1. Introduction
1.1 In this Policy You will find the description of the processing activities of Your Personal Data that are essential for the operation of
DORIS.MOBI’s Virtual Fitting Room called “Doris Mirror” and for the provision of our services.
1.2 To operate, the Doris Mirror of
DORIS.MOBI requires Personal Data to be provided by You, which are processed and used to enable and improve the provision of services by
DORIS.MOBI and/or
Doris.MOBI Licensees.
1.3 When You use our services and products, You provide
DORIS.MOBI and/or
Doris.MOBI Licensees with information and Personal Data through the submission of Image.
1.4 It is very important that You read, at each use of the Virtual Fitting Room, the provisions of this Policy, to understand how we collect and Process Your Personal Data. We emphasize that
DORIS.MOBI and the
Doris.MOBI Licensees do not sell Your Personal Data to Third Parties.
2. Meaning of the Expressions Used in this Policy
2.1 The expressions below, whenever used or initiated in capital letters, shall have the following meanings:
Anonymized Data: means any data relating to the data subject that cannot be identified, considering the use of reasonable and available technical means at the time of its Processing. Anonymized Data will not be considered Personal Data for the purposes of this Policy.
Applicable Law: means any law, code, decree, regulation, regulatory requirement, rule, ordinance, instruction, statement, resolution, judicial, arbitral, or administrative decision, of any Government Authority, including but not limited to LGPD and GDPR.
Clothing Item: means the image of a specific clothing item, Wearable, that allows its virtual projection, in order to enable the simulation of wearing such clothing item by a person.
Consent: means the free, informed, unequivocal, and specific manifestation of the data subject, expressed by means of a clear affirmative action, through which they agree with the processing of their Personal Data. Consent may be revoked at any time, without affecting the lawfulness of the processing carried out while Consent was valid.
Content: means any and all content sent, made available, and/or in any way transmitted by You.
Controller: means the natural or legal person, public or private, to whom the decisions regarding the Processing of Personal Data pertain. Doris.MOBI and/or Doris.MOBI Licensees are the Controllers and, therefore, responsible for making decisions regarding the Processing of Users’ Personal Data.
Database: means the structured set of Personal Data, established in one or several locations, in physical and/or electronic support, generated as a result of the activities carried out by Users through the use of Doris Mirror DORIS.MOBI.
Deletion: means the exclusion of Personal Data or sets of Personal Data stored in a Database, regardless of the procedure used.
DORIS.MOBI: means DORIS.MOBI TECNOLOGIA S.L., headquartered in the city of Barcelona, Spain, at Calle Beethoven, 15, 5th Floor, CP 08021, holder of tax identification document no. B-55484471 and registered with the Commercial Registry of Barcelona under no. B-617736, owner and/or holder of the right to use the Virtual Fitting Room.
Doris.MOBI Licensees: means the entity that has received a license for use and exploitation of Doris, granted by Doris.MOBI, including DORIS.MOBI TECNOLOGIA S.A., headquartered in the City of São Paulo, State of São Paulo, at Avenida Brigadeiro Faria Lima, no. 2.092, 10th floor, units E102 and E104, room 02, Jardim Paulistano, ZIP 01451-905, registered under CNPJ no. 19.782.186/0001-06.
GDPR: means the General Data Protection Regulation, which regulates the processing of data within the European Union and the European Economic Area.
Government Authority: means any government, authority, governmental entity, regulatory agency, public prosecutor’s office, tax authority (including, without limitation, the Brazilian Federal Revenue Service and state and municipal tax offices), commission, board, council, stock exchange, agencies, and any court, arbitral tribunal, judge, arbitrator, foreign or domestic, with jurisdiction, as the case may be, over DORIS.MOBI and/or Doris.MOBI Licensees and/or Users. Includes, but is not limited to, the National Data Protection Authority (ANPD) in Brazil, and the data protection supervisory authorities established by the GDPR in the European Economic Area (EEA), such as the European Data Protection Board (EDPB).
Image: means, with respect to a natural person, any forms of representation, including photographic, of the human figure, visual appearance, countenance, gestures, distinct body parts, externalizations of personality, name, surname, nicknames, codenames, and pseudonyms, as well as the audiovisual process that results in the fixation of images with or without sound, intended to create, through their reproduction, the impression of movement, regardless of the processes of their capture, the medium initially or subsequently used to fix them, as well as the means used for their dissemination, including but not limited to (i) newspapers, magazines, brochures, marketing materials, catalogs and/or any other printed media; (ii) fashion art, painting, sculpture, drawing, photography, reprography, caricature or decorative representation; (iii) sound image from phonography and broadcasting; and/or (iv) cinematography, television and the Internet. Your Image will be captured by the Virtual Fitting Room, following certain position and distance conditions mentioned in the equipment, and will be used so that You can virtually try on selected clothing items without the need for a physical fitting room.
International Transfer of Personal Data: means the transfer of Personal Data from the Controller’s territory to a foreign country or international organization of which the country is a member.
LGPD: means Law no. 13.709/2018 and its respective regulations that may be created, as amended from time to time.
Personal Data: means, with respect to a natural person, any and all data related to an identified or identifiable natural person, directly or indirectly, including but not limited to identifying numbers, images, location data, and/or electronic identifiers and IP addresses, or any data that, alone or together, allow the formation of the behavioral profile of an identified or identifiable natural person. When referring to You, Personal Data shall be understood as any Personal Data sent and/or transmitted by You through the DORIS.MOBI Virtual Fitting Room.
Policy: means this document entitled “Privacy and Personal Data Protection Policy,” which contains provisions regarding the Processing of Users’ Personal Data when using the Virtual Fitting Room, whose terms must be fully accepted by You as a condition for use.
Processing: means any operations carried out with Personal Data, including but not limited to collection, production, reception, classification, use, access, reproduction, transmission, sharing, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination, or extraction.
Processor: means the natural or legal person, public or private, residing or headquartered within or outside the national territory, who carries out the Processing of Personal Data on behalf of the Controller.
Sensitive Personal Data: means any Personal Data regarding racial or ethnic origin, religious belief, political opinion, union membership or membership in a religious, philosophical or political organization, Personal Data concerning health or sexual life, genetic or biometric Personal Data, when linked to a natural person.
Shared Use of Personal Data: means the communication, dissemination, international transfer, interconnection of Personal Data, or shared Processing of Databases by public bodies and entities in the exercise of their legal competencies, or between these and private entities, reciprocally, with specific authorization, for one or more Processing modalities permitted by such public entities, or between private entities.
Support: means the communication channel contained in our privacy portal, available at
https://portallgpd.doris.mobi.
Terms of Use: means the document entitled “Terms of Use,” which, together with this Policy, contains the general terms and conditions of DORIS.MOBI solutions for Users.
User: means, indistinctly, any natural person who uses the Virtual Fitting Room.
Virtual Fitting Room: means the interactive digital totem, used in physical establishments, allowing the client to virtually try on selected clothing items from their Image, captured by the equipment, without the need to use a physical clothing fitting room.
Wearable: means, with respect to a clothing item, that said clothing item meets the technical requirements to enable, successfully, its virtual projection, in order to allow the simulation of wearing such clothing item by a person.
You (and, when referring to You, the pronouns “Your” and “Yours”): means the natural person who is, at this moment, agreeing to the Terms of Use and this Policy. You must: (i) have legal capacity or, if You are under 18 (eighteen) years of age or do not have legal capacity, You must be assisted or represented by Your parents or legal representatives, in accordance with the Applicable Law; and (ii) comply with all Applicable Laws, as a User.
