Browzwear – 3D Fashion Design System

Privacy Policy - March 2023

Browzwear Group, comprised of the entities listed on  the Browzwear Group Entities List (“BW Entities List”), develops and operates a 3D Fashion Design System (the “System”) accessible, on subscription base, on-line,  through a browser (or with a local installed module, or a combination of both)*.

*Detailed information about the System and its use options, is published on the Browzwear Group website at the address: (the “Site”)

BW Regional Entities (as defined in the BW Entities List) interacts with potential customers and engages with customers (for purchasing subscriptions to use the System and related services, such as training and support), each in a specified territory as detailed in the BW Entities List. Each of the BW Regional Entities also provides services (such as training and support) to its customers’ users.

In order to enable ‘around the clock’  services to each of BW Regional Entities’ customers, and in order to enable maximum availability to potential customers: (i) BW Regional Entities assist each other in service provision (each acting for and on behalf of the BW Regional Entity that engaged with the customer) (ii) BW Development Entity (as defined in the BW Entities List and which is ISO 27001 Certified) that operates the System and BW Regional Entities assist each other in demonstrations and in reply to inquiries of potential customers.

BW Group Entities (“We” or “BW Group”) respects privacy. This privacy policy explains what personal information BW Group Entities collects, how and for what purposes it is processed, when and for what purposes it is transferred to third parties, and data subjects’ rights in relation to such personal information.

Please note that You are not legally required to provide personal information to any of BW Group Entities, however without providing personal information You might not be able to receive answers to Your inquiries, to purchase a subscription to use the System (from the BW Regional Entity that operates in the territory You are residing in), to use the System or receive related services.
Please also note that in order to use the System, receive information or services in relation to the System, You agree to, and authorize the BW Regional Entity that you engaged with (or any other BW Group Entity that you interacted with, as the case may be), to transfer your personal data* to other BW Group Entities and any of their sub-processor**.

* To assure appropriate protection to personal data and lawful cross border data transfers, BW Group Entities entered into a binding agreement among them (in addition to administrative and technological security measures that they maintain).

** Sub-processors are third parties that provide tech tools and services in relation to the System. For more information on sub processors please see below.

Information We Receive and Collect

Visiting the Site – If You just visit the Site and you are not a User (i.e. an authorized user of a customer of any of BW Regional Entities) no more information is collected other than is typically collected in server logs by web sites in general such as IP address, your browser type etc. Simply visiting the Site, does not expose your identity. However,  please note that your network IP address, depending on your connection, may be traceable.

We also use cookies* on our Site for functional, analytics and performance and purposes. Visitors can reject and manage such use of cookies with the cookies management tool implemented on the Site.

* Generally, Cookies are packets of information sent to (or generated by a command of a website) users’ device for record keeping purposes. Cookies may contain information such as: IP address, browser type, operating system type, and other ‘user information’. Cookies serve various purposes such as: functional, analytics, performance, personal advertisements.

Some Cookies expire when the session ends, and the user closes the browser. Other cookies are stored on the users’ device for a limited or unlimited period.

All major browsers allow blocking or deleting cookies. Blocking or deleting some cookies may reduce functionality or disable the use of certain services.

For more information on cookies and how to block or delete cookies (in addition to the cookies management tool implemented on the site) please visit:

Contacting BW Entities – when contacting BW Entities, We collect first and last name, email address, and workplace (if provided).

Becoming a customer – Entities – when entities subscribe to use the System (from a BW Regional Entity), the BW Regional Entity collects the first and last name, email address, workplace and role of the customer’s contact persons (such as administrative contact, CTO, accounts representative etc.).

Becoming a customer – Natural Persons – when natural persons subscribe to use the System (from a BW Regional Entity), the BW Regional Entity collects the first and last name and email address, address, and phone number.

Users – Administrator Account – each customer is provided with an Administrator Account (“User Administrator”). The BW Regional Entity collects the first and last name, email address, phone number (and sometimes additional contact details) of the User Administrator.

Users – Users Accounts – In accordance with the scope of subscription purchased by the customer, customers’ User Administrator can set up Users’ accounts and set permissions per each such User including the ability to interact with Users of other customers*). All Users Accounts (of each customer) are managed by the User Administrator (of each customer).

*Detailed information on user accounts is published on the Site.

The BW Regional Entity collects Users account name, first and last name, email address, contact details such as phone number or ‘WeChat account’, and account details – account name and profile picture (if User chose to add a profile picture to their account details).

Users – System Access and Use data – We collect accessing data (such as entry times, IP addresses, device type) and System use data (such as activity logs). 

Cookies in our System  We may use cookies in our System for functional, analytics or performance purposes. For Information how to reject or handle such cookies, please check the cookie management tool implemented on the System.

