Recurate, privacy policy. 

Effective Date: June 12, 2021
 

Sections:

  • Overview

  • Personal Information We Collect and How We Use It

  • How We Use Your Personal Information

  • How We Disclose Your Personal Information

  • Your Privacy Rights and Choices

  • Security of Your Personal Information

  • International Data Transfers

  • Personal Information of Children

  • Notice to California Residents

  • Notice to Nevada Residents

  • Supervisory Authority

  • Changes to this Privacy Policy

  • Contact Us

 

Overview
Recurate, Inc. (“Recurate”, “we”, or “us) knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Privacy Policy explains how we collect, protect, use and share Personal Information about you when you use our Website and any of our services that we created for the purposes of using the Website or our services (collectively, the “Services”), and whether you access the Website directly or through a third-party website or via one or more of the Services. “Personal Information,” as used in this Privacy Policy, is information that allows the direct identification of an individual, such as a name or email address, and information that is directly combined with such identifying information.
 
This Privacy Policy does not apply to any of the Personal Information that our business clients (“Brand Partners”) may collect and process using their own services (“Client Data”). Our Brand Partners’ respective privacy policies govern their collection and use of Client Data. Our processing of Client Data is governed by the contracts that we have in place with our Brand Partners, not this Privacy Policy. Any questions or requests relating to Client Data should be directed to our Brand Partner. In the event that that our Website links to other websites that include our branding, this Privacy Policy does not apply to those other websites. Visitors to those websites are advised to carefully read the policies on those individual websites.

Personal Information We Collect and How We Use It
We collect the following types of Personal Information: (1) information that you voluntarily submit to us (“User-Submitted Information”); (2) technical data automatically collected from all visitors to the Website, and individuals that use the Services (“Automatic Data Collection”); and (3) information collected from other sources, including our Brand Partners. Our primary purpose in collecting Personal Information is to provide you with a safe, smooth, efficient, and customized experience. We only collect Personal Information about you that we consider necessary for achieving this purpose. We describe each of these types of collection in further detail below.

 

1.    User-Submitted Information

We may collect information that you submit to us directly, as described below. 

Services
If you use Recurate’s services, we request certain Personal Information from you, such as your contact information (including name, shipping address, telephone number). We use this information for billing purposes and payment purposes and to fill your orders. If we have trouble processing an order, we will use this information to contact you.
 
Surveys or Contests
We may provide you the opportunity to participate in surveys or contests on our site or our Brand Partners’ sites. If you participate, we will request certain Personal Information. The requested information typically includes contact information (such as name and shipping address) and demographic information, such as your age range and zip code.
 
We use this information to notify contest winners and award prizes, to monitor Website traffic, or to personalize the Website (in the case of anonymous information collected in surveys) and to send participants an email newsletter. By participating in a survey or contest you submit to that activity’s terms and conditions, including providing us with permission, if required, to share your Personal Information with sponsors of that survey and/or contest.
 
We may use a third-party service provider to conduct these surveys or contests, in which case the third party's service providers use of our users’ Personal Information will be governed by its privacy policy, which will be made available to users at the time they enroll for the survey or contest.
 
Product Discussion/Q&A
If you choose to post messages on a public forum or page (e.g., messages or questions to the seller, reviews regarding your purchases), please note that such information is available to anyone with Internet access. We may, but are not obligated to, collect the information you post to resolve disputes, provide customer support and troubleshoot problems as permitted by law. 
 
2.    Automatic Data Collection

We may automatically collect certain personal information based upon your use of the Website or our Services. We may use this information to do internal research and enhance our Website and Services.
 
Website and Services Usage
We may collect certain information automatically when you use our Website or Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. 
 
Cookies, Pixel Tags/Web Beacons, and Other Technologies
Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. We may use cookies and other tracking technologies on the Website and Services. This Privacy Policy covers the use of cookies by Recurate only and does not cover the use of cookies by any advertisers or other third-parties.
 
Our uses of these Technologies fall into the following general categories: 

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;

  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);

  • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

  • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

  • For more information about cookies, web beacons and how to opt out of third-party data collection, please see the “Your Privacy Rights and Choices” section of this Privacy Policy.

 

Analytics

We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include: 

  • Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

  • FullStory. For more information, please visit FullStory’s Privacy Policy. To learn more about how to opt-out of FullStory’s use of your information, please click here.

 

3.    Information Collected from Other Sources

We may obtain information about you from other sources, including through our Brand Partners and other third-party services and organizations. For example, if you access our Services through a third-party website or application, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

To use some features of our Services, you may need to register and create a username and password on our Brand Partners’ websites. To use our Services, you are required to give truthful contact and demographic information (including name, email address, and physical address, including city and zip code) as we use this information to provide our Services to you.
 
How We Use Your Personal Information

Provide the Services
We use your information to fulfil our contract with you and provide you with our Services, such as:

  • Listing your items for resale and facilitating payment for your sales;

  • Processing your purchases and the shipment thereof;

  • Managing your information and accounts;

  • Providing access to certain areas, functionalities, and features of our Services;

  • Answering requests for customer or technical support; 

  • Communicating with you about your account, activities on our Services, and policy changes;

  • Processing applications if you apply for a job we post on our Services; and

  • Allowing you to register for events.

Administrative Purposes
We use your information for various administrative purposes, such as:

  • Sharing information with third parties as needed to provide the Services;

  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

  • Measuring interest and engagement in our Services; 

  • Short-term, transient use, such as contextual customization of ads;

  • Improving, upgrading or enhancing our Services; 

  • Developing new products and Services;

  • Ensuring internal quality control and safety;

  • Authenticating and verifying individual identities, including requests to exercise your rights under this policy;

  • Debugging to identify and repair errors with our Services;

  • Auditing relating to interactions, transactions and other compliance activities;

  • Enforcing our agreements and policies; and

  • Complying with our legal obligations.

