How PENTAX Measure handles your data

1. Who we are

The controller is [LEGAL ENTITY], company number [COMPANY NUMBER], registered with the Information Commissioner's Office under [ICO REGISTRATION]. Privacy contact: [PRIVACY CONTACT].

2. What we process

• Camera images: processed on your device only while you use the camera screen. They are never uploaded, stored or logged.
• Face map: a set of points located on your face in each camera frame, used to calculate the measurements. It may be biometric data. It exists only in your phone's memory during the measurement and is then discarded.
• Measurements: your pupillary distances, nose-pad geometry and the margin of error of each value, in millimetres and degrees.
• Contact details: your name and email.
• Fitting details: your line of work, which sets the working distance for the near PD, and whether you wear glasses under loupes.
• Capture details: phone model and browser, picture size, camera used, whether you used the optional card step, and quality checks, so a fitter can judge how reliable the result is.
• Optional review photo: one picture with the measurement points drawn on, only if you tick that box on the send screen. If you used the optional card step, the card is pixelated on your phone before the picture is sent.

The optional card step uses the front of a card as a size reference only. We never ask to see, and never capture, the numbers on it.

3. Why, and on what legal basis

• To measure and fit your loupes and prepare your quote: taking steps at your request before a contract (UK GDPR Art 6(1)(b)).
• For the face map and measurements, which may be special category biometric data: your explicit consent (Art 9(2)(a)), given on the consent screen.
• To contact you about your fitting, and separately for marketing: your consent, each given by its own unticked box.

You do not have to use the app. We will measure you in person at your fitting, or with a ruler, at no extra cost.

4. On your device, and what leaves it

All picture processing happens in your browser. Only the measurements, your contact details, your consent record and the capture details are sent to PENTAX Loupes UK, plus the optional review photo if you opted in.

5. Who receives your data

• PENTAX Loupes UK fitting staff, through our customer system.
• Vercel Inc., which hosts the app in London (UK). [Confirm plan tier and the UK Extension to the EU-US Data Privacy Framework.]
• [EMAIL PROVIDER, REGION] for service emails.
• No advertising or analytics companies. No session recording on any camera screen.

6. How long we keep it

• Camera images and the face map: not kept at all.
• Measurements and contact details: until you withdraw consent, or [N] months after a quote that does not lead to an order; for orders, for the contract and warranty period.
• Optional review photo: 12 months.

7. Your rights

You can withdraw consent at any time from the result screen, at /withdraw with your reference, or by contacting [PRIVACY CONTACT]; we then delete your measurements. You can ask for access, correction, erasure or restriction, and object to processing. You can complain to us at [PRIVACY CONTACT] (we acknowledge within 30 days) and to the Information Commissioner's Office at ico.org.uk.

8. Decisions and accuracy

No decision about you is made automatically. A fitter reviews every result. The app gives estimates with a stated margin of error and will refuse to give a pupillary distance when it cannot be confident enough. It does not infer ethnicity, health or age.

9. Storage on your device

The app keeps your progress in your browser's session storage and caches the face-measurement model so it loads quickly. Both are strictly necessary for the service and are cleared when you close the tab or your browser clears site data.

10. Children

The app is for adults only. We do not knowingly process measurements from anyone under 18.

11. Changes

Version 2026-09-18-draft. [DATE]. Change log: first draft.