Privacy Policy – Size Finder

1. Introduction

eComID AB (“eComID”, “we”, “our”, or “us”), registered with the Swedish Companies Registration Office under reg. no. 559428-6188 and with its registered address at Fiskargatan 8, SE-116 20 Stockholm, Sweden, is committed to protecting your privacy. This privacy policy (the “Privacy Policy”) explains how we, as a data controller, collect, use, disclose, and safeguard your information when you use our Size Finder, integrated on retailers' websites or mobile applications (“Websites”), and other related services we provide (the “Service”).

For the purposes of the Service, eComID acts as a data controller for the personal data it collects or creates. This means eComID determines how and why this data is processed in accordance with applicable privacy laws, including the General Data Protection Regulation (the “GDPR”).

2. Processing of your personal data

Purpose	Categories of personal data	Legal basis	Retention period
We process your personal data for the purpose of providing you accurate size recommendations for different products and brands.	Demographic information: Age and gender Physical characteristics: Height, weight and body shape Preference data: Your fit preferences Information about the retailer and product you want a size recommendation for	The legal basis for the processing of personal data is our legitimate interests. Our assessment is that the processing of your personal data is necessary to enable us provide size recommendations to you. We have also concluded that these interests override any competing interests and fundamental rights and freedoms. You always have the right to object to this conclusion and can read more about your rights below under the section “Your rights”. If you do not provide us with the personal data, we will not be able to fulfil our commitments towards you.	Your personal data will be retained for one day.
We process your personal data for the purposes of enhancing the functionality and accuracy of the Size Finder by analysing usage patterns.	Technical data: Device information (IP address, browser type, operating system) Interaction data: Behavioural and contextual data collected via cookies or similar technology Demographic information: Age and gender Physical characteristics: Height, weight and body shape Preference data: Your fit preferences Information about the retailer and product you want a size recommendation for	The legal basis for the processing of personal data is our legitimate interests. Our assessment is that the processing of your personal data is necessary to enable us provide size recommendations to you. We have also concluded that these interests override any competing interests and fundamental rights and freedoms. You always have the right to object to this conclusion and can read more about your rights below under the section “Your rights”.	Your personal data will be retained for three years from the date of collection.
If applicable, we process your personal data in order to establish, exercise, or defend legal claims.	Personal identifiers: Name and email address Technical data: Device information (IP address, browser type, operating system)	The legal basis for the processing of personal data is our legitimate interests. We have concluded that the processing of your personal data is necessary to establish, exercise and defend legal claims. We have also concluded that these interests override any competing interests and fundamental rights and freedoms. You always have the right to object to this conclusion and can read more about your rights below under the section “Your rights”.	The personal data may be retained for five years, or such longer time as is necessary due to an on-going dispute (or preparations thereof).

3. Data sharing

We may share your information with:

• Third-party service providers: Who assist us in delivering the Service, such as data analytics providers and email service providers.
• Legal authorities: If required by law or a compelling authority decision, to protect our legal rights or the legal rights of a third party (subject to a balance of interests determination).

4. Global operations and data transfers

We are committed to keeping your personal information within the EU/EEA as much as possible. However, as we operate globally, there may be instances where your personal data are transferred to, stored, or processed outside of the EU/EEA. In cases where personal data is transferred to countries outside the EU/EEA, we ensure that there is either (i) a decision from the European Commission that the country in question ensures an adequate level of protection or (ii) appropriate safeguards that ensure that your rights are protected in the form of e.g. standard contractual clauses.

To ensure transparency of our processing of your personal data, you have the right to obtain a copy of any such standard contractual clauses by contacting us. You can also read more about which countries are considered to have an 'adequate level of protection' on the European Commission's website here: Adequacy Decisions, and more about standard contractual clauses here: Standard Contractual Clauses.

5. Your rights

You have the following rights regarding your personal data:

• Access: The right to request access to the personal data we hold about you.
• Rectification: The right to request correction of any inaccuracies in your data.
• Deletion: The right to request deletion of your data under certain conditions.
• Restriction: The right to request that we restrict the processing of your personal data.
• Data portability: The right to receive your data in a structured, commonly used format and transfer it to another data controller.
• Objection: The right to object to our processing of your personal data.

To exercise any of these rights, please contact us at [email protected].

6. Lodging a complaint

If you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the Swedish Authority for Data Protection (Sw. Integritetsskyddsmyndigheten). Information on how to lodge a complaint is available on the website of the Swedish Authority for Data Protection.

Contact information:

Integritetsskyddsmyndigheten
Box 8114
104 20 Stockholm
Sweden
Email: [email protected]
Telephone: +46 8 657 61 00

7. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. Any updates will be effective immediately upon posting on the Website. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

8. Contact information

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at [email protected].