1. Introduction
This Privacy and Cookie Policy ("Policy") explains how The Fitting Room ("we", "us", or "our") collects, uses, stores, and protects personal data when individuals ("you", "user") interact with our platform, whether directly through our website or via the embedded widget installed on partner brand websites.
This Policy complies with the EU General Data Protection Regulation (GDPR), the Swiss Federal Data Protection Act (DSG), and other applicable privacy laws.
2. Data Controller And Contact
- Controller (Direct Users): The Fitting Room, when you use our website or upload content directly.
- Processor (Widget Users): When our widget is embedded in a brand’s website, we process data on behalf of that brand (the controller).
Contact for privacy inquiries: 📧 concierge@thefittingroom.com 🏢 Address: Polychrome - 20 rue Joseph Girard - 1227 Carouge - Switzerland
3. Types Of Data We Collect
3.1 Directly Provided Data
- Uploaded photos or images for try-on visualizations
- Name and contact information (if account created)
- Payment and billing details (via Stripe)
3.2 Automatically Collected Data
- IP address, browser type, device information
- Referring URLs, session IDs, cookies, and analytics data
- Widget interaction data (clicks, image generation events, etc.)
3.3 From Third Parties
- Payment confirmations from Stripe
- Hosting and AI processing data from Google Cloud and AWS/S3
4. Purposes And Legal Basis Of Processing
| Purpose | Legal Basis |
|---|---|
| Providing AI try-on service and widget functionality | Contract performance (Art. 6(1)(b) GDPR) |
| Analytics, optimization, and fraud prevention | Legitimate interests (Art. 6(1)(f) GDPR) |
| Payment processing | Contract performance + legal obligation |
| Consent management for cookies | Consent (Art. 6(1)(a) GDPR) |
| AI model training (if applicable) | Explicit consent (Art. 9(2)(a) GDPR) |
| Compliance with law, defense of claims | Legal obligation (Art. 6(1)(c) GDPR) |
5. Data Retention
- Uploaded images are retained only for the duration of the session unless the user creates an account.
- Logs and analytics data are retained for up to 90 days.
- Backups containing personal data are automatically deleted or anonymized within 6 months.
- Stripe payment records are kept as required by accounting laws.
6. Data Sharing And Subprocessors
We may share personal data only with:
| Recipient | Purpose | Location |
|---|---|---|
| Google Cloud (Gemini) | AI image generation | EU/EEA |
| AWS/S3 | Image and file storage | EU/CH |
| Stripe Payments | Payment processing | EU/US (adequate safeguards) |
| Cloudflare / CDN | Content delivery and DDoS protection | Global |
All subprocessors operate under GDPR-compliant Data Processing Agreements and provide Standard Contractual Clauses (SCCs) where applicable.
7. International Data Transfers
If data is transferred outside Switzerland or the EEA, we rely on:
- Adequacy decisions (e.g., for EU/CH)
- Standard Contractual Clauses (SCCs) approved by the European Commission
8. User Rights
You have the following rights under GDPR and DSG:
- Access your personal data
- Request correction or deletion
- Withdraw consent
- Object to processing or restrict it
- Data portability (receive a copy in machine-readable form)
Requests can be made by email to concierge@thefittingroom.com. We may require identity verification before processing requests.
9. Cookies And Tracking Technologies
9.1 What Are Cookies
Cookies are small text files stored on your device when visiting a website or using a widget. They help improve usability, remember preferences, and analyze usage.
9.2 Types of Cookies Used
| Type | Purpose | Retention |
|---|---|---|
| Strictly Necessary Cookies | Enable core features (security, session management) | Session only |
| Performance Cookies | Collect anonymous usage statistics | Up to 12 months |
| Functional Cookies | Remember settings and preferences | Up to 12 months |
| Advertising Cookies | Track cross-site activity for marketing | Up to 6 months |
| Third-Party Cookies | Set by analytics, CDN, or payment processors | Variable |
9.3 Cookie Consent
Upon first visit, users see a cookie banner allowing acceptance or customization. Consent is stored for 12 months and can be withdrawn anytime via the banner link or browser settings.
9.4 Widget Cookies
When our widget is embedded on a brand website, cookies may be set on:
- Our domain (e.g., the-fitting-room.app)
- The host website’s domain (if permitted)
Brands must display cookie notices referencing this Policy and obtain end-user consent.
10. SECURITY
We apply industry-standard technical and organizational measures including:
- HTTPS encryption
- Firewalls and DDoS protection
- Access control and role-based permissions
- Regular security audits and vulnerability scans
However, no system is 100% secure, and we cannot guarantee absolute protection.
11. CHILDREN’S PRIVACY
Our Service is not directed to children under 16 years of age. We do not knowingly collect their data. If discovered, such data will be deleted promptly.
12. CHANGES TO THIS POLICY
We may update this Policy periodically. Material updates will be announced through our website and widget interface. Continued use after updates constitutes acceptance of the revised Policy.
13. CONTACT AND COMPLAINTS
Questions or complaints can be addressed to: 📧 concierge@thefittingroom.com
If you believe your rights under GDPR/DSG have been violated, you may lodge a complaint with:
- The Swiss Federal Data Protection and Information Commissioner (FDPIC), or
- Your local EU Data Protection Authority (DPA).
14. SUMMARY OF COOKIE PURPOSES
| Cookie Name | Type | Purpose | Retention |
|---|---|---|---|
_tfr_session |
Strictly necessary | Maintains session ID | Session |
_tfr_consent |
Functional | Stores cookie preferences | 12 months |
_ga, _gid |
Analytics | Google Analytics tracking | 12 months |
__stripe_sid, __stripe_mid |
Payment | Fraud prevention | 12 months |
15. EFFECTIVE DATE
This Privacy and Cookie Policy enters into force on November 1, 2025 and remains effective until replaced or withdrawn.
The Fitting Room Email: concierge@thefittingroom.com Address: Polychrome - 20 rue Joseph Girard - 1227 Carouge - Switzerland