 

Communication from Us or the Website

 

We may use your contact information to communicate with you about Recurate and our Brand Partners, as described below.
 
Messages about the Service and Your Account
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
 
We will communicate with you in response to your inquiries, to provide the services you request, to manage your account, and to provide the best customer service possible.

 

Address Verification
We use third party software to verify your identity and address, in order to ensure proper shipping and billing procedures for your sales and purchases.


How We Disclose Your Personal Information
 
Brand Partners
Recurate provides certain personal information to our Brand Partners in order to provide the Services, including your usage activity and information relating to your listings, sales, or purchases so that those transactions may be fulfilled.
 
Service Providers
We may provide Personal Information to third parties for their use in performing internal business functions (e.g., mailing, maintenance, security, data analytics, email transmission, CRM, database management services, credit card payment processing or data hosting) on our behalf. These service providers agree to only use your Personal Information in accordance with this Privacy Policy and for no other purpose than to provide us or our Partners with the contracted-for services.
 
Related Parties
We may share some or all of your Personal Information with our affiliates (including a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us), in which case we will seek to require those affiliates to honor this Privacy Policy.
 
As required by Law / Certain Business Transactions
We may disclose Personal Information if we have a good-faith belief that doing so is required by a subpoena or other judicial or administrative order or otherwise required by law or in connection with an actual or proposed corporate transaction or insolvency proceeding involving all or part of the business or asset to which the information pertains. This may include responding to legal requests from jurisdictions outside of the United States, where we have a good faith belief that the response is required by law in that jurisdiction.
 
Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
 
APIs/SDKs
We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth below.

Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.

  • Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

  • Automated Decision Making. We may engage in automated decision making, such as for anti-fraud purposes. Our processing of your Personal Information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth below.

  • De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

  • Other Users/Website Visitors. As described above in “Product Discussion/Q&A,” our Services allow you to share your information with other users and publicly, including to those who do not use our Services.

 
Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

Your Privacy Rights and Choices

Your Privacy Choices. The privacy choices you may have about your Personal Information are determined by applicable law and are described below. 

  • Email and Telephone Communications. If you receive an unwanted marketing email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Privacy Policy). 
     

  • Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

    The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

    Please note you must separately opt out in each browser and on each device. 
     

  • “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

 

Your Privacy Rights. In accordance with applicable law, you may have the right to:

  • Access Personal Information about you, including: (i) confirming whether we are processing your Personal Information; (ii) obtaining access to or a copy of your Personal Information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of Personal Information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”);

  • Request Correction of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information;

  • Request Deletion of your Personal Information; 

  • Request Restriction of or Object to our processing of your Personal Information; and  

  • Withdraw your Consent to our processing of your Personal Information. 

If you would like to exercise these rights, please contact us as set forth below.

 
Security of Your Personal Information
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. The files and records containing your personal information will be kept in our offices and/or on our servers or those of our service providers and only those employees that require it for the purposes of their duties will have access to this file. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.


By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.


International Data Transfers 
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
If we transfer personal information to countries outside the European Economic Area, we will put in place appropriate safeguards to comply with applicable laws and regulations. For more information about these safeguards, please contact us as set forth below.


The files containing your information will be on our servers and those of our service providers and will be accessible to persons that require it for the purposes of their duties. Information may be accessible to the courts and the law enforcement and national security authorities of the United States. To obtain more information about Recurate’s policies and practices with respect to service providers outside of your country, please contact us as set forth below.


Personal Information of Children
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. Recurate and the Website are not directed toward individuals under the age of eighteen (18), and we request that such individuals do not provide Personal Information through our Website. Additionally, we do not knowingly collect or maintain Personal Information from anyone under the age of 18, unless or except as permitted by law. If we learn that Personal Information has been collected from a user under 18 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 18 who has registered on the Website or our Services, or you believe has otherwise provided Personal Information to Recurate, please contact us as set forth below to have that child’s account terminated and information deleted.
 
Notice to California Residents
This Supplemental California Privacy Notice only applies to our processing of Personal Information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of Personal Information Recurate has collected about them and whether Recurate disclosed that Personal Information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

The categories of sources from which we collect Personal Information and our business and commercial purposes for using Personal Information are set forth in “Notice of Information We Collect and How We Use It” above. 

 

“Sales” of Personal Information under the CCPA

California residents have the right to opt out of the “sale” of their Personal Information. Under the CCPA, “sale” is defined broadly and includes the transfer of Personal Information by a business to a third party for valuable consideration (even if there is no exchange of money). For purposes of the CCPA, Recurate does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

 

Additional Privacy Rights for California Residents

Non-Discrimination
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA. 

 

Authorized Agent
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth below and provide written authorization signed by you and your designated agent.

 

Verification
To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include asking you to answer questions regarding your use of our Services.

 

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws. 

 

Accessibility
This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

Notice to Nevada Residents
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have questions or would like to request that we do not sell your information in the future, you can email us as set forth below with the subject line “Nevada Do Not Sell Request” and provide us with your name and the email address associated with your account.   

 

Supervisory Authority
If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.

 

Changes to this Privacy Policy
We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the Website, with the "Effective Date" posted at the top of the Privacy Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make any material changes to our Privacy Policy or how we handle your Personal Information, or we are going to use any Personal Information in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will give you a reasonable opportunity to consent to the change. By using our Website or Services after the Effective Date, you are deemed to consent to our then-current Privacy Policy.


Contact Us
If you have questions, concerns or feedback regarding this Privacy Policy, you can contact us at privacy@recurate.com or Recurate, Inc., 712 H St NE, PMB 70, Washington, DC 20002.