CRISPCOMMERCE LLC mission is to put people at the heart of commerce, empowering everyone to thrive. We strive to protect the privacy of our users and any personal data shared with us. This Privacy Policy describes the types of personal data CRISPCOMMERCE LLC, Inc. and our subsidiaries and affiliates (collectively “CRISPCOMMERCE LLC”, “we”, “us”, and “our”) obtain; how we may collect, use, and share it; and how you may exercise your rights and choices with respect to that data.
Scope This Privacy Policy applies to personal data we obtain when you interact with CRISPCOMMERCE LLC services, products, tools, and features (collectively “Services”) through the use of our websites, mobile applications, or on any other medium used to access our Services and through other data collection points that reference this Privacy Policy. We may provide additional information about our privacy practices at other points, for example, where this will help us provide more relevant and timely information.
What Data We Collect We collect personal data about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below. Information You Provide to Us Directly: We collect information about you when you provide it directly to us as part of our Services, such as when you register for an account, set brand, style, and other preferences, and participate in various features, surveys, promotions, or events. This information may include your name, address (including relevant shipping and delivery information), phone number, email, username, sizing, social media accounts, gender, age, education (college and class year), and any other personal data you may provide. Information You Provide when Using Our Services and Interacting with Other Users: We collect information and content when you create closets and listings, post stories, participate in a Posh Show, make purchases, search for items, and comment or otherwise interact with listings, closets, or other users. This includes any pictures, video and audio clips, closet descriptions, search terms, information about items you have listed, sold, or purchased, and any interaction with users and listings, such as likes, comments, replies, and offers.When you buy and sell on CRISPCOMMERCE LLC, we will need to collect payment and billing information, such as credit card and bank account information to complete the transaction. Information You Provide through Our Support Channels: We collect information when you contact CRISPCOMMERCE LLC and our customer support for any reason, such as asking questions and sharing feedback, issues, or problems. You may be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving an issue. Information You Provide when Verifying Your Identity: Identity verification may be required for fraud prevention and compliance purposes. We may collect certain identification information, such as driver’s license information, date of birth, social security number, and passport number to verify your identity. We may also ask to verify your identity using photo verification, which involves the processing by our identity verification vendor of face geometry data that is deleted upon completion of the verification process. Information We Collect Automatically when You Use the Services: We collect information about you when you use our Services, including when browsing or taking certain actions within the Services. This includes information about the features you may use, links or pages you click on, pages viewed, search and browsing history, IP address and device data (e.g. operating system, version, model, identifiers, etc.), referring and exit pages, and other analytics data about your usage or our Services. Cookies and other tracking technologies: We, our service providers, and other third-party partners may collect information such as device data, IP address, hashed emails, transaction data (such as order value) and online activity data through automated means such as cookies, web beacons, software development kits (SDKs), tracking URLs, and similar technologies. Cookies are used to store and receive identifiers and other information, such as the name of the domain from which the cookie originated and when the cookie expires. Cookies and similar technologies may enable CRISPCOMMERCE LLC, as well as parties other than CRISPCOMMERCE LLC, to collect information through our Services. We and the companies we work with may use cookies and similar technologies to improve the functionality and user experience of our Services, gather and store information about user preferences and past actions, perform analytics, detect fraud, measure our ad conversion and performance, optimize our ad campaigns, customize your experience, and bring you ads through interest-based advertising (also called “targeted advertising”). Interest-based advertising enables us to provide you with more relevant advertising about products and services based on the information we and other parties may collect about your online activities over time and across different websites. For example, you can learn how Google collects and uses information when we use their services (including Google Analytics) and how Connexity and Taboola use cookies and similar technologies to optimize ads and recommend content to you. Most browsers will allow you to control cookies through the browser settings. View your browser developer’s support center, help menu, or website to learn whether or how you can manage cookies on your browser. Please note that, without cookies, you may not be able to use some or all of the features on or functionality of our Services. Our Service currently does not respond to “Do Not Track” (DNT) signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. Information We Collect from Social Media Platforms: You can connect your social media or other third-party account to your CRISPCOMMERCE LLC account, such as Facebook, Twitter, Instagram, Pinterest, or Snapchat. If you choose to connect your social media accounts to our Services, we may collect information about you from these accounts, such as username, friend or following lists, and other profile information. Information about Others: Prior to sharing any information about others for any purpose through the Service, you must satisfy any consents or other applicable legal and regulatory requirements. This includes, but is not limited to, the information or media (e.g., images, videos) you provide about any third parties on comments, listings, Posh Stories, or Posh Shows.
