Privacy & Security Policy

In order to provide you with personalized footwear recommendations, StrutFit Limited (“StrutFit”) needs you to provide us with certain Personal Information about yourself. We take the privacy of your Personal Information very seriously. We provide this policy so that you can understand what Personal Information we collect, how we collect Personal Information, and how we use the Personal Information you provide.

Last Modified: January 2021; This Privacy Policy is effective as of date last modified.

From time to time, we may change this privacy policy to ensure it is up to date with the latest technologies, policies, or for other purposes. We will notify you by email (sent to the email address specified in your profile) of any material changes to our use of your Personal Information. Please revisit this Privacy Policy to stay updated on any changes.

This Privacy Policy applies to Personal Information provided to us about or relating to you, and from which, either alone or when connected with other information to which we may have access, you can be individually identified (“Personal Information”). That Personal Information is described in more detail below.

StrutFit Privacy Principles

StrutFit follows these principles in order to protect your privacy:

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

This Privacy Policy addresses the following questions:

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?
Whom do I contact if I have questions or concerns?
Additional Terms

1. What is the Personal Information that we collect?

(a) Personal Information provided by you. We collect Personal Information by having you scan your feet. The StrutFit profile will also request Personal Information such as your age and gender. We may also request your email address, which is recommended, but not mandatory to use StrutFit. You may also provide us with Personal Information through any website or mobile application provided to you by StrutFit, or controlled by a StrutFit retail partner. StrutFit retail partners are third parties for whom StrutFit provides its fit recommendation service (the “StrutFit Service”). When accessing the StrutFit Service through a StrutFit retail partner, the Personal 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 StrutFit Privacy Policy will apply to your Personal Information that are provided to StrutFit in order to perform the StrutFit Service. Once the data contained in the profile is sent back to the retail partner, the data will subject to the retail partner’s privacy policy (which may be different than our privacy policy).

(b) Personal Information automatically collected. While you use the StrutFit 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 footwear items you view and/or purchase, and the Internet address of the website from which you accessed the Service. We use this information to analyze the use of our Service and to see how we may improve your experience.

The most common sources of this Personal Information include:

Cookies
Service Analytics
Pixel tags or clear Graphics Interchange Format files, known as GIFs
Occasionally; retail partners, business partners, contractors, shared databases, and other third parties

We provide a summary description of each of these circumstances below.

Cookies: Cookies are small files that are sent to your computers to tell us who you are when you are using our Service. Cookies help to: (1) associate you with your StrutFit Profile and enable you to update and modify your StrutFit Profile; (2) remember who you are provide you with personalized fit recommendations on product pages; (3) keep you logged in so you don’t have to manually login every time; (4) determine the effectiveness of some of our marketing communications; and (5) count the total number of visitors and pages viewed. Browsers are typically set to create cookies automatically. You can 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, you will not be able to create a StrutFit account or use the StrutFit Service properly. Also, by not using cookies, features within our Service or a Partner Site may not function properly.

Service Analytics: We may work with one or more third party analytics providers to help us better understand how you use our Service. The service provider may place cookies on your computer to collect Personal Information. The Personal Information that is collected will tell us things like where you navigated and which path you took through our Service. This Personal Information will help us to better serve you and improve our service. We will not grant permission to any such third party service provider to collect your credit card, Personal Information, e-mail address, or password Personal Information. 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.

Pixel tags or clear GIFs: To help us understand the effectiveness of our service and marketing, we may use “message format” and “message open” sensing technologies that use pixel tags or clear GIFs. 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.

Outside sources: We may periodically collect Personal 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 Personal Information. For example, retail partners may provide us with Personal Information about items you have purchased from them, so that we can improve our service for you and provide better fit recommendations.

2. Why do we collect Personal Impersonal Information?

We collect your Personal Information to provide you with the StrutFit Service and to improve our service. It allows us to provide you with easy access to our products and services. Your Personal Information also allows us to communicate with you about personalized offers, promotions, and other marketing programs and news that may be of interest to you.

3. How do we use Personal Information?

StrutFit uses your Personal Information to provide you with the StrutFit Service through our Partner Sites, to provide you with a superior customer experience, and to improve our service. We use your Personal Information to:

Provide recommendations on the size footwear items.
Analyze the fit footwear items.
Create a StrutFit Profile (personal account) you can log into from any device.
Provide you with personalized offers, promotions, and other marketing programs and news that may be of interest to you.
Answer questions any of your questions regarding our service.
Make communications necessary to notify you regarding security, privacy, and administrative issues.
Test and improve our systems and services.

We will only keep your data for as long as necessary to carry out our services or as long as we are required by law. After this, your personal data will be deleted. We cannot remove your data when there is a legal requirement such as book keeping rules.

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

StrutFit may share a copy of your StrutFit Profile, which may include your email address (if provided) with: (i) our retail partners, so they can better personalize footwear 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) to 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 StrutFit and the third party. If you provide Personal Information in connection with a co-branded service or feature, that Personal Information may be shared between StrutFit and the third party. StrutFit’s treatment of that Personal Information is governed by this privacy policy, but the third party’s treatment of your Personal Information will be subject to the third party’s privacy policy.

In addition, StrutFit may share any of your Personal Information with third parties as follows:

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

5. How do we secure Personal Information?

We take appropriate 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 StrutFit 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 StrutFit Profile to individual companies and customers of StrutFit as part of the services offered by StrutFit 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 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 StrutFit or third parties with whom StrutFit has a business relationship and those communications may include advertisements. The most common of these circumstances may include:

Creating a StrutFit 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 StrutFit, 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 StrutFit Profile update 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.

StrutFit provides you with the ability to access, correct, change or delete the Personal Information in your StrutFit Profile at any time. Please be advised that StrutFit may periodically archive Personal Information it has collected and there may be times that such archived information cannot be permanently removed from our systems.

7. Whom do I contact if I have questions or concerns?

If you have any questions about this Privacy Policy, please contact us at privacy@strut.fit.

To request to have all your Personal Information deleted, please contact us at privacy@strut.fit.

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

By doing business with or interacting with StrutFit in the manner described in this Privacy Policy at any time on or after the Effective Date, you are accepting the practices described in this Privacy Policy and you expressly consent to the application of this Privacy Policy to the collection, storage, use and disclosure of your Personal Information as described.