RingSizer

Privacy Policy

Last Modified: September 3rd, 2025

This Privacy Policy of R11N Ventures GmbH (doing business as Ring Sizer) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Understanding this Privacy Statement will give you clarity about your privacy protections and available options. As the entity determining how your personal data is handled, we take responsibility for its processing and protection. Should you find yourself uncomfortable with these data handling practices, we encourage you to refrain from utilizing our platform and associated features. For any privacy-related inquiries or clarifications, our Data Protection team is available to assist you via privacy@r11n.io.

Data controller and responsible body: R11N Ventures GmbH, Glasbläserallee 6, 10245 Berlin

Duly represented by Lars Triebel / Data Protection Officer: dpo@r11n.io

1. Privacy of Marketing Website Visitors and B2B Customers

The following applies to visitors of our marketing website (https://ringsizer.app/) and B2B customers of our services (e.g. through Shopify marketplace).

Configure Your Consent

1.1. Information collected

Personal information disclosed by you

We gather personal information that you voluntarily submit when requesting details about our organization, products, or Services, engaging with platform features, or initiating contact with us.

Business communications: When you interact with our sales team or customer support representatives, we collect information you provide including your name, company details, business email, phone number, and the content of your inquiries or support requests. This information may be shared with our authorized service providers who assist in delivering these services.

Sensitive Data Processing: Our systems do not process sensitive personal information.

Payment Data:

To facilitate purchases, we may collect payment-related data such as payment instrument details and associated security credentials. Payment processing and data storage are managed exclusively by our payment processor, Shopify Inc. Their privacy practices can be reviewed at https://www.shopify.com/ca/legal/privacy?lang=en.

You are responsible for ensuring all personal information provided is accurate, complete, and truthful. You must promptly inform us of any changes to maintain data accuracy.

Automatically collected information

During your interaction with our platform, our systems automatically gather technical data about your visit and usage patterns. The collected technical details include your device specifications, system settings, browsing habits, and network identifiers - such as operating system version, language settings, IP address, browser type, entry pages, and timing of platform usage. While this technical data does not directly identify you as an individual, it helps us ensure platform security, maintain stable operations, analyze usage patterns, and generate internal reports.

Additionally, we employ standard web tracking methods, including cookies and related technologies, to collect usage data.

The information we collect includes:

1.2. How we process your information

Your data enables us to provide our services in the following ways:

1.3. Overview of Tracking Use

Essential > Security Monitoring

Purpose: We use a web application firewall to keep our services and users protected from malicious activity.

Data Processor: Cloudflare, Inc., located at 101 Townsend St., San Francisco, California 94107 United States of America

Location of processing: Global (depending on user location in a Cloudflare data center close to the user)

Data Categories: IP address, timestamps, device information, traffic information, cookie identifiers (e.g. cf_clearance).

Duration: 7 days

Legal basis: Article 6(1)(f) - Legitimate Interest

Essential > Customer Service and Sales Support

Purpose: Provide customer support, handle sales inquiries, process B2B customer onboarding, and manage client relationships

Data Processor: Trepkas Aps

Location of processing: Copenhagen, Denmark

Data Categories:

Legal Basis: Article 6(1)(b) - Contract (necessary for performance of contract) and Article 6(1)(f) - Legitimate Interest (for improving services)

Data Protection Measures: Data processing agreement in place with appropriate technical and organizational measures

Marketing > Live Chat

Purpose: Provide customer support through live chat service integrated in the website

Data Processor: Sendinblue SAS (Brevo) — 17 rue de Salneuve, 75017, Paris, France

Location of processing: European Union

Data Categories: IP address, timestamps, device information, traffic information, cookie identifiers, sent messages, name, company name, email address

Duration: Up to 2 years

Legal basis: Art. 6 (1) (a) GDPR - Consent

Marketing > Newsletter

Purpose: Provide a newsletter about products and services of RingSizer

Data Processor: Sendinblue SAS (Brevo) — 17 rue de Salneuve, 75017, Paris, France

Location of processing: European Union

Data Categories: IP address, timestamps, device information, traffic information, cookie identifiers, sent messages, name, company name, email address

Duration: Up to 2 years

Legal basis: Art. 6 (1) (a) GDPR - Consent

Analytics > Web Analytics

Purpose: Gather usage statistics to improve the product experience

Data Processor: Google Analytics – Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Location of processing: Global (incl. United States of America)

Data Categories: IP address (anonymised), pseudonymous identifiers (e.g. GA cookie ID, Client ID), timestamps, requested URLs and referrer URL, pages viewed and on‑page interaction events (clicks, scroll depth, video plays), session duration and frequency, browser and device details (type, operating system, screen resolution, language), and approximate geolocation (city/region derived from IP).

Duration: Up to 2 years

Legal basis: Art. 6 (1) (a) GDPR - Consent

Analytics > Web Analytics

Purpose: Gather usage statistics to improve the product experience

Data Processor: Google Analytics – Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Location of processing: Global (incl. United States of America)

Data Categories: IP address (anonymised), pseudonymous identifiers (e.g. GA cookie ID, Client ID), timestamps, requested URLs and referrer URL, pages viewed and on‑page interaction events (clicks, scroll depth, video plays), session duration and frequency, browser and device details (type, operating system, screen resolution, language), and approximate geolocation (city/region derived from IP).

Duration: Up to 2 years

Legal basis: Art. 6 (1) (a) GDPR - Consent

2. Privacy of Ring Sizer Application Users

The following applies to visitors of online stores embedding the Ring Sizer “Find My Size” button, Ring Sizer product demos and the Ring Sizer application used for ring size and finger measurements:

2.1. Information Collected

Personal information disclosed by you

We gather personal information that you voluntarily submit when requesting details about our organization, products, or Services, engaging with platform features, or initiating contact with us.

Sensitive Data Processing: Our systems do not process sensitive personal information.

You are responsible for ensuring all personal information provided is accurate, complete, and truthful. You must promptly inform us of any changes to maintain data accuracy.

Email My Size Feature: Where enabled by the online store operator, you may voluntarily provide your email address to receive your measurement results. If the store operator has enabled a marketing opt-in, you may also choose to consent to receiving marketing communications from the store operator. By submitting your email address, your data is transmitted to the store operator's e-commerce platform for customer record creation. Marketing communications, if consented to, are managed by the respective store operator, not by us.

Automatically collected information

During your interaction with our platform, our systems automatically gather technical data about your visit and usage patterns. The collected technical details include your device specifications, system settings, browsing habits, and network identifiers - such as operating system version, language settings, IP address, browser type, entry pages, and timing of platform usage. While this technical data does not directly identify you as an individual, it helps us ensure platform security, maintain stable operations, analyze usage patterns, and generate internal reports.

Additionally, we employ standard web tracking methods, including cookies and related technologies, to collect usage data.

The information we collect includes:

2.2. How We Process Your Information

Your data enables us to provide our services in the following ways:

2.3. Overview of Tracking Use

2.3.1. Essential Category

The following tracking is happening automatically without explicit consent based on the specified legal basis and minimal privacy impact on users:

Functional Session Information

Purpose: We store certain information that are important for the correct functioning of the application and security.

Data Processor: R11N Ventures GmbH (on Cloudflare, Inc. infrastructure)

Location of processing: Global (depending on user location in a Cloudflare data center close to the user)

Data Categories: Language preferences (lng), measured sizes and calibration data

Legal Basis: Article 6(1)(b) - Contract

Duration: Session (expire when closing your browser)

Security Monitoring

Purpose: We use a web application firewall to keep our services and users protected from malicious activity.

Data Processor: Cloudflare, Inc., located at 101 Townsend St., San Francisco, California 94107 United States of America

Location of processing: Global (depending on user location in a Cloudflare data center close to the user)

Data Categories: IP address, timestamps, device information, traffic information, cookie identifiers (e.g. cf_clearance).

Duration: 7 days

Legal basis: Article 6(1)(f) - Legitimate Interest

Anonymous Cookie-less Usage Analytics

Purpose: Improve the user experience and detect issues with the platform (without IP addresses)

Data Processor: PostHog, Inc., located at 2261 Market Street #4008, San Francisco, California 94114 United States of America

Data Categories: Pageviews, Usage data, geo information, A/B test interaction

Duration: 1 Year

Legal basis: Article 6(1)(f) - Legitimate Interest

Location of processing: Frankfurt, Germany (using PostHog EU Cloud and proxied through first-party domain)

Anonymous Cookie-less Billing-related Usage Tracking and Aggregated Usage Statistics

Purpose: Track usage of the platform based on the quota of a subscribed online store and provide high-level aggregated event data to online store operators

Data Processor: R11N Ventures GmbH (on Cloudflare, Inc. infrastructure)

Data Categories: Events including “Find My Size” button shown, measurement started and completed

Duration: 1 Year

Legal Basis: Article 6(1)(b) - Contract

Location of processing: Global (depending on user location in a Cloudflare data center close to the user)

Order Attribution Tracking

Purpose: Identify and track orders where customers utilized the Ring Sizer application for size determination prior to purchase, enabling merchants to understand the application's impact on conversion and providing usage metrics.

Data Processor: R11N Ventures GmbH (on Cloudflare, Inc. infrastructure)

Data Categories: Order ID, timestamp, information if a user has interacted with the RingSizer app (i.e., clicked, viewed the button, added a product to cart and made an order), no personal identifiers

Duration: 1 Year

Legal Basis: Consent (through merchant's Shopify "analytics" consent category)

Location of processing: Global (depending on user location in a Cloudflare data center close to the user)

Human Verification for Email Submission

Purpose: Prevent automated or fraudulent submissions of email addresses in the "Email My Size" feature.

Data Processor: Cloudflare, Inc., located at 101 Townsend St., San Francisco, California 94107 United States of America

Location of processing: Global (depending on user location in a Cloudflare data center close to the user)

Data Categories: Turnstile verification token, IP address, timestamps, device information, browser interaction data

Duration: Session

Legal Basis: Article 6(1)(f) – Legitimate Interest

Email My Size – Transactional Email Delivery

Purpose: Send measurement results to end users who voluntarily provide their email address through the "Email My Size" feature.

Data Processor: Sendinblue SAS (Brevo) — 17 rue de Salneuve, 75017, Paris, France

Location of processing: European Union

Data Categories: Email address, measurement result data, timestamp of submission

Duration: Transient (retained only for the period necessary to deliver the email)

Legal Basis: Article 6(1)(b) – Contract (user-initiated request to receive their measurement result)

Email My Size – Marketing Consent and Customer Record Creation

Purpose: Where the store operator has enabled the marketing opt-in and the end user consents, transmit the email address and marketing consent status to the store operator's Shopify platform for customer record creation.

Data Processor: R11N Ventures GmbH (acting on behalf of the store operator as Controller)

Location of processing: Dependent on store operator's Shopify region

Data Categories: Email address, marketing opt-in status, timestamp of consent

Duration: Transmitted to the store operator's platform; not retained by the Processor beyond delivery confirmation

Legal Basis: Article 6(1)(a) – Consent (end user's explicit opt-in to marketing)

3. General privacy notice

The following applies to all data subjects of both marketing visitors, business users and end users:

3.1. Legal Basis

This section applies to you, when located in the EU or UK:

Under data protection laws, including European and UK regulations, we must establish valid legal grounds for processing your personal data. Our processing activities are based on and are referenced with the respective activity in Section 1 and 2:

This section applies to you, when located in Canada:

Your personal information may be processed based on either explicit authorization (express consent) or reasonably presumed permission (implied consent) for specified purposes. You maintain the right to revoke such consent at any time.

Applicable law permits certain exemptions where we may process your information without obtaining consent, including but not limited to:

3.2. Sharing of Personal Information

In connection with corporate transactions, we reserve the right to transfer your personal data as part of any merger, asset sale, financing arrangement, or acquisition, whether during preliminary negotiations or upon completion of such transactions, where your information may be among the transferred business assets or be subject to ownership changes.

We engage trusted third-party service providers to assist in delivering our Services. These providers are contractually bound to process personal information solely for the purposes we specify and in accordance with this Privacy Notice and applicable data protection laws.

3.3. Use of Tracking and Cookies

Our platform employs cookies and related tracking mechanisms (including but not limited to web beacons and pixel tags) to collect usage data during your interaction with our Services. Certain tracking technologies are essential for maintaining platform security, preventing system failures, addressing technical issues, retaining user preferences, and enabling core functionality.

We additionally authorize third-party service providers to deploy tracking technologies across our Services for analytical and advertising purposes. Such technologies enable these providers to manage advertisement delivery, and implement remarketing campaigns (subject to your communication preferences). These authorized providers utilize their proprietary technologies to deliver relevant advertisements about products and services, which may appear within our Services or across other digital properties.

Please review the specific tracking and cookie use under Section 1.3. and 2.3. depending on your data subject group.

What are Cookies: Cookies are small text files that websites place on your device to store information about your preferences, improve your experience, and help the website operator understand how people use their site. Similar tracking technologies like web beacons, pixels, and tags work in comparable ways.

