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Returnly Privacy Policy

Returnly Holdings, LLC (“Returnly,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy (“Policy”) explains how we collect, use, disclose and protect Personal Information (as defined below) of our customers and users. It applies to all Personal Information collected by us or affiliates or third parties on our behalf through our products and services on our website or through third party websites (the “Sites”), Returnly mobile applications, and any other websites or mobile applications that link to this Policy, as well as during any written, electronic, and oral communications (collectively, the “Services”).

1. How Returnly collects your information

1.1. Personal Information we collect

Your Use of the Services. If you use the Returnly Services, either directly or through the Sites, we may collect the following types of Personal Information: your name, address, phone, email, third-party user IDs, and other similar.

Automatic Data Collection. We may collect certain information automatically when you use the Services, including your MAC address, cookie identifiers, Internet protocol (IP) address, mobile advertising, and other unique identifiers, details about your browser, operating system or device, Internet service provider, mobile carrier, location information (including inferred location based off of  your IP address), actions that you take while using the Services, information about how you interact with the Services, including the frequency and duration of your activities, information about the links you click, and other information about how you use the Services.

Cookies, Pixel Tags, and other Technologies. We may use cookies, pixel tags, local storage, and other technologies when you interact with the Services. We use cookies in accordance with this Policy to: ensure that our Services function properly, enable features that enhance the Services, such as remembering your preferences, detect and prevent fraud, understand how visitors use and engage with the Sites, deliver tailored advertising based on your preferences or interests, and analyze and improve Services. Some cookies are essential to the operation of the Sites and Services and make it usable and secure by enabling basic functions like page navigation and access to secure areas of the Sites.

1.2. Information Returnly learns from your Use

When you visit the Returnly website or use the Services, we may collect information sent to us by your computer, mobile phone or any other device. This information may include:

Usage, viewing, logs, and other devices and technical data collected when you visit our sites as an end user, or open or reply to emails we send. This may include information such as your web request, Internet Protocol (“IP”) address, device identifiers, device information (such as OS type or browser type), cookies that may uniquely identify your browser or your account, referring / exit pages and URLs, interaction information (such as clickstream data), domain names, pages viewed, and other similar technical data;

Location information about your use and interaction with our website, application or the Services, including location information either provided by a mobile device interacting with one of our sites or applications or associated with your IP address. For example, we may evaluate your computer, mobile phone or other access device to identify any malicious software or activity that may affect the availability of the Services.

We may also collect information about you from any contact you have with any of our services or employees, such as, with our customer support team, in surveys, or through interactions with our affiliates.

1.3. Cookies and other tracking technologies

We use various technologies to collect and store information when you use the Services, and this may include sending one or more cookies or device identifiers. We also these tracking technologies when you interact with the services we offer to our partners, such as advertising services or Affirm features that may appear on other sites and in any other manner that we deem necessary for our business purposes, such as:

  • Site Operations: Enabling features that are necessary for providing you the Services on our site, such as identifying you as being signed in, tracking content views, remembering your preferences, and the number of times you have been shown an advertisement.
  • Analytics: Allowing us to understand how our Services are being used, track site performance, and make improvements.
  • Personalized Advertising: Delivering tailored advertising based on your preferences or interests across services and devices and measuring the effectiveness of advertisements.
1.4. Information obtained from third parties

We may also obtain information about you from third parties such as our merchant partners you interact with, identity verification services, or public sources or that we receive from companies that partner with us to provide products and services; this may include information about you we receive from our advertising and market research partners, who may provide us with information about your interest in and engagement with our Services. Information obtained from third parties will be used in accordance with the third party’s privacy policy.

2. How Affirm protects your information

2.1. Security policies

Returnly stores and processes your information maintaining physical, electronic and procedural safeguards. We maintain physical security measures to guard against unauthorized access to systems and use safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings, and we authorize access to personal information only for those employees or agents who require it to fulfill the responsibilities of their jobs.

3. How Returnly uses your information

3.1. To provide and improve the Services

Returnly uses information to provide and improve our Services, contact you, respond to questions, comments, and other requests, conduct research or analysis, and provide anonymous reporting for clients. For example, we may use information to provide customer service and support, process transactions, resolve disputes, authenticate and verify identities, collect payments, prevent illegal activities, customize the Services, reduce risk to all parties involved in our transactions, and verify the accuracy of information. Returnly may also use information to market the Services to you.

