Privacy Policy
What a fitting session collects, why, and how to get it back.
Draft for review. This document was prepared as part of the Wristcraft site build and has not been reviewed by counsel. Confirm the entity details, retention periods and jurisdiction clauses with your lawyer before launch.
Wristcraft Atelier S.r.l. (“Wristcraft”, “we”, “us”) runs the fitting app and the site at wristcraft.app. This policy explains what personal data we collect when you run a fitting session, order a build or talk to the concierge, why we collect it, how long we keep it and what you can do about it. It covers the app, the site, our email programme and our support channels.
1. Who is responsible
The data controller is Wristcraft Atelier S.r.l., Via dei Serragli 108, 50124 Firenze, Toscana, Italy. VAT IT 04812390488, REA FI-612904. Our privacy contact is privacy@wristcraft.app. We have not appointed a Data Protection Officer; we are below the thresholds in Article 37 GDPR, and the privacy address reaches the person who is actually accountable.
2. What we collect
- Fitting data. The watch reference you enter, the lug width and lug-to-lug span the Caliper fit engine resolves or you override, your wrist circumference, the answers you give to the wear-pattern questions (how you wear it, how tight, over or under a cuff, desk work or wet work), and any caseback or lug photographs you upload so we can confirm the spring-bar geometry.
- Account data. Email address and a hashed password if you create an account, plus your saved watches and saved wardrobes.
- Build and order data. The build specification you confirm — leather, thickness, taper, curve, stitch, hardware, length — together with your name, shipping and billing address, phone number, order history and any concierge notes attached to the build.
- Payment data. Handled by our payment processor inside their own hosted frame. We receive the last four digits of the card, the card brand and the authorisation result. We never see or store the full card number.
- Support data. Messages you send the concierge, and photographs you attach to a fit query, warranty claim or repair.
- Marketing data. Your email address and subscription status if you opt in, plus whether our emails were opened or clicked.
- Technical data. IP address, browser and device type, screen size, whether your device can render the 3D preview, referring page and pages viewed. See the Cookie Policy for the detail.
You can run a fitting session without an account. In that case the session lives in a strictly-necessary cookie on your device and we hold the measurements against a random session identifier, not against you.
3. Why we use it, and on what legal basis
| Purpose | Data used | Legal basis (GDPR Art. 6) |
|---|---|---|
| Running a fitting session and resolving your reference against the fit database | Fitting, technical | Performance of a contract, or our legitimate interest before you register |
| Generating and rendering your wardrobe | Fitting, account | Performance of a contract |
| Cutting, stitching and shipping a build | Build, fitting, payment | Performance of a contract |
| Confirming spring-bar and lug geometry from an uploaded photograph | Fitting (photographs) | Performance of a contract |
| Concierge support, fit guarantee, warranty and repairs | Build, support | Performance of a contract |
| Improving the accuracy of the fit database | Fitting, aggregated and stripped of identifiers | Legitimate interest |
| Fraud and chargeback prevention | Build, payment, technical | Legitimate interest |
| Tax, customs and accounting records | Build, payment | Legal obligation |
| Newsletter, wardrobe reminders and product announcements | Marketing | Consent |
| Measuring how the app and site are used | Technical | Consent (analytics cookies) |
Where we rely on legitimate interest we have balanced it against your rights and recorded the assessment. You can object at any time using the address in section 7.
4. Who we share it with
We do not sell personal data and we do not use your fitting data to profile you for advertising. We share data only with processors who need it to run the atelier, under a written Article 28 agreement and only for the purpose we specify:
- Payment processing and fraud screening.
- Our hosting, storage and CDN providers, inside the EU.
- The email platform that sends order confirmations and, if you opted in, the newsletter.
- Carriers and customs brokers, to deliver your build and clear it into your country. They receive name, address, phone number and a customs description — never your measurements.
- Our leather and hardware suppliers, who receive a cut sheet with dimensions and a build number. No name, no address.
- Our accountants and, where a dispute needs it, our lawyers.
- Authorities, where we are legally required to disclose.
A current list of sub-processors is available from privacy@wristcraft.app on request. We will tell subscribers before we add a sub-processor that handles fitting data.
5. International transfers
Our infrastructure sits in the EU — Frankfurt for the application and Milan for object storage. Two processors, our email platform and our error-reporting service, may process data in the United States. For those we rely on the European Commission’s Standard Contractual Clauses together with a transfer impact assessment, or on an adequacy decision where one applies. Copies of the clauses are available on request.
6. How long we keep it
| Data class | Retention | Why |
|---|---|---|
| Fitting measurements on an account | 24 months from last use | So a returning collector does not have to measure their wrist and lugs again. Rolling: each new session resets the clock. |
| Fitting data with no account | 30 days | Long enough to come back and finish a session. |
| Uploaded caseback and lug photographs | Deleted 90 days after the build ships | Kept only long enough to settle a fit dispute. Deleted on request sooner. |
| Build specifications and cut sheets | 5 years | Warranty is two years and a remake needs the original spec. |
| Invoices and order records | 10 years | Required by Italian tax and civil law. |
| Account data | Until you delete the account, then 30 days in encrypted backups | Backup rotation. |
| Concierge conversations | 3 years from the last message | Context for repeat work and dispute defence. |
| Newsletter data | Until you unsubscribe, plus a permanent suppression record | So we do not email you again by accident. |
| Analytics data | 14 months | Year-on-year comparison, then gone. |
7. Your rights
Under the GDPR you can ask us to give you a copy of your data, correct it, delete it, restrict how we use it, object to processing based on legitimate interest or direct marketing, and send your data to another provider in a portable format. Where we rely on consent you can withdraw it at any time, which does not affect processing that already happened.
To exercise a right, email privacy@wristcraft.app from the address on your account. We respond within one month and can extend by two further months for a complex request, telling you why. We do not charge for a request and we will not treat you worse for making one.
Deleting an account deletes your saved watches, wardrobes and measurements. It does not delete invoices we are legally obliged to keep, or the cut sheet for a build still inside its warranty.
8. Complaints
If you think we have handled your data badly, tell us first — we would rather fix it. You also have the right to lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Roma, or with the authority in your own country of residence.
9. Security
Traffic is encrypted with TLS 1.3. Passwords are hashed with Argon2id. Uploaded photographs are stored encrypted at rest and served only through signed, expiring links. Access to customer records is limited to the concierge and atelier staff who need it, protected by hardware-key multi-factor authentication and logged. If a breach affects your data and poses a risk to you, we notify the Garante within 72 hours of becoming aware and tell you without undue delay.
10. Children
The app is not directed at children under 16 and we do not knowingly collect their data. If you believe a child has given us personal data, write to the privacy address and we will delete it.
11. Changes
If we make a material change we publish the new version here and email account holders at least 14 days before it takes effect. The date at the top of this page always reflects the version in force.