Privacy Policy

GOODSIZE INC. is a Delaware Corporation, located at 251 Little Falls Drive, Wilmington, DE 19808. Goodsize inc , is the owner and operator of the Avaturn platform («Platform»),website (the «Site») and services ( «Services» )

This Privacy Policy describes the privacy practices of Goodsize Inc. in connection with Avaturn services and Avaturn.me website (the «Site»).Welcome to Goodsize’s Privacy Policy!

If you decide not to read this entire Privacy Policy, we want you to walk away with a few key points about Goodsize’s privacy practices:

Avaturn is 3D body scanning for creating virtual body avatars.

Due to the limited processing resources available on mobile devices, we use third-party cloud providers – specifically, Google Cloud Platform and Amazon Web Services – to process and edit photographs and videos.

Avaturn only uploads to the cloud the video and photos that you specifically record using the Platform.

Videos and photos are encrypted using a key stored locally on your mobile device.

We do not use the videos you provide when you use the avaturn for any reason other than to provide you with the 3D body scanning functionality of the avaturn or to use anonimized data internally for the technology improvement.

If you have any questions about our privacy practices, please email at hello@avaturn.me.

Here’s more on our privacy practices. Individuals located in the European Economic Area should also read our Notice to European Users below.Personal Information We Collect

When you use the services, we may collect information about you, including:

Video and TrueDepth data you provide when you use the avaturn, via your camera (further, video will mean video and TrueDepth data). We obtain only the specific video you record using the avaturn; we do not record any video besides scanning screen even if you grant us your access for that.

avaturn usage information, such as information about how you use the avaturn and interact with us, including your preferred language, the date and time when you first installed the avaturn and the date and time you last used the avaturn.

Social media information, if you choose to login to the avaturn via a third-party platform or social media network (for example, Facebook), or otherwise connect your account on the third-party platform or network to the avaturn. We may collect information from that platform or network, such as your social media alias, first and last name, number of «friends» on the social media platform and, if depending on your Facebook or other network settings, a list of your friends or connections (though we do not use or store this information). Our collection and processing of the information we obtain from social media platforms is governed by the requirements these social media platforms impose on us in their relevant terms and conditions.

Email address, if you choose to sign up with your email address, or if you choose to login to the avaturn via a third-party platform or social media network we will get your email address from this third-party platform or social media network.

Device data, such as your computer and mobile device operating system type and version number, manufacturer and model, device ID, push tokens, Google Advertising ID, avaturnle ID for Advertising, browser type, screen resolution, IP address (and the associated country in which you are located), the website you visited before visiting our Site; and other information about the device you are using to visit the avaturn and Site.

Online activity data, such as information about your use of and actions on the avaturn and the Sites, including pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and certain third parties (e.g., online advertising networks and their clients) also may collect this type of information over time and across third-party websites and mobile applications. This information may be collected on our Site using cookies, browser web storage (also known as locally stored objects, or «LSOs»), web beacons, and similar technologies. We may collect this information directly or through our use of third-party software development kits («SDKs»). SDKs may enable third parties to collect information directly from our avaturn.

How We Use Your Personal Information

To operate and improve the avaturn:

Enable you to use the avaturn’s features;

Establish and maintain your account, if you choose to login to the avaturn using your social media account;

Communicate with you about the avaturn, including by sending you announcements, updates, and security alerts, which we may send through a push notification, and responding to your requests, questions and feedback;

Provide technical support and maintenance for the avaturn; and

Perform statistical analysis about use of the avaturn (including through the use of Google Analytics).

