Privacy Policy

Effective March 1, 2020

YOUR PRIVACY IS OUR PRIORITY

 

About Retold

This Privacy Policy is an agreement between you and Family Wagon LLC, which is known as Retold or retoldrecycling.com. Along with our representatives, officers, shareholders, subsidiaries, affiliates, parents, employees, and agents (collectively “Retold” or “we” or “us” or “our”), we provide our website, Retoldrecycling.com, to you subject to the following Policy. For our European Economic Area (“EEA”) customers, Family Wagon LLC is the data controller – the company responsible for your personal information.

You may contact us regarding this policy by emailing [email protected] 

 

Who You Are

Under the Retold Terms of Service, you must be at least 18 years old and not a person barred from receiving services under the laws of the United States or other applicable jurisdictions to use our website. Persons between the age of 13 and 18 should use our website only with the consent and supervision of your parents or guardian.

We do not knowingly collect personally identifiable information from children under the age of 13. If you are under 13, please do not submit personal information to us or use the website.

 

Accepting This Privacy Policy

To provide you with services, including access to our website, we need to collect and process some information about you (your “personal information”). By using our website, you agree that we may do that in the ways described below. 

IF YOU DO NOT AGREE TO THESE TERMS FOR ANY REASON, YOU MAY SIMPLY STOP USING THE WEBSITE.

We may amend or change this Privacy Policy from time to time. Changes to the Privacy Policy will be posted to our website.

 

Information We Collect

To provide you with the full Retold experience, we collect and retrieve your personal information in a number of different ways. Why we collect your information and what we do with it depends on the type of information. The tables below provide more details.

 

YOUR NAME AND CONTACT DETAILS

If you create a Retold account or place an order with us, we collect your name and contact details, such as your email address, shipping addresses, and phone number. We also collect your email address if you enter it on our website to join our mailing list.

 

Information Collected	Why?
Name	·       For shipment or billing details ·       To personalize your contact or website experiences ·       To prevent and detect fraud against either you or Retold
Email	·       To send updates about your order ·       To contact you regarding issues around your order, experience, contests entered, or requested product information ·       To update you on items in your cart ·       To keep you up to date about Retold products and promotions. We will only send you these emails with your permission, and you can unsubscribe at any time – just use the “unsubscribe” link at the bottom of any Retold email ·       To prevent and detect fraud against either you or Retold
Phone Number	·       To contact you for urgent issues surrounding your order ·       To prevent and detect fraud against either you or Retold ·       To support you as a customer when requested ·       If you opt into SMS messaging, to send you SMS messages about your order and/or for marketing purposes
Shipping Address(es)	·       To complete the shipment of your order ·       To prevent and detect fraud against either you or Retold ·       To allow us to understand and improve the experience for users like you

 

YOUR DATE OF BIRTH INFORMATION

 

Information Collected	Why?
Birthday	·       To prevent and detect fraud against either you or Retold ·       To send a birthday offer, if you are subscribed to our promotional emails
Birth Year	·       To improve and personalize your shopping experience

 

YOUR PAYMENT INFORMATION

When you place an order, we require payment information on file. When you enter your payment information (credit card number, expiration date, and CVV code) it is sent directly to a secure third-party credit card processing center. Retold does not store any direct credit card or 3rd party payment information. We do store billing addresses, generic payment type, and, if you opt in, the last four digits of your credit card for your convenience during the ordering process.

 

Information Collected	Why?
Billing Address	·       Our payment partners require this information to process an order ·       To prevent and detect fraud against either you or Retold
Generic Payment Type	·       To give reference for support issues ·       To alert you when we detect or are verifying fraudulent activity ·       To allow us to understand and improve the experience for users like you
Last Four Digits of Credit Card	·       To provide convenience for you when you choose to order again

 

YOUR CONTACT HISTORY WITH US

What you’ve said to us — for example, over the phone, on email, or on live chat.

