Last Updated: January 20th, 2025
This Privacy Policy describes how NetVirta, Inc. and its affiliates (“NetVirta,” “We,” or “us”) collect, use, and disclose your personal information where this Privacy Policy appears or is referenced, including through the Verifyt® mobile application (the “App”), the Verifyt® web plugin (the “Plugin”), the Verifyt website at http://www.verifyt.com and the NetVirta website at http://www.netvirta.com (the “Websites”), and any other websites operated by the brands and retailers that use the NetVirta Plugin(“Partners”).
By accessing the Websites, Partner websites where the Plugin is used, the App, or any service from which this Privacy Policy is referenced, you confirm that you have read, understand, and acknowledge the terms of this Privacy Policy, and you consent to the data collection, use, and disclosures described herein. For the purpose of European data protection laws, NetVirta acts as a controller in connection with certain personal information described in this Privacy Policy.
If you are a California resident, see Section 6 for information provided pursuant to the California Consumer Privacy Act.
We and our agents, vendors, and other service providers may collect, receive, and develop several categories of personal information about you depending on the nature of your interactions with us. For example, we may collect:
Contact Information and Other Identifiers.
We might collect your name, email address, account username and password, phone number, mailing address, and country of residence.
Commercial, Purchase, and Preference Information.
We may collect information about the products you purchase, consider, or shop for from our Partners, and information about your other transactions and preferences.
Device, Internet and Network Activity Information.
When you use our Websites or the App, we automatically collect certain information about your usage and device. This may include information about the browser, device and operating system you are using, device identifiers, and your IP address. We might collect information about the site you came from or the site you visit when you leave us. We may collect page interaction information and other electronic communication on the page (such as what search terms or other data you enter, and what products, content, or links you view and click on). If you use our App, we may also look at the date/time stamps when you access the App. We embed web beacons (also known as pixels) in the emails we send you to help us understand how you interact with those messages, such as whether and when you opened an email or clicked on any content within the email. We may engage or otherwise permit third parties to also collect information on our sites and apps in these ways.
Location Information.
The App offers certain location-based services to users who choose to participate.
If you choose to enable Bluetooth and Wi-Fi, or to opt into other geolocation functionality on our App and Websites, we (and our Partners) may collect, infer, and/or use your precise geolocation data. In some jurisdictions, your precise geolocation may be considered sensitive personal information. We do not use sensitive personal information for purposes of inferring characteristics about users.
Demographic Information.
We may collect information like your age and gender.
Physical Characteristics and Descriptions.
We may collect physical characteristics, descriptions, and photographs you submit of yourself through the App. If you use the App to create a 2D image or 3D model, we may: collect images that you take through your device’s camera (e.g., images of specific body parts for measurement and when a user selects full body scan, an obfuscated image of your face). We may receive depth map data from third party providers (for example, TrueDepth API technology from iOS devices, and 3D depth images from Android devices) to improve the accuracy of 3D model reconstruction and measurements, and to place AR wardrobe on your body in a realistic position and scale. We may collect or record other information about your physical characteristics, such as your height, waist size, inseam, cup, band, and other physical aspects. We do not share your body scans or measurements with any third parties.
Audio, Electronic, Visual, and Thermal Information.
We will collect audio, electronic, visual, thermal or similar information about photos and videos you provide and submit to us when creating an account, uploading content, or contacting us. For example, you may upload images of your wardrobe, purchase history, product reviews, and more. In addition, we may collect content such as visual, audio, and thermal information to help accurately map your features with 3D body scan technology.
Professional and Employment-Related Information.
When you apply for a job, we collect the information you submit as part of your application and resume. Depending on the location and type of job you apply for, this might include your work experience and previous employment, your education, whether you need a visa or require sponsorship, and/or current salary and compensation. Prior to extending a job offer, we may also conduct a credit check, background check, and/or employment verification to the extent permitted by applicable law. If you apply for a job, you may choose to also voluntarily provide any of the following information: ethnicity, gender, disability status, and/or veteran status.
Inferences.
We may develop inferences about you based on other personal information we have collected, considering your interests, personality, and preferences.
We use the above-referenced categories of personal information for various business purposes, including:
· to provide you with our products and services;
· to test, analyze, and improve our products and services, including the App and our websites;
· to conduct audits;
· to map your body measurements in order to provide products and recommendations, including to facilitate virtual try on using augmented reality;
· to send you personalized marketing communications and serve you advertisements for our products and services, or those of our Partners;
· to conduct research and analysis; to contact you in connection with your relationship with us;
· to identify and authenticate your access to the parts of our services that you are authorized to access;
· to send you updates regarding our products, services, website, or App;
· to provide support and respond to your inquiries or administrative requests;
· to comply with any applicable law, regulation, legal process or governmental request;
· to enforce our Terms & Conditions, including investigations of potential violations thereof;
· to detect, prevent, or otherwise address fraud or security issues;
· to protect against harm to the rights, property or safety of NetVirta, its users, yourself, or the public;
· to verify your identity in relation to requests you make pursuant to this Privacy Policy;
· to evaluate your job application and conduct background and employment checks
· and for other purposes as may be required or permitted by law, or as we may notify you.
We may use anonymized or aggregated information for any lawful purposes. Such data is not considered personal information and will not be used to identify you.
We collect and receive personal information about you from various sources, directly and indirectly, including:
Directly from you. We may collect information directly from you. For example, when you create an account, contact us, sign up to receive communications from us[, or apply for a job with us.
From your devices. We, our vendors, and our service providers may use a variety of online technologies that are capable of automatically collecting information about you and your devices, such as browser cookies and web beacons. We collect information about how and when you interact with our websites, our App, our online advertisements, or the emails that we, our vendors, and our service providers send to you. To learn about your choices for these tracking tools, read Section 5 of this Privacy Policy.
From vendors we hire to work on our behalf. We may engage or hire vendors and service providers to help us operate certain parts of our business, such as website or App hosting and support, email or text communications, employment and recruiting. We may also engage marketing agencies, advertising technology vendors, and analytics providers. Any of these vendors and service providers may, from time to time, provide us with information about you when they collect such information on our behalf.
From your friends and family. We may enable you to invite your friends to use the services by sending invitations on third party social media platforms or by sending an email through our services. If you send an invitation to your friend through these channels, we will collect any information you provide about your friend. Our services may allow you to add family members to your account, provided that: (i) if the family member is under 18 years of age, you are their guardian and you read the Privacy Policy (including this section) and agree to the Terms & Conditions on their behalf; (ii) if the family member is above 18 years of age, you have had the family member review this Privacy Policy (including this section) and they have agreed to the Terms & Conditions.
From our Partners and from other sources. We may receive personal information about you from our Partners’ websites where the Plugin is used, and from other sources, such as marketing partners and social media platforms. If you apply for a job, we may also get personal information from your current employer and background check providers. If you link social media accounts with the Websites or the App, the authentication of your log in credentials will be conducted through the social media account, which may collect information about your activities on NetVirta. You may review the social media platform’s privacy policies to understand what kinds of information the social media platform may make available to us.
We may receive personal information about you from our parents, subsidiaries, and affiliate companies.
We combine information. We may combine information that we have collected offline with information we collect online. We may combine information we get from another party with information we already have. We may also aggregate your information with other consumers’ information to understand preferences and trends over time. We may store information from various sources in a common database.
We share your personal information in accordance with this privacy policy, as described below.
We may share personal information with our affiliates.
We may share your personal information with vendors and service providers who perform services on our behalf. These may include vendors who send emails for us, help us manage and operate our websites and App, provide advertising or marketing services, place our advertisements, provide analytics and search engine support, track advertising impressions, investigate and prevent data incidents, provide physical and digital security services, audit our business and financial statements, vet job applicants, and provide legal advice. These services include Google Analytics.
We may share your personal information with our Partners.
NetVirta services will facilitate your desire to transfer your personal information to any Partner company you request. We will disclose your personal information if you (1) use the App to scan a QR code that is associated with a Partner; (2) share your services-specific identifier with a Partner (the services identifier could be an account username, email address that you used to register, a QR code that is generated by the services unique to you, or any other means that lead to identification of you); or (3) any other selection action that is performed deliberately by you that signifies your deliberate intent to transfer your personal information to that Partner. If you perform one of those requested actions, NetVirta will transfer your personal information to that Partner. We may disclose your personal information to third parties to fulfill your requests on our website; for example, you may wish to participate in surveys, sweepstakes, or special events with our Partners.
