Effective Date: July 22, 2019
Revision Date: August 10, 2026
Virtusize Co., Ltd. ("us," "we," or "our") operates the https://www.virtusize.com website and all related applications and content ("Virtusize" or "Service"). We provide size and product recommendation services for online shoppers through our partner websites.
We are committed to protecting your privacy. This Privacy Policy outlines our policies regarding the collection, use, and disclosure of personal data when you use Virtusize, and the choices you have associated with that data. We adhere to the Japanese Act on Protection of Personal Information ("APPI"), the General Data Protection Regulation 2016/679 ("GDPR"), and the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA").
a. Collection of data
We collect personal data to provide and improve our Service, helping you find the right size when shopping online. Where our processing relies on your consent, we ask for it through a clear affirmative action before collection begins. You are entitled to withdraw your consent to the collection and use of personal data at any time.
b. Withdrawal of consent
You may withdraw your consent to the collection and use of your personal data at any time by contacting us at privacy@virtusize.com. Upon receiving your request, we will stop processing your personal data that relies on your consent and confirm once this has been completed. Please note that certain features of our Service may no longer be available if you withdraw your consent.
c. Legal bases for processing
Where the GDPR applies, we rely on the following legal bases:
To create a cross-platform ecosystem that allows you to manage all your previously purchased items in one closet, we require certain information to match the items you've purchased across the web to your browser and/or account.
a. Information Provided by Our Partner Websites
Through contractual agreements with our partner websites, the following information is shared with us:
b. Information Automatically Collected by Us
When you visit any site or application operated by our partner websites, we collect information on how our Service is accessed and used ("Usage Data"). This may include:
c. Information You Provide Directly
To create a Service account or utilize certain features, we may ask you to provide personal data, including:
We use cookies and similar tracking technologies to monitor activity on our Service and hold certain information.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Virtusize uses the collected data for various purposes:
Our size recommendations are generated automatically using artificial intelligence. The system compares the body information you provide, together with the measurements and fit characteristics of the product, and calculates the size most likely to fit you. Where you have chosen to compare against items you already own, those measurements are also used.
This processing is a recommendation only. It does not produce a legal or similarly significant effect: you remain free to select any size, and the decision to purchase is always yours. You may adjust the information you have provided at any time, or contact us at privacy@virtusize.com if you wish to discuss how a recommendation was reached.
Your information, including personal data, may be transferred to—and maintained on—computers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ. Virtusize is established in Japan. The European Commission has determined that Japan provides an adequate level of protection for personal data, which permits transfers of personal data from the European Economic Area to Japan without additional safeguards. For transfers from the United Kingdom, we rely on the equivalent United Kingdom adequacy regulations. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
Virtusize may disclose your personal data in good faith when:
a. Data security
The security of your data is important to us. We strive to use commercially acceptable means to protect your personal data, including encryption and secure servers. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Virtusize is ISO 27001 certified, meaning we adhere to internationally recognized standards for information security management.
b. Data retention
Virtusize retains user interaction data (including information such as age, gender, height, and weight, and related usage data) for a maximum period of six (6) months from the date of collection. If a user chooses to create a Virtusize account, certain account-related data and purchase history may be retained for as long as the account remains active or as necessary to provide the Service. We may retain data for a longer period where required by applicable law or to resolve disputes and enforce our agreements.
To operate and improve our Services, we engage trusted third-party Service Providers who assist us with hosting, analytics, customer support, and security. All our Service Providers are contractually required to protect personal data and process it only as instructed by Virtusize. They cannot use this data for their own purposes. Where data transfers occur to a country that has not been recognised as providing an adequate level of protection, we implement appropriate safeguards such as Standard Contractual Clauses.
Virtusize may provide retailers with access to certain user interaction data collected through the Virtusize service on the retailer's website via our analytics platform. User interaction data may include information you voluntarily provide (such as age, gender, height, and weight) and interaction data generated during use of the Virtusize service.
Access to such data is limited strictly to the retailer on whose website the data was collected. Virtusize does not share user interaction data across different retailers and does not sell or disclose such data to unrelated third parties.
The retailer independently determines how it uses any data made available to it and is responsible for its own compliance with applicable data protection, marketing, and advertising laws.
Categories of Service Providers and Their Roles
Our Service may contain links to other sites that are not operated by us. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Under applicable data protection laws, you may have the following rights in relation to your personal data:
To exercise any of these rights, please contact us at privacy@virtusize.com. We will respond within one calendar month, extendable by a further two months where the request is complex, in which case we will inform you within the first month.
This section applies to residents of United States states with comprehensive consumer privacy legislation, including California, Virginia, Colorado, Connecticut, Texas, Oregon, and Montana. It supplements the information provided above.
a. Our role
Where Virtusize provides size and fit recommendation services on a retailer's website, the retailer is the business or controller and Virtusize acts as its service provider or processor, processing personal information solely on the retailer's instructions under written contractual terms. Where you create a Virtusize account, Virtusize acts as the business or controller with respect to that account.
b. Categories of personal information
The categories of personal information we collect, the sources from which we collect it, and the purposes for which we use it are described in Sections 3 and 5 above. In the terminology used by United States state privacy laws, these categories are: identifiers; commercial information; internet or other electronic network activity; physical characteristics you choose to provide; and inferences drawn to generate a size recommendation.
c. Sale and sharing
Virtusize does not sell personal information and does not share personal information for cross-context behavioural advertising, as those terms are defined under applicable United States state privacy laws. We have not done so in the preceding twelve months. We do not combine user data across different retailers.
d. Sensitive personal information
We do not use or disclose sensitive personal information for purposes other than those permitted without a right to limit under applicable law.
e. Retention
Our retention periods are set out in Section 8(b) above.
f. Your rights
In addition to the rights listed in Section 11, residents of these states have the right not to be discriminated against for exercising their privacy rights, and, where provided by the law of their state, the right to appeal a refusal to act on a request. We will respond to an appeal within the period required by applicable law.
g. Exercising your rights
Contact us at privacy@virtusize.com. We will verify your request using information reasonably necessary to confirm your identity, and will respond within forty-five days, extendable where permitted by law. An authorised agent may submit a request on your behalf with written authorisation. Where Virtusize acts as a service provider to a retailer, we will direct your request to that retailer or assist them in responding.
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