Products Customers Company Contact Book a demo Privacy Policy Our mission is to help shoppers find footwear that fits! Our products and services – including our 3D Foot Scanner, Mobile app, in-store and online footwear recommendations, footwear discovery services, and others that link to this Privacy Policy – provide easy, accurate, and fast ways to find perfectly fitting footwear. When you use these services, you’ll share some information with us. Your information helps us on our mission to get folks into comfortable, well fitting, footwear, and we want to be upfront about that. So we have written this Privacy Policy to describe what information we use, how we use it, why we use it and whom we share it with. Our company name is Volumental AB (556912-4141) and we are located at Tegelbacken 4A, 11152 Stockholm, Sweden. We can be contacted at: support@volumental.com. How we work - Brand and retail partners Our services are generally provided to you through our footwear retail or brand partners. Volumental’s 3D Foot Scanners, for instance, are owned and operated by retail stores or footwear brands and our Mobile App may be integrated into our partners’ apps. In all cases, the name details of these retail stores or brands will be clearly identifiable in our apps. Some of your information is also collected by the retailer or brand who provided our service to you. This generally includes your name, email, 3D foot scan, foot measurements, and any profile information. We also collect some information about you from the retailer or brand, such as purchase history which helps improve our recommendations. This is all described in more detail in this Privacy Policy. Our apps will always inform you whether the retailer or brand is following this Privacy Policy or whether they are relying on their own Privacy Policy when collecting your information. If they rely on their own Privacy Policy, then we will tell you and make that Policy available in our app before information is collected. Information we collect There are three basic categories of information we collect: Information you provide Information we collect when you use our services Information we collect from the retailer or brand who provided the service Information you provide. When you use one of our services, we collect information that you provide us. For example, name, email, running habits such as long distance or short distance, sports position, preferred category of footwear, date of birth, and similar information related to you and your feet. Because footwear is generally categorized by gender, we also collect gender information so that we know which category of footwear for you to choose from. Most of our services include an ability to save a user profile allowing re-access of your information for future footwear shopping. If you create an individual or a family profile, then any information you provide within that profile will be stored by us. For example, you may choose to add your children’s information into your family profile alongside your profile. When you contact customer support or communicate with us in any other way, we’ll collect whatever information you volunteer or that we need to resolve your question. Information we collect from your use of our services. Our services will generate information about you when you use one of our services. For example, the service will generate a 3D foot scan if you complete a scan and will also generate information about how you’ve used the service. We might know, for instance, that you interacted with your 3D foot scan for a specific amount of time or that you got stuck somewhere through the process. Here is a full explanation of the categories of information we collect when you use our services: Images, photos and videos. These are required in order to generate your 3D foot scan. For instance, when using the Mobile App your device’s camera will be used to capture images of your feet which are used to generate your 3D foot scan. Data on physical foot characteristics. Once a 3D foot scan is generated then our services will use the 3D foot scan to generate measurements such as foot width, length, arch height, heel to toe length, instep height. Annotations. When using the in-store 3D Scanner, the store clerk may create annotated notes which reflect observations about your feet. This information can help when selecting a pair of shoes or when creating a custom footwear product. Usage information. We collect information about your activity through our services. For instance, this may include which functions in our apps you used, which pages were viewed, buttons you have selected, or whether there were any errors during your use of our service. Device Information. When using our services, for instance the Mobile App or when accessing your 3D scan online, we collect information from and about the devices you use. For example, we collect information about your hardware and software, such as the hardware model, operating system version, device memory, browser type, signal strength, language, and time zone, as well as information about your wireless and mobile network connections, such as IP address. This helps us understand if our service is having trouble with a particular phone model or operating system and to monitor and analyze trends and usage. We also collect information from device sensors, such as accelerometers, gyroscopes, compasses that help create the 3D foot scan on our Mobile app. Location. When you use our services, we may collect information about your location. With your permission, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, and Wi-Fi access points. Pressure information. Volumental’s 3D Foot Scanner may be integrated with a brand partner’s pressure mat located in the store. In such cases Volumental may also collect foot pressure data and related physical characteristic from the pressure mat. Information we collect from the retail or brand partner who provided you our service. We collect information about you from our retail or brand partners who provide you our services. The information we collect includes your history of footwear purchases and related data. For instance, we may collect data about which shoe styles you have previously purchased including purchase date, size, width, and price. This information helps us make and improve our footwear recommendations. How we use information What do we do with the information we collect? In short, we provide you with an awesome set of footwear fit and discovery services, that we relentlessly improve, to help you find footwear that fits. For personalized footwear discovery and recommendations. Your information, for instance 3D scan and previous footwear purchases, will be used to recommend footwear which you are interested in. We may also display to you a list of recommended footwear with explanations and visuals describing how each style of footwear fits you. To