WHO WE ARE
Rakuten Fits Me is part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company Rakuten, Inc., based in Tokyo, Japan. More information about Rakuten is available at http://global.rakuten.com/corp/about/company.
WHAT IS PERSONAL INFORMATION?
Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.
PERSONAL INFORMATION WE USE
In this section, we explain the different types of personal information that we collect or hold about you and what we use it for. We will collect personal information from you from a variety of sources, including information we collect from you directly (e.g. when you contact us), and information we collect about you from other sources, described below.
1. If you are a client or prospective client
Information we collect directly from you:
Contact information: your name, job title, company address, telephone number and email address; your signature if you have signed any documents with us; and the content of any emails or messages you send to us.
Service administration information: your account log-in information (username and encrypted password); support service requests; and data collected using cookies and other device tracking technologies to monitor your use of our Services.
Information we collect from other sources (such as publicly available information on LinkedIn):
Contact information: your name, job title, company address, telephone number and email address
What we use your information for:
Services: to provide our Services to you, including billing, customer support, and account management.
Sales and marketing: to contact you with marketing and offers relating to products and services offered by us.
Security: to keep our Services secure and to comply with any law, rule, legal decision or regulation that we are obliged to comply with.
2. If you visit our Website or use one of our Fit Recommendation Tools on a retailer’s website
Information we collect directly from you:
Fit measurements: if you use one of our Fit Recommendation Tools on a retailer’s website, you will be asked to enter certain information including your height, weight, age and body measurements.
Cookies: if you opt-in to cookies when you enter your information in the Fit Recommendation Tool, we will place a persistent cookie on your browser which allows us to match you with your measurements when you come back onto the retailer’s website (or to another retailer’s website which uses our Fit Recommendation Tools), so you do not have to re-enter that information again. On mobile, this will be your Advertising Identifier or IFDA.
Automatic log data: our computer servers also automatically make a log of certain information, including the date and time of your use, your internet protocol (IP) address, location, the address of the last website you visited, your browser type and settings, and what type of device you are using.
Information we collect from other sources:
Information from the retailer: the retailer on whose website you have used our Fit Recommendation Tool will give us some limited information about your online transaction (such as a transaction ID number, and product ID number), but no information which identifies you as an individual.
What we use your information for:
Fit recommendations: After you enter your information into our Fit Recommendation Tool, our software algorithms use that information, plus information that the retailer has provided to us about their clothing sizes, to recommend the best size of clothing for you. This is an automated process (see below under Profiling[link to (d)]).
Service improvements: to understand where our users are coming from, what browsers or devices they are using and how often they are using our tools. It helps us improve our Services, including our algorithms (by understanding more about the relationships between body shapes, garment sizes, fit preferences and geography).
Client analytics: We also use your information (only in an aggregated and anonymised format) as part of the analytics that we pass to our clients, showing how shoppers use our Fit Recommendation Tools.
Using your information for profiling:
When you enter your fit measurement information into our Fit Recommendation Tool, our software algorithms carry out an automated profiling process, based on the information you have provided, to assess your body type. We then combine that with data that the retailer has given us on the size and fit of their clothing, and work out what size clothing would be the best fit for you.
We only ever present a recommended size and you always have the option to choose a different size. This automated profiling will not have any legal or similar effects for you.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
We must have a legal basis to process your personal information. The legal basis will be one of the following:
To fulfil our contractual obligations to you, for example to provide the Services. Failure to provide this information may prevent or delay the fulfilment of these contractual obligations.
To meet our legitimate interests, for example to deliver fit recommendation results to you, and understand how you use our Fit Recommendation Tools so we can make them better. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
What are cookies? A cookie is a small data file sent by us to your computer/device and from your computer/device to us when you use our Fit Recommendation Tools or our Website.
Types of cookies we use: We use both session cookies (which disappear when you close your browser) and persistent cookies (which stay on your browser for a set period of time or until you delete them).
