This Privacy Notice describes how ReFiProcity (“we”, “us”,“our”) collects, uses and discloses information about you when you use our website (https://www.refiprocity.com), applications, services, tools and features, or otherwise directly or indirectly interact with us (collectively, the “Services”).For the purposes of this Privacy Notice, “you” and “your” means you as the user of the Services. For the purpose of applicable data protection laws, we are the data controller.
Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Services.
We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to how we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.
When you use or access the Services, we collect certain categories of information about you.
Some features of the Services may require you to directly provide certain information. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Such information may include:
Information We Collect
·Basic contact details, such as name, title, email address, and phone number. We use this information to create and maintain your account and provide the Services, as required to perform our contract with you, and because it is in our legitimate interest to communicate with you (including to tell you about products or services that may be of interest to you, to the extent you have consented to receiving marketing communications from us).
·Any other information you choose to include in communications with us, for example, when sending a message through the Services, because it is in our legitimate interest to be responsive to you.
We may disclose your information for legitimate purposes subject to this Privacy Notice, including to the following categories of third parties:
·Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, customer relationship management, and web analytics.
·Third parties for marketing purposes based on your consent.
·Third parties to whom you request or direct us to disclose information, such as through your use of social media widgets, with your consent or to perform our contract with you.
·Professional advisors, such as auditors, law firms, or accounting firms, as a matter of our legitimate interests to assess, protect, enforce and defend our rights and to comply with our legal and regulatory obligations.
·Third parties in connection with or anticipation of an asset sale, merger, bankruptcy, or other business transaction, as a matter of our legitimate interests to run a successful and efficient business.
We may also disclose your information as needed to comply with applicable law or any obligations thereunder or in our legitimate interests to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.
Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to access our pages on third-party platforms, and from there “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. For more information, see the section below, Third Party Websites and Links.
We may provide links to third-party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.
Our Services are not intended for children, and we do not seek or knowingly collect any personal information about children. If we become aware that we have unknowingly collected information about a child, in particular any child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.
Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.
We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property, or products. In particular, we retain certain of your information as follows:
·your account data for as long as you keep your account open or as needed to provide you with our Services;
·if you contact us, we will keep your communication with us for 3 years after you contact us, unless required by law to retain it for longer; and
·data on your use of our Services is retained until it is used to further develop our analytics capabilities, at which point it can no longer be used to identify you.
If you are resident of the European Economic Area (EEA) or United Kingdom (UK), please note that the information we collect from you may be stored and processed in countries outside the EEA and UK. For any transfers of data from the EEA or the UK, the data transfer will be under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the EU standard contractual clauses) or the UK Information Commissioner’s international data transfer addendum to the EU standard contractual clauses, as relevant. Please contact us should you wish to examine a copy of these clauses.
California law permits users in California to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is disclosed to third parties for direct marketing purposes. If you are a Shopper, we may disclose certain “personal information” about you to the Brands to whom you submit offers using the Services, who may use your information for their own direct marketing purposes. California users may, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information disclosed and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year. To make such a request, please contact us using the information listed below. Please note that we are only required to respond to one request per California resident each year.
Depending on your location, you may have certain rights in relation to your personal data. Please note that a number of these rights only apply in certain circumstances and in certain locations, and all of these rights may be limited by law. To exercise any of these rights, you can contact us at the email address provided below:
·Access: You have the right to access the personal data we hold about you, and to obtain information about how we use it, and who we share it with.
·Portability: You have the right to receive a copy of the personal data we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
·Correction: You have the right to correct any of your personal data we hold that is inaccurate.
·Erasure: In certain circumstances, you have the right to delete the personal data we hold about you.
·Restriction of processing to storage only: You have the right to require us to stop processing the personal data we hold about you, other than for storage purposes, in certain circumstances.
·Objection: You have the right to object to our processing of your personal data in certain circumstances.
·Objection to marketing: You can object to marketing at any time by opting-out using the unsubscribe / opt-out function displayed in our communications to you. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you administrative messages that are required to provide you with the Services.
·Withdrawal of consent: Where we rely on consent to process your personal data, you have the right to withdraw this consent at any time by contacting us at the email address provided below.
·Complaints. You have the right to complain to your local data protection authority about how we process your personal data. Of course, we hope you will contact us first so we can resolve any issues.
Should you have any questions about our privacy practices or this Privacy Notice, please email us at help@refiprocity.com.