Saritoria Privacy Policy

1. Introduction

This privacy policy (the Policy) relates to your personal information in connection with your use of, and access to,our website at https://www.saritoria.com and any services provided through that website (together, the SaritoriaPlatform) and any other services provided by Saritoria (these services, together with the Saritoria Platform,form the Saritoria Services).

We are committed to protecting your Information (as defined in paragraph 4.1 below) and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at info@saritoria.com.

When you use the Saritoria Services, you trust us with your Information. We take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through this Policy carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of the Saritoria Services.

This Policy was last updated on [insert date].

In this Policy, Member means anyone who registers to use the Saritoria Platform as a buyer or seller and User means anyone who uses the Saritoria Platform without being a Member. Your rights and obligations as a Member or User of the Saritoria Platform are governed by our Terms and Conditions (the Terms).

2. Changes to this Policy or your personal information

We review this Policy regularly and it is your responsibility to check it regularly todetermine whether it has changed. If you do not agree to any change to this Policy then you must immediately stop using the Saritoria Services. In the event we make any significant changes to this Policy we will use our reasonable endeavours to inform you of such changes in advance in writing.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes (for example, if you change your email address).

3. About us

The Saritoria Platformis owned and operated by Saritoria Limited (trading as “Saritoria”) a company registered in England and Wales with company number 12553067 and whose registered office is at 20 Guildford Road, Tunbridge Wells, England, TN1 1SW(Saritoria/we/us/our). Saritoria is the controller (also known as a data controller) and is responsible for your personal information. The term “you” refers to the person wishing to access and/or use the Saritoria Services.

The Saritoria Platform enables you tobuy pre-loved clothing and accessories from, and advertise and sell pre-loved clothing and accessories to, other individuals on the Saritoria Platform.

4. Information we may collect about you

4.1 Personal information you disclose to us

Summary: We collect personal information that you provide to us including information such as name, address, contact information, clothing size and payment card information.

We collect personal information that you voluntarily provide to us when registering and using the Saritoria Services, or otherwise contacting us. The personal information that we collect depends on the context of your interactions, the choices you make and the products and features that you use. When you use the Saritoria Services and/or when you otherwise deal with us, we may collect the following information about you (the Information):

• Identity and Personal Data includes first name, last name, date of birth, clothing and shoe size, body measurements, style preferences, photographs, personal characteristics and gender.
• Contact Data means the data we use to contact you including your billing address, delivery address, work address, email address and contact numbers.
• Purchasing History means any shopping receipts (whether paper or electronic) or other proofs of purchase that you upload to the Saritoria Platform.
• Financial Data means any bank details or payment card information that you provide to us. We do not store or process your bank or card details ourselves – they are processed and stored via one of our contracted third party service providers. We encrypt your Financial Data and securely transfer this data to our relevant third party payment provider to process any payments.
• Transaction Data means details about any transactions you have made in connection with the Saritoria Services, including payments to and from you, along with other details of items you have purchased or sold through the Saritoria Platform.
• Profile Data includes your username, email address, login data, interests, preferences, feedback, survey responses and orders made by you.
• Usage Data includes information about how you use the Saritoria Services. This includes your browsing patterns, how long you might spend on one of the webpages on the Saritoria Platform,which items you look at, the page that referred you to the Saritoria Platform, the click stream during your visit to the Saritoria Platform, page response times and page interaction information (clicks you make on a page).
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Social Media Data. We may provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we may collect the Information described in paragraph 13 All Information that you provide to us must be true, complete and accurate and you must notify us of any changes to that Information.
• Other information relevant to services, customer surveys and/or offers.

All Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to your Information.

5. The Saritoria Platform and your Information

You are required to register as a Member and create an account and profile in order to make full use of the Saritoria Platform. Some of your profile Information may be visible to other Members when you interact with them, including your first name.

If you choose to access the Saritoria Platform from a shared computer or open wifi connection, we strongly recommend logging off and removing cookies and the history of the website visited once you have finished.

5.1 Information automatically collected

Summary: Some information (e.g. IP address and/or browser and device characteristics) is collected automatically when you use the Saritoria Platform.

We automatically collect certain information when you visit, use or navigate the Saritoria Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Saritoria Platform and other technical information. This information is primarily needed to maintain the security and operation of the Saritoria Platform, and for our internal analytics and reporting purposes. Most devices allow you to manage the use of location services through your settings menu. If you would prefer not to share your location, please disable this function through your device directly.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookies Policy (the Cookies Policy).

6. How do we use your Information?

Summary: We process your Information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations and/or your consent.

We use your Information collected via the Saritoria Services for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual), with your consent (Consent), and/or for compliance with our legal obligations (Legal Obligations). We indicate the specific processing grounds we rely on next to each purpose listed below.

We may process your Information for the following purposes:

• To fulfil and manage any orders in connection with the Saritoria Services and administer and manage your account (Contractual). We may use your Information or pass it onto other Members in order to enable the services you have requested through the Saritoria Platform, including the sale or purchase of items.
• To send administrative information to you for Business Purposes, Legal Obligations and/or possibly Contractual. We may use your Information to send you product, service and new feature information and/or information about changes to our Terms, this Policy, our Cookies Policy and any other terms or policies provided to you by Saritoria.
• To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our third party partners may use your Information for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails – see below for further details.
• To facilitate account creation and logon process with your Consent.
• To administer promotions for our Business Purposes and/or with your Consent.
• To request Feedback for our Business Purposes and/or with your Consent. We may use your Information to request feedback and to contact you about your use of the Saritoria Platform.
• To protect the Saritoria Services for Business Purposes and/or Legal Obligations. We may use your Information as part of our efforts to keep the Saritoria Services safe and secure (for example, for fraud monitