CurveTips B.V. - Privacy Policy for CurveTips Fashion Recommendation Services

Last Updated 2018-05-15

This Privacy Notice sets out the basis on which we will process the personally identifying information (‘Personal Data’) that we collect and receive from and about users of our fashion recommendation services.

We deliver these services through:

  • Our own websites (www.curvetips.com, www.dressadvisor.com)
  • Retail partner websites which embed our fashion recommendation services (typically named: curvetips.[Retailer’s URL] - ie: curvetips.ullapopken.com, curvetips.ullapopken.de, curvetips.ullapopken.nl
  • In store to customers who use use our in-store kiosks or interact with our service robots
  • Through CurveTips branded email, chatbot and social media channels

Together these channels are called the “Sites”.

Our privacy commitments

  • We will only collect, keep, use and share Personal Data for legitimate business purposes that we explain here below, or if we’re legally required to do so.
  • We will be as clear and open as we can with you on what Personal Data we collect and how it will be processed.
  • For as long as we maintain records of your Personal Data, we will keep it up to date and protect it with appropriate safety measures.

Website Visitors & Registered Members

Data Collection

We collect the following Personal data from or about you as a CurveTips website user or a registered member:

  • Personal Data Collected Directly from you through the registration process for our personalized styling advice service: your name, email address, phone number, postal address, gender, age and information about your body shape and measurements including basic body-shape, how you would like certain body characteristics to appear and measurements if you choose to provide them. Our legal basis for the collection and processing of this data is the provision to you of personalized fashion and styling recommendation services to identify clothing that flatters your unique body shape..
  • Personal Data Collected Automatically from the use by you of the Sites. The data transmitted from your browser includes your IP address, the date and time of the visit the pages accessed, the access status/HTTP status code, your browser, your operating system and interface, as well as the language and version of the browser software. The legal basis for collecting and processing this personal data is to be able to operate the Sites and provide you with access to the pages you wish to access.
  • Personal Data received Indirectly through our partners which enables us to create and store a record of your purchase history. The legal basis for collecting and processing this personal data is our legitimate interests in knowing more about our customers and their shopping preferences in order to better advise them of .

Data Uses

We use your Personal Data:

  • To provide a shopping recommendations based on an items appropriateness for your body shape, style and color and fit preferences.
  • To contact you with marketing messages which you have requested or agreed to receive from us (for example a weekly curated list of items that flatter your body);
  • To contact you with feedback requests and surveys (for example relating to an item you purchased and if you liked it and felt the advice we gave was appropriate and accurate);
  • to provide you with bespoke website content (for example by identifying which items on a particular page are best for your body shape);
  • to gain insight into your behaviour and preferences (for example by analysing the website pages you visit);
  • to create bespoke marketing messages (for example by analysing the click throughs on our Sites);
  • to re-target our website visitors with relevant marketing messages (for example by using cookies hosted on our Sites);
  • To collect site statistics.
  • To analyse the purchase history of our customers and the way our customers use the Sites.

Cookies

We use cookies (small text files which are transferred to your browser by the Sites to identify data traffic patterns, personalise contents and support security. The cookies we use are described in more detail in our cookie statement. They do not provide any information which might disclose the identity of a specific person but they may potentially identify your computer, your browser and your internet settings. You may change the storing of cookies in your browser settings at any time by selecting the function “accept no cookies”. However, disabling essential cookies may result in you no longer be able to receive the style advice and fashion tips, as well as other functionality of the Sites.

Google Analytics

Google Analytics, a web analytics service provided by Google, Inc. (“Google”) also places cookies on your computer, to enable Google to provide us with activity reports relating to the Sites. Google uses this data only to provide us with information on how users use the Sites and does not associate your IP address with any other data held by Google. The information generated by Google cookies about your use of the platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. You may refuse these cookies by selecting the appropriate settings on your browser or by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.

Data Sharing

CurveTips will not sell your information. CurveTips works with fashion retailers who embed the service on their website, apps or stores. If you registered with CurveTips as a function inside a specific retailer’s property, we will share psudoanonomized user identification including name, email and loyalty card number with the retailer to enable tracking of sales and items purchased. This enables us to improve our clothing recommendations by considering items you have looked at, or already own when recommending clothing. This sharing does not give the retailer permission to add you to marketing and mailing lists. We will not share your information with any other third party except as stated in this Privacy Notice or as required to operate the Sites, provide our services to you and administer your account.

