StrutFit

Privacy Policy

Last updated: 18 May 2026  |  Effective: 18 May 2026

StrutFit Limited (“StrutFit”, “we”, “us”) is a New Zealand company (NZBN 5917240) with registered address Level 6/391–393 Khyber Pass Road, Newmarket, Auckland 1023, New Zealand. This Privacy Policy explains how we collect, use, and protect personal information. It covers two groups of people:

Please read the section that applies to you. For questions, contact us at privacy@strut.fit.

We may update this policy from time to time. We will notify you of material changes by email or by posting an updated version here. Continued use of our services after the effective date constitutes acceptance of the updated policy.

Part A — End Users

This section applies to individuals who use a StrutFit-powered feature on a retailer's website or app — for example, a size recommendation tool (Fit), a virtual try-on experience (Try), or a product discovery feature (Find).

A1. What We Collect

Information you provide directly

When you use StrutFit features, you may provide:

AR Try-On Feature — camera and image data

When you use the AR Try-On feature, your device camera is used to display a live augmented reality overlay of footwear in real time. This feature has been designed so that:

Your camera is used solely to render the live try-on experience. Nothing is saved. Nothing leaves your device.

The limited data we do collect during AR Try-On sessions is: which footwear items were viewed (product IDs only), device type and operating system (for rendering compatibility), and session-level analytics in aggregate (e.g. feature usage counts and errors) — none of which is linked to your identity.

Your device or browser will prompt you to grant camera permission before the feature activates. You can revoke this permission at any time through your device settings. Revoking camera permission will prevent use of AR Try-On but will not affect any other StrutFit functionality. If you access AR Try-On through a retailer's site or app, the permission request may appear under that retailer's domain or app name — our data handling described here still applies.

Note on biometric data and GDPR/CCPA: Because AR Try-On processes camera data entirely on-device and retains nothing, no biometric data is collected or stored by StrutFit. No special category processing under GDPR Article 9 occurs in respect of Try-On camera data. Under CCPA/CPRA, we do not collect biometric information from the AR Try-On feature.

Information collected automatically

When you use the StrutFit service, we automatically collect:

Cookies and tracking

We use cookies and similar technologies to:

You can control cookies through your browser settings. Disabling cookies may limit some features. Where required by law, we obtain your consent before placing non-essential cookies.

A2. Our Legal Basis for Processing Your Data

If you are in the European Economic Area (EEA), the United Kingdom, or another jurisdiction with similar requirements, we process your personal data on the following legal bases under GDPR Article 6 (and Article 9 for special category data):

Contract performance

We process your data to provide the StrutFit service you have requested — including generating size recommendations, virtual try-on results, and product discovery features.

Legitimate interests

We process certain data based on our legitimate interests in operating and improving the service, including:

We have assessed that these interests do not override your fundamental rights and freedoms.

Consent

We rely on your consent for:

You may withdraw your consent at any time by contacting privacy@strut.fit or adjusting your cookie settings. Withdrawal does not affect the lawfulness of processing before withdrawal.

Legal obligation

We may process data where required to comply with applicable laws or respond to lawful government requests.

A3. How We Use Your Information

We use your information to:

We do not use your personal data for unrelated marketing without your consent.

A4. Automated Decision-Making and Profiling

Our service uses AI to generate size recommendations and product suggestions based on the information you provide and your interactions with the platform. These AI outputs are probabilistic suggestions, not binding decisions. You are not subject to any decision based solely on automated processing that produces significant legal effects concerning you.

If you have questions about how a recommendation was generated, or wish to request human review of any automated output, contact us at privacy@strut.fit.

A5. Who We Share Your Information With

Retailers

If you use StrutFit through a retailer's website, we may share a copy of your StrutFit Profile (including your email address if provided) with that retailer so they can personalise their service to you. Once shared, the retailer's own privacy policy governs their use of that data.

Service providers and subprocessors

We use trusted third-party providers to operate our service (for example, cloud hosting, analytics, and infrastructure providers). These providers act as data processors on our behalf and are contractually required to keep your data secure and use it only to perform services for us. A current list of subprocessors is available at privacy@strut.fit on request.

Legal requirements

We may disclose your information if required by law, regulation, or a valid government request, or to protect the rights, property, or safety of StrutFit, our users, or others.

Business transfers

If StrutFit is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you if this results in a change to how your data is handled.

We do not sell your personal information to third parties.

A6. International Transfers

StrutFit is based in New Zealand, which the European Commission has recognised as providing adequate protection for personal data from the EEA. Your data may also be processed by our service providers in other countries, including the United States.

Where we transfer personal data from the EEA or UK to countries that do not have an adequacy decision, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent mechanisms, to ensure your data receives an equivalent level of protection. You may request a copy of the applicable transfer mechanism by contacting privacy@strut.fit.

A7. How Long We Keep Your Information

We retain your personal information for as long as necessary to provide the service or comply with our legal obligations:

Anonymised and aggregated data does not identify you and may be retained indefinitely.

A8. Your Rights

Depending on where you live, you may have the following rights regarding your personal data. To exercise any of them, contact privacy@strut.fit. We will respond within 30 days (or 45 days for California residents).

Rights available to everyone

Additional rights under GDPR (EEA and UK residents)

California residents (CCPA/CPRA)

See Section A9 below for your specific rights under California law.

A9. California Residents — CCPA/CPRA

This section applies to California residents and supplements the rest of this policy. It is provided pursuant to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

Categories of personal information we collect

In the past 12 months, we have collected the following categories of personal information from end users:

We collect this information for the purposes described in Section A3. We do not sell or share (as defined under CPRA) your personal information with third parties for cross-context behavioural advertising.

Your California rights

To exercise your California rights, contact us at privacy@strut.fit. We will respond within 45 days. We do not charge a fee and will not require you to create an account. We may need to verify your identity before processing your request.

A10. Security

We use industry-standard technical and organisational measures to protect your personal information, including encryption in transit (TLS), access controls, and secure cloud hosting. Our subprocessors are subject to equivalent security requirements.

No method of internet transmission is 100% secure. If we become aware of a breach affecting your personal data, we will notify you and relevant authorities as required by applicable law.

A11. Contact and Complaints

For privacy questions, data access or deletion requests, or security concerns:

EEA/UK residents may also lodge a complaint with their local data protection authority if they believe we have not handled their data in accordance with applicable law.

Part B — Business Customers

This section applies to retailers, brands, and other businesses that subscribe to the StrutFit platform, and to the individual contact persons at those businesses (e.g. the account manager or billing contact). It explains how we handle personal data relating to business contacts.

B1. What We Collect

When your business signs up to StrutFit, we collect:

B2. Our Legal Basis for Processing Your Data

If you are in the EEA or UK, we process business contact data on the following legal bases:

B3. How We Use Your Information

We use business contact information to:

We may occasionally send you information about new features or products relevant to your subscription. You can opt out of non-essential communications at any time by contacting privacy@strut.fit.

B4. Who We Share Your Information With

We share business contact data only where necessary:

We do not sell business contact information to third parties.

B5. International Transfers

Your data may be processed by StrutFit or our subprocessors in countries outside your home jurisdiction, including New Zealand and the United States. Where we transfer personal data from the EEA or UK, we rely on Standard Contractual Clauses (SCCs) or equivalent approved transfer mechanisms. New Zealand has been recognised by the European Commission as providing adequate data protection.

B6. How Long We Keep Your Information

We retain business contact data for as long as your subscription is active and for a reasonable period after termination:

You may request earlier deletion of data that is not subject to a legal retention requirement by contacting privacy@strut.fit.

B7. Your Rights

As an individual whose data we process, you have the following rights. To exercise them, contact privacy@strut.fit. We will respond within 30 days.

B8. Security

We maintain industry-standard security measures to protect business account data, including encrypted communications (TLS), role-based access controls, and secure cloud infrastructure. Subprocessors including Stripe are subject to equivalent security standards. If we become aware of a breach affecting your personal data, we will notify you and relevant authorities as required by law.

B9. Contact

For questions about how we handle personal data as a business customer:

StrutFit Limited · Level 6/391–393 Khyber Pass Road, Newmarket, Auckland 1023, New Zealand · NZBN 5917240 · privacy@strut.fit

Copyright © 2026 StrutFit Limited. All rights reserved.