How We Use Your Data We use the information we collect for the purposes described below: Personalize your experience. For example, we use your information, including but not limited to profile information, search, likes, and purchase histories, to suggest items, closets, offers, features, or events that we think you might enjoy. We may use the data collected through cookies and other tracking technologies (if enabled) to remember information so that you will not have to re-enter it during your visit or the next time you visit the site and to provide custom, personalized content and information. Process and fulfill orders and complete transactions. This includes sharing information, such as your contact and shipping information, with sellers and our shipping and delivery partners. For clarity, if you participate in the CRISPCOMMERCE LLC Consignment Network, this also includes sharing your contact details, such as your name, address, and phone number with our delivery partner, Uber, to facilitate pickup and delivery of the consignment shipment. Provide you with customer support, communications, updates, promotions, announcements, and other news about relevant features and aspects of our Services. For example, we may send you communications responding to customer support questions, providing information about transactions, or notifying about user engagement. You may adjust your email and push notification preferences through our app or website, or follow any opt-out instructions provided with the communication (e.g. at the bottom of an email). Improve safety, security, and integrity and prevent fraud. This includes investigating suspicious activity, preventing the sale of counterfeit items, and fulfilling anti-money laundering and know-your-customer obligations. We and our fraud vendors, such as LexisNexis Risk Solutions and Sift Science, may use information such as name, address, email, general location information, IP address, device data (e.g., operating system, version, model, identifiers, etc.), the content you post, and your use of the Services to verify accounts and activity, and to monitor suspicious or fraudulent activity. Enable social features such as connecting you with other users. Provide, develop, analyze, and improve the Services. We use the information we collect to provide, develop, analyze, and improve the Services. This includes research and development and the creation and testing of new and existing features, which may involve analyzing your usage of our Services and creating anonymous and aggregated data. For advertising and marketing purposes. Depending on your location and any applicable rights or choices you may have exercised, this may include providing you with advertising and marketing related to our Services (including marketing communications), measuring our ad performance and conversion, optimizing our ad campaigns, and showing you personalized and non-personalized marketing or advertisements on or off of the Services. For legal or compliance purposes, including to fulfill or protect our legal rights, interests, and protect the interests of others. This includes identifying violations of our Services’ terms and policies, complying with relevant laws, regulation, or other obligations in connection with legal claims, audit functions, an acquisition, merger, or sale of a business. With your consent or for other disclosed purposes. We may use information about you where you have given us consent to do so or for a specific disclosed purpose provided to you prior to the processing of the information.
How We Share the Information We Collect We share your information as described below: Provide the Services: We will share your information with companies that provide a service to us or our users, such as shipping or delivery, identity verification, fraud monitoring, payment processing, storage, database maintenance, analytics, and hosting. For example, we may use Google Maps API to help autocomplete and validate your address. Offers, Ads, and Promotions: We may share your information with partners and affiliates, which may include brands or other third parties, as well as online advertising services like advertising or affiliate networks and related providers for advertising, marketing, and promotional purposes. Complete and Facilitate Transactions: We may share information with others users when you make a purchase or a sale or otherwise conduct transactions on the Service. Sharing Feedback: We may share feedback we receive from you. This may include, but is not limited to love notes, comments on listings, and survey responses. This feedback may be attributed to you, for example, with your username. Law Enforcement or Legal Requests: We may share information about you with a third party if we believe that sharing is reasonably necessary to comply with the law and the reasonable requests of law enforcement, to enforce our Terms of Service or to protect the security or integrity of our Service, or to exercise or protect the rights, property, or personal safety of CRISPCOMMERCE LLC, our users, or others. Business Transaction: We may transfer the personal data we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation), or other business transaction. With your consent: We may also share information about you with third parties when you give us consent to do so. For example, you may choose to connect your social media accounts to your CRISPCOMMERCE LLC account and direct us to share your listings on these platforms. We may also share aggregated and anonymous information, including demographic information, survey results, market trends, and other analysis that we create based on the information we receive. In addition, please note that we are not responsible for the personal data you choose to submit on pages and content accessible to the general public, including but not limited to, your profile, closet, listings (including any “Meet the Posher” listings), photos, comments (including on our blog), love notes, Posh Stories, or Posh Shows. Once displayed on a publicly accessible location, that information can be collected, used, and shared by the public at large both on and off our Services (e.g. a listing could be shared to social media).
