Effective May 24, 2018
- What information we collect and how it is collected;
- How we use the information;
- With whom we may share information;
- Legal basis for processing the information;
- Your rights and choices;
- Security and storage of the information;
- Third party websites;
- Users outside the United States;
- California Disclosures; and
- Changes to the Policy and Contact Information.
Throughout this document, we will use a few terms to describe various roles. RefurbMe Members have signed up to use our service and created an account by providing their email address (Product Alert, Newsletter). RefurbMe Guests are people who use RefurbMe to browse products without providing their email address in any way.
Information We Collect
We collect information about you directly from you and automatically through your use of our Platform. We may combine information automatically collected with other information that we have collected about you including from publicly available sources.
In order to help you protect yourself and your information, we encourage you to provide only that information that is necessary for using our Platform. For example, to set up a notification you may only need to provide us with an email address, filters regarding the product you're looking for.
RefurbMe is not directed to children under thirteen (13) years or age and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.
Information You Provide Voluntarily
- Product Alert. When RefurbMe Guest comes to RefurbMe to browse products and is interested in a configuration that is out-of-stock, he may create an alter for that and thus voluntarily give us certain information. This can include your email address, criteria for the product you're looking for. If it's the first time you provide your email address, we enforce that you actually own this address and send you a confirmation email instantly to confirm your consent. If you fail to confirm your email, we delete your account in 48 hours.
- Newsletter. Any user may opt-in to receive our Weekly newsletter. This can be done by signing up on the different modals available on the website, but also by creating a Product Alert. When you sign up for a newsletter, we automatically convert your Guest account to a Member account. You can opt-out any time by clicking at the unsubscribe link in emails you receive, or by adjusting your setting on the Product alert page. You may also Pause, Snooze, Change frequency of the newsletter.
Information Collected Automatically
- Log & Device data. When you use RefurbMe, our servers automatically record information (“log data”), including information that your browser sends whenever you visit our Website. This log data may include your web address you came from or are going to, your device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, and time zone or location. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device makes available to us, please check the policies of your device manufacturer or software provider.
- Product Browsing history. In order to provide a tailored experience for all users, we collect information about viewed products and criteria that used to filter results, so that we can recommend products based on that information.
- Search queries. We log search queries that users input, so that we can evaluate what next product category we should focus on, and also improve our search engine mechanism.
Cookies and Other Tracking Mechanisms
- Other Web Site Analytics Services. Subject to your opt-out preferences (see Your Rights and Choices below), we use third party service providers such as Google Analytics to provide certain analytics and user interactions services to RefurbMe in connection with our operation of our Platform, including the collection and tracking of certain data and information regarding the characteristics and activities of visitors RefurbMe. You may opt-out of Google Analytics’ and UserVoice's cookies using Opt-Out Features on their respective websites.
How We Use Your Information
We may use information that we collect about you, including personal information, to:
- Provide the RefurbMe Service. RefurbMe is a comparator for refurbished products, as well as we help users monitor out-of-stock products. We use criteria that you provide and your email address to constantly monitor availabilities and alert you as soon a product becomes available for sale. We use your browsing history to fuel our recommendation engine to sort products based on your interest.
- Understand and improve our products. We will perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others. We do this to help make our products better and to develop new products.
- Communicate with you.
- Service related communications. We may send you service and administrative emails to ensure the service is working properly. These messages are considered part of the service and you may not opt out of these messages.
- Promotional. Subject to your opt-out preference, we may send you emails about new product features or other news about RefurbMe or on topics we think would be relevant to you. You may opt out of receiving these communications at any time. Visit the Your Rights and Choices section below.
- Responding to your requests. We will also use your information to respond to your questions or comments.
- Administrative. We may contact you to inform you about changes in our services, our service offering and other important service related notices, such as changes to the Policy or about security or fraud notices.
- Advertising. Subject to your opt-out preferences, we may develop and display content and advertising tailored to your interests on our services and other sites. See Your Rights and Choices below.
- Protecting Rights and Interests. We will use your information to protect our rights and interests as well as the rights and interests of our users and any other person, as well as to enforce this Policy or our Terms of Service.
- Legal Compliance. We may use your information to comply with applicable legal or regulatory obligations, including informal requests from law enforcement or other governmental authorities.