We will share your personal information for safety and security purposes, if we think we must to comply with the law, or to protect ourselves, our customers and others. We may share any or all personal information to respond to a court order or subpoena. We may also share any or all personal information if a government agency or investigatory body requests it. We might share your personal information to enforce our agreements and to protect our rights and/or the rights of others. We might share your personal information when we are investigating potential fraud.
We may share your personal information with a successor to all or part of our business. If part of our business (including any of our affiliates, divisions, and business units) is acquired by a third party, we may include personal information as part of that transaction, which may include some or all categories of your personal information. We may also share your personal information if there is a change to our corporate structure. We may also share your information with others as they conduct diligence of our corporate changes. If any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset and may be transferred or sold to others.
We may share personal information for other reasons we may describe to you from time to time or as permitted or required by law.
We may share, in our sole discretion, aggregated information which does not identify you, or de-identified information about you, with third parties for any purpose.
Marketing Communications
You can opt out of receiving our marketing emails and text messages. To stop receiving promotional emails, you can follow the instructions in any promotional message you get from us. You may also email us at verifyt-support@netvirta.com with the word UNSUBSCRIBE in the subject field of the email. Your opt out is limited to the email address used and will not affect your receipt of transactional messages, such as responses to your questions and updates to your account. If you receive promotional text messages from us, you may opt out anytime by replying “STOP”.
Location Data
You may control the collection of location data by adjusting the settings on your device and/or application, and any related preferences and permissions, such as disabling location services or turning off your Bluetooth and Wi-Fi. Note that doing so may impact the functionality of certain features of our Websites and Apps.
Cookies and Tracking Tools
We and our service providers use tracking tools like pixels and cookies to collect information about users that access NetVirta websites and Apps. Cookies are small files that a website transfers to your computer’s hard drive through your web browser. We use cookies for several purposes, such as to recognize new or past users; store your password if you are registered on our site; improve our site; serve you with interest-based or targeted advertising; observe your behaviors and browsing activities over time and across websites; and better understand the interests of our users and website visitors. To learn how you can reject or delete cookies from us or other companies, or to reset your advertising identifiers, refer to the help menu of your Internet browser and your devices. If you block all cookies, certain functionality of our websites may be negatively impacted. If you block or reject cookies, not all the tracking described here will stop. Choices you make are both browser- and device-specific, meaning that you should exercise your preference on each browser and on each device you use. If you clear cookies from your browser, you may need to exercise these choices again.
Google Analytics
We use Google Analytics to help us understand how you use our Websites and App so we may personalize and improve the Websites and App for you. You can opt-out of Google Analytics’ use of cookies here: https://tools.google.com/dlpage/gaoptout .
Interest Based Advertising
You may opt out of having your online behavior recorded and used for targeted advertising. To opt out of receiving interest-based advertising from participating companies, visit the opt-out mechanisms of the Digital Advertising Alliance and the Network Advertising Initiative. Choices you make are both browser- and device-specific, meaning that you should exercise your preference on each browser and on each device you use. If you clear cookies from your browser, you may need to exercise these choices again. Please be aware that even if you opt out of interest-based advertising, you will continue to receive non-customized online ads.
Our Do Not Track Policy.
Our Website responds to opt out preference signals as described further in Section 6 below.
If you reside in the United States, you can make the following requests with respect to your personal information, as clarified or limited by the applicable privacy law(s) of your state of residence:
Access/Right to Know – You can request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected the personal information, the categories of personal information we sold or disclosed, our business or commercial purpose for collecting and selling the personal information, the categories of third parties with whom we shared the personal information, a portable copy of the specific pieces of personal information we collected about you over the past 12 months, and information about the logic involved in any automated decision making processes we use (if applicable), as well as a description of the likely outcome of the process with respect to you.
Correct/Update – You can request that we correct, update, or modify the personal information we maintain about you.
Deletion – You can request that we delete your personal information that we maintain about you, subject to certain exceptions. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to facilitate customer requests.
