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Data Protection Information - Smartfit Integration

Overview​

This page provides technical and data protection information for merchants, integration partners, and data protection officers who integrate SmartFit into an online shop.

It serves as B2B documentation for the technical integration of the service and complements the respective privacy information of the shop.

This documentation is primarily intended for:

  • technical integration partners
  • product managers
  • data protection officers on the merchant side

This page is not an end-user privacy notice.

Roles and Responsibilities​

Controller​

The respective online shop acts as the controller for the integration and use of SmartFit within its shop environment. The shop is responsible in particular for:

  • the legal assessment of the integration
  • its end-user privacy information
  • the configuration of any consent management system

Data Processing on Behalf​

SmartFit (Radlabor GmbH) processes personal data as a data processor pursuant to Art. 28 GDPR on behalf of the respective shop, unless explicitly stated otherwise.

Technical Storage Mechanisms​

SmartFit does not use traditional cookies for advertising, marketing, or cross-site tracking. For the operation of the service, the following browser-side storage mechanisms may be used.

Session Storage​

Session Storage is used to store temporary technical session information during an active browser tab session.

Purpose:

  • maintaining the current widget state
  • synchronizing interactions during usage

Storage duration:
Session Storage is automatically cleared when the browser tab is closed or reloaded.

Local Storage​

SmartFit may store a pseudonymous session identifier in the browser’s Local Storage. This session identifier is only created after a user actively starts a SmartFit function.

The Local Storage contains only the following information:

  • a pseudonymous SmartFit session ID

The following information is not stored in the browser:

  • body measurements
  • leasing or financing data
  • marketing or tracking identifiers

Purpose of the Session Identifier​

The session identifier is used to:

  • technically associate repeated SmartFit interactions on the same device
  • prevent unnecessary duplicate sessions
  • maintain continuity of a SmartFit interaction initiated by the user

Depending on the specific implementation, the session identifier may also allow previously processed SmartFit inputs or results to be reassociated with the same SmartFit session when the service is used again on the same device.

This may allow, for example:

  • continuing an interrupted SmartFit interaction
  • pre-filling previously entered inputs

The session identifier automatically expires after 30 days of inactivity.

Categories of Processed Data​

Depending on the SmartFit feature used, the following categories of data may be processed.

Technical Data​

  • IP address (where technically required)
  • browser and device information
  • session identifiers and technical configuration data
  • shop, product, or feature identifiers

Functional User Inputs​

  • body measurements entered by the user
  • product-related information used to generate size recommendations
  • leasing or calculation parameters where applicable

Such inputs may be processed server-side on behalf of the shop as part of the service.

They are not stored in the browser’s Local Storage, unless explicitly described for a specific implementation.

Purpose of Processing​

Data processing is carried out exclusively for the following purposes:

  • technical provision of the SmartFit service
  • execution of the function requested by the user (e.g. size recommendation)
  • application stability and synchronization
  • error analysis and misuse prevention
  • reconnecting a previously initiated SmartFit interaction
  • avoiding unnecessary duplicate sessions
  • contractual documentation and billing towards the merchant

SmartFit does not use data for:

  • advertising
  • marketing profiling
  • cross-site tracking
  • cross-shop user profiles.

GDPR​

Where personal data is processed through SmartFit, this generally takes place within the framework of data processing on behalf pursuant to Art. 28 GDPR on behalf of the respective shop.

The legal basis for the collection and use of data with respect to the end user is determined by the respective shop.

Storage on the User’s Device (§ 25 TDDDG)​

The storage of information on a user’s device or access to such information must be assessed separately under Section 25 TDDDG.

From a technical perspective, the storage described above serves the provision and continuity of a SmartFit function actively requested by the user.

In particular:

  • only a pseudonymous session identifier is stored in the browser
  • the identifier is created only after active use of the service
  • the storage is not used for advertising, tracking, or profiling purposes

Where the session identifier also enables the continuation or restoration of a previously initiated SmartFit interaction on the same device, this is considered a functional extension of the same user-initiated interaction.

The final legal classification within the shop environment, including any configuration of a consent management system, remains the responsibility of the respective shop as controller.

Storage Location and Retention​

Processing generally takes place within the European Union or the European Economic Area.

Retention periods:

Session Storage
→ until the browser tab is closed or reloaded

Local Storage
→ automatic expiration after 30 days of inactivity

Server-side data
→ retained only as long as necessary for

  • technical operation
  • security purposes
  • documentation
  • billing

Data Subject Rights​

Since the respective online shop acts as the controller, requests from data subjects should generally be addressed to the shop.

SmartFit supports the shop in fulfilling its obligations within the scope of data processing agreements.

FAQ​

Is SmartFit a tracking technology?​

No.

The storage mechanisms described above are not used for advertising, cross-site tracking, or cross-shop user profiling.

Can the session identifier enable a convenience feature?​

Yes.

Depending on the implementation, the pseudonymous session identifier may allow a previously initiated SmartFit interaction on the same device to be recognized and resumed.

This may allow, for example:

  • continuing an interrupted interaction
  • pre-filling previously entered inputs.

However, only the session identifier itself is stored in the browser, not the user inputs.

This depends on the legal assessment of the respective shop and its consent management setup.

From a technical perspective, the storage described above supports the provision of a user-requested SmartFit function and is not used for advertising or analytics purposes.

Some merchants may nevertheless decide to include such mechanisms in their consent management systems as part of their compliance or risk management approach.

This information does not constitute legal advice.

Merchants should consult their own legal or data protection advisors for a binding legal assessment.