PRIVACY POLICY

Last Updated on June 1, 2022

This Privacy Policy (“Policy”) describes the treatment of information provided or collected on our website (www.reversible.com) or the Reversible mobile app (the “Platform”). The purpose of this Policy is to describe how the Platform collects, uses, shares and secures Personal Information (as defined herein) provided by you. Therefore, before you provide Reversible Inc. ( “Company”, “Reversible”, “we” or “us”) with any Personal Information, you should read through this Policy in its entirety and understand its terms. We may update this Policy from time to time, so please check in occasionally.

In this Policy, “Personal Information” means any information relating to an identified or identifiable individual, such as name, address, e-mail, phone number, location, credit or debit card information, or anything other information that may be used to identify an individual.

Our Platform can contain links to and from third party e-commerce websites for sale of goods (“Third-party E-Commerce Websites”), websites of payment processors such as PayPal, social media platforms such as Facebook, Twitter or Instagram, and advertisers, amongst others. If you follow a link to any of these websites, please note that this Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any Personal Information to those websites.

COLLECTION OF PERSONAL INFORMATION
USE OF PERSONAL INFORMATION
USE OF PERSONAL INFORMATION OF RESIDENTS IN EEA
SHARING OF PERSONAL INFORMATION
COOKIES
DATA PROTECTION RIGHTS FOR RESIDENTS IN EEA
DATA SECURITY
YOUR CONTROLS AND CHOICES
CHANGES TO THIS POLICY
NOTICE TO CALIFORNIA RESIDENTS
CHILDREN UNDER 13
MISCELLANEOUS ISSUES
CONTACT US

COLLECTION OF PERSONAL INFORMATION:

You will be asked to provide us Personal Information when signing up or registering our Platform or otherwise using our Platform. It is your choice whether to provide us with Personal Information. If you do not provide Personal Information when requested, you will not be able to benefit from our Platform or our services if that information is necessary to provide such services.

In most cases, we collect Personal Information directly from you. However, we may also obtain Personal Information about you from third parties (such as PayPal, Stripe, Facebook, Twitter, Instagram or Third-party E-Commerce Websites) or automatically when you interact with our Platform. Please keep in mind that when you provide any information to us through a third-party site or platform (e.g. PayPal, Stripe, Facebook, Twitter, Instagram or Third-party E-Commerce Websites), that any information you provide may be separately collected by the third-party site or platform and subject to the third-party site or platform’s privacy practices.

Below is a description of some types of Personal Information we process and the sources from which we obtain them:

User Information. If you sign-up or register for our Platform as an user, participate in social media functions with our Platform, opt in to receive our newsletters and special offers alerts, we will collect your name, email, password, phone number, address or location, images or photos, currency preference, shopping preference or favorite products and other information you provide to us, and we may also obtain from third parties your Personal Information when providing services to you, such as your account name/username, profile, images or messages posted or sent on a third-party site or platform like PayPal, Stripe, Facebook, Twitter, Instagram or Third-party E-Commerce Websites, etc.
Commercial Information. When you search for products in our Platform, upload and post product information for sale through our Platform, bid for the products posted by other users of our Platform, place orders for products posted by other users or via Third-party E-Commerce Websites, we will collect commercial information related to such search, purchase or sale of products by you, such as records of products you purchased, obtained, considered, including products, merchants, and deals you searched for, viewed, or clicked, product types, merchant sites visited from our Platform, merchant types, purchase confirmation data, your order history, products you reviewed and favored, preferred gender category of clothing, favorite stores, brands, products, influencers, and looks, etc. We may also obtain the aforesaid commercial information from Third-party E-Commerce Websites you are directed to visit through our Platform.
Payment Information. We do not currently collect financial information, such as your payment method (valid credit card number, type, expiration date or other financial information); that information is collected and stored by our third party payment processing company such as PayPal (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy policy. But we may collect financial information in the future if and when we decide to charge service fees from users.
User Content. The social media features of our Platform allow you to message other users with texts or images, to share thoughts and images which other users can like or comment, follow other users to receive recommended information or update, or otherwise provide content in our Platform. We will collect the user content submitted or shared voluntarily by you in our Platform and all such user content may be integrated and retained by us indefinitely, even after you terminate your account. We may continue to disclose such content to third parties in a manner that does not reveal Personal Information, as described in this Policy.
Communications. If you choose to contact us for any purpose, we will collect your contact details, your name, and the content, date and time of your message, as well as our reply and any follow up action we take in relation to your inquiry.
Device data. We may receive, store or automatically record usage, viewing and technical data, including your device identifier, IP address or location, time zone or language preference, type of device you use, or operating system version, when you visit our Platform. We may use website analytics software to better understand the functionality of our Platform on your device. This software may record information such as how often you use the Platform, the events that occur within the Platform such as products you viewed and Third-party E-Commerce Websites you clicked through the Platform, aggregated usage, performance data, and from where the Platform was downloaded.
Other sources. We may receive Personal Information about you from other sources, including third parties that help us identify new users, process payments (e.g. PayPal or Stripe), or prevent or detect fraud. We may also receive information about you from social media platforms (e.g. Facebook, Twitter or Instagram) when you interact with us on those platforms or access our social media content. The information we may receive is governed by the privacy settings, policies, and/or procedures of the relevant social media platform, and we encourage you to review them.

