Effective Date: July 18, 2020
- Personal Data
- How We Share Your Personal Data
- Tracking Tools, Advertising and Opt-Out
- Data Security and Retention
- Personal Data of Children
- California Resident Rights
- Other State Law Privacy Rights
- Contact Information
2. Personal Data
2.1. Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
|Category of Personal Data||Examples of Personal Data We Collect||Categories of Third Parties With Whom We Share this Personal Data:|
|Profile or Contact Data||
|Social Network Data||
|Consumer Demographic Data||
|Internet or other similar network activity information||
|Other Identifying Information that You Voluntarily Choose to Provide||
2.2. Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
When you provide such information directly to us.
- When you create an account or use our interactive tools and Services.
- When you place an order for the Cleaning Services, we collect payment data, depending on the form of payment you choose.
- When you send in your garments or other items for the Cleaning Services, we may collect information on such items, including type, service requested, brand, color, size, and photos.
- When you voluntarily provide information in text messages or in free-form text boxes through the Services or through responses to surveys or questionnaires.
- When you choose to refer a friend through the Services, we will ask for your friend's contact information.
- When you send us an email or otherwise contact us.
When you use the Services and such information is collected automatically.
- Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
- If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
- If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
- When you provide such information directly to us.
- We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
- We may use vendors to obtain information to generate leads and create user profiles.
- We receive information about you from some of our vendors who assist us with marketing or promotional services for the Rinse Services related to how you interact with our websites, applications, products, Services, advertisements or communications.
- If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
2.3. Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Services
- Creating and managing your account or other user profiles
- Processing orders or other transactions; billing
- Providing you with the Cleaning Services, or other products, services or information you request
- Meeting or fulfilling the reason you provided the information to us, such as to message to your friend inviting him or her to sign-up for the Service
- Providing support and assistance for the Services
- Analyzing trends and consumers’ interactions with the Services
- Improving the Services, including testing, research, internal analytics and product development
- Personalizing the Services, website content and communications based on your preferences
- Doing fraud protection, security and debugging
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”)
Marketing the Services
- Marketing and selling the Services
- Providing you with customized offers or promotions that we think might be interested to you
- Showing you advertisements, including interest-based or online behavioral advertising, and retargeted online and mobile advertisements to you across computers or devices you may use
Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Rinse or the Services
- Sending emails and other communications according to your preferences or that display content that we think will interest you
Meeting Legal Requirements and Enforcing Legal Terms
- Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities
- Protecting the rights, property or safety of you, Rinse or another party
- Enforcing any agreements with you
- Responding to claims that any posting or other content violates third-party rights
- Resolving disputes
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
3. How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
- Hosting, technology and communication providers, such as AWS
- Security and fraud prevention consultants
- Analytics providers, such as Google Analytics and Facebook Pixel
- Support and customer service vendors
- Product fulfillment and delivery providers
- Our payment processing partner Braintree (offered by PayPal, Inc.) (“Braintree”) collects your voluntarily-provided payment card information necessary to process your payment.
Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
- Ad networks
- Data brokers
- Marketing providers
Parties You Authorize, Access or Authenticate
- Third parties you access through the services
- Social media services
3.1. Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
3.2. Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
3.3. Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
4. Tracking Tools, Advertising and Opt-Out
We use the following types of Cookies:
- Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
- Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
4.1. Information about Interest-Based Advertisements
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
4.2. Opt-out Choices
We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices or www.aboutads.info/choices. To opt-out of the use of your mobile device ID for targeted advertising, see http://www.aboutads.info/appchoices.
We provide our consumers with the opportunity to opt-out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product or service. To opt-out of marketing communications, you may use one of these convenient methods:
- Electronic Promotional Offers. If you do not want to receive emails from us regarding special promotions or offers, you may click the unsubscribe link in the footer of any email, or contact us at email@example.com with “Unsubscribe Promotional Offers” in the subject line.
- Mobile Promotional Offers. When you provide us with your mobile number for marketing purposes, we may send you certain marketing alerts via text message. Standard data and message rates will apply. If you no longer wish to receive mobile alerts from us, you can follow the instructions provided in those messages or otherwise reply “STOP” to any Rinse alert.
Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable. Additionally, we are not responsible for informing third parties (including without limitation our third party service providers or partners) with whom we have already shared your personal information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.
5. Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
6. Personal Data of Children
7. California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
- The categories of Personal Data that we have collected about you
- The categories of sources from which that Personal Data was collected
- The business or commercial purpose for collecting or selling your Personal Data
- The categories of third parties with whom we have shared your Personal Data
- The specific pieces of Personal Data that we have collected about you
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
7.3. Exercising Your Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (for instance, we may require you to send an email from the email address on your account), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
7.4. Personal Data Sales Opt-Out and Opt-In
In this section, we use the term ‘sell’ as it is defined in the CCPA. We sell your Personal Data, subject to your right to opt-out of these sales.
As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out of these sales by following the instructions in this section.
We sell your Personal Data to the following categories of third parties:
- Analytics providers, such as Google Analytics and Facebook Pixel
- Ad Networks
- Data brokers
- Marketing providers
Over the past 12 months, we have sold the following categories of your Personal Data to categories of third parties listed above:
- Profile or Contact Data
- Payment Data
- Commercial Data
- Device/IP Data
- Web Analytics
- Social Network Data
- Consumer Demographic Data
- Geolocation Data
- Internet or other similar network activity information
- Other Identifying Information that You Voluntarily Choose to Provide
You have the right to opt-out of the sale of your Personal Data. You can opt-out using the following methods:
- You can complete the online form found here: Do Not Sell My Personal Information
- Email us at firstname.lastname@example.org
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
To our knowledge, we do not sell the Personal Data of minors under 16 years of age.
7.5. We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
8. Other State Law Privacy Rights
8.1. California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at email@example.com.
8.2. Nevada Resident Rights
If you are a resident of Nevada, you 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. You can exercise this right by contacting us at firstname.lastname@example.org with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
10. Contact Information