 

Information Collected	Why?
Email Correspondence	·       To respond to your requests to make sure you receive great customer service and ensure that any and all concerns or issues have been addressed ·       For a historic record of your contacts to save time during your inquiries ·       To ensure issues and questions you raised are proactively addressed for other customers  ·       To train our staff to ensure the best experience possible for all customers who contact us
Phone Correspondence	·       To respond to your requests to make sure you receive great customer service and ensure that any and all concerns or issues have been addressed ·       To train our staff to ensure the best experience possible for all customers who contact us
Live Chat Logs	·       To respond to your requests to make sure you receive great customer service and ensure that any and all concerns or issues have been addressed ·       For a historic record of your contacts to save time during your inquiries ·       To train our staff to ensure the best experience possible for all customers who contact us
Survey or Site Feedback	·       To respond to your requests to make sure you receive great customer service and ensure that any and all concerns or issues have been addressed  ·       To improve the experience for you and other users

 

PURCHASE AND PRODUCT FEEDBACK HISTORY AND SAVED PRODUCTS

 

What you’ve bought, what’s in your shopping cart, or products you have browsed

 

Information Collected	Why?
Purchased Items	·       To fulfill and ship your order as requested ·       To allow you to return and review delivered items ·       To tailor your experience around your interests ·       To improve our product selection and experience for you and other users ·       To help our buyers make sure we have the best items in stock for you and other customers ·       To prevent and detect fraud against either you or Retold
Items Added to Your Cart	·       To allow your order to be completed smoothly when you’re ready to check out ·       To update you on items in your cart, including low quantity or sale status ·       To tailor your experience around your interests
What you browsed	·       To allow you to save, organize, recall, and share items you’ve selected ·       To allow us to personalize product recommendations toward your interests
Reviewed Items	·       To better inform other customers about the pros and cons of a product ·       To improve our products in the future

 

INFORMATION ABOUT YOUR DEVICE TYPE, AND HOW YOU USE OUR WEBSITE

We automatically receive and record information from your browser or device when you visit our site, including your IP address and device type (i.e. computer, tablet, or smartphone), cookies, and data about which pages you visit. This information is stored in log files and is collected automatically. If you have an account with us, we may combine this information with other personal information we collect about you.

 

Information Collected	Why?
IP Address	·       To ensure the security of our website and determine, on an anonymous basis, where our customers are located ·       To prevent and detect fraud against either you or Retold
Device Type	·       To improve the experience for you and other users like you ·       To resolve customer issues that center around devices, operating systems, or browsers used ·       To prevent and detect fraud against either you or Retold and to keep your data secure
Page Visit History	·       To improve the experience for you and other users like you ·       To respond to and resolve any customer issues based on a specific page or page type
Identification Cookies	·       To provide you with Retold advertising, including across your devices ·       To provide you with a personalized shopping experience and ensure our advertising is relevant to you
Location Information	·       If you have location tracking enabled on your browser or mobile application, we may collect your precise location ·       We also may infer your location, for example by using your IP address ·       In order to improve the experience for you and users like you. ·       To determine, on an anonymous basis, where our customers are located ·       To prevent and detect fraud against either you or Retold

 

SPECIFIC DETAILS ABOUT YOU

You may enter some specific details about yourself to help other customers or for personalization towards yourself. There are two ways we might have your photographs: if you post a photo review or if you accepted our request to use your photo from a third-party site (like Instagram). We will never use your photograph without your express permission.

 

Information Collected	Why?
Uploaded Photos	·       To help other customers see what using our service looks like at home ·       To offer other customers the products and shopping experience most relevant to them

 

YOUR PUBLIC REVIEWS AND BLOG COMMENTS

We allow our customers to provide public feedback in the form of reviews about our website and comments on our social media posts. Please remember that any information that you disclose on public portions of the website, such as the reviews section, are not private and may be viewed (and potentially shared) on the Retold website and beyond. Please use caution when deciding to disclose your personal information in the public portions of our website.

 

Information Collected	Why?
Site Review	·       To improve the experience for you and other users like you ·       To respond to your requests and ensure you receive great customer service
Social Comments	·       To provide feedback based on your communications ·       To allow us to reference contest entries

 

ANONYMOUS AGGREGATED INFORMATION

We also receive anonymous and aggregated personal information through data analytics services. We use these analytics to ensure our website functions and to improve the Retold shopping experience. These analytics services record information such as how often you visit Retoldrecycling.com, what actions you take on our website, aggregated usage, performance data, errors and debugging information, and how you got to our website. We do not link the information from our analytics services to any personal information that you submit to us.