Cookie Management: You can control cookies through your browser settings:

Popular browsers provide these controls at:

Please note that blocking certain cookies may impact website functionality.

Each third-party partner processes data according to their own privacy policies, which we encourage you to review.

3.4. How long we keep personal information

Your personal information shall be retained only for the duration necessary to fulfill the purposes outlined in this Privacy Notice, except where extended retention periods are mandated or permitted by law, including but not limited to tax regulations, accounting requirements, or other legal obligations. The purposes described herein do not necessitate retention of your personal information beyond a period of two years.

Upon cessation of legitimate business necessity for processing your personal information, we shall either permanently delete or irreversibly anonymize such data. In instances where immediate deletion or anonymization is not technically feasible (such as data stored in backup systems), such personal information shall be securely maintained in isolation from active processing until permanent deletion becomes technically practicable.

Email addresses submitted through the "Email My Size" feature are retained only for the period necessary to deliver the measurement result email. Where the email address and marketing consent are transmitted to the store operator's platform, subsequent retention is governed by the store operator's own privacy policy and data retention practices.

3.5. Security

Our organization maintains comprehensive technical and organizational security protocols designed to safeguard all personal information under our control. These security measures are regularly evaluated and updated to protect data during processing, transmission, and storage.

Notwithstanding these protective measures, please be advised that no method of electronic transmission or digital storage system can ensure absolute security. While we employ industry-standard protections, we cannot guarantee complete immunity from unauthorized access, acquisition, or alteration of your information by third parties who may circumvent our security infrastructure. Therefore, any transmission of personal information in connection with our Services carries inherent risks. We recommend accessing our Services only through secure networks and environments to minimize potential vulnerabilities.

3.6. Collection of information of minors

Our Services are intended solely for users aged 18 and above. We neither intentionally gather information from nor direct marketing activities toward individuals under 18 years of age. Furthermore, we do not engage in the sale of personal information belonging to minors under 18.

Your use of our Services constitutes an affirmation that you have reached the age of majority (18 years) or are a parent/legal guardian consenting to a minor dependent's use of the Services. Upon discovery of any personal information collected from users under 18, we shall promptly terminate the associated account and implement reasonable procedures to delete such data from our systems. Please notify our Data Protection team at dpo@r11n.io if you become aware of any information we may have inadvertently collected from individuals under 18.

3.7. Data Subject Rights

Residents of certain jurisdictions (including the EEA, UK, Switzerland, and Canada) are entitled to specific rights under their respective data protection laws. These rights encompass: accessing and obtaining copies of your personal information; requesting corrections or deletion; limiting information processing; exercising data portability where applicable; and exemption from automated decision-making. To exercise these rights, contact us through the methods outlined in our "Contact Information" section.

Each request will be evaluated and addressed in compliance with applicable data protection regulations.

EEA and UK residents may file complaints with their respective data protection authorities (EU and for UK) if they believe our processing activities violate applicable laws. Swiss residents may seek recourse through the Federal Data Protection and Information Commissioner.

Direct privacy-related inquiries to dpo@r11n.io.

3.8. Do-not-track Features

We acknowledge that various web browsers, mobile operating systems, and applications offer Do-Not-Track ("DNT") functionality to indicate your tracking preferences for online activities. However, due to the current absence of a standardized implementation protocol for DNT signals across the digital ecosystem, our systems do not presently recognize or process such signals. Should industry-wide standards for DNT signal processing be established and legally mandated, we will update our practices accordingly and notify you through revisions to this Privacy Notice.

Specific to California privacy regulations, we are required to disclose our response to DNT browser signals. Given the lack of established industry or legal standards regarding DNT signal recognition and processing, we do not currently alter our data collection practices in response to these signals.

4. Policy Updates

This Privacy Notice may be periodically revised to reflect changes in our practices. Material updates will be indicated by a new "Last Modified" date at the beginning of this Notice. We reserve the right to notify you of significant changes either through prominent website notifications or direct communications. Regular review of this Privacy Notice is recommended to stay informed about our data protection practices and your privacy rights.’

5. Review, Edit or Delete Personal Information

Subject to the privacy laws of your jurisdiction (country or U.S. state of residence), you may be entitled to: request details about your personal information in our systems, understand our processing activities, rectify inaccurate data, obtain copies of your information, or request its deletion. Additionally, you may have the right to revoke previously granted authorization for processing your personal information. Please note that certain legal restrictions may limit the exercise of these rights.

To exercise your data privacy rights or manage your personal information, please submit your request to dpo@r11n.io.

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