How We Store and Maintain the Information We Collect The information we obtain will be retained to provide the Services to you and to fulfill the business and commercial purposes for which they are collected or as needed to satisfy applicable governmental laws, regulations, investigations, proceedings or for reasonable backup, archival, audit, legal, tax, accounting, compliance, or other similar purposes. For example, requirements related to financial transactions and anti-money laundering purposes often require us to keep certain information for 7 years but may vary depending on your location. Security: CRISPCOMMERCE LLC employs organizational, technical, and physical safeguards intended to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Depending on the circumstances, our safeguards to protect personal data may include facilities access restrictions, system access controls, firewalls, data encryption, and other security best practices. No internet, email, or other electronic transmission is ever fully secure or error free, however, so you should take special care in deciding what information you send to us in this way. Your information may be stored with third-party cloud service infrastructure providers. International Data Transfers: We are headquartered in the United States and may share your information with service providers and other recipients in the United States and worldwide. If you are located in a region with laws governing data collection and use that may differ from U.S. law, please note that we may transfer personal data to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. We use appropriate transfer mechanisms where required.
Legal Basis for Processing Your Information CRISPCOMMERCE LLC may collect and process your information on the basis of different legal grounds, depending on the nature of the information being provided, the type of processing involved, and your location of residence, as follows: Performance of a contract: By using our Services or otherwise purchasing or selling on our platform, you are agreeing to our Terms of Service which constitutes a valid legal contract. We process your data in order to fulfill any obligations, such as completing transactions between you and other users and you and CRISPCOMMERCE LLC. Legitimate interest: Such legitimate interests will include where CRISPCOMMERCE LLC sends you marketing about our products and services where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf or where such processing is necessary for fraud detection and prevention. CRISPCOMMERCE LLC will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products, and features to you. Legal obligations: Where the processing is necessary for compliance with a legal obligation. Consent: Finally, in certain situations, CRISPCOMMERCE LLC may rely on your implied or express consent in order to process your personal data.
