Privacy Policy

Last updated: February 13, 2024

Thank you for using Rue! Capitalized terms used but not defined shall have the respective meanings given to them in the Terms of Service (the “Terms”). The provisions of the Terms apply to this Privacy Policy (“Policy”) as well. We created this Policy to give You confidence as You visit and use Our websites, including, but not limited to, userue.com, app.userue.com, and any other website. We operate that links to this Policy, and any of Our pages or accounts on any other online platforms (including, but not limited to, social media sites such as Facebook, Instagram, LinkedIn and Twitter) (collectively, Our “Sites”), and all other products or services available through Our Sites, or otherwise (collectively, with Our Sites and general business operations, Our “Service”). This Policy covers how We collect, use, store, and share Your information when You use Our Service. This Policy has been written to comply with the requirements of the EU General Data Protection Regulation (“GDPR”) and various other data privacy laws.

Please Read This Policy Carefully. By Creating An Account, You Represent And Agree That You Have Read, Understand, And Agree To Be Bound By Both This Policy And Our Terms As Binding Agreements.Rue Reserves The Right To Change This Policy From Time To Time, With Or Without Notice To You, Except To The Extent Required By Gdpr. If You Continue To Use The Service, You Consent To The New Policy. We Will Always Have The Latest Policy Posted On The Service. 

Do not hesitate to contact us at hello@userue.com if You have any questions related to Your use of the Sites and/or this Policy.

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Rue, Inc., 1178 Broadway, 3rd Floor #3416, New York, NY 10001. For the purpose of the GDPR, the Company is the Data Controller.
• Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
• Personal Data is any information that relates to an identified or identifiable individual.For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
• Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to Rue, accessible from this link
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Types of Data Collected

This Policy applies to personal information We collect on the Service. As used in this Policy, “personal information” means information that can be used to identify any natural person either directly or indirectly.

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Depending on the types of activities You engage in on Our Sites or how You otherwise use or interact with Our Service, We may collect the following categories of personal information about You:

• Identifiers and contact information, such as Your real name or alias, physical address, email address, telephone number and similar information;
• Online identifiers You use, such as Your username, social media handles and similar information;
• Account information, such as Your username, password, account activity and similar information;
• Biographical and demographic information, such as Your age, gender and similar information;
• Employment or organizational information, such as Your employer, membership in organizations and similar information;
• Information about Your interests, hobbies and similar information;
• Any other information You or third parties provided to Us; and,
• Usage Data.
• We collect information that You provide to Us directly when You:
• Create an account;
• Contact Us to ask a question or otherwise communicate with Us;
• Respond to surveys;
• Participate in a contest, sweepstakes, or other promotional activity;
• Request customer service including dispute resolution, correspondence through any part of Our Services, and any correspondence You send to Us;
• Post a review or comment any part of Our Service, post other user-generated content on any part of Our Service;
• Upload content, including without limitation photos, videos, and other digital content;
• Apply for a job with Rue;
• Sign up to receive announcements, newsletters, or other promotional materials; or
• Otherwise provide Us with Your personal information.

The collection of this information is necessary to provide the functionality of the Service and/or to comply with applicable laws and regulations related to the Service’s product offerings. While the information described here is provided to Us only with Your permission, some aspects of the Service may not be available if You choose not to provide Us with such information and personal information.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

• Google

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device when You visit certain websites. Cookies may be first-party or third-party cookies. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Service. Unless You have adjusted Your browser setting so that it will refuse Cookies, Our Service may use Cookies.Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies here: Cookies by TermsFeed Generator.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

‍Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

‍Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

‍Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering Your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.

Tracking and Performance Cookies

‍Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify You as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device You use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how Our users react to them.

• Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at this link
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
• Other Technologies. We may use other third-party services, including but not limited to, the technologies listed in this Policy (see Detailed Information on the Processing of Your Personal Information), that automatically collect information about You to better understand how You use and interact with the Service. For example, We may use third-party vendors to provide Us with services surrounding analytics, advertising, and cybersecurity. The information collected through this process by the third-party service providers does not enable Us or them to identify Your name, contact details or other personal information that directly identifies You unless You choose to provide these. We use this information to better understand how users interact with the Service and to improve Your experience while using the Service. We may also use these analytics services to record mouse clicks, mouse movements, scrolling activity, as well as any text that You type into Our Service. By using Our Service, You acknowledge and agree that You are aware that Our Service may record Your activities on Our Service and that You consent to this recording.
• Log Files. Log files refers to the information that is automatically sent by Your web browser or device (or otherwise automatically collected) each time You view or interact with Our online Service. The information inside the log files may include IP addresses, type of browser, internet service provider, date/time stamp, referring/exit pages, clicked pages and any other information Your browser may send to Us.
• Device and Online Usage. We may collect information about Your computer, browser, mobile or other device that You use to access Our Service. We may use cookies, pixels, log files and other techniques to collect such information, including IP address, time zone, device identifiers and other unique identifiers, browser type, browser language, operating system name and version, device name and model, version, referring and exit pages, dates and times of Service access, links clicked, features uses, crash reports and session identification information.
• Do Not Track Signals. We do not currently respond or take any action with respect to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of information about an individual consumer's online activities over time and across third-party websites or online services. 

We use the personal information that We collect to make the Service available to Our users, to comply with Our legal obligations under applicable laws, to market and promote the Service, to improve the Service, and to protect Our legal rights. 

Examples of the ways in which We may use Your personal information include:

• For any purpose with Your consent and/or to fulfill any other purpose for which You provide Your personal information to Us;
• To provide, operate, analyze, administer, improve, personalize, and maintain Our Service, including to monitor the usage of Our Service.
• To manage Your Account: to manage Your registration as a user of the Service and Account and provide You with the Service and any information, product, or order fulfillment. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
• Send You updates and promotional materials.
• Process and deliver contest entries and rewards.
• To manage Your requests: To attend and manage Your requests to Us.
• Advertise or market product or services to You, including to deliver direct mail, email, mobile messages, social media notifications and other electronic marketing communications, and provide personalized or interest-based advertising to You;
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Our Service users is among the assets transferred.
• Protect Our rights or Our property and to ensure the technical functionality and security of the Service;
• Comply with applicable law, assist law enforcement, and to respond to regulatory or other legal inquiries.
• For other purposes: We may use Your information for other purposes, such as data analysis, market research, identifying usage trends, determining the effectiveness of Our promotional campaigns and to evaluate and improve Our Service, products, services, marketing, advertising, and Your experience.

By using the Service, You consent to Us using Your personal information to contact You with email newsletters or about Our products and special events. If You no longer want to receive marketing-related emails from Us, You may opt-out via the unsubscribe link included in such emails, or by whatever other means We allow You to unsubscribe. We will try to comply with Your request(s) as soon as reasonably practicable. Please note that if You opt-out of receiving marketing-related emails from Us, We may still send You important administrative messages that are required to provide You with Our Services. Upon receipt of any of the above request(s), We will reflect any changes You request in Our databases to the full extent required by GDPR, the SCCs, or other applicable law and We will confirm the changes to You.

We may disclose and share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to support aspects of the Service and Our business, including services related to website hosting, data analysis, information technology and related infrastructure, bank account identity and authentication, helpdesk and support, partner identity verification, and fraud protection as well as monitor and analyze the use of Our Service and to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, reorganization, dissolution, or other sale or transfer of some or all of the Company assets, financing, or acquisition of all or a portion of Our business to another company whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Us about Our users is among the assets transferred (in such event, We will provide notice to Our users of such transfer).
• With Affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
• When We believe: In good faith, that disclosure is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of Our Terms or any other applicable policies or Rules.
• With Your consent: We may disclose Your personal information for any other purpose with Your express consent.

Additionally, from time to time, We may receive requests from government agencies to obtain information about Our users. In handling such government requests, We greatly value the privacy of Your information. While We may be required to turn over partner information at times, We will strive to require a search warrant or subpoena, to the extent that We can reasonably demand such warrant or subpoena, before We turn over information about You and We will also strive to notify users when We receive government requests about their data. We will only share Your personal information for the foregoing reasons to the extent permitted by GDPR or other applicable data privacy laws. 