We use first-party cookies (controlled by us to provide the Services) and third-party cookies (controlled by third-parties, often for analytics, social sharing and advertising purposes).
We use the following categories of cookies:
Strictly necessary cookies: these are necessary for our website to provide you with the functionality you need, or for system administration. Without these cookies, the Website services cannot fully function. We are not required to obtain your consent for strictly necessary cookies.
Performance, function & analytics cookies: these help us assess the performance of our Website and include analytics cookies that help us understand how our Website is being used (for example, whether you have visited our Website before and which parts of the Website you visit). This helps us make our Website better and easier for you to use.
Advertising cookies: these cookies from our advertising parties collect information to be able to show you advertising that is relevant to you.
|Description||Source||Category||What these cookies do||How to exercise your cookie choices|
|fmLongTerm-live||Rakuten Fits Me||Performance, function & analytics||This cookie creates a unique identifier that we link to information that we have collected on how you use our Fit Recommendation Tool (such as whether you click certain buttons).||http://www.allaboutcookies.org|
|fo_visitor||Rakuten Fits Me||Performance, function & analytics||This cookie creates a unique identifier (a randomly generated number) (Cookie ID) that we use to match you to the fit measurement information that you provide to us.||You can set your preference to on or off on our Fit Recommendation Tool. If you turn this cookie off, then the next time you use the Fit Recommendation Tool, you will have to input your information again.|
|_utma, _utmb, _utmc, _utmt, _utmv, _utmz||Google Analytics||Performance, function & analytics||We use Google Analytics on our Website to collect information on how the Website is used and to report on the Website usage statistics.||https://policies.google.com/technologies/cookies|
|Visitor_id#####, pardot,||Pardot||Performance, function & analytics||These cookie helps us manage our newsletter marketing campaigns.||http://www.allaboutcookies.org|
|_atuvc, _atuvs, bt2, di2, mus, uid, uvc, _ouid, loc, vc xtc||AddThis||Social media||AddThis provides social sharing buttons so you can share our Website content on social channels.||http://www.addthis.com/privacy/privacy-policy|
|lang, auth_token, twll, secure_session, guest_id, _utma, _personalization_id, remember_checked, remember_checked_on||Advertising||These cookies are used by Twitter for targeted advertising.||https://help.twitter.com/en/rules-and-policies/twitter-cookies|
|datr, fr, lu||Advertising||These cookies are used by Facebook for targeted advertising.||https://www.facebook.com/policies/cookies/|
|SID, HSID, APISID, SSID, PREF, GPS, demographics, VISITOR_INFO_LIVE, PREF, id, LOGIN_INFO, YSC||YouTube, Google, Doubleclick||Advertising||These cookies are embedded in YouTube videos on our Website, or are set by Google or Doubleclick and used for targeted advertising.||https://policies.google.com/technologies/cookies|
|BizoID, _utma, utmv, _qca, Lidc, bcookie, bscookie, visit, UserMatchHistory, lang||Advertising||This cookie is used by LinkedIn for targeted advertising.||https://www.linkedin.com/legal/cookie-policy
How to turn off cookies: You can set your browser not to accept cookies and you can remove any cookies that are already stored on your browser. These websites tell you how to remove cookies from your browser: www.allaboutcookies.org or www.youronlinechoices.eu. Our cookie choices setting on our cookie banner allows you to set your cookie preferences.
YOUR RIGHTS OVER YOUR PERSONAL INFORMATION
Your rights: You have certain rights regarding your personal information. These include the rights to:
Access your personal information
Rectify the information we hold about you
Erase your personal information
Restrict our use of your personal information
Object to our use of your personal information
Receive your personal information in a usable electronic format and transmit it to a third party (right to data portability)
Some of these rights are only available in certain circumstances or only apply to certain information that we hold about you.
