Effective Date: June 19th, 2020

This privacy policy (as amended from time to time, the “Privacy Policy”) describes our policies and procedures on the collection, use and disclosure of data obtained through your access to and use of the services available on the Application and Website (the “Application”) operated by ChangeRoom, 40 Cimarron Crescent, Ottawa, Ontario, Canada (“ChangeRoom”). The use of the Application is governed by the Terms of Use. ChangeRoom prepared this Privacy Policy to demonstrate our commitment to ensuring the privacy and security of the data that you share with us in accordance with our obligations under the applicable laws, rules and regulations. ChangeRoom is committed to fully comply with the Canadian Regulatory Laws. By accessing the Application or using our services you agree to accept and be bound by the current version of this Privacy Policy. In case you do not agree to the current version of this Privacy Policy, you are not authorized to continue accessing the Application or using our services.

ChangeRoom Sizing “the App” provides a sizing recommendation widget “the Service” to merchants who use Shopify to power their stores. This Privacy Policy describes how personal information is collected, used, and shared when you install or use the App in connection with your Shopify-supported store.

Personal Information the App Collects

When you install the App, we are automatically able to access certain types of information from your Shopify account: shop information, product related data such as the image and order data.

Additionally, we collect the following types of personal information from you and/or your customers of 16 years of age and above once you have installed the App: Information about you and others who may access the App on behalf of your store, such as your name, address, email address, phone number, and billing information; Information about individuals who visit your store, such as their IP address, web browser details, time zone, sizing data including age, weight, height and bra size and information about the cookies installed on the particular device.

We collect personal information directly from the relevant individual, through your Shopify account and using the following technologies: “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

How Do We Use Your Personal Information

We use the personal information we collect from you and your customers in order to provide the Service and to operate the App. This information will help us provide accurate recommendations to your customers.

Sharing Your Personal Information

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Behavioural Advertising As described above, we use your Personal Information to provide you marketing communications we believe may be of interest to you.

Your Rights If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

Data Retention

When you place an order through the Site, we will maintain your Order Information for our records for 90 days unless and until you ask us to delete this information.

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Data Storage, Security And Usage

Your personal data is stored either in our database or in those of our service providers, located in the Amazon Web Services. We maintain appropriate physical, electronic and procedural safeguards to protect our System, including firewalls, individual passwords and encryption and authentication technology, and take all other necessary and adequate administrative, organizational, technical, personnel, and physical measures to safeguard the same against unauthorized or unlawful processing and use, accidental loss or destruction or damage, theft, disclosure, or modification and to ensure its integrity. Please note, however, that data transported over an open network, such as the Internet or email, may be accessible to anybody. We cannot guarantee, and are not responsible for, the confidentiality of any communication or information transmitted via such open networks. When disclosing any Data via an open network, you should consider that it is potentially accessible to others, and consequently, may be collected and used by others without your consent. In particular, while individual data packets are often encrypted, the names of the sender and recipient are not. Even if both the sender and recipient are located in the same country, data may be transmitted via such networks to other countries regularly and without controls, including countries that do not afford the same level of data protection as Canada. Your Data and Information may be lost during transmission or may be accessed by unauthorised parties. We do not accept any liability for direct or indirect losses as regards the security of the Data and Information during its transfer via Internet.

ChangeRoom will not use your personal Data for marketing purposes, including the distribution of promotion emails, and will not sell, rent or otherwise make available any Data submitted by users to any third parties without the relevant user’s consent, unless allowed under this Privacy Policy or required by law. You authorise ChangeRoom to de-identify your Data and subsequently to copy, process, use, publicly disclose and distribute the Data in anonymized form for academic and statistical purposes. Such anonymized Data shall no longer be considered as “personal data”. You authorise ChangeRoom to receive, review and store technical data (including crash reports) retrieved from the devices you are using to access the Application. We reserve the right to disclose Data to the extent we reasonably believe it is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce the Terms, including investigations of a potential violation thereof, (iii) detect, prevent or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or to (v) protect the rights, property or safety of ChangeRoom, its users and the public. Please note that ChangeRoom uses encryption software that may be subject to export control regulations. The Application may contain links to Applications or materials that are not operated by ChangeRoom. Such other Applications are not subject to this Privacy Policy and ChangeRoom is not responsible in any way for the content or accuracy of such Applications or for the policies applied to the treatment of personal data and information. Connecting to or otherwise accessing such Applications is at your own risk.

We recommend that you read the policies used by these Applications, and check how these Applications protect your personal data and information and whether they are trustworthy. This Privacy Policy shall in all respects be governed by Canadian substantive law. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Ottawa, Canada and you consent to such jurisdiction of and venue in such courts and waive any objection as to inconvenient forum. We may revise this Privacy Policy from time to time. The most current version will be available at our Application (www.changeroom.io). The revised Privacy Policy shall become effective from the date of its publication on the Application.