Social Media

We will share your Personal Data with social media sites to enable them to provide marketing messages that you have agreed to receive from them. The social media sites we share your Personal Data with as at the date of this Privacy Notice and their respective privacy statements are:

  1. Facebook,. https://www.facebook.com/privacy/explanation
  2. Hootsuite, https://hootsuite.com/legal/privacy

USERS OF CURVETIPS IN-STORE KIOSKS OR FASHION SERVICE ROBOTS

Data Collection

We collect the following Personal data from or about you as a CurveTips in-store kiosk or Fashion Recommendation Social Robot user:

  • Personal Data Collected Directly from you through the registration process for our personalized styling advice service: your name, email address, phone number, postal address, gender, age, loyalty card number, and information about your body shape and measurements including basic body-shape, how you would like certain body characteristics to appear and measurements if you choose to provide them. If you use a social network like Facebook to login, we will receive your Name, email and public profile information. Our legal basis for the collection and processing of this data is the provision to you of personalized fashion and styling recommendation services to identify clothing that flatters your unique body shape..
  • Personal Data Collected Automatically from the use by you of the Kiosks or Social Robots. The data transmitted from the Kiosk or Social Robot includes the date and time of the interaction and the pages viewed, as well as clothing you looked at. The legal basis for collecting and processing this personal data is to be able to operate the Kiosks and Robots to provide you fashion recomendationation and shopping advice.
  • Personal Data received Indirectly through our partners which enables us to create and store a record of your purchase history and personalized your service. The legal basis for collecting and processing this personal data is our legitimate interests in knowing more about our customers and their shopping preferences.

Data Uses

We use your Personal Data:

  • To provide a shopping recommendations based on an items appropriateness for your body shape, style and color and fit preferences.
  • To contact you with marketing messages which you have requested or agreed to receive from us (for example a weekly curated list of items that flatter your body);
  • To contact you with feedback requests and surveys (for example relating to an item you purchased and if you liked it and felt the advice we gave was appropriate and accurate);
  • To analyse the purchase history of our customers and the way our customers use the Kiosks and Social Robots.

Data Sharing

CurveTips will not sell your information.

For customers using kiosks or service-robots inside a retail store, CurveTips will share minimal identifying information of name and email with the retailer in order to verify identity to tell the retailer which items were recommended to you, and to confirm purchase history. We encrypt and pseudonymize this information so that it cannot be directly used.

We will not share your information with any other third party except as stated in this Privacy Notice or as required to operate the Kiosks and Social Robots, provide our services to you and administer your account.

SOCIAL MEDIA FOLLOWERS

Data Collection

We receive the following Personal Data about you if you follow one of our social media accounts: Your account name, gender, general interests, location, age, and profile picture. Our legal basis for processing this data is our legitimate interest in providing social media and marketing content that is of interest to our followers on social media.

Data Uses

We use this Personal Data:

  • to provide bespoke social media content and fashion recommendations (for example by analysing your general interests);
  • to create targeted advertising across all our social media channels (for example by analysing responses to posts and existing advertisements);
  • to find out more about our digital community (for example by analysing the age ranges of our followers).

Data Sharing

CurveTips will not sell your information. We will not share your information with any third party except as stated in this Privacy Notice or as required to operate the Sites, provide our services to you and administer your account.

DATA PROCESSORS

We use third party processors to collect, export, process and store Personal Data on our behalf. The processors we use currently are the following:

