Privacy

This Privacy Policy was last updated on January 6, 2020.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. THIS POLICY DESCRIBES THE WAYS RETURNLY TECHNOLOGIES, INC. (“Returnly”, “we”, “us”, “our”) OR OUR VENDORS COLLECT, PROTECT, USE AND STORE YOUR PERSONAL INFORMATION. YOU ACCEPT THIS PRIVACY POLICY BY USING OUR PRODUCTS AND SERVICES ON OUR WEBSITE OR THROUGH ANY OTHER MEANS (COLLECTIVELY THE “SERVICES"). IF YOU ARE ENTERING INTO THE PRIVACY POLICY ON BEHALF OF A COMPANY, BUSINESS OR OTHER LEGAL ENTITY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH ENTITY AND AFFILIATES TO THE PRIVACY POLICY, IN WHICH CASE THE TERMS “YOU” OR “YOUR” SHALL REFER TO SUCH ENTITY AND ITS AFFILIATES. IF YOU DO NOT HAVE SUCH AUTHORITY, OR IF YOU DO NOT AGREE TO BE BOUND BY THE PRIVACY POLICY, YOU MAY NOT ACCESS OR USE THE SITE OR THE SERVICES.

We may amend this Privacy Policy at any time by posting a revised version on our website. We will attempt to give a reasonable notice period upon making any changes; however, unless otherwise stated, the revised version will be effective at the time we post it.

1. How Returnly collects your information

1.1. Information you give Returnly

If you open an account or use the Returnly Service, we may collect the following types of information:

Personal information - first name and surname, username and password, email address, contact information, country of residence, job title, and other information you provide us when you create an account, sign-up to receive communications or materials from us, or otherwise submit a form to us and other similar information.

Content and information that you submit when using Returnly; this information includes, for example, information you provide on the Sites, information you provide when you participate in any interactive features or surveys, and information you submit when filing a support ticket;

Financial information - bank account numbers and/or credit card numbers that you link to your Returnly account or give us when you use the Services.

Before permitting you to use the Services, we may require you to provide additional information, including but not limited to your date of birth, shipping address and other personal information.

We may use this information to verify your identity or other information you provide.

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, details of your purchases, 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 use these tracking technologies when you interact with the services we offer to our partners, such as advertising services or Returnly 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 content.
  • Analytics: Allowing us to understand how our Services are being used, track site performance, and make improvements.
  • Personalized advertising and product recommendations: 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 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.

You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook and Twitter). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. By associating an account managed by a third party with your Returnly account and authorizing Returnly to have access to this information, you agree that Returnly may collect, store and use this information in accordance with this Privacy Policy.

2. How Returnly protects your information

2.1. Safety 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.

From time-to-time, we review our security procedures to consider appropriate new technology and methods.

Please be aware, though, that despite our efforts, no security measures are perfect or impenetrable. We cannot ensure, and do not warrant or guarantee that the information you transmit to Returnly will remain secure, nor do we guarantee that this information will not be accessed, disclosed, altered, destroyed or used in an unauthorized manner.

If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on the Site if a security breach occurs. Depending on where you live, you may have a legal right to receive a notice of a security breach in writing.

3. How Returnly uses your information

3.1. To improve our service

Returnly uses information to perform and improve our services, contact you, conduct research, and provide anonymous reporting for clients. For example, we may use the information to provide customer service and support, process transactions, resolve disputes, collect payments, prevent illegal activities, customize the Services, reduce risk to all parties involved in our transactions, and verify the accuracy of information.

3.2. To serve relevant marketing and product recommendations to you

We may use information to deliver targeted marketing, service update notices, and promotional offers based on your communication preferences. We may combine your information with information we collect from other companies and use it to improve and personalize the Services, content, and advertising.

4. How Returnly shares your information.

4.1. For our everyday business purposes

We share your personal information with employees, affiliates, vendors, partners, merchant partners, marketing providers, and third parties as required to offer the Returnly Service. This includes, but is not limited to, processing transactions, maintaining your account, responding to court orders and legal investigations, litigation purposes, complying with audits or other investigations, and reporting to credit bureaus.