Your Rights and Choices Depending on your location, you may have certain rights, choices, and means available to you when it comes to your information, including the use and disclosure of that data. Below is a summary of the rights you may have and how to exercise them. Access, Correct, or Delete Your Personal Data: You may submit a request to access or delete your personal data in your account settings. You may also go to your account settings to make corrections to your personal data. Please note that when you make a request, we may need information from you to help us confirm your identity and verify your right to access, correct, or delete your personal data (or to exercise any of your other rights), and may charge you a fee for such request, where allowable. Please note that we cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. If a request you made to exercise your rights is denied, you may appeal the denial by writing to support@crispcommercee.com. Your requests and choices may be limited in certain cases, such as the following examples: if fulfilling your request would reveal information about another person, or if you ask to delete information which we are required by law or have compelling legitimate interests to keep. Opt Out of Certain Types of Processing Activities: We may disclose certain of your personal data to third parties, such as online advertising services (like advertising and affiliate networks) and our marketing partners, in exchange for monetary or non-monetary consideration (hereafter referred to as the “Sale” or “Selling” of personal data) or for targeted advertising purposes. The personal data we may Sell to these third parties include information like email addresses, device identifiers, cookies, beacons, pixel tags, mobile ad identifiers or similar technologies, demographic information, and other information about your online activity, such as your browsing or search history and interaction with websites, applications, or advertisements. This helps us optimize the placement of our ads and serve more relevant advertisements, including on other websites and services. Depending on where you live, you may have the right to opt-out with respect to these processing activities. If you are accessing this Privacy Policy using your web browser, you may request to opt out here: Do Not Sell or Share My Personal Information. If you are accessing this Privacy Policy using the CRISPCOMMERCE LLC App, you may request to opt out here: Do Not Sell or Share My Personal Information. If we detect that you have enabled the Global Privacy Control (“GPC”) browser signal and determine that you are a resident of a state where we are legally required to respond to such signals (including but not limited to Colorado), you will be opted out of these processing activities without further action from you. Please note that, if you are not logged in, your opt-out will be specific to the web browser or device you use at the time you exercise your opt-out rights and, if you use multiple web browsers or devices, you will need to opt out from each browser and device. Withdraw Consent: Where allowed by law and where we rely on your consent to process your personal data, you may withdraw such consent at any time; however, withdrawing such consent may limit or restrict your use or access of our Services. Please direct your request to support@crispcommercee.com unless a different means of making the request is listed in a region-specific section. Region-Specific Information: California Residents The California Consumer Privacy Act (“CCPA”) requires that we provide California residents with additional information about their rights and our information practices. If you are a California resident, please review our California Privacy Notice, which supplements this Privacy Policy and details your California privacy rights. Colorado Residents As required by law and to help protect your privacy, we may take steps to verify your identity when you submit a request to exercise your rights. The steps we take may vary depending on the type of request you make and whether you have an account with us. If you have an account with us, we may verify your identity by requiring you to sign into your account. If you do not have an account with us, we may require you to provide certain information (such as your name and email address) to verify your identity. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal data, we reserve the option to require you to sign a declaration under penalty of perjury that you are the consumer whose personal data is the subject of the request. To submit a request as an authorized agent on behalf of a consumer, please email us at support@crispcommercee.com, and be sure to reference the Colorado Privacy Act in your request and include proof that the consumer has provided permission for you, the authorized agent, to submit the request. Please note that, for requests submitted by an authorized agent on behalf of a consumer, we may still require the consumer to verify their own identity directly with us. Canada Residents We will process your information with your consent, unless an exception applies. Your consent may be explicit, such as when you check an online box approving the collection of your information, or it may be implied based on the circumstances or your actions. After collection, we may transfer your information outside Canada for processing. Section 5 describes how we protect that information and the risks associated with its transfer. Other sections of this Privacy Policy explain your rights and how you may exercise them, including how to withdraw your consent.
Additional Information Depending on your location, you may have certain rights, choices, and means available to you when it comes to your information, including the use and disclosure of that data. Below is a summary of the choices you may have and how to exercise them. Links to External Content: The Services may also include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third-party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit. Children’s Privacy: CRISPCOMMERCE LLC does not knowingly collect or solicit any information from anyone under the age of 13 through this Service. If you believe that a child under 13 years of age may have provided us with personal data, please contact us at support@crispcommercee.com. Your Acceptance of this Privacy Policy: By accessing or using our Services, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal data as described in this Privacy Policy. If you do not agree, you should discontinue use of the Services immediately. Your Acceptance of this Privacy Policy: By accessing or using our Services, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal data as described in this Privacy Policy. If you do not agree, you should discontinue use of the Services immediately. Changes to this Privacy Policy: We reserve the right to revise this Privacy Policy from time to time. We will post changes on this page and indicate the “Last Updated” date at the top of this page. If we determine, in our sole discretion, that the changes are material, we may also notify you by sending an email to the address associated with your account or by otherwise providing notice through our Services. We encourage your to check back often for any updates. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and that your continued use of our Services after any change in this Privacy Policy will constitute your acceptance of such change. Contact Us: If you have any questions about this Privacy Policy, you may contact us at support@crispcommercee.com.