- Other. We also may use your information to manage our business or perform functions as otherwise described to you at the time of collection subject to your consent. Please read all online agreements carefully before accepting them.
With Whom We May Share Your Information
We do not share your personal information with others except as indicated within this Policy or when we inform you and give you an opportunity to opt out of having your personal information shared.
We will share information we collect about you, including personal information, in the following ways:
- With third party service providers, agents, or contractors. We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service, and to analyze and enhance data (including data about users' interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We require our Service Providers to agree to take reasonable steps to keep the personal information that we provide to them secure. We do not authorize them to use or disclose your personal information except in connection with providing their services.
- Business Transfers. We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy. In such transactions, customer information is typically one of the business assets that is transferred or acquired by a third party. If we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, in the unlikely event of a bankruptcy proceeding, or as part of any other similar business transfer, you acknowledge that such transfers may occur.
- Aggregate or De-identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.
Legal Basis for Processing Your Information
We rely on the following legal grounds to process your personal information:
- Consent. We may use your personal information as described in this Policy subject to your consent. To withdraw your consent, please contact us at email@example.com.
You may also refrain from providing, or withdraw, your consent for cookies. Please see Your Rights and Choices below for more information on opt-outs.
- Performance of a contract. We may need to collect and use your personal information of RefurbMe Users, as applicable, to perform our contractual obligations.
- Legitimate Interests. We may use your personal information for our legitimate interests to provide our Platform and services and to improve our services and the content on our Platform. We process information on behalf of our customers who have legitimate interests in operating their businesses. We may use technical information as described in this Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.
Your Rights and Choices
- Account. In order to keep your personal information accurate and complete, you can log in to you account using our magic link page. You can also delete completely your account from our system, by clicking on the link "close your account" after being logged in the Product Alert Page. You may also contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information. We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at firstname.lastname@example.org or the address set forth at the end of this Policy. Subject to applicable law, we will retain and use your account information only as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
- E-mail. As described above, if you do not wish to receive promotional emails from us, you may opt out at any time by following the opt-out link contained in the email itself. Please note that it may take up to ten (10) days to process your request. Please also note that if you opt out of receiving marketing communications from us, we may continue to send to you service-related emails which are not available for opt-out. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.
- Cookies. You may also refrain from providing, or withdraw, your consent for cookies. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time.
- Third Party Analytics Services. Some of the services used provide the ability to opt-out. You may opt-out of Google Analytics’ and UserVoice's services using Opt-Out Features on their respective websites.
The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: www.google.com/policies/privacy.
- Additional Rights. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
Security and Storage of Information
We have taken reasonable steps to help protect the personal information we collect. These measures include using SSL encryption and two-factor authentication. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information in all circumstances.
You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims.
Our Platform may contain links to third-party websites and applications. Subject to your opt-out preferences (see Your Rights and Choices), we may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements on our websites. Any access to and use of such linked websites and applications is not governed by this Policy but instead is governed by the privacy policies of those third parties. We do not endorse these parties, their content, or any products and services they offer, and we do not endorse these parties, their content, or any products and services they offer, and we are not responsible for the information practices of such third-party websites or applications.
Users Outside the USA
Our application and database servers are located with Google Cloud Platform in the United States. Google Cloud Platform has certified with the Department of Commerce that it adheres to the Privacy Shield Principles under the EU-U.S. and Swiss-U.S. Privacy Shield frameworks. If you are an individual located in the European Economic Area, the United Kingdom, Canada or another jurisdiction outside of the United States with laws and regulations governing personal data collection, use, and disclosure that differ from United States laws, please be aware that information we collect (including through the use of methods such as cookies and other web technologies) will be processed and stored in the United States or in other countries where we or our third-party services providers have operations. By submitting your personal information to RefurbMe and using RefurbMe, you expressly consent to having your personal data transferred to, processed, and stored in the United States or another jurisdiction which may not offer the same level of privacy protection as those in the country where you reside or are a citizen.
- California Information-Sharing Disclosure. California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to email@example.com with “California Privacy Rights” in the subject line.
- Do Not Track. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.
Changes to the Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, and if we do we’ll post any changes, including any material changes, on this page, so please be sure to check back periodically. If you continue to use RefurbMe after those changes are in effect, you agree to the revised Policy.
If you have any questions or comments about this policy, please contact us at:
P.O. Box 9327
Berkeley, CA 94709