For more information on cookies and how to block or delete cookies please visit:

Users Content Uploaded to the System – the System stores data uploaded by Users (such data is accessible in accordance with the Users permissions that the User Administrator granted them). Although the System is a ‘working tool’ for fashion design, and therefore the collection and processing of personal data is purely incidental to its use, if a User chooses to upload personal information, such personal information is stored on the System.

We use Users content uploaded to the System for service provision*, on behalf of and for customers. We act as processors of Users content uploaded to the System (each BW Regional Entity is a processor of its customers). *Including for:
  • System operation
  • Security
  • System’s terms of use enforcement

How and for What Purposes We Use Personal Information


Data Security – BW Development Entity – the Entity that operates the System is ISO 27001 Certified. In addition, each of the BW Group Entities operates in accordance with an information security policy and implements technical and organizational security measures which are consistent with industry standards.

These measures include, among others: physical security, equipment protection, network security, limited access, access control, routine review of access privileges, access and use monitoring, encryption, and routine data backups.

Use of Personal Information  We use personal information for the following purposes:

  • To provide Services for customers (including support, assistance, communicating, complying with customers’ requests etc.).
  • Security, cyber protection, and fraud detection.
  • Legitimate business interests, incident to the provision of the services (such as billing, usage monitoring).
  • Complying with applicable laws and regulation.
  • Customer surveys, marketing campaigns, market analysis, or promotional activities.
  • Use of aggregated or anonymized data for Services improvement and further development.

Sharing and Disclosing Personal Information

BW Group Entities share personal data among themselves for: service provision, assistance in marketing, customer relations management, and on aggregated base for BW Group high level management. Such data sharing will usually include only: first and last name, email address, workplace (i.e. name of customer) and role.

We may share data (including personal data) with others in the following instances:

  • With our service providers for provision of the Services (on a confidential basis) including security, cyber protection and fraud detection. A list of our main sub-processors is provided below. A full list is provided to the customer, or to potential customers upon request.
  • If We reasonably believe that You have breached the terms of use of the System.
  • If You perform or attempt to perform any activity which We may reasonably believe to be illegal.
  • If We are required by applicable law to do so.
  • To investigate or handle actual or suspected fraudulent or criminal activities.
  • In any case of dispute, or legal proceedings.
  • When We reasonably believe that sharing information is necessary to prevent physical damage or serious damage.
  • When We reasonably believe that sharing is required in order to comply with your instructions.

Data Portability

  • During the subscription period, the customer may request to export any or all data uploaded to the System by its Users and We will comply with such requests in a timely manner, provided that in case that such a service requires more than 2 working hours, We may charge a fee for ‘actual working hours’ (to be approved in advance by the customer).

Data Retention and Deletion

  • During subscription, customers may delete at any time any or all of the content uploaded to the System by their Users*.
  • 120 days after the subscription ends all content uploaded by a customer’s Users will be deleted*.

*Save for interactions of their Users with Users of other customers, unless or until, as the case may be, all parties to an interaction (i.e. all customers that their Users participated in an interaction) request us to delete an interaction.

  • We may retain data about Users use of the System for 24 months or for a longer duration if required by applicable law (for security and System operation). We may also aggregate such data and retain it for longer periods.
  • We retain data about customers (such data may include personal information such as contact persons of customer) as required by applicable law.

Data Access

Customer is entitled to access all information relating to its Users stored in the System. Most of such information is accessible to customers through their User Administrator account.

If customers encounter inaccurate information, or believe that certain details are incorrect, they may ask the BW Regional Entity with which they engaged with for correction or removal of such information.

Amendments to this Privacy Policy

  • We may amend the terms of this privacy policy from time to time subject that such change will become effective after 30 days from its publishing, unless it is for Customers’ benefit, due to legal requirement or due to instruction of an authorized authority. We recommend that you read the privacy policy periodically.
  • If you disagree with an amendment (excluding technical amendments, or amendments in your favor) you may terminate the subscription without termination costs by providing us written termination notice within 30 days from the day the amendment became effective.
EU Customers and Customers Subject to the GDPR*

If you are a customer or a potential customer and in addition: (1) an entity established in the EU; or (2) located in the EU and your use of the system involves processing of personal data and such processing is subject to the GDPR, you may ask the BW EU Regional Entity to execute a data processing agreement in accordance with the provisions of the GDPR under which BW EU acts as a processor for content uploaded by Your users to the System.

You may also contact BW EU Regional Entity to exercise (or for assistance in exercising) any of your rights under this privacy policy / the GPDR. If you believe that any of rights were infringed, you may lodge a complaint with a supervisory authority. 

*GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data

Lists of Main Sub Processors

Sub-processors Name Service Name Location Purpose
Amazon AWS Ireland, US, Singapore, China Cloud services
Microsoft Azure US Cloud services