Privacy Policy

Fit Analytics Innovation GmbH

Last Significant Update: 13 Aug 2026

Introduction

Fit Analytics Innovation GmbH ("we", "us", "our") is committed to protecting your privacy. This privacy policy explains how we collect, use, and safeguard the user’s (“you”, “your”) personal data when interacting with our Products, including Fit Finder, Fit Cues, the Shopping Assistant, and any future additions (collectively, the "Products"), as integrated via Widget (SDK) or API into the websites of our commercial partners ("Stores").

Stores may license any individual Product or combination of Products, and we may expand our offerings over time. Because feature availability varies by Store, certain data processing activities described below may not apply to your visit. Where a section applies exclusively to a single Product, it is explicitly noted.

For more on how we use AI within our Products and how we meet the transparency requirements of the EU AI Act, please refer to our AI Transparency Statement.

Data Collection

We collect the following types of personal data depending on which Product you interact with:

Note: We only process pseudonymised data, meaning the data cannot be directly linked to your actual identity without additional information. We do not ask for or collect direct identifiers such as your name, email address, phone number, or shipping address, and we do not attempt to link the data we hold to your real identity. Indirect identifiers such as Store Session IDs, Store User IDs, Order IDs, and IP addresses are strictly pseudonymised.

This is subject to one exception. Conversations with the Shopping Assistant are free text, so any information you choose to include in a message is stored as part of that conversation. We recommend you do not share any unnecessary personal information with the Shopping Assistant.

All collected data is managed with strict security measures to ensure your privacy and data protection.

Use of Data

The collected data is used to:

Data Storage and Processing

We store all collected data exclusively in multi-region data centres within the European Union, hosted on Google Cloud Platform (GCP). This ensures that our data handling practices comply fully with the General Data Protection Regulation (GDPR). Our data protection measures include encryption, access controls, and regular security audits to safeguard data against unauthorised access and breaches. Where any of our service providers process data outside the European Union, we apply the safeguards described under International Data Transfers.

Data is retained according to our Data Retention section below. Access to personal data is restricted to authorised personnel only and is subject to strict confidentiality obligations.

Role as Data Processor

This policy describes how we process personal data on behalf of the Stores that use our Products.

As a data processor, we do not own the collected data; full ownership and control remain with the respective Stores.

All data processing is carried out strictly in accordance with the Store’s instructions and under contractual obligations. We execute Data Processing Agreements (DPAs) with each Store, which define our scope of processing, outline technical security measures, and enforce strict compliance with applicable data protection laws, including GDPR. Stores serve as the data controller of processed data, and are responsible for maintaining their own privacy notices accordingly.

Lawful Basis for Processing

Our processing activities are conducted in accordance with GDPR. We rely on the following lawful bases for processing personal data:

Loading our Products on a Store's website requires your consent. There are two ways consent can be given:

  1. Store’s Cookie Consent: by accepting analytics cookies through the Store’s cookie consent banner, where analytics covers our product usage.

  2. Fit Analytics Consent: by consenting to the use of our products directly through our Fit Finder widget or the Shopping Assistant.

This consent allows us to collect and analyse the usage data needed to provide personalised size recommendations and shopping assistance, improve our Products over time, and report on their effectiveness to the Store. Without your consent, our Products will not load and you will not be able to use them.

We do not use the data for any purpose other than those described in this policy.

You can manage and withdraw your consent in the following ways:

You can also delete your size profile at any time through the privacy settings in our widget, or clear everything we have stored on your device by deleting all cookies and storage whose name begins with "fitanalytics" through your browser settings.

For assistance with managing your consent preferences, contact us at privacy@fitanalytics.com.

Our Products are intended for use by adults. Where consent is required from a child, or from a parent or guardian on a child's behalf, the Store is responsible for obtaining it.

Storage

To provide a personalised experience, we store a small amount of information on your device using cookies and your browser's local and session storage. Every item we store has a name beginning with "fitanalytics", so that you can find and remove it through your browser settings.