To send you marketing and promotional communications. We may send you marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or avaturnropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes.How We Share Your Personal Information

We do not disclose user videos to third parties other than to our cloud providers (Amazon Web Services and Google Cloud Platform) when uploading encrypted images to provide the 3D body scanning features of the avaturn, or to our service providers for the purposes of data annotation for the technology improvement (in this case user data is not linked to the account). We may share your non-photograph information in the following circumstances:

Affiliates. We may share avaturn usage information with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may share your personal information with services providers that perform services on our behalf or help us operate the avaturn (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Third-party platforms and social media networks. If you have enabled features or functionality that connect the avaturn to a third-party platform or social media network (such as by logging into avaturn or Site using your account with the third-party, providing your API key or similar access token for the avaturn to a third-party, or otherwise linking your account with the avaturn to a third-party’s services), we may disclose the personal information that you authorized us to share (such as when you elect to upload a photograph to your social media account). We do not control the third-party platforms’ use of your personal information, which is governed by that third party’s privacy policy and terms and conditions.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.Compliance with Law

We may be required to use and share your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.Your Choices

In this section, we describe the rights and choices available to all users. Users who are located within European can find additional information about their rights below.

Opt out of marketing communications and other push notifications. You may opt out of marketing-related communications and other notifications we may send you via push notification by changing the settings on your mobile device. If marketing communications and other notifications are sent via email you may opt out of them by sending ‘Unsubscribe’ at hello@avaturn.me.

Device permissions. You may revoke any permissions you previously granted to us, such as permission to access your camera or camera roll, through the settings on your mobile device.

Cloud processing. You may request that we remove your information, including videos, by clicking the «Delete your user» button in the «Legal Info» section of the avaturn Settings on your mobile device.

Cookies & Browser Web Storage. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Site may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the avaturn to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to use the avaturn by designating it as required at the time of collection or through other appropriate means.

Third-party platforms or social media networks. If you choose to connect to the avaturn via a third-party platform or social media network, such as by using Facebook login, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the avaturn using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. For example, you may access and change your settings through the Facebook settings page for avaturns and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.Other Sites, Mobile avaturnlications and Services

The avaturn may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.Security Practices

We use commercially reasonable security practices to help keep the information collected through the avaturn secure and take reasonable steps to verify your identity before granting you access to your account (if you have an account with us). However, Goodsize Inc cannot ensure the security of any information you transmit to Goodsize or guarantee that information on the avaturn may not be accessed, disclosed, altered, or destroyed.

Please do your part to help us. You are responsible for maintaining the confidentiality of your login information and device identifiers, and for controlling access to communications between you and Goodsize Inc, at all times. Your privacy settings may also be affected by changes the social media services you connect to Goodsize Inc make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.Retention

We may store anonimized video information for the technology improvement purposes on our cloud provider (Amazon Web Services and Google Cloud Platform) for as long as necessary to fulfill the purposes we have set out in this Privacy Policy. With respect to non-video information that we may collect, we will retain such information in a personally identifiable format only for as long as necessary to fulfill the purposes we have set out in this Privacy Policy.

You may also ask that we delete your information by contacting us at hello@avaturn.me..Cross-Border Data Transfers

We store the information we collect in connection with the avaturn on Amazon Web Services and Google Cloud Platform. Your personal information may be accessed by our service providers in other locations outside of your state, province, or country. Your device ID (and general avaturn usage information) may also be accessed by the Company’s technical support team in other locations outside of your state, province, or country. We rely on the Privacy Shield, as described below, for transfers of data to Goodsize Inc. in the United States.EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Goodsize Inc. is the US entity that publishes and hosts the avaturn. Goodsize Inc. complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Goodsize Inc. has submitted its certification to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.

Goodsize Inc. may transfer your personal information to third parties as described in this Privacy Policy. Goodsize Inc. maintains contracts with its third-party service providers restricting their access, use and disclosure of personal information in compliance with our Privacy Shield obligations. Goodsize Inc may be liable if these third parties fail to meet those obligations and we are responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Goodsize Inc commits to resolve complaints about our collection or use of your personal information. European individuals with inquiries or complaints regarding our Privacy Policy should first contact Goodsize Inc at hello@avaturn.me.. Goodsize Inc has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. If neither Goodsize Inc nor JAMS resolves your complaint, you may have the ability to engage in binding arbitration through the Privacy Shield Panel. Additional information on the arbitration process is available on the Privacy Shield website at www.privacyshield.gov.

Goodsize Inc may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. The Federal Trade Commission has jurisdiction over Goodsize Inc’s compliance with the Privacy Shield. Goodsize Inc’s commitments under the Privacy Principles are subject to the investigatory and enforcement powers of the Federal Trade Commission.Children

The avaturn is not directed at children under the age of 13, and our Terms of Use do not allow children under 13 years of age to use the avaturn.Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the avaturn. We may, and if required by law, will, provide notification of changes in another way that we believe is reasonably likely to reach you, such as through the avaturn.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the avaturn (or as otherwise indicated at the time of posting). In all cases, your continued use of the avaturn after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to hello@avaturn.me.Notice to European Users

The information provided in this «Notice to European Users» section applies only to individuals who reside in Europe.

Personal information. References to «personal information» in this Privacy Policy are equivalent to «personal data» governed by European data protection legislation.

Controller and EU Representative. Goodsize Inc. is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Processing purpose. Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information" Legal basis

To operate and improve the avaturn Processing is necessary to perform the contract governing our provision of services in connection with the avaturn, or to take steps that you request prior to signing up for the avaturn. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the services you access and request in connection with the avaturn.

To send you marketing and promotional communications, To display advertisements to you, For compliance, fraud prevention and safety, To create anonymous, aggregated or de-identified data These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Compliance with Law Processing is necessary to comply with our legal obligations.

With your consent Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the avaturn.

Your rights

European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.

Correct. Update or correct inaccuracies in your personal information.

Delete. Delete your personal information.

Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

Restrict. Restrict the processing of your personal information.

Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to hello@avaturn.me or our postal address provided above.

If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Notice to California Residents

We are required by the California Consumer Privacy Act of 2018 («CCPA») to provide to California residents an explanation of how we collect, use and share their personal information, and of the rights and choices we offer California residents regarding our handling of their personal information.

We do not sell personal information. As we explain in this Privacy Policy, we use cookies and other tracking technologies to analyze Site and avaturn traffic and use, and to facilitate advertising.

In addition to disclosures of personal information to our service providers and professional advisors, for compliance, fraud prevention and safety, and in connection with a business transfer, as described in the «How We Share Your Personal Information» section of the Privacy Policy, the following chart further describes our privacy practices with respect to the personal information of our California consumers.

Personal information we collect CCPA-defined categories Sources of personal information Purposes for which we may collect and use the personal information Data Sharing

Videos Physical description You To operate and improve the avaturn Shared with third-party platforms (e.g., social media networks) at your direction, shared with cloud service providers (i.e., Google Cloud Platform and Amazon Web Services)

avaturn usage information Online identifiers, Internet or network information, Inferences You, Automatic collection To operate and improve the avaturn, to send you marketing and promotional communications Shared with affiliates that provide services to us

Purchase history Commercial information, Online identifiers The avaturnstore provider through which you purchased your subscription (i.e., Google or avaturnle) To operate and improve the avaturn None

Social media information Identifiers, Online identifiers Third-party platforms To operate and improve the avaturn Shared with third-party platforms (e.g., social media networks) at your direction

Device data, Online activity data Online identifiers, Internet or network information, Inferences You, Automatic collection To display advertisements to you Collected directly by advertising partners

California Residents’ Privacy Rights

Except as excluded from the scope of this notice above, the CCPA grants California residents the following rights.

Information. You can request information about how we have collected, used and shared and used your personal information during the past 12 months. We have made this this information available to California residents without having to request it by including it in this notice, in the above chart.

Access. You can request a copy of the personal information that we maintain about you.

Deletion. You can ask us to delete the personal information that we collected or maintain about you.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

You are entitled to exercise the rights described above free from discrimination.

How to Submit a Request

To request access to or deletion of personal information:

email hello@Avaturn.me

Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We may attempt to verify your identify by asking you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.

Authorized agents. California residents can empower an «authorized agent» to submit requests on their behalf. We will require the authorized agent to have written authorization confirming such authority.