send you your results. If you input your email, we will send you a unique link to your 3D scan and measurements! Develop new features & improve existing ones. We constantly work to improve our services and create new ones that help get shoppers into footwear that fits! Just by using our services you help our development team improve our ability help shoppers. For example, we look at how your 3D foot scan and previous purchases match with others that have a similar shaped 3D foot scan. We do this with millions of 3D foot scans, and this allows our developers to improve our footwear recommendation algorithms which in turn helps others find footwear that fits. We’re always looking out for ways to improve our users’ experience with our services which is why we analyze and monitor how our services are being used. Knowing how you’ve used our products, including any issues you’ve run into, allows us to fix those issues quickly and improve the smoothness of the experience. Research. Weconduct research on the information we collect as it relates to how feet fit into footwear. For example, we compare foot shapes across the globe to learn about how foot shapes differ by region. We publish some of our findings in scientific journals such as Nature in an effort to increase human knowledge. We also work with industry bodies to help standardize footwear fit and sizing across the industry. Such research also allows us to increase the accuracy and relevancy of our footwear recommendations. To create a profile. If you choose to create a profile then the profile may be used in a variety of ways, either online or offline. For example, the next time you re-enter a store then you and a store clerk can gain quick access to your personalized footwear recommendations. If you have a family profile then you may also be able to check how your children’s feet have grown since the last visit. Marketing. If you have consented within one of our apps, the retail or brand partner who provided you our service may use your email to send you offers and footwear recommendations. Support. When you contact Volumental we may keep a record of communications and other contact information to help resolve issues promptly. Safety and security. We work continuously to enhance the safety and security of our services and to prevent unauthorized or illegal activity. Information we share Service providers. We use service providers who perform services on our behalf, for instance, we use Google Cloud Storage to safely store your information. These service providers allow us to better, and more securely, manage our data, distribute emails, conduct research and analysis. We have agreements with these third-party service providers to make sure your information is kept secure. These processing agreements include appropriate privacy and security protections as required by law, for instance, cross-border data transfer mechanisms. Service provider Cloud Storage Customer Support Providers Data Analytics Providers Data Management Providers Data Solution Providers Marketing Providers* Advertising Providers* Email Service Providers Purpose Data Storage Customer support Data analytics Machine learning and algorithms Research Email Marketing Advertising, Measurement, Pixel Email management e.g sending of 3D scans Region EEA EEA EEA EEA EEA EEA EEA EEA *marketing and advertising is conducted by the retail or brand partner who provides our service to you and only if you have consented. Information we share with the retail or brand partner who provided you our service. We share your information with the retail or brand partners who provide you our services. Our apps will always identify which retail or brand partner is collecting your information in addition to us. The information shared includes your 3D scan, associated measurements, name, email address, user profile including any notes, and basic meta data about your use of our service such as time of use and general location. The retail or brand partner may use your information for improvement to their footwear products, to create custom footwear you have ordered, to conduct research relating to footwear fitting, and marketing purposes when you have consented to such marketing. They may utilize service providers for these purposes. Our apps will always inform you whether the retailer or brand partner is collecting your information in accordance with this Privacy Policy or whether they are relying on their own Privacy Policy. If the partner relies on their own Privacy Policy, then we will tell you and make that Privacy Policy available in our app before information is collected. International transfers. Our service providers, or the retailer or brand partner who provided our service, may be located outside of the country where you live and they may not be in a country that provides the same level of data protection compared to the European Union. Whenever we share personal information outside the EU we make sure an appropriate transfer mechanism is in place. You can contact us at support@volumental.com for further information about the transfer mechanisms. Sale or transfer of business. We may transfer personal information to a purchasing entity in the event we sell or transfer all or a portion of our business or assets. Non-personally identifiable information. We may share non-personally identifiable information publicly. For example, we may share aggregate data that is anonymized and used in statistical analysis. Protection and management of your information Encryption & Security. We use a variety of security measures, including encryption and authentication tools to maintain the safety of your personal information in line with legal requirements. Additionally, we practice pseudonymization when processing your information. This means that we keep the information in a form that makes it difficult to identify you even while we are utilizing the information. How long will your data be held? We will hold and utilize the personal information whilst it is still needed for the purposes outlined in the “How we use your data” and “information we share” sections of this Privacy Policy. If we no longer need to use some aspects of your personal information, then we will remove or make inaccessible those aspects of your personal information. Once per year Volumental undertakes a periodic review of personal information and we pseudonymize, anonymize, or remove, personal information that is no longer necessary for such purposes. Using Volumental products and website together with third party products and services. Our services or website may provide links to third-party websites and apps. These sites and apps have their own privacy policies which we encourage you to review. We are not responsible for their content or the privacy practices of those websites or apps. Bases for using your information Under EU law, we are only allowed to process your personal information when a “legal basis” for the processing applies. At Volumental we typically rely on one of three legal bases when we process your information. Legitimate interests. We generally use your information because we have – or a third party has – a legitimate interest in doing so. For instance, we need your information to generate your 3D foot scan, provide customer support, or to improve our ability to recommend footwear. In defining “legitimate interest” it’s that our interests don’t outweigh your right to privacy. We conduct a balancing analysis when we rely on legitimate interest to make sure that our use of your information is proportional to your right to privacy. In practice, this means we only rely on legitimate interest when we think the way we are using your information doesn’t significantly impact your privacy, would be expected by you, or there is a compelling reason to do so. We explain our legitimate interests in using your information in more detail in the ‘How we use your information’ and ‘Information we share’ sections of this Privacy Policy. Consent. We sometimes use consent as the basis for processing. For example, we will ask the parents of children under 13, and sometimes for children under 16, to consent before 3D scanning the child’s feet or including their information in a family profile. We strive to be clear in our apps when we are relying on consent as the basis of processing. Legal obligation. We may be required to use your personal information to comply with the law, for instance when responding to a valid legal process. Your rights Below is a summary of your rights in relation to your personal information. Data portability. For any information we process pursuant to consent, you may request it to be sent to you in a structured, commonly used machine readable format. You may also request Volumental to transmit the data directly to another controller. Right to be forgotten (erasure). You have a right to have your information erased in specified situations. For example, where your data is no longer necessary for the purpose it was collected or where your consent has been withdrawn. Right of information and access. You may request a confirmation that Volumental holds data about you and to obtain a copy of that data. You may also request supplemental information about the processing which Volumental undertakes. Rectification. You may request Volumental to rectify inaccuracies within the personal information which Volumental holds about you. Restriction. In specified situations, you have a right to restrict the processing of your information. For example, where an objection to processing has been made and verification of the objection is being undertaken. Right to object. For certain processing of information, you have a right to object to the processing of your information. Right to lodge a complaint. You have the right to lodge a complaint with a supervisory authority. You may find your Member State supervisory authority here. Statutory or contractual obligations. The provision of your personal information to Volumental is not a statutory or contractual requirement. If you decline to provide your personal information, then our services may be unable to function to their full extent. You will be given on screen options to limit the amount of personal information you provide. California residents If you are a resident of California then the below information supplements the information in this Privacy Policy in accordance with the California Consumer Privacy Act of 2018 (“CCPA”) and other Californian privacy law. What personal information is collected? From where? And for what purpose? Please see the “Information we collect” and “How we use information” sections of this Privacy Policy. Disclosure of personal information. Volumental does not sell your personal information. The store or footwear brand which owns the Foot Scanner, or who provides our Mobile App to you, also collects and has access to your personal information. We may also disclose your personal information for a business purpose to one of our service providers who is required to keep your personal information confidential and may not use the personal information except for performing our contract with them. Such service providers include, for example, our Cloud and analytics service providers or where you have ordered a custom product that requires use of your 3D scan. For further information about disclosures, see the “Information we share” section of this Privacy Policy. In the preceding twelve months we have disclosed for a business purpose the categories of personal information described in the section “Information we collect”. Right of access to your personal information. You have the right to ask us for confirmation on whether we are processing your personal information and access to the personal information. This may include what personal information we collect, use, or disclose about you. Right to deletion. You have the right to ask us to delete your personal information. Right to Opt-out of "Sale". California law provides you with the right to opt-out of sales of your personal information. Please note that we do not sell your personal information. Right to Non-Discrimination. We will not discriminate against you, in terms of services that we offer, if you submit one of the rights requests listed above. Authorized Agent. You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, please ensure the agent is able to provide a signed document indicating their authorization to act on your behalf. Disclosure of third parties. California Civil Code Section 1798.83 permits California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for that third party's direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Exercising your rights. In order to submit a request regarding any of your rights, or for general questions, please contact support@volumental.com with the email address you used when using one of our services. If you cannot use such an email address then we will ask for further information in order to verify your identity. We will assess the request in relation to the requirements of the CCPA and respond within 14 days. Changes to this policy Applicable law and our practices change over time. If we decide to update our Policy, we will post the updated Policy on our website and make it available within the software of our products. We strongly encourage you to read our Policy and regularly check for any changes. This Policy was last modified in August 2021. Any questions? - Get in touch! Please send any questions you may have to our Data Protection Officer at privacy@volumental.com. Facebook Twitter Instagram LinkedIn © 2021 Volumental AB PRODUCTS Volumental Retail Scanner Volumental Mobile App Volumental Engage Customers COMPANY About Blog Careers Privacy Policy ADDRESS Tegelbacken 4A, 8TR 111 52 Stockholm Sweden Contact support