Privacy and
Security Policy

From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. Please revisit this Privacy Policy to stay updated on any changes.

This Privacy Policy applies to Information provided to us about or relating to you. That Information is described in more detail below.

True Fit Privacy Principles

True Fit follows these principles in order to protect your privacy:

• We do not collect any more Information about you than is necessary;
• We do not collect Information that can identify you;
• Unless you agree otherwise, we only use your Information for the purposes we specify in this Privacy Policy;
• We do not keep your Information if it is no longer needed; and
• Other than as we specify in this Privacy Policy, we do not share your Information with third parties.

This Privacy Policy addresses the following questions:

1. What Information we collect?
2. Why do we collect Information?
3. How do we use Information?
4. With whom do we share Information?
5. How do we secure Information?
6. How do we respect your choices about your Information?
7. How do we use third-party advertising and analytics services?
8. Whom do I contact if I have questions or concerns?
9. Additional Terms.

1. What Information we collect and how is it collected?

(a) Information provided by you. We collect Information by asking you questions about yourself. Your True Fit account profile (the “True Fit Profile”) will request Information such as your age, gender, size, brand preferences, body shape, and fit preferences to use our service (“Service”). As you can see this Information does not allow us to identify you personally, since the combination of this Information cannot be linked to a particular individual. You may also provide us with Information through any website mobile application provided to you by True Fit or controlled by a True Fit retail partner. True Fit retail partners are third parties for whom True Fit provides its online fit recommendation service (the "True Fit Service"). When accessing the True Fit Service through a True Fit retail partner, the Information you provide through the retail partner's website or mobile application ("Partner Site") will be subject to the retail partner's privacy policy; however, the True Fit Privacy Policy will apply to those aspects of your Information that are provided to True Fit in order to perform the True Fit Service and the data contained in your True Fit Profile that may be transmitted back to the retail partner. To be clear, data collected by True Fit through the Partner Site is limited to Information listed above, and True Fit does not collect any additional data, e.g. your name, via the Partner Site, even if the retail partner collects such data. Once the data contained in your True Fit Profile is transmitted back to the retail partner, such data will subject to the retail partner's privacy policy (which may be different than our privacy policy; please see Section 4, below, regarding third-party privacy policies).

(b) 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 do not use this Information to identify you and we are generally not able to identify you on the basis of this Information. 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 Information include:

• Cookies;
• Service Analytics;
• 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 help you in use of 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 your computer with your True Fit Profile and enable you to update and modify your True Fit Profile; (2) speed navigation and provide you with fit recommendations; (3) remember 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.

Outside sources: We may collect Information about you from retail partners, business partners, contractors, and other third parties. This includes, but is not limited to, instances in which you affirmatively authorize those third parties to provide us with Information. For example, retail partners may provide us with Information about items you have purchased from them in the past so that we can provide better fit recommendations for you. This Information is shared with us in accordance with that third party’s privacy policy. We limit the Information collected through third parties to those, which will not allow us to identify you. If you have any questions or concerns about the information that we may have received about you, please contact us at privacy@truefit.com.

2. Why do we collect Information?

We collect your 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. 

3. How do we use Information?

True Fit uses your 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 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 (account) you can log into from any device;
• 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 Information for as long as necessary to carry out our services or as long as we are required by law. After this, your 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.

4. With whom do we share Information?

Protecting the privacy and security of your Information is a priority at True Fit. EXCEPT AS OTHERWISE DESCRIBED IN THIS PRIVACY POLICY, TRUE FIT DOES NOT SELL OR RENT YOUR INFORMATION TO THIRD PARTIES.

True Fit may share a copy of your True Fit Profile with: (i) our retail partners, so they can make better apparel offerings to you; (ii) service providers, subcontractors, and agents who perform services on our behalf; (iii) manufacturers of products sold on our Partner Sites to provide insights relating to the fit, style, and purchase preferences relating to their products; and (iv) third parties in certain business relationships, such as, but not limited to, co-branded offerings where we may offer a service or feature that is co-branded by True Fit and the third party. If you provide Information in connection with a co-branded service or feature, that Information may be shared between True Fit and the third party. True Fit's treatment of that Information is governed by this Privacy Policy, but the third party's treatment of your Information will be subject to the third party’s privacy policy.

In addition, True Fit may share any of your Information with third parties as follows:

• Law Enforcement Officials and as Required by Law. True Fit may release any or all of your 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.
• Sales, Mergers, and Acquisitions. If True Fit becomes involved in a merger, acquisition, or any form of sale of some or all of its business or assets, your Information may be provided to the entities and advisors involved, and your Information may be transferred to a third party in connection with consummation of any such transaction. We will provide notice if your Information becomes subject to a different privacy policy as a result of any such transaction.

Finally, True Fit may share aggregated or de-identified information for our business purposes.

5. How do we secure your Information; Transfers of Information?

We take commercially reasonable security measures, including physical, technological, and procedural measures, to help to safeguard your 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 Information, designed to prevent unauthorized persons from gaining access to your 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 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 Information is transferred, stored, or processed by us, we will take reasonable steps to safeguard the privacy of your Information. You acknowledge and agree that your Information may be processed and stored in different countries, including, without limitation, the European Union and 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 Information. The Information that is collected will tell us things like how you navigated around our Service, and how quickly we helped you to enter registration Information. This Information will help us to better serve you and provide you with more offerings. Additionally, some of our service providers use these technologies on our Service to provide certain behavioral advertising services as well as marketing services 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 Information to perform services for us, securely and in confidence. Any such third-party service provider will be restricted from using your 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 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 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 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 from third parties
• Entering a sweepstakes or a contest

If, at any time, you wish to no longer receive Promotional Communications from third parties, you will be able to follow instructions provided with the Promotional Communication.

True Fit provides you with the ability to access, correct, change, or delete the Information in your True Fit Profile at any time. Please be advised that True Fit may periodically archive 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 have any questions about this Privacy Policy, please contact us at privacy@truefit.com or call customer service at 617-848-3740. To request to have all your Information deleted, or to request a copy of your Information, please contact us at  privacy@truefit.com.

If you would like to report a Security concern about any of our products, please contact us at security@truefit.com.

9. Additional Terms

Transfers to the United States. Information collected from visitors from outside the United States. If you are interacting with True Fit from outside the United States and provide us with any Information, please note, in order for us to provide the True Fit Service as set forth in this Privacy Policy, it will be necessary for your Information to be transferred, stored, and processed within the United States. By doing business or interacting with True Fit, you are consenting to the transfer of your Information to facilities located in the United States and other facility locations selected by True Fit.

Children's and Minor's Privacy. The True Fit Service is not designed to attract minors, in particular, children under the age of 18. True Fit does not market to or knowingly collect Information from anyone under the age of 18. Children should always get permission from their parents before sending any 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.

Third-Party Websites. Please be advised that whenever you click on links and banners that take you to a third-party website, you will be subject to the third party's privacy policies, not True Fit's. This Privacy Policy applies solely to Information collected by True Fit.