Do Not Sell or Share My Personal Information, or Process My Personal Information for Targeted Advertising – We use certain third-party cookies that can be considered “sales” or “sharing” of personal information, or processing of personal information for targeted advertising, under applicable laws. If you would like to opt out of such cookie-based sales, sharing, and processing for targeted advertising, you will need to update your cookie preferences by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of this page. Alternatively, you can use an opt-out preference signal or universal opt-out mechanism on a supported web browser. Only certain web browsers currently support such a signal. To find and download a browser that supports the GPC browser signal, visit https://globalprivacycontrol.org/orgs . Your cookie selections and GPC selections are specific to the device, website, and browser you are using. Your selections are deleted whenever you clear your cookies or browser’s cache.
Limit the use of my Sensitive Personal Information – You can request that we limit our use and sharing of any sensitive personal information identified in Section 1 above only to those uses which are necessary to carry out our relationship with you, or as otherwise expressly allowed by relevant California privacy laws. Please note that we do not use sensitive personal information for purposes of inferring characteristics about users.
How to submit a privacy request
U.S. residents can make these requests by emailing us at verifyt-privacy@netvirta.com. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. If you are not satisfied with the outcome of your request and would like to request further review, you may send an email to verifyt-privacy@netvirta.com with “Personal Information Requests Appeal” in the subject line. If you have concerns about the results of such an appeal, you may contact the Attorney General in your state for further assistance.
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps may vary depending on the sensitivity of the personal information and whether you have an account with us.
You may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.
Additional California Privacy Disclosures
For purposes of California residents making these requests, please also note the following disclosures regarding how we collect, use, and share your personal information as described in this Privacy Policy, including in the previous 12 months:
We may collect, use, and disclose for our business and commercial purposes, categories of personal information as set forth in applicable California law, including: identifiers; customer records information; characteristics of protected classifications under California or federal law (such as age and gender); categories of personal information described under Cal. Civil Code. Section 1798.80(e); commercial information; professional or employment information; internet or other electronic network activity information; geolocation data; and audio, electronic, visual, thermal, or similar information. See Section 1 above for additional detail.
We collect and use the above categories of personal information for the business and commercial purposes described in Section 2 of this Privacy Policy.
We collect the above categories of personal information from the sources described in Section 3 above.
We may disclose each of the foregoing categories of personal information for the business and commercial purposes described in this Privacy Policy to the extent permitted by applicable law, to the categories of third parties as described in Section 4 of this Privacy Policy.
As detailed below, to the extent provided by the law of your jurisdiction, you may have legal rights in relation to the personal information about you that NetVirta holds. We may require you to prove your identity with approved identification if you request this information.
A. Lawful basis for processing your personal information.
We process on the following legal bases:
1. Contract: It is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal information to us, we will not be able to carry out our obligations under the terms of the contract.
2. Legitimate Interests: We process your personal information if it is based on our legitimate interests. For example, we may process personal information in reliance on a legitimate interest in the effective and lawful operation of our business, the effective delivery and improvement of our products, services, and platforms, information security operations, compliance with laws and regulations, compliance with requests for disclosure to law enforcement, courts, and regulatory bodies, and to prevent and detect fraud or suspected fraud. In relation to general inquiries and complaints you send us, our legitimate interest is to provide you with information you have requested and to provide customer support. You can object to the processing that we carry out on the grounds of legitimate interests. See the section “Rights of data subjects” below to find out how.
3. Consent: Where you have given us consent to do so, we may share your personal information with Partners. You have the right to withdraw your consent. Please see the section “Rights of data subjects” below to find out how.
4. Legal Claims: We may need to process your personal information to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).
B. Rights of EU, UK, and Australia data subjects
You may have the following rights, where provided under applicable law, regarding your information for which NetVirta is a data controller (each of which are subject to various exceptions and limitations):
1. The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Policy.
2. The right of access: You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we are using your information in accordance with data protection law
3. The right to rectification: You are entitled to have your information corrected if it is inaccurate or incomplete.
4. The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions and this right may not apply in certain jurisdictions.
5. The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability: You have rights to obtain and reuse your personal information for your own purposes across different services and platforms.