Finally, We may disclose anonymized, non-personal information about the Service and Our users without restriction.

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Information collected in the European Economic Area (“EEA”) may be transferred, stored and processed by Us or third parties (as provided in this Policy) in the United States and other countries whose data protection laws may be different than the laws of Your country. Whenever We transfer Your personal information out of the EEA, We ensure a similar degree of protection is afforded to it by entering into SCCs with the relevant third party.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

As described in this Policy, We may share personal information with third parties and may be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

You Consent To Any And All Information You Provide And Submit Via The Site Being Sent To The United States Of America. The United States Has Not Sought Nor Received A Finding Of “Adequacy” From The European Union Under Article 45 Of The Gdpr. Rue Relies On Derogations For Specific Situations As Set Forth In Article 49 Of The Gdpr. You Are Also Informed That The United States Presently Does Not Have An Adequate Level Of Personal Data Protection As Determined By The European Commission’s Adequacy Decision On October 6, 2015 (Case C-362/14) And Articulated In The European Union’s General Data Protection Regulation And Has Not Received A Similar Designation Of Adequacy By Any Other Foreign Data Protection Authority. You Agree To The Transfer Of Your Data And Personal Data To The United States, However, To Be Used In Accordance With This Privacy Policy.

Please contact Us at hello@userue.com if You want further information on the specific mechanism used by Us when transferring Your personal information out of the EEA.

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

We use commercially reasonable physical, technical, and administrative measures to secure Your personal information from accidental loss and from unauthorized access, use, and disclosure. For example, We (i) restrict access to personal information to employees, contractors, and other service providers, (ii) limit the storage of personal information to users’ name and email address only, (iii) train Our personnel on privacy issues as needed, and (iv) require Our employees to sign confidentiality agreements that extend to Your personal information. However, the transmission of information via the Internet is not completely secure. As We cannot guarantee the security of information transmitted to or from Us, We are not responsible for any unauthorized access to and disclosure of any information You send to or receive from Us. Any transmission of personal information is at Your own risk. We are not responsible to Our users or to any third party due to any loss, misuse, or alteration, except to the extent required by GDPR, the SCCs, or other applicable law.

Please also keep in mind that the safety and security of Your information also depends on You. You are responsible for keeping Your account information, including Your password, confidential. We ask You not to share Your password with anyone. If You have reason to believe that Your data is no longer secure, please contact Us immediately at the email address or mailing address listed at the end of this Policy.

If You would like to deactivate Your Account, please email the address provided at the end of this Policy. However, even after You request deactivation of Your account, We can retain copies of information about You, including Your name and email address, and any transactions or services in which You may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as We believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with Our services and products, to assist with investigations, to enforce any of Our terms and conditions or other applicable agreements or policies, or to take any other actions consistent with applicable law. In addition, You acknowledge that Your Account will not be deleted, and You may request reactivation by emailing the address provided at the end of this Policy.

We will use commercially reasonable efforts to ensure that Service Providers delete or modify Your personal information to the extent required by GDPR and the European Commission’s model contracts for the transfer of personal data to third countries (the “SCCs”). 

The Service Providers We use may have access to Your Personal Data. These Service Providers collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Any third-party services integrated with the Service shall be subject to the policies and practices of such third parties, and We are not responsible for how they collect, use, and share Your personal information except to the extent required by GDPR and the SCCs. We encourage You to review the privacy practices and policies of such third parties. We make no guarantees about, and assume no responsibility for the information, services, or data/privacy practices of third parties except to the extent required by GDPR and the SCCs.

When You create an Account, link a social media account, or connect with a third-party service, You are authorizing Us to share Your identity and banking information with the Service Providers. You are also agreeing to the terms of each applicable Service Provider (collectively, the “Partner Terms”). The Partner Terms may be modified from time to time, and the governing versions are incorporated by reference into this Policy. Any term not defined in this section but defined in the Partner Terms assumes the meaning as defined in the Partner Terms.

