QUESTIONS; REPORTING VIOLATIONS
The Information We Collect
Personal Data. “Personal Data” is information that identifies you or can reasonably be expected to allow us to identify or contact you. Such Personal Data may include your name, address, email address, telephone number, birth date, or other personally identifiable information. When registering for an Gloria account, you will be required to provide us with Personal Data. We may also collect Personal Data that you voluntarily provide to us, such as when you contact us with inquiries, respond to one of our surveys, or submit your own content (e.g. photos, reviews, or comments) using the Site or the App. In addition, we collect information as part of your Style Profile, such as your date of birth and clothing size.
Billing Information. If you wish to subscribe to our paid services, including our digital wardrobe services (together, the “Services”) through the Site or App, you will also be required to provide certain information to us or our third-party payment processors. Such information may include credit or debit card information and similar data (collectively, “Billing Information”).
Other Information Automatically Collected. We may also collect additional information, including: (i) information that we automatically collect when you visit the Site using analytics tools, such as your IP address, Internet service provider, browser type and language, referring and exit pages and URLs, date and time of your visit, amount of time spent on particular pages, what sections of the Site you visit, number of links you click while in the Site, and similar information concerning your use of the Site; (ii) additional information that you voluntarily provide to us regarding your use and interest in our programs, offers, products, and services; and (iii) information collected by our cookies (see below) (collectively, “Other Information”).
Device Information. When you use the App or access the Site by or through a mobile device (including but not limited to smartphones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier. Device identifiers are small files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Site, and may remain persistently on your device, to help you log in faster and enhance your navigation through the Site. Some features of the App, Site or Services may not function properly if you disable or impair our access to or use of device identifiers.
HOW WE USE YOUR INFORMATION
We use the information described above to:
provide you access to and use of the Site, App and Services, including:
processing, verifying, validating, and completing your transactions,
associating the photographs in your Digital Wardrobe (your “Wardrobe”) with your account,
creating and organizing photographs of your Wardrobe in your account,
creating, managing, and maintaining your membership to the Services,
providing requested customer support and similar services,
keeping records of your purchase history,
permitting your participation in contests and promotions we may offer, and
sending emails and notification regarding your transaction and otherwise as appropriate and for purposes described above;
send notifications and communications to inform you about our products and services that may be of interest to you, as well as those of our third-party marketing partners;
inform you about rewards and promotional programs we may offer;
solicit your feedback, and improve our Site, App and Services;
conduct analytics based on your activity using the Site, App or Services;
fix any technical problems in the Site, App or your account; and
automatically update our App on your mobile device, if you permit us to do so.
WHO ELSE MAY RECEIVE YOUR INFORMATION
We will not rent or share your information with third parties without your consent. However, we may share your information within Gloria and with third parties that help us in providing the Site, App or Services to you or perform certain other operational or business-related functions. In particular:
Third Party Service Providers. We sometimes hire other service providers to perform certain business-related functions (“Contractors”). We may share your Personal Data and Billing Information with our Contractors in order to enable them to perform these functions such as process payments, edit photos of your Wardrobe, organize your Wardrobe, maintain databases and other related services. When we employ Contractors, we require them to use Personal Data and Billing Information only in connection with the services they perform for us.
Affiliates and Business Partners. In an ongoing effort to better understand our users and our Site, we might analyze the Other Information in aggregate form in a way that does not personally identify any one user (“Aggregated Information”). We may use Aggregated Information to conduct research on our end users’ demographics, interests, and behaviors or to otherwise operate or improve our business and we may share Aggregated Information with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and the Site to current and prospective business partners and to other third parties for other lawful purposes.
Mergers and Acquisitions. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data, Billing Information, Device Information and Other Information may be part of the transferred assets.
ACCESSING, MODIFYING, AND DELETING PERSONAL INFORMATION AND COMMUNICATION PREFERENCES
You may access, review, delete, or make changes to Personal Data that you have provided to us by [viewing the “My Account” section of the App, or by emailing us at email@example.com. In addition, you may manage your receipt of marketing and non-transactional communications by clicking the unsubscribe link located in any Gloria marketing emails or by emailing your request to firstname.lastname@example.org. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.
We may send you certain communications relating to your registration, your transactions and our other services, such as customer service responses and other administrative messages, without offering you the opportunity to opt out of receiving them. You can opt out from receiving such messages by canceling your registration. If you opt out, we may still send you non-promotional communications, such as emails about your account or our ongoing business relations.
We will retain your information for as long as your account is active or as needed to provide you Services, and for a reasonable time thereafter bearing in mind the possibility of your re-using our Services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements with you.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by us to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us as described in the “Our Contact Information” section below.
A NOTE ABOUT CHILDREN
The Site is not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act and will not knowingly register or otherwise collect Personal Data from any child under the age of 13. We ask that minors under the age of 13 not submit any Personal Data to us. If a child under the age of 13 has provided us with Personal Data, a parent or guardian of that child may contact us as described below and request that such information be deleted from our records.
LINKS TO OTHER WEBSITES
We take reasonable security measures to protect against the loss, misuse, or alteration of Personal Data, Billing Information, Device Information and Other Information that we have collected. Although we make good faith efforts to store the information collected by or through the Site in a secure operating environment that is not available to the public, we are unable to guarantee that the security measures we take will not be penetrated or compromised, or that your Personal Data will remain secure under all circumstances. Further, while we take efforts to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining this information.
OUR CONTACT INFORMATION
Last updated: Nov. 13, 2017