log into from any device;
- Provide you with special offers, promotions, and other marketing programs and news that may be of interest to you;
- Answer questions you ask of us regarding the Service or recommendations;
- Make communications necessary to notify you regarding security, privacy, and administrative issues;
- Validate you are of legal age to use our services;
- Test and improve our systems and services; and
- Manage our business.
We will only keep your Personal Information for as long as necessary to carry out our services or as long as we are required by law. After this, your Personal Information will be deleted. We may not remove your data when there is a legal storage requirement such as book keeping rules, or when there is a legal ground to keep the data, such as an on-going contractual relationship.
Non-personal data is used as described above and in other ways as permitted by applicable laws, including combining non-personal data with personal data.
4. With whom do we share Personal Information?
In addition, True Fit may share any of your Personal Information with third parties as follows:
- Law Enforcement Officials and as Required by Law. True Fit may release any or all of your Personal Information to third parties when we determine, in our reasonable judgment, that it is necessary to (a) comply with the law, regulation, legal process, or enforceable governmental request; (b) enforce or apply the terms of any of our policies or user agreements; or (c) protect the rights, property, or safety of True Fit, our employees, our customers, users, or others.
Finally, True Fit may share aggregated or de-identified information for our business purposes.
5. How do we secure your Personal Information; Transfers of Personal Information?
We take commercially reasonable security measures, including physical, technological, and procedural measures, to help to safeguard your Personal Information and to prevent unauthorized access and disclosure. In addition, we use industry-standard technology, such as edge-protection devices and encryption in the transmission of certain sensitive Personal Information, designed to prevent unauthorized persons from gaining access to your Personal Information and True Fit Profile, and, as technology develops, we intend to take additional measures to improve security. No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. Therefore, we cannot guarantee its absolute security.
We operate globally and may transfer your Personal Information and True Fit Profile to individual companies and customers of True Fit as part of the services offered by True Fit to its customer base. Wherever your Personal Information is transferred, stored, or processed by us, we will take reasonable steps to safeguard the privacy of your Personal Information. You acknowledge and agree that your Personal Information may be processed and stored in countries outside of the European Union including, without limitation, the United States.
6. How do we use third-party advertising and analytics services?
From time to time, we may work with third-party service providers to help us better understand how you use our Service. These service providers may place cookies on your computer or use other technologies, such as pixel tags and clear gifs, to collect Personal Information. The Personal Information that is collected will tell us things like how you navigated around our Service, and how quickly we helped you to enter registration Personal Information. This Personal Information will help us to better serve you and provide you with more personalized offerings. Additionally, some of our service providers use these technologies on our Service to provide certain behavioral advertising services as well as marketing services via email and display advertising.
We will not grant permission to any of these third-party service providers to collect your credit card information, e-mail address, or password information through this technology. Any third-party service provider will be restricted to use your Personal Information to perform services for us, securely and in confidence. Any such third-party service provider will be restricted from using your Personal Information for any other purpose, except on an aggregate, anonymous basis. With your privacy in mind, we will work toward engaging third-party service providers who enable you to opt-out of their Personal Information collection processes.
The third-party services we use include, but are not limited to, Google ads, Facebook ads, Pinterest ads, LiveRamp, and TowerData. To learn more about Google’s advertising policies, see: policies.google.com/technologies/ads; your ad settings with Google, see: adssettings.google.com; and Google’s ad personalization, see: policies.google.com/technologies/partner-sites. To learn more about Facebook’s privacy practices, see: facebook.com/policy.php. Additionally, you may choose to opt out of certain behavioral advertising through the following websites: http://www.aboutads.info/choices and http://www.youronlinechoices.eu/. To learn more about LiveRamp’s privacy practices, see: https://liveramp.com/privacy/, and to opt out of their services, see: https://liveramp.com/opt_out/. To learn more about TowerData privacy practices, see: https://www.towerdata.com/privacy-policy, and to opt out of their services, see: https://instantdata.towerdata.com/optout.
7. How do we respect your choices about your Personal Information?
When you interact with our Service in certain ways, you may be eligible to receive certain marketing-related and promotional communications as well as special offers (collectively "Promotional Communications") from True Fit or third parties with whom True Fit has a business relationship and those communications may include advertisements. The most common of these circumstances may include:
- Creating a True Fit Profile
- Signing up to receive newsletters or email notices
- Entering a sweepstakes or a contest
If, at any time, you wish to no longer receive Promotional Communications from True Fit, you will be able to follow instructions provided with the Promotional Communication or within our Service in connection with Promotional Communications. Even if you opt-out of receiving Promotional Communications, you may continue to receive e-mails relating to your True Fit Profile, Personal Information, and/or other security or business-related communications. Although the primary purpose of these emails is not to provide you with promotional material, they may contain within them some promotional material.
True Fit provides you with the ability to access, correct, change, or delete the Personal Information in your True Fit Profile at any time. Please be advised that True Fit may periodically archive Personal Information it has collected and there may be times that such archived information cannot be permanently removed from our systems.
8. Whom do I contact if I have questions or concerns?
If you would like to report a Security concern about any of our products, please contact us at firstname.lastname@example.org.
If you are located in the European Economic Area, please see our GDPR FAQ for more information regarding your rights under the GDPR.
9. Additional Terms
Children's and Minor's Privacy. The True Fit Service is not designed to attract minors, in particular, children under the age of 16. True Fit does not market to or knowingly collect Personal Information from anyone under the age of 16. Children should always get permission from their parents before sending any Personal Information about themselves (such as their names, email addresses, and phone numbers) to anyone over the Internet.
Do Not Track Signals. Your web browser may let you choose your preference as to whether you want to allow the collection of information about your online activities over time and across different websites or online services. At this time, the Service does not respond to the preferences you may have set in your web browser regarding such collection of your information, although we do provide other opportunities for you to control your information, including, for example, honoring your cookie preferences.
California Residents. If you are a resident of California, you may find additional
information regarding your rights in our Notice for California Residents.
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