Additionally, Our Site may include links to other third-party websites as a convenience to You. If You click on one of those links You will be taken to websites We do not control, and this Policy does not apply to those third-party websites. The inclusion of any link does not imply Our endorsement of any other company, its site(s), or its product(s) and/or service(s). We are not responsible for the privacy practices or content of any other site.

IT IS YOUR RESPONSIBILITY TO READ AND UNDERSTAND THE PARTNER TERMS BECAUSE THEY CONTAIN TERMS AND CONDITIONS CONCERNING YOUR Rue ACCOUNT, INCLUDING BUT NOT LIMITED TO USE OF YOUR PERSONAL INFORMATION.

We may use third-party Service providers to monitor and analyze the use of our Service.

‍Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made Your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms.

Hotjar

We partner with Hotjar to collect foot traffic data analytics. Rue will have access to aggregate data through this partnership. For more information on the privacy practices of Hotjar, please visit their webpage.

We may use Email Marketing Service Providers to manage and send emails to You.

MailGun

MailGun is an email marketing sending service provided by MailGun LLC. For more information on the privacy practices of MailGun, please visit their Privacy Policy.

We may provide paid products and/or services within the Service. In that case, We may use third-party services for payment processing (e.g. payment processors).We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

‍Stripe

Their Privacy Policy can be viewed at Stripe Privacy Policy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected. You are solely responsible for ensuring that any personal information that You provide to Us is accurate. You may be able to view and update certain personal information that We have about You by logging into Your Account or by emailing the address provided at the end of this Policy. Please note that except to the extent required to comply with GDPR, We reserve the right to reject any changes You make to Your personal information and to reject any requests to change Your personal information submitted through inappropriate channels.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

‍Category A: Identifiers.

• Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
• Collected: Yes.

‍Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

• Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
• Collected: Yes.

‍Category C: Protected classification characteristics under California or federal law.

• Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
• Collected: Yes.

‍Category D: Commercial information.

• Examples: Records and history of products or services purchased or considered.
• Collected: Yes.

‍Category E: Biometric information.

• Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
• Collected: Yes.

‍Category F: Internet or other similar network activity.

• Examples: Interaction with our Service or advertisement.
• Collected: Yes.

‍Category G: Geolocation data.

• Examples: Approximate physical location.
• Collected: Yes.

‍Category H: Sensory data.

• Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
• Collected: No.

‍Category I: Professional or employment-related information.

• Examples: Current or past job history or performance evaluations.
• Collected: Yes.

‍Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

• Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
• Collected: No.

‍Category K: Inferences drawn from other personal information.

• Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Collected: Yes.

Under CCPA, personal information does not include:

• Publicly available information from government record.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, such as:

— Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

— Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.Indirectly from You. For example, from observing Your activity on our Service.
• Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
• From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

• To operate our Service and provide You with our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Category A: Identifiers

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

• Category D: Commercial information

• Category F: Internet or other similar network activity

Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

• Service Providers

• Payment processors

• Our affiliates

• Our business partners

• Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Please refer to the "Use of Your Personal Data" section for more details on how We may share Your personal information.

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

‍The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

‍The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:

• The categories of personal information We collected about You

• The categories of sources for the personal information We collected about You

• Our business or commercial purpose for collecting or selling that personal informationThe categories of third parties with whom We share that personal information

• The specific pieces of personal information We collected about You

• If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:

— The categories of personal information categories sold

— The categories of personal information categories disclosed

‍The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.

‍The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:

• Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

‍The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:

• Denying goods or services to You

• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

• Providing a different level or quality of goods or services to You

• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

• By email: hello@userue.com

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative

• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

• Verify Your identity or authority to make the request

• And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI's opt-out platform: click here

‍• The EDAA's opt-out platform click here

‍• The DAA's opt-out platform: click here

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If You change browsers or delete the cookies saved by Your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices

• "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

To ask questions or comment about this Policy and our privacy practices, contact us at hello@userue.com or 1178 Broadway, 3rd Floor #3416, New York, NY 10001. Please note that email communications may not be secure. Accordingly, you should not include personal or other sensitive information in your email correspondence.