Privacy Policy

Personal Information You Provide to Us Directly

We may collect the following personal information that you provide to us:

• Name and contact information. We collect information when you create an account or use our Services, such as first and last name, email address, postal address, phone number, and other contact data.
• Purchases. We collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by Stripe. Stripe may also collect a picture of your government-issued ID for identification verification purposes when you make purchases via the Services. You may find their privacy policy athttps://stripe.com/privacy. We do not directly collect or store payment card numbers entered through our Services, but we may receive information associated with your payment card information (for example, your billing details).
• Your communications with us. We collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, apply for a job, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
• Interactive features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (for example, messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services (referred to herein as "User Content") will be considered public, unless otherwise required by applicable law, and is not subject to this Privacy Policy. Please exercise caution before revealing any information that may identify you in the real world to other users.
• Sweepstakes, contests, and promotions. We may collect personal information you provide for any sweepstakes, contests, or other promotions that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
• Conferences, trade shows, and other events. We collect personal information from individuals when we attend conferences, trade shows, and other events.
• Business development and strategic partnerships. We collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, résumé, and/or cover letter to us, we will collect and use your information to assess your qualifications.

Personal Information Collected Automatically

We may collect the following personal information automatically when you use our Services:

• Device and usage information. We collect certain information automatically when you use our 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 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. In addition, we may collect information that other people provide about you when they use our Services, including information about you when they tag you.
• Cookies, pixel tags/web beacons, and other technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (collectively, "Technologies") to automatically collect information through your use of our Services.
  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  • Pixel tags/web beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

  Our uses of these Technologies fall into the following general categories:

  • Operationally necessary. Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality.
  • Performance-related. Technologies that help us assess the performance of our Services, including as part of our analytic practices to better understand how individuals use our Services (see Analytics below).
  • Functionality-related. 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- or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
• 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 visitGoogle Analytics' Privacy Policy. To learn more about how to opt out of Google Analytics' use of your information, pleaseclick here.
  • Facebook Connect. For more information about Facebook's use of your personal information, please visitFacebook's Data Policy. To learn more about how to opt out of Facebook's use of your information, please visit Facebook while logged in to your account.
  • Social media platforms. Our Services may contain social media buttons such as Instagram, TikTok, Twitter, and Facebook (that might include widgets such as the "share this" button or other interactive mini programs). These features may collect information such as your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

Personal Information Collected from Other Sources

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

Provide Our Services

We use your personal information to provide you with our Services, such as:

• Managing your information and accounts.
• Providing access to certain areas, functionalities, and features of our Services.
• Fulfilling and managing your orders, payments, returns, and exchanges.
• Administering prize draws and competitions when you elect to participate.
• Answering requests for customer or technical support.
• Communicating with you about your account, activities on our Services, and policy changes.
• Enabling our payment processor to manage your financial information.
• Processing applications if you apply for a job with us.
• Allowing you to register for events.

Administrative Purposes

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

• Pursuing our legitimate interests such as research and development, security, and fraud prevention.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible.
• Measuring interest and engagement in our Services.
• 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.
• Debugging to identify and repair errors.
• Auditing relating to interactions, transactions, and other compliance activities.
• Sharing personal information with third parties as needed to provide the Services.
• Enforcing our agreements and policies.
• Complying with our legal obligations.

Marketing and Advertising Our Products and Services

We may use personal information to tailor and provide you with content and advertisements, including email campaigns, custom audience advertising, and personalized advertising, including through cross-device tracking. You may opt out of marketing communications at any time (see Your Privacy Choices below).

Other Purposes

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

• Consent. We may use personal information for other purposes 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, including profiling for anti-fraud purposes. RefaireAI's 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.
• Customizations. We may use your personal information to improve your user experience on the Services by providing content recommendations based on the actions you take on the Services.
• De-identified and aggregated information. We may use personal information and other information about you to create de-identified and/or aggregated information. This information does not identify you directly and is not personal information subject to this Privacy Policy.
• Share content with friends. Our Services may offer tools and functionalities that allow you to provide personal information about your friends, or for your friends to provide personal information about you, through referral services. Please only share contact information of people with whom you have a relationship.

Disclosures to Provide Our Services

The categories of third parties with whom we may share your personal information include:

• Service providers. Third-party service providers that use information to help us provide our Services, including IT support, hosting, payment processing, customer service, and related services.
• Business partners. Business partners to provide you with a product or service you have requested or with whom we jointly offer products or services.
• Affiliates. Company affiliates for administrative purposes, including IT management, and to support or supplement the Services we provide.
• Other users/website visitors. As described above, if you choose to share profile information or User Content publicly, it may be visible to other users and visitors.
• Advertising partners. Third-party analytics and advertising partners that may set Technologies and other tracking tools on our Services to collect information for delivering personalized advertisements.
• APIs/SDKs. Third-party application program interfaces and software development kits that support the functionality of our Services.

Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store about 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; 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.

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 personal information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

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 email from us, you can use the unsubscribe link found at the bottom of the email to opt out of future emails. We may still send you certain non-promotional communications regarding our Services.
• Text messages. You may opt out of receiving text messages from us by updating your preferences in your account or contacting us at privacy@refaire.ai.
• Mobile devices. We may send push notifications through our mobile application. You may opt out from receiving these notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application; you may opt out by adjusting your device settings.
• Do Not Track signals. Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. We do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and interest-based advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your browser or device settings. Cookie-based opt-outs are not effective on mobile applications, but you may opt out of personalized advertisements on some mobile applications by following the instructions for your device.