None of these items are used to track you across websites. They are set within the context of the Store’s domain and cannot be accessed or read by any other website. For some integrations, such as API, we store no data on your device, and session management is handled directly by the Store.

You can clear this information at any time through your browser settings. See Managing Consent above for how to withdraw your consent entirely.

User Rights

You have comprehensive rights regarding your personal data, as granted by GDPR and other relevant data protection laws. These rights include:

Exercising Your Rights

We facilitate the exercise of these rights via email to ensure secure and verifiable communication. Please direct all such requests to our dedicated email at privacy@fitanalytics.com.

We will respond to all requests within one month of receipt. Where a request is particularly complex, we may extend this by up to two further months, and will tell you within the first month if we need to. For requests under the California Consumer Privacy Act, we will acknowledge your request within 10 business days and respond within 45 calendar days.

Data Security

We implement advanced technical and organisational measures to protect the security of all personal data, ensuring data integrity and protection against unauthorised access. Leveraging the robust security infrastructure provided by Google Cloud Platform (GCP), our security measures include:

By implementing these measures, we ensure that your personal data is handled securely and in compliance with GDPR as well as other relevant data protection regulations, such as the California Consumer Privacy Act (CCPA) or Data Protection Act 2018.

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

We regularly review our retention practices. For more detailed information, contact us at privacy@fitanalytics.com.

International Data Transfers

As part of our services, we act as a data processor on behalf of our partner Stores, who act as the data controllers. In this role, we may transfer processed data back to the relevant Store, including Stores located outside the European Union. We are committed to ensuring that these data transfers are conducted securely and in compliance with applicable data protection laws.

When a Store requests data, we share it as they are the rightful data owners. We adhere to strict protocols to ensure that all international data transfers are secure and comply with relevant regulations.

Transfers to our service providers

We use a small number of service providers to operate our Products. These are listed in our sub-processor list, which is available on request. For any service providers that process personal data outside the European Union, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses and, where applicable, the UK International Data Transfer Addendum. To request a copy of these safeguards, contact us at privacy@fitanalytics.com.

Third-Party Sharing

We do not sell personal data, and we do not share it with third parties for their own purposes.

To operate our Products, we rely on a limited number of trusted service providers who process data strictly on our behalf and under binding contractual obligations. These providers support our operations through cloud hosting, secure data storage, and powering the AI models behind the Shopping Assistant. They may not use the data for any purpose of their own. Our current sub-processor list is available on request.

We do not use advertising networks, marketing platforms, session recording tools, or third-party analytics services.

Automated Decision-Making

Automated decision-making refers to making decisions or generating recommendations using automated algorithms without human involvement, based on data you provide.

Fit Finder can use automated decision-making to preselect sizes for you. This is done by analysing the measurements and fit preferences you voluntarily provide, alongside pseudonymised purchase and return data shared by the Store. The sole purpose of these automated suggestions is to enhance your shopping experience by helping you find the right fit quickly. The automated size preselection can be changed by you at any time during your shopping session.

We comply with GDPR and US privacy laws by ensuring transparency and obtaining user consent for these automated processes. These automated decisions do not impact your rights or freedoms, and are intended to improve your shopping experience.

Do Not Track

Do Not Track ("DNT") is a privacy preference that can be set in certain web browsers. There is no common standard for how DNT signals should be interpreted, and we do not currently respond to them. You can control our processing of your data through the consent mechanism described under the Manage Consent section above.

Changes to this Privacy Policy

This Privacy Policy is updated to reflect changes in our practices or legal requirements. It is reviewed at least annually or more frequently as required by regulatory shifts, organisational needs, or emerging requirements. When updates occur, we will notify the Stores that use our Products before publishing the revised version. If an update affects how we collect or use your data, we will notify you directly through our Products.

You are encouraged to review this Privacy Policy periodically to stay informed about how we are protecting your personal data.

Contact Information

For questions or concerns about our data privacy practices, or to exercise your data rights, please contact our Data Protection Officer at:

Data Protection Officer

Fit Analytics Innovation GmbH

Schwedter Straße 263

10119 Berlin, Germany

privacy@fitanalytics.com