 

OUR LEGAL BASES FOR COLLECTING AND PROCESSING YOUR INFORMATION

When you access or use our website, we collect, use, and otherwise process your personal information as described in this policy. We rely on a number of legal bases to use your information:

• As necessary to perform a contract with you or to take steps in preparation for a contract with you, including enabling you to make a purchase from us;
• Because you have consented to the processing, such as for receiving marketing messages or third-party data sharing related to advertising;
• As necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims;
• As necessary for the purposes of our or a third party’s legitimate interests;
• As necessary to protect your vital interests, or those of others.

Here are some of our legitimate interests for collecting and processing your personal information:

Detecting and preventing fraud: We have a legitimate interest in detecting and preventing fraud. To do so, it is necessary that we collect and retain information about each transaction made at Retold. Our auditors require that we keep this information so they can verify that all transactions recorded by Retold were made by real customers. The credit card companies we work with require this information in the event that fraudulent charges are made using your credit card.

Providing access to and improving Retoldrecycling.com: We may use your information to improve and customize our website, including sharing of your information for such purposes, and this is necessary to pursue our legitimate interests of improving our website and our service. This is also necessary to enable us to pursue our legitimate interest in understanding how our website is being used, and to develop and expand our customer base. It is also necessary to allow us to pursue our legitimate interest in improving our website’s functionality and in obtaining insights into what our customers and potential customers want.

Providing access to and improving our customer service: We may use your information to provide you with customer service, and also to improve the service we provide to all customers. This is necessary for us to pursue our legitimate interest in providing great customer service.

Improving our product offerings: We may use your information to improve the products / subscriptions offered at Retold.

Keeping our website and your data secure: We have a legitimate interest in ensuring the security of our website, including enhancing protection of our company and our customers against spam, harassment, intellectual property infringement, crime, and security risks of all kind.

 

Information We Share

Except as otherwise set forth in this Privacy Policy, we will not provide access to your personal information to third parties for any unauthorized purpose. We never sell or share your contact information to other companies for their direct marketing purposes.

Retold works closely with third-party businesses (our “vendors” or “service providers” under the CCPA) for a variety of purposes, including assisting us to perform and improve the Retold website, to deliver your orders, and to provide advertising and email services. These vendors include payment processors, research companies, and analytics and security providers. These third parties have only limited access to your information, and may use your information only to perform these tasks on our behalf. We take reasonable steps to require that any such vendor complies with the terms of this Privacy Policy.

It is necessary for us to share your information with some of our vendors in order to complete our contract with you; for example, to allow them to process payments and shipments and to help us keep our website secure. Other vendors help us improve our website and our products; for example, by helping us conduct research into how we could better serve our customers, or reach new customers. We have a legitimate interest in working with these vendors to improve our business. We rely on your consent (which can be withdrawn at any time) to send marketing messages and for third-party sharing relating to advertising.

Retold also may share demographic information about our website visitors with vendors, but it will be aggregated and de-personalized, so personal information is not revealed.

Your information will remain subject to the terms of this Privacy Policy even if we undergo a business transition. However, we may transfer your information to a successor person or entity upon an acquisition or other corporate reorganization. You hereby consent to such transfers, and agree that we may assign and transfer all of the rights, benefits, duties, and obligations of this Privacy Policy to a successor person or entity.

We may also disclose your information if we have a good faith belief that we are required to do so by law or if acting with a good faith belief that such disclosure is reasonably necessary to: (1) comply with legal process; (2) enforce this Policy or the Terms; (3) respond to legal claims; (4) respond to your requests for customer service or transaction completion; or (5) protect the rights, property or personal safety of Retold, the website’s users or the public. In these cases, our use of your information may be necessary for the purposes of our or a third party’s legitimate interest in keeping our website secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage. Such use may also be necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims. It may also be necessary in the public interest (such as to prevent crime).

 

Consent, Control, Retention

Much of your information is stored in your Retold account profile. You may change or correct the information in your account profile by emailing [email protected]. If you would like to cancel your account entirely, please email [email protected].