Your Privacy Rights

In accordance with applicable law, you may have the right to:

• Access personal information about you and obtain a copy of such personal information.
• Request correction of your personal information where it is inaccurate, incomplete, or outdated.
• Request deletion, anonymization, or blocking of your personal information.
• Request restriction of or object to our processing of your personal information.
• Withdraw your consent to our processing of your personal information.
• Request data portability.
• Be informed about third parties with which your personal information has been shared.
• Request the review of decisions taken exclusively based on automated processing.
• Opt out of certain processing activities, including targeted advertising or profiling where applicable.

If you would like to exercise any of these rights, please contact us at privacy@refaire.ai. We will process requests in accordance with and to the extent required by applicable laws.

California Resident Rights

Under California law, residents are entitled to contact us to prevent disclosure of personal data to third parties for their direct marketing purposes. Please contact us at privacy@refaire.ai to submit such a request.

Nevada Resident Rights

Nevada residents have the right to opt out of the sale of certain personal data to third parties who intend to license or sell that personal data. We do not sell personal data as that term is defined under Nevada law, but you may still contact us at privacy@refaire.ai to exercise your rights.

Colorado Resident Rights

Colorado residents may opt out of the sale of certain personal data to third parties. We do not sell personal data as defined under Colorado's Privacy Act, but you may contact us at privacy@refaire.ai to exercise your rights or authorize an agent to do so on your behalf.

Connecticut Resident Rights

Connecticut residents may opt out of the sale of certain personal data to third parties. We do not sell personal data as defined under Connecticut's Personal Data Privacy and Online Monitoring Act, but you may contact us at privacy@refaire.ai to exercise your rights or authorize an agent on your behalf.

Virginia Resident Rights

Virginia residents may opt out of the sale of certain personal data to third parties. We do not sell personal data as defined under Virginia's Consumer Data Protection Act, but you may contact us at privacy@refaire.ai to exercise your rights.

Utah Resident Rights

Utah residents may opt out of the sale of certain personal data to third parties. We do not sell personal data as defined under Utah's Consumer Privacy Act, but you may contact us at privacy@refaire.ai to exercise your rights.

EU, EEA, and UK Residents

If you are a resident of the EU, EEA (including Lichtenstein, Norway, Sweden, or Iceland), or the UK, you may have additional rights under the General Data Protection Regulation (GDPR). For personal data collected through our website, RefaireAI is the controller. In other cases, such as personal data processed in connection with our enterprise offerings, we may act as a processor on behalf of our customers.

Personal Data We Collect

The categories of personal data we collect are described in the section titled "Personal Information We Collect."

Personal Data Use and Processing Grounds

We will only process your personal data if we have a lawful basis for doing so, such as contractual necessity, legitimate interests, consent, or compliance with legal obligations. When processing is based on legitimate interests, those interests include providing, customizing, and improving the Services; marketing the Services; corresponding with you; meeting legal requirements; and completing corporate transactions.

Sharing Personal Data

We share personal data with third parties as described in the section titled "How We Disclose Your Personal Information."

EU Data Subject Rights

You have certain rights with respect to your personal data, including the rights to:

• Access the personal data we hold about you and request a copy.
• Rectify or supplement personal data we hold about you.
• Erase some or all of your personal data from our systems.
• Withdraw consent where processing is based on consent.
• Request portability of your personal data.
• Object to the further use or disclosure of your personal data for certain purposes.
• Restrict further processing of your personal data.
• Lodge a complaint with the supervisory authority of your country or EU Member State.

To exercise these rights, please contact us at privacy@refaire.ai. We may need additional information to verify your identity and the nature of your request.

Disclosure Regarding Individuals Under the Age of 16

RefaireAI does not have actual knowledge of any sale or sharing of personal information of minors under 16 years of age for cross-context behavioral advertising.

Disclosure Regarding Sensitive Personal Information

RefaireAI only uses and discloses sensitive personal information to:

• Prevent, detect, and investigate security incidents.
• Resist malicious, deceptive, fraudulent, or illegal actions directed at RefaireAI.
• Verify user identity in limited circumstances (for example, government ID verification).
• Use for purposes that do not infer characteristics about individuals.

Non-Discrimination

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

Authorized Agent and Verification

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

De-Identified Information

If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.

Refer-a-Friend and Similar Financial Incentive Programs

We may offer referral programs or other incentivized data collection programs that provide discounts, promotional items, or credit in connection with the program. Participation is voluntary and allows us to provide additional benefits to you. The value of your data to us depends on how you use our Services, whereas the value of the referred party's data depends on whether they ultimately become a user and use our Services.

Accessibility

This Privacy Policy uses industry-standard technologies and is intended to be accessible. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

California Shine the Light

The California "Shine the Light" law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

Right for Minors to Remove Posted Content

Where required by law, California residents under the age of 18 may request to have their posted content or information removed from publicly viewable portions of the Services by contacting us at privacy@refaire.ai or using available self-service tools.

Third-Party Websites/Applications

The Services may contain links to other websites or applications, and other services may reference or link to our Services. These third-party services are not controlled by us. We encourage you to read the privacy policies of each website and application with which you interact. Providing personal information to third-party websites or applications is at your own risk.

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 Our Privacy Policy

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes, we will notify you to the extent required by applicable law. Continued use of our Services after the new Privacy Policy takes effect means you accept the updated policy.

Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please email us at privacy@refaire.ai.