In order to use Snapfeet service, You have to provide us with some of Your personal data. Therefore, according to Article 13 of Italian legislative Decree 196/2003, we are required to provide you with the following information.
PURPOSES OF PERSONAL DATA PROCESSING
Snapfeet is a software service offered by Trya that works as a personal shopping assistant to help You to find and buy, from our Partner Shops, the shoes that best fit Your feet dimensions and your preferences (“Virtual Fit”).
Snapfeet may be used only through dedicated client applications provided by Trya (smartphone App and other possible client applications for other devices, if made available).
By elaborating 2D pictures (that You will have to take with Your client device according to the provided instructions), Snapfeet will create a 3D model of Your feet and calculate their relevant dimensions (length, ball girth, instep girth, and possibly other dimensions in the future): – in order to help you to choose (and also to suggest to You) the shoe sizes and models from our Partner Shops that best fit the dimensions of your feet and Your personal preferences, and – in order to help You to benefit from possible discounts and promotions offered by our Partner Shops (always concerning shoe models and sizes that may fit Your feet dimensions and Your preferences).
Your preferences will be obtained from Your indications in the dedicated area of Your user profile, as well as from Your previous purchases in our Partner Shops.
TYPES OF DATA PROCESSED
The types of personal data processed will be:
- i) 2D Pictures, ii) 3D models and iii) dimensions of Your feet;
- common personal data (name, address, email, phone, date of birth, gender, nationality);
- personal preferences relevant to shoe shopping (like sport activity, preferred kinds of shoes and so on) and location data, where relevant to shoe shopping (f.e., to provide you with shopping suggestions related to Partner Shops near to You);
- data related to purchases made by You in Partner Shops (date of purchase, model, size, price paid).
MODALITIES OF PERSONAL DATA PROCESSING
Your personal data will be processed using electronic systems and applying a rationale strictly related to the purposes of processing, in order to protect data security and confidentiality.
All communications between Snapfeet client applications and Snapfeet servers, as well as between Snapfeet servers and Partner Shops’ infrastructures, will be encrypted.
All servers used to provide Snapfeet services are located in the European Union.
Data of type A above will be processed separately from data of types B-C-D, by use of appropriate technical means and specific authorization profiles so that data of type A can be processed anonymously when a specific data processing does not require identification of data subjects.
When You start shoes purchase process from any Partner Shop, Snapfeet sends to the Partner Shop only data of type A-iii (dimensions of Your feet), associated with an anonymous ID provided by the Partner Shop itself (via QR code, deep link or other equivalent technical means) in order to help you to choose the right size and model. The Partner Shop will not receive any data of type B-C from Snapfeet but, if needed, it will autonomously collect them from You under its sole responsibility. The Partner Shop will send back to Snapfeet only data of type D, associated with the same ID above.
DATA RETENTION PERIOD
Your personal data shall be processed for the time strictly required to achieve the purposes for which it was collected. Once the need for processing has terminated, it will be kept for one year to detect and solve possible errors or inaccuracies of Snapfeet 3D modeling software also on the basis of Your feedback. You may authorize us to keep Your personal data for a further period of 5 years, in order to allow You to take advantage of possible improvements and new features of the Snapfeet software platform.
In any case, after one year (or after the further period of 5 years, if authorized by You), only data of type A will be kept in anonymized form for an undetermined period of time, as test data to develop improvements and new versions of the Snapfeet software platform, while other types of data will be destroyed.
OBLIGATORY OR VOLUNTARY NATURE OF PROVIDING THE REQUESTED DATA
Since Snapfeet is specifically intended and conceived as a personal shoe shopping assistant, to make it work properly we need You to provide Your feet data as well as Your preferences, Your previous shoe purchases data and Your location data (data of types A-B-C-D) so if you are not willing to provide such data, we cannot provide You with the Snapfeet service.
SCOPE OF DATA COMMUNICATION
Employees and collaborators appointed by Trya as persons in charge of processing may acquire knowledge of your data in order to provide You with the Snapfeet service and to send advertising materials or else to perform market or commercial communication surveys. Besides Partner Shops, Your personal data may be communicated to third parties to meet legal obligations, to execute orders coming from public authorities legitimated to do so, or to enforce or defend a right in the courts. Your personal data will never be disseminated.
You have the right to access personal data and the other rights provided by Section 7 of Legislative Decree no. 196/2003, as shown here below.
DATA CONTROLLER AND DATA PROCESSOR
Data Processor, limited to the security and availability of the computer systems (servers) used by Trya and provided by Amazon AWS, is Amazon EU Sarl, Rue Plaetis 5, L-2338 Luxembourg, according to the terms and conditions available from time to time at www.aws.amazon.com Amazon AWS servers are content agnostic, so Amazon will not access Your personal data. A complete list of data Processors, will be readily available from Trya by sending an email to the above email address.
LEGISLATIVE DECREE NO. 196/2003 – SECTION 7
(Right to Access Personal Data and Other Rights)
- A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
- A data subject shall have the right to be informed:
- of the source of the personal data;
- of the purposes and methods of the processing;
- of the logic applied to the processing, if the latter is carried out with the help of electronic means;
- of the identification data concerning data controller, data processors and the representative designated as per Section 5(2); and
- of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
- A data subject shall have the following rights:
- to obtain updating, rectification or, where interested therein, integration of the data;
- to obtain erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
- to obtain certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
- A data subject shall have the right to object, in whole or in part, a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.