Depending on your location, such as the EEA, Canada, California, and Nevada, you may also have certain additional rights with respect to your information, such as: 

1. a). data access and portability (including the right to obtain a copy of your personal data, some of which is available through your account profile);
2. b) data correction (including the ability to update your personal data, much of which you can change directly using your account settings);
3. c) data deletion (including the right to have Retold delete your personal information, except information we are required by law to retain);
4. d) withdrawal of consent (when we rely on your consent to process your information, such as for our marketing emails); and
5. e) objection to processing (when our processing is based on legitimate interests; this includes, in limited circumstances, the right to ask Retold to stop processing your personal data). 

If you are located in California, the EEA or Canada and would like to exercise your rights, please email [email protected] with your request and your place of residence.

Unless you have exercised one of your rights listed above, Retold will retain your information for as long as is necessary for our legitimate business purposes. Retold will always retain data to the extent necessary to comply with our legal and financial obligations (for example, to satisfy our auditors, to comply with applicable tax/revenue laws, to enforce our agreements, and as otherwise described in this policy).

Without prejudice to any other rights you may have, if you are located in the EEA or Canada, you have the right to lodge a complaint with your local data protection regulator.

 

Cookies and Advertising

When you visit Retoldrecycling.com we insert some instructions on your computer or mobile device. These instructions will be in the form of a “cookie” or similar file. Cookies are small pieces of instruction stored on your hard drive or device, not on our website. Cookies provide us with information that we use to enhance your experience on Retoldrecycling.com. There are two basic types of cookies. One is a session cookie which terminates when the user’s session ends. The second is a persistent cookie, which is a text file that remains stored on your computer for a period of time, generally until you delete them. Your Internet browser contains instructions about how to remove persistent cookies. If you reject all cookies, you may not be able to create or sign in to your account with us or otherwise take full advantage of the Retoldrecycling.com website.

We use cookies to collect information, on an aggregate basis, about how Retoldrecycling.com is used. This information includes the date and time of visits to Retoldrecycling.com and time spent on our website. We also use cookies to learn more about our audience size and usage patterns, to store information about your preferences to allow us to customize our website according to your interests and to provide a more personalized experience, to speed up searches or to recognize you when you return to our website, to identify the pages viewed or searched for, page response times, download errors, length of visits, page interaction information (such as click, scrolling, etc.) or methods used to browse away from a page, but none of our cookies is intended to identify you personally. You can obtain more information about cookies at http://www.allaboutcookies.org/.

We may also use web beacons. A web beacon is an invisible graphic on a web page or email that is programmed to collect non-personally identifiable information about the use of a given website or newsletter, such as whether or not an email is opened and viewed.

 

Interest Based Advertising

Our website integrates technologies of trusted advertising partners (third-party companies) that allow the recognition of your device and the collection of information about your browsing activity in order to provide advertisements about goods and services likely to be of greater interest to you. In particular, these partners collect information about your activity on this website to enable us to show advertisements for our products and/or services to you on third-party websites and apps.

Our partners may use non-cookie technologies on which browser settings that block cookies might have no effect. Your browser may not permit you to block such technologies. For this reason, please keep in mind that you can block the collection and use of information related to you by advertising companies for the purpose of serving interest based advertising by visiting the following platforms of self-regulatory programs of which those companies are members:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

Please note that you will continue to receive generic advertisements.

We also may share data, such as technical identifiers derived from your registration information on our website or our CRM system with our advertising partners. This allows them to link devices or browsers and provide you a seamless experience across the different environments used or likely used by you.

Some of the advertising companies we work with include: Facebook/Instagram, Pinterest and Google Ads. You may read more about our advertising partners’ services and technologies, as well as information about how to exercise your rights with them, in their privacy policies.

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals.

 

Security and Storage

HOW WE PROTECT YOUR INFORMATION

We take commercially reasonable steps to safeguard and deter unauthorized access to your information. Retold complies with the Payment Card Industry Data Security Standard (PCI DSS). This means that when we collect or transmit sensitive information such as a credit or debit card number, we use industry standard methods to protect that information.

Although we take reasonable measures to safeguard against unauthorized disclosures of your information, no e-commerce platform, website, electronic database or system is completely secure. 

WHERE WE ARE LOCATED

Retold is located in the United States, and we primarily store your information in the United States. By using our website and/or providing us with information, you are agreeing to transfer and store your data in the United States.