USE OF PERSONAL INFORMATION:

We use your Personal Information for the follow purposes:

To provide services to our users, including to allow you to purchase and/or sell products directly through our Platform or via Third-party E-Commerce Websites, to share your thoughts, images, product information and other content with other users, to communicate with other users using our Platform, to administer your account, to optimize your shopping experience, and other related services that you specifically request from us.
To provide customer support, including but not limited to responding to customer support questions or your requests, and investigating and addressing user concerns.
Assist users of our Platform in the resolution of complaints and disputes between them, as necessary for our legitimate interests in facilitating positive relations among users.
For marketing purposes, including to send our users offers or promotion alerts, newsletters and other communications to our users and business contacts. Where you have told us you would like to receive marketing communications or when you have made a purchase using our services, we or our partners will use your Personal Information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. You may unsubscribe from our email marketing communications by modifying your preferences in your account, or by following the opt out instructions in the promotional emails that are sent to you.
To manage our business relationships with our users, vendors, suppliers, Payment Processor, Third-party E-Commerce Websites and other business partners, including processing payment and sending service-related communications.
To communicate with you and respond to your inquiries, and to notify you about changes to our Platform, and any services we provide through the Platform.
To protect the security and effective functioning of our Platform and information technology systems.
For other business purposes, such as to provide, operate and improve our products and services, perform data analyses, detect, prevent, and respond to actual or potential fraud or illegal activities, defend our legal rights, and comply with our legal obligations and internal policies.

USE OF PERSONAL INFORMATION OF RESIDENTS IN EEA:

If you are located in the European Economic Area (“EEA”), we only process your Personal Information when we can rely on a valid legal ground such as:

Execution of a contract. We need your Personal Information to provide you with our services, including to allow you to purchase and/or sell products directly through our Platform or via Third-party E-Commerce Websites, or to otherwise respond to your queries.
Compliance with a legal obligation. We are required or allowed to collect and use your Personal Information, for example to detect fraud or to comply with our tax, accounting and anti-money laundering obligations.
Legitimate interest. We or a third party, have a legitimate interest in processing your Personal Information. For example, we have a legitimate interest in using your Personal Information to conduct business analytics or to improve the safety, security and performance of our products and services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
Consent. You have consented to the use of your Personal Information, for example to send you our newsletter or promotional emails or for the use of certain cookies.

SHARING OF PERSONAL INFORMATION:

We will share Personal Information with the following categories of recipients, subject to applicable law:

Payment Processor and Third party E-commerce websites: We may share Personal Information with Payment Processor for the purpose of processing the payment to facilitate the purchase and sale of products between users through our Platform. We may also share Personal Information with Third party E-commerce websites you clicked in connection with your purchase of products in that Third party E-commerce websites, including your user name, email, mailing address or shopping preference or favorite products, or other information necessary for completion of your transaction with Third party E-commerce websites.
Affiliates/Employees: We share Personal Information with our affiliates (if we have any in the future), and employees all over the US as needed to provide our services, for purposes consistent with this Policy or to operate shared infrastructure, systems and technology.
Suppliers and service providers: We share Personal Information with companies that provide product or services to us for the operation of our business. These include providers of IT and software services, remote office services, cyber security services, mailing services, marketing services and finance systems. Such parties provide reasonable security for Personal Information and to use and process such Personal Information on our behalf only.
Professional advisors. We share Personal Information with our accountants and other outside professional advisors in the course of the services they provide to us.
Financial institutions: We share Personal Information with financial service providers such as in connection with collection and payment of our service fees (if any).
Corporate purchasers: We may share Personal Information with any corporate purchaser or potential purchaser to the extent permitted by law as part of any merger, acquisition, sale of Company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Information would be transferred as an asset of Company.
Mandatory disclosures and legal claims: We share Personal Information in order to comply with any subpoena, court order or other legal process, to comply with a request from our regulators, governmental request or any other legally enforceable demand. We also share Personal Information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
Other third parties with your consent. We share Personal Information with other third parties with your consent.

If you have questions about the parties with which we share Personal Information, please contact us as specified below.

COOKIES:

Through the use of cookies and similar technologies such as web beacons, we may collect your device identifier or IP address, unique device ID, hardware and software type, internet service provider, serving domain, geographical area, location data, browser type and settings data (such as screen resolution, color depth, time zone settings, browser extension and plugins) operating system, referring URLs, search history, usage patterns, information on actions taken or interaction with our digital assets (e.g., page views) and dates and times of actions. We may also place web beacons in emails sent to you to track which emails are opened and which links are clicked by you.

The types of cookies we use include:

Operational Cookies: To the extent applicable, we use operational cookies which are required for the operation of our Platform, for example, cookies that enable you to log into some areas. These operational cookies are session cookies that are erased when you close your browser.
Google Analytics Cookie: We use third-party analysis tools such as Google Analytics to collect information about how you use our services. We use this information to create reports and improve our service. This cookie can help us understand the number of visitors to our Platform, where visitors come from, and how visitors browse or use our Platform. It can also help us identify areas we can improve such as navigation, shopping experience and marketing campaigns. To learn more about how Google uses data, visit https://policies.google.com/technologies/partner-sites. To opt-out from these cookies across our Platform, visit http://tools.google.com/dlpage/gaoptout.
Functional Cookies: We use functional cookies to improve the functional performance of our Platform and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Platform. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Platform.

With your consent, some of Reversible’s business partners (such as advertisers) may use cookies on the Platform. Reversible has no access to or control over these cookies. This Policy covers the use of cookies by Reversible only and does not cover the use of cookies by any Reversible’s business partners, such as third-party advertisers, Third-party E-Commerce Websites or third party social media platforms to which the Platform provides links.

We may also use social plugins on our services through the Platform, for instance plugins of the social media platforms such as Facebook, Twitter or Instagram, and may feature icons, like the “thumbs up” icon or text like “Recommend”, “Like” or “Comment”. Your browser may create a connection to the servers of such social media platforms and/or transmit data to such servers when you view a page on our Platform. If you use the plugin functionality (e.g. click the “Like” button or make a comment), this information is also transmitted directly to the social network by your browser and may be stored there. This Privacy Policy does not cover the practices of these third party social media platforms.

Most web browsers allow you to manage cookies through the browser settings. Be aware that, if you opt out from and do not agree to certain cookies, your experience on our Platform may be diminished and some features may not work as intended depending on the cookie. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org.

DATA PROTECTION RIGHTS IN EEA:

If you are in EEA, you have the following rights:

Access. Subject to certain exceptions, you have the right to request a copy of the Personal Information we are processing about you, which we will provide to you in electronic form. At our discretion we may require you to prove your identity before providing the requested information. If you require multiple copies of your Personal Information, we may charge a reasonable administration fee.
Rectification. You have the right to require that any incomplete or inaccurate Personal Information that we process about you is amended.
Deletion. You have the right to request that we delete Personal Information that we process about you, unless we are required to retain such information in order to comply with a legal obligation or to establish, exercise or defend legal claims.
Restriction. You have the right to request that we restrict our processing of your Personal Information where:
- You believe such information to be inaccurate;
- Our processing is unlawful; or
- We no longer need to process such information for a particular purpose, but where we are not able to delete the information due to a legal or other obligation or because you do not want us to delete it.
Portability. You have the right to request that we transmit the Personal Information we hold in respect of you to another data controller, where this is:
- Personal Information which you have provided to us; and
- We are processing that information on the basis of your consent or in order to perform our obligations under contract to you (such as to provide our services).
Objection. Where the legal justification for our processing of your Personal Information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
Withdrawing Consent and Opt-out. If you have consented to our processing of your Personal Information, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages and promotional email communications that you receive from us at any time by clicking the unsubscribe button or by contacting us by email. However, please note that some communications (such as service messages, account notifications, etc.) are considered transactional and necessary for account management, and you cannot opt out of these messages unless you cancel your Reversible account.

If you are in the EEA, you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. Access a list of local data protection authorities in EEA countries.

DATA SECURITY:

We maintain administrative, technical and physical safeguards that are intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. However, because no information system can be 100% secure, we cannot guarantee the absolute security of your information.

YOUR CONTROLS AND CHOICES:

In addition to Section 6, we provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your Personal Information. In accordance with local law, your controls and choices as described in this Section:

You may correct, update and delete your registration account in our Platform at any time. You may also update and correct inaccuracies in your account information at any time by logging in your registration account.
You may change your choices for subscription, alerts and newsletters.
You may choose whether to receive offers and updates from us and promotions for our services.
You may request access to the Personal Information we hold about you and that we amend or delete such information.
You may set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.

You may exercise your controls and choices, or request access to your Personal Information, by contacting us as specified below. Please be aware that if you do not allow us to collect Personal Information from you, some of our services may not be available to you. If you have questions regarding the specific Personal Information about you that we process or retain, please contact us as specified below.

CHANGES TO THIS POLICY:

We may make changes to this Policy. The “Last Updated” date at the top of this page indicates when this Policy was last revised. If we make material changes, we may notify you via a notice posted on our Platform or other method. We encourage you to read this Policy periodically to stay up-to-date about our privacy practices. Your continued use of our Platform after such changes will constitute your: (a) acknowledgment of the updated Policy; and (b) agreement to abide and be bound by the updated Policy.

NOTICE TO CALIFORNIA RESIDENTS:

If you are a California resident, California Civil Code Section 1798.83 permits you to request a notice regarding the disclosure of your Personal Information by the Company to partners for the partners’ direct marketing purpose. If you are a California resident and would like a copy of this notice, please contact us at privacy@reversible.com.

CHILDREN UNDER 13:

The Company is committed to protecting the online privacy of children and making the internet safe. We do not provide products and services to children, or knowingly collect or solicit Personal Information from children under 13 years of age. Any communication we get that is identified as being from a child under 13 will not be kept by the Company. We encourage parents or guardians of children under 13 to regularly check and monitor their children’s use of email and other activities online. Further, you affirm that you are at least 18 years of age.

MISCELLANEOUS ISSUES:

What are the consequences of not providing Personal Information?
You are not required to provide all Personal Information identified in this Policy to visit our Platform or to interact with us offline, but certain functionality will not be available if you do not provide Personal Information. If you do not provide Personal Information, we may not be able to respond to your request, provide services to you, or provide you with information that we believe you would find valuable.
Does the Platform honor do not track (“DNT”) signals sent via browsers?
Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we generally do not respond to DNT signals at this time.
How long do we retain Personal Information?
We typically retain Personal Information related to marketing activities for as long as you accept marketing communications from us, and we will securely delete such data in accordance with applicable law upon request. For Personal Information that we collect and process for other purposes, we will typically retain such Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise specified in applicable record retention policies and procedures.
Are third party websites governed by this Policy?
Our Platform may contain links and references to other websites administered by unaffiliated third parties. This Policy does not apply to such third-party sites. When you click a link to visit a third-party website, you will be subject to that website's privacy practices. We encourage you to familiarize yourself with the privacy and security practices of any linked third-party websites before providing any Personal Information on that website.

CONTACT US:

If you have any questions about this Policy, or if you would like to exercise your rights to your Personal Information, you may contact the Reversible chief data protection officer at privacy@reversible.com.