HOW TO EXERCISE YOUR RIGHTS
If you are a client with an online account: you can access, correct and delete certain of your information by accessing your user account, using your unique user name and password.
If you are a shopper: the only way that we can identify you is if you give us your Cookie ID. However, when you get in touch with us, you will be giving us more personal information than we currently hold (such as your email address, name etc), so you may find it easier to delete your cookies on your browser, which would mean we have no way of linking it back to you.
If you do want to find your Cookie ID, here are the steps:
Step 1: Find our cookie
Search through the cookies stored on your browser for fo_visitor. Click on the file to see the number inside. This is your Cookie ID.
If you use more than one browser (for example, Google Chrome and Internet Explorer), you will need to do the same process for each browser. If you need help finding the cookies for your browser, please email us at email@example.com.
On mobile? You’ll need to follow instructions from your mobile device manufacturer on how to find cookies on your device.
At this step, you can also delete your cookie, which would mean that we would not be able to identify you.
Step 2: Take a screenshot
We need to make sure we only provide personal information to the correct person, so we will need you to verify your Cookie ID. Please take a screenshot of the cookie that shows both the name of the cookie and your Cookie ID.
Step 3: Contact us
Email your request to us at firstname.lastname@example.org with your Cookie ID and screenshot.
For all other enquiries regarding your rights, please contact us at the details below. We will contact you if we need additional information from you in order to respond to your request.
SHARING YOUR INFORMATION WITH THIRD PARTIES
Third party service providers: We share certain of your personal Information with our service providers that perform business services and/or operations on our behalf. For example, we use other companies to process secure payments, provide website hosting services, perform analytics, send newsletters and emails, and provide professional advice to us (such as our accountants, solicitors, business advisers and consultants).
Rakuten Group companies: We may share certain information with specific companies in the Rakuten Group of companies, either for internal reporting purposes, or where one of the group companies helps us to provide the Services. For example, one of our subsidiary companies provides technical support services to our clients and therefore, if you are a client, we will share your contact and account information with that company to enable them to provide that support.
Legal obligations: Sometimes, we may be under a duty to disclose or share your information to law enforcement agencies, courts, regulators and government authorities to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements or to protect the rights, property, or safety of our clients, or others.
TRANSFER OF YOUR INFORMATION OVERSEAS
We are part of an international group of companies. We also work with third party service providers in different countries (for example, web hosting, helpdesk software providers, payment processors). Therefore, your information may be transferred outside of the European Economic Area (EEA) and stored, or processed in other countries (including Japan, Australia and USA), as part of our business operations.
To ensure that your data is adequately protected when it is transferred, we have put in place appropriate safeguards (generally, either the Standard Contractual Clauses or the EU-US Privacy Shield) that comply with the law on data transfers. For more information on the appropriate safeguards in place, please contact us at the details below.
As part of the Rakuten Group, Rakuten Fits Me relies on the Rakuten Group Binding Corporate Rules to safeguard international data transfers within our group of companies.
SECURITY AND RETENTION OF YOUR PERSONAL INFORMATION
Security: We implement technical and organisational security measures to protect your information against misuse, loss, unauthorised access, and disclosure. However, you should note that sending information via the Internet is not 100% secure, so we cannot guarantee the security of any information that you send to us via the Website, the Fit Recommendation Tools, or by email or other internet communication method.
Retaining your information: We only retain your information for as long as we need it to provide our Services to you, or as long as is required under our contract with you, or as long as we are obliged to keep it to comply with laws or regulations.
CONTACT, DATA PROTECTION OFFICER, AND COMPLAINTS
Contact us: If you would like to contact us to discuss the way in which your personal data is used, please contact email@example.com.
Complaints: We aim to resolve all of your concerns about privacy. However, you always have the right to lodge a complaint with your own data protection authority, or with the Information Commissioner, which is the UK’s data protection authority. You can find contact details here: https://ico.org.uk.
If we have your contact details, we will notify you of the changes. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).