To any international customers: the privacy laws and standards in the United States, including the level of protection applied to your data and the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. The European Commission has not made a determination that the United States adequately provides safeguards for the transfer of data, and at this time Retold has not put in place the exact safeguards set forth in GDPR Article 46. The transfer of your data to the United States is necessary for the performance of our contract with you (so we can process an order) and/or to take pre-contractual measures at your request (i.e. to set up your Retold account).

At times, we may transfer your personal information outside of the United States, in which case we take reasonable steps to make sure your personal information continues to be appropriately protected. However, no data transfer system is completely secure.

Third Party Websites

Retoldrecycling.com contains links to other websites. Other websites we link to include social platforms. We also use third-party plug-ins in certain places on our website. For example, when you click on an icon on the Retold website to share our products on a third party social platform, you are also loading content from that third-party site. That site may request cookies directly from your browser. These interactions are subject to the privacy policy and terms of service of the third-party site, not ours. We are not responsible for the privacy practices or the content of such services. We do not make any representations regarding the policies or practices of third parties. When you use third-party sites or services, their own terms and privacy policies will govern your use of those sites or services. We encourage you to read the privacy policies of third parties before disclosing personal information to them. For the purposes of E.U. law, these third parties are independent controllers of data.

Your California Privacy Rights

These additional disclosures apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“ CCPA ”) provides certain rights to California residents. The words used in this section have the meanings given to them in the CCPA, which may be broader than their common meaning.

1. Notice of Collection.

As described above in the “Information We Collect” section, we collect and use several categories of personal information about you for our business purposes. Some of this information is shared with our trusted service providers in order to improve your shopping experience and to complete your order.

1. Request to Know / Request to Delete.

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months.

In the “Information We Collect” section above, we disclose

• 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 that personal information.
• The categories of third parties with whom we share that personal information.

You also have the right to request that we disclose the specific pieces of personal information we collected about you. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The specific pieces of personal information Retold has retained about you.

You also have the right to request that we delete any of your personal information that we collected from you and retained, with certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We reserve the right to retain and will not delete information that is necessary for us or our service providers to retain in order to:

• Complete the transaction for which we collected the personal information, provide a product 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.).
• 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 which you provided it.

How to Request to Know or Request to Delete

You can submit verified consumer requests by emailing [email protected]. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

1. Right to Opt-Out.

You have a right to opt out of any sale of your personal information. Retold does not sell your personal information to any other retailers. However, our website integrates technologies of trusted advertising partners (third-party companies) that allow the recognition of your device and the collection of information about your browsing activity in order to provide advertisements about goods and services likely to be of greater interest to you. In particular, these partners collect information about your activity on Retold to enable us to show advertisements for our products and/or services to you on third-party websites and apps. If and to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those implemented specifically for interest-based advertising, we will comply with applicable law as to such activity. See the section on “Interest Based Advertising” above for information about how to opt out of interest based advertising.

1. Authorized Agent.

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

1. Right to Non-Discrimination.

You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights. We will never discriminate against you for exercising your privacy rights. However, there are certain functions of our website that are only available to specific customers, such as Retold Rewards for subscribers only, or offers for new customers only.

1. Financial Incentives.

Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them. There are no penalties for requesting disclosure or opting out of sharing of your personal info. However, if you request to delete your data we can no longer offer you certain discounts and promotions that are tied to your account. The value we obtain from collecting and analyzing data about account holders’ use of the website, app, and purchases is less than or equal to the value of the promotions and discounts we offer exclusively to those account holders. We also from time to time offer discounts connected to consumer’s submission of their email address or other personal information. The value of these discounts is greater than or equal to the value we obtain by being able to reach you about promotional offers. You can always opt out of our marketing emails or SMS messaging at any time.

1. Shine the Light.

California Civil Code Section 1798.83 permits customers of Retold who are California residents to request certain information regarding its disclosure of personally identifiable information to third parties for their direct marketing purposes. However, at this time we do not share any of your personally identifiable information with third parties for their direct marketing purposes.

1. Consumer Affairs.

Under California Civil Code Section 1789.3, California residents are entitled to the following specific consumer rights notice: If you have a question or complaint regarding the Website, please send an email to [email protected]. You may also contact us by writing to us at the address provided below under the Section entitled “Contact Information”. California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210.

 

Your Nevada Privacy Rights

If you are a Nevada resident, you have the right to direct Retold not to sell your covered information. However, to repeat, Retold does not sell your personal information.