Effective Date: June 12, 2021
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.
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.
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
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.
We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
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.
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.
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
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.
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.
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.
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.
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
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
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
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.
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.
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.
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.
You can reach our UK legal representative under:
71, Warriner Gardens
London, SW11 4DX