7. The right to object: You have the right to object to certain types of processing, in particular processing based on our legitimate interests. You also can object at any time to your information being used for direct marketing purposes (including profiling related to such direct marketing). Where you object to processing for direct marketing purposes, the personal information shall no longer be processed for such purposes.
8. The right to refuse or withdraw consent: You have the right to refuse to provide and withdraw your consent to processing of your personal information at any time with effect for future processing.
If you are not satisfied with our response to your complaint and would like to request further review, you may send an email to verifyt-privacy@netvirta.com with “Personal Information Requests Appeal” in the subject line. If you believe our processing of your information does not comply with data protection law, you can make a complaint to
your local data protection authority.
Please note your rights in relation to your personal information are not absolute and may not apply in certain jurisdictions. We may, for example, deny you access to your personal information when required or authorized by law, or if granting access would have an unreasonable impact on another individual’s privacy.
We will retain your personal information and any communications you send us if we reasonably determine it is necessary for achieving the purposes described in this Privacy Policy, including as necessary to comply with our legal and business obligations, resolve disputes, and enforce our agreements. We may archive your personal information for a commercially reasonable time thereafter for backup, fraud detection and prevention, and audit purposes, as part of our ordinary business procedures. To determine applicable retention periods, we rely on: the necessity of the information to provide our services to a customer; the types and sensitivity of personal information processed; regulatory requirements that we are subject to, including laws and regulations related to tax, employment, accounting, and securities; and whether a legal claim may be brought against us, for which the information would be relevant.
Information we collect from you in our role as a data controller may be transferred to, processed in, or stored in the United States, Singapore, or another destination outside of the European Economic Area (“EEA”), the United Kingdom, Australia or your jurisdiction of residence. Note that if we have collected personal information from users in the EEA or UK in the capacity of a data processor on behalf of a data controller, we will process such personal information within the EEA or UK. Information may be processed by personnel operating in these locations who work for us or one of our Partners. Information we collect as a data controller and transfer to the United States, Singapore, or elsewhere may be subject to access by and disclosure to government and law enforcement agencies in those countries according to their laws. The European Commission and the UK government may consider the standard of data protection in the United States and in certain other countries where we may process your information to be inadequate. By using our Websites, our App, or submitting your personal information, you consent to such transfer, storing and processing.
Our websites, Apps, products, and services are intended to be used by consumers over the age of 18. If you are a consumer under the age of 18 and would like to access these, you must ensure that your parent or legal guardian reads and explains this Privacy Policy to you. By using our websites, Apps, products, or services, your guardian consents to us collecting, processing, and sharing your personal information for the purposes set forth in this Privacy Policy. If your parent or guardian does not consent to the processing disclosed in this Privacy Policy, you may not access or otherwise use our Websites, Apps, products, or services. If we learn that we have collected personal information from a consumer under the age of 18 without his/her parent or guardian’s consent, we will delete that information as quickly as possible. If you believe that NetVirta might have any such information, please contact us at verifyt-privacy@netvirta.com.
We use administrative, physical, and technical safeguards designed to protect the personal information we store, which are meant to be appropriate to the nature and sensitivity of the information we store. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use reasonable means to protect your personal information, we cannot guarantee its absolute security or confidentiality.
If you click on a link to a third-party site or a third-party app, you will be taken to a website or service we do not control, own, or operate. This Privacy Policy does not apply to the privacy practices of third-party websites or services, such as social media platforms. These third parties may collect and solicit information about you; your browsing and interaction will be subject to the third parties’ rules and procedures. Read the privacy policy of these websites, apps, and services carefully. We are not responsible for third-party websites or services or their policies, including the information or content contained therein.
We reserve the right, at our discretion, to change this Privacy Policy at any time. Notice of such change will occur by posting the revised Privacy Policy on the websites and/or the App, or as otherwise required by applicable laws, with the changes effective ten (10) days following posting. Your continued use of the websites, Apps, or services thereafter means that you acknowledge and consent to those changes.
If you have any questions about this Privacy Policy or your information, please email us at verifyt-privacy@netvirta.com. You can also write us at 53 State Street, Boston, Massachusetts 02127, or call us at [617-855-5616].