  1. Cloud Data Storage and Processing
    1. Amazon Web Services: https://aws.amazon.com/. Our data is located in Europe, and covered by Amazon’s Standard European Clauses. AWS is Privacy Shield Certified. https://aws.amazon.com/privacy/
  2. CRM Tool for email delivery and management:
    1. Mailchimp. https://kb.mailchimp.com/accounts/management/about-mailchimp-the-eu-swiss-privacy-shield-and-the-gdpr
  3. CRM Tool for customer service and internal communication:
    1. Hubspot, located in the US, but GDPR compliant. https://www.hubspot.com/data-privacy/gdpr/product-readiness
    2. Slack, located in the US. Privacy Shield Certified. https://slack.com/gdpr
  4. Cloud Storage:
    1. Google Drive, https://cloud.google.com/security/compliance/eu-data-protection/
    2. Microsoft Exchange, https://privacy.microsoft.com/en-GB/privacystatement
    3. Dropbox,. https://www.dropbox.com/help/security/data-transfers-europe-us
  5. Social Media Platform:
    1. Facebook, some data centres located in the U.S. Privacy Shield Certified. https://www.facebook.com/privacy/explanation
  6. Survey Tool:
    1. Survey Monkey, located in the U.S. Privacy Shield Certified. https://www.surveymonkey.com/mp/policy/privacy-policy/
  7. Web Management Tools
    1. Google Analytics, located in the U.S. Privacy Shield Certified. https://www.google.com/policies/privacy/
    2. eConda, located in Germany and certified by TUV for Certified Data Protection.

International Data Transfers

We use data processors located outside the European Economic Area only after taking such steps as are required to ensure that Personal Data they process on our behalf receives protection equivalent to that provided in the EEA. Our processors are either certified as compliant with the EU-U.S. Privacy Shield Framework where they are located in the USA or have entered into an agreement with us containing the model clauses approved by the European Commission as providing contractual protection equivalent to that provided by the data protection regulations applicable in the EEA. To learn more about the Privacy Shield program, please visit www.privacyshield.gov.

Data Security

  • We maintain technical and physical safeguards that are designed to protect the security and integrity of your Personal Data, and to guard it against accidental or unauthorised access, use, alteration or disclosure to unauthorised third parties. These measures include device encryption, firewalls and virus checking procedures.
  • Where we keep Personal Data files on local devices these devices are protected and accessible only to authorised CurveTips employees.
  • We regularly review our security systems to ensure that your Personal Data remains safe and secure.
  • Duration of Storage

    We will maintain records of your Personal Data for as long as you remain:

  • a registered user of any of our Sites;
  • a registered subscriber to our mailing lists;
  • have visited a site with CurveTips services embedded in the last 60 months; or
  • for as long as is necessary to provide our services to you.

Your Rights in Relation to Personal Data

  • You can update your account preferences, registration details or unsubscribe from our newsletters and marketing communications at any time by clicking this link, by following the link in the footer of the last email you received from one of our brands (“Update your subscription preferences” or “Unsubscribe”) or by sending a request to our Customer Services team at info@curvetips.com
  • You have the right to update and correct the personal information on your account. Your account can be accessed here. You also have the right to request from us all personal information that we hold that relates to you, to request restriction of the processing of that data and to request that we delete that data. Where allowed by applicable law there may be an administrative charge for supply of copies of data and we may also require you to provide us with appropriate identification before we comply with this request. You also have the right to object to our continued processing of your personal data and can delete your account here.
  • If you have a complaint about the way in which we use your personal information you have the right to complain to the Dutch Data Protection Authority (Dutch DPA) at https://autoriteitpersoonsgegevens.nl/
  • You can contact us with questions about the personal information we hold about you using the contact information provided in the contact us section of this privacy notice.

Changes to our Privacy Notice

We will update this Privacy Notice from time to time to reflect changes in our business. All such changes will be posted to the Sites and if we consider it to be appropriate we will notify subscribers of any material changes by e-mail.

Contacting us

CurveTips B.V. is the Data Controller in respect of any Personal Data that you submit to us or that we collect from or about you. We are a limited company registered in The Netherlands (registered KvK no. 62952439) with registered offices at Schimmelpenninckstraat 8, 2316 DT Leiden The Netherlands

If you would like to know what information we hold about you or if you have any other queries or complaints in relation to this Privacy Notice, or our Sites, our contact details are as follows:

CurveTips BV. Schimmelpenninckstraat 8, 2316 DT Leiden The Netherlands
info@curvetips.com
+31 620 607 695
CurveTips Logo

CurveTips B.V.

Schimmelpenninckstraat 8
2316 DT Leiden The Netherlands

info@curvetips.com+31 620 607 695

Copyright © 2015 CurveTips B.V.

Privacy statement: English | Dutch | French | German