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.

We may share your information with the merchants you use the Returnly Services with for marketing purposes, and as otherwise permitted by law.

4.2. When required by law

We will share your information with any party when required by law or by a government request to do so or to combat fraud or criminal 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 creating an Returnly account, you consent to Returnly sharing your information with merchants you use the Returnly 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.

5. What are your options?

5.1 Changes to your personal information

You can easily access personal information that you have submitted to us and request the correction of any inaccurate information you have submitted to us via your user account or by emailing support@returnly.com.

If you close your Returnly account, we will mark your account in our database as “Closed,” but will keep your account information in our database to comply with our legal obligations. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. If you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law or in accordance with this Privacy Policy.

Returnly reserves the right to close or limit access to your account should you opt out of the crucial notices that are required to perform the Returnly Service. You are still responsible for any amounts due to Returnly even if we close or limit access to your account.

6. California consumers

6.1 Your California privacy rights

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 the company 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 email support@returnly.com.

California Consumer Privacy Act: The California Consumer Privacy Act (“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 the sharing of Personal Information. The CCPA defines “Personal Information” to mean “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.” Certain information we collect may be exempt from the CCPA because it is considered public information (e.g., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

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

You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.

  • Personal identifiers:
    • We collect your name, phone number, and email address and contact address when you create an account or complete a transaction. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile. We use this information to provide the Services, respond to your requests, and send information and advertisements to you.
    • We collect payment information when you provide it to us, which may be your credit card number or a bank account, when you complete a transaction. You have the option to store this information to your account or set up a recurring transaction. We use this information to streamline and facilitate payments and transactions.
    • We may collect your Social Security number or Driver’s License number. We use this information to identify you, authenticate and collate information about you, prevent fraud, and conduct background checks or other screening activities.
    • We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.
    • We collect your Device ID automatically when you use our Services. We use this information to monitor your use, and the effectiveness of, our Services, to identify you, and to provide you with targeted information and offers.
  • Protected classifications: We collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors.
  • Commercial information: When you engage in transactions with us, we create records of goods or services purchased or considered or returned, as well as purchasing or consuming histories or tendencies. We use this information to measure the effectiveness of our Services and to provide you with targeted information, advertisements, and offers.
  • Internet or other electronic network activity information: We collect information about your browsing history, search history, interaction with websites, and applications or advertisements automatically when you utilize our Services. We use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.
  • Geolocation data: As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device’s IP address. When you use the Services for the first time, we may ask for your permission to collect your precise location (i.e., your GPS coordinates). If you allow your device to provide us with this information, we use it to make improvements to our products and services, and to provide recommendations and deliver relevant advertising.
  • Audio, electronic, visual, or similar information: If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We may collect your photographic or video image, or similar information. We use this information to monitor our customer service, maintain the security of our systems and physical locations, and train employees.
  • Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile. We use this information to gauge and develop our marketing activities, measure the appeal and effectiveness of our Services, applications, and tools, and to provide you with targeted information, advertisements, and offers.

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.

We may share any of the above-listed information with Service Providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service Providers are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of Service Providers with whom we share information and the services they provide are described in this Privacy Policy.

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

In order to process your request to know about or delete personal information we collect, disclose, or sell, we must verify your request. We do this by:

  • Providing personal identifiers we can match against information we may have collected from you previously, and
  • Asking you to confirm your request using the email address or telephone account stated in the request.

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.

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 identity 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.

Right to opt out of sale of personal information to third parties

Though Returnly does not sell Personal Information to third parties, California law requires that we maintain a separate webpage that allows you to opt out of the sale of your Personal Information in the future, which can be accessed by visiting our “Do not sell my info" webpage.

Please note that your right to opt out does not apply to our sharing of Personal Information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the Personal Information only for that function.

We may also disclose information to other entities when required by law or to protect Returnly or other persons, as described in our Privacy Policy.

How to submit a request

You may submit a request to exercise your rights by clicking here.

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.

8. Nevada residents

8.1 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 support@returnly.com.

9. Contact Returnly

9.1 Contact Returnly

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