4. How Returnly shares your information.

4.1. For our everyday business purposes

We share your personal information with employees, affiliates, service providers, partners, merchant partners, marketing providers, and third parties as required to offer the Returnly Services. This includes, but is not limited to, processing transactions, account reminders and invoices, responding to court orders and legal investigations, litigation purposes, complying with audits or other investigations. We also engage the following types of service providers to perform functions on our behalf: marketing providers, billing and collection providers, auditing and accounting firms, professional services consultants, providers of analytics services, security vendors, and IT vendors. Occasionally, these service providers may also collect data directly from you and their privacy policies may also apply.

4.2. When required by applicable law

We may access, preserve, and disclose any information to external parties if we, in good faith, believe doing so is required or appropriate to: comply with applicable law; comply with law enforcement or national security requests and legal process, such as a court order or subpoena; or assist with an investigation and prosecution of suspected or actual illegal activity.‍

4.3. With our merchant partners to provide personalized offers

We may share your information with merchants you interact with using Returnly for marketing, if you consent or as permitted by law. By using the Services, you consent to Returnly sharing your information with merchants you use the Services with, for those merchants to market to you. We do this to help merchants personalize services and offers, so you can have a better experience. You’re able to revoke your consent at any time by following the steps below. If you choose to do so, we will stop sharing your information with merchants from that point onward, except as necessary to complete transactions you initiate. To revoke your consent to information sharing with merchants for marketing, you can click on the “unsubscribe” hyperlink at the bottom of any email communication where you may opt-out or change your communication preferences.

4.4 Corporate Transactions

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Information with third parties in connection with such transaction.

5. What are your options?

5.1 Updates to this Policy and Notifications

We may change this Policy from time to time to reflect new services, changes in our Personal Information practices or relevant laws. The “Last updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Services. If applicable law requires that we obtain your consent or provide notice in a specified manner prior to making any changes to this Policy applicable to you, we will provide such required notice and will obtain your required consent.

5.2 SMS messaging

You can opt out of receiving SMS messages by typing STOP in reply to an SMS message sent by Returnly.

6. California consumers

6.1 Your California privacy rights

If you are a consumer residing in California, we process your personal data in accordance with the California Consumer Privacy Act (“CCPA”).

Persons with disabilities may obtain this notice in alternative format upon request by contacting us at support@returnly.com.

California Civil Code Section 1798.83, also known as the Shine the Light law: Residents of the State of California have the right to request information from Returnly regarding other companies to whom Returnly has disclosed certain categories of information during the preceding year for the other companies’ direct marketing purposes. If you are a California resident and would like to make such a request, please click HERE or email support@returnly.com.

The CCPA provides California residents with the right to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as the right to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” as”information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to notice at collection regarding the categories of personal information collected

Section 1 describes the personal information we may collect about you, including the categories of sources of that information. We collect this information for the purposes described in Section 3. We share this information as described in Section 4.

Right to know about personal information collected, disclosed, or sold

You have the right to request that we disclose to you the Personal Information we collect, use, disclose, or sell. In order to process your request to know/access your Personal Information or delete your Personal Information we may ask you to take additional steps to verify your request or identity.

Verification procedures

When exercising your rights, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. Authentication based on a government-issued and valid identification document may be required.

If you have authorized someone else to make requests on your behalf, we will require that you provide notarized statements confirming the identity and authority of that person. Such notarized statements can be obtained by emailing privacy@affirm.com

Right to know/access information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request.

Right to request deletion of information

You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to information regarding participation in data sharing for financial incentives

You have the right to be free from discrimination based on your exercise of your CCPA rights. We may run promotions from time to time wherein we incentivize a consumer to share certain pieces of information with us. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.

Sale of personal information to third parties

Returnly does not sell Personal Information to third parties under any circumstances.

How to submit a request

You may submit a request to exercise your rights through the following means:

  1. By contacting support@returnly.com, where you can request and download specific pieces of information we have collected.
  2. By clicking HERE and submitting a request form.

Authorized agent

You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf.

7. Nevada residents

7.1 Special information for Nevada residents

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. Returnly does not sell the Personal Information of its customers. However, if you are a Nevada resident and would like to make such a request, please email privacy@returnly.com.

8. Contact Returnly

8.1 Contact Returnly

If you have questions or concerns regarding this Privacy Policy, you should contact us at support@returnly.com.

Rev. July 1, 2021