TrueFit3D Privacy Policy

Privacy Policy for the TrueFit3D Scanning Application

Effective Date: 16 April 2025

1. Introduction

This Privacy Policy applies to the TrueFit3D Scanning Application (the “App”), developed and operated by The Masuri Group Ltd (“Masuri”, “we”, “us”, or “our”). The App is used by authorised users such as retailers and professional sports partners (e.g. elite cricket teams) to scan individuals’ heads and submit related data to Masuri for the production of a 3D printed, custom-fit helmet liner, known as TrueFit3D.

Our registered office is:

The Masuri Group Ltd

Unit F, Wykeham Industrial Park

Moorside Road

Winchester, Hampshire

UK SO23 7RX

Email: info@masuri.com

2. Purpose of the App

The App is designed for use by authorised users only — including Masuri retailers and professional sports partners — to collect and submit scan data from individuals (“Data Subjects”) for the purpose of manufacturing a bespoke, 3D printed helmet liner as part of Masuri’s product offering.

The App is not intended for consumer use. It is the responsibility of the authorised user to obtain appropriate consent before collecting and submitting personal data.

3. Information Collected by the App

a. Head and Scan Data

The App collects the following personal data from individuals being scanned:

3D Head Scan Data
Photographic Images
Personal Details (e.g. name, contact info, delivery address, order reference)
Device Information (e.g. device type, operating system, app version)

This data is transmitted securely to Masuri and used solely for order fulfilment.

b. Use of Apple TrueDepth API

When using compatible Apple devices, the App utilizes the TrueDepth API to collect:

Depth and RGB data of each frame from the front-facing TrueDepth camera
Camera metadata, including intrinsic matrix and distortion map

This information is used to perform a depth fusion process, generating a colored 3D mesh of the scanned object. The resulting mesh can be viewed and shared by the user. The raw data is not shared with any third parties and is used solely for generating the 3D mesh.

4. Storage of Scan and Camera Data

During the scan process, all raw data (depth, RGB, metadata) is stored temporarily in the App’s internal documents folder.
These temporary files are overwritten with each new scan, and are also deleted if the user logs out or uninstalls the App.
The App may allow users to store or share the generated 3D mesh or upload it to a secure Masuri server, where it can be deleted upon request.

5. Face Data Handling Policy

Although the App is not designed for capturing 3D face data, it is technically possible for users to do so.

We do not recommend using the App to scan facial data, as it is classified as sensitive biometric data.
In the event that facial data is captured and uploaded to our cloud server:

Masuri will not use, disclose, or share facial data with any third party.
Facial data will be retained for a maximum of one (1) year and may be deleted at any time at Masuri’s discretion.

6. How We Use the Data

Masuri uses data submitted via the App to:

Design and produce the custom-fit TrueFit3D helmet liner
Communicate with the submitting authorised user (retailer or partner)
Improve the App and scanning quality
Ensure security and integrity of order fulfilment processes

We do not use the data for advertising or marketing purposes without explicit consent.

7. Legal Basis for Processing

We process data on the basis of:

Legitimate interest – fulfilling custom product orders
Consent – which must be obtained by the authorised user before scanning and submission

8. Sharing of Personal Data

We may share data with:

Internal personnel and systems involved in order processing and production
Trusted third-party services used strictly for data storage or technical operations, under appropriate data protection agreements
Legal authorities if required by applicable law

We do not sell or share data for advertising or unrelated third-party use.

9. Data Security and Retention

All personal data is encrypted in transit and at rest
Access is limited to authorised personnel
Scan data is retained only as long as necessary to fulfil its purpose, or to comply with legal or quality obligations
Facial data, if captured, is subject to additional restrictions (see Section 5)

10. Rights of Individuals (Data Subjects)

Individuals whose data is submitted via the App have the right to:

Access their personal data
Request correction of inaccurate data
Request deletion of data (subject to retention obligations)
Object to or restrict processing

Requests can be made directly to info@masuri.com or through the submitting authorised user.

11. Changes to This Privacy Policy

We may update this policy periodically. Changes will be made available in the App and/or on our website. Continued use of the App by authorised users implies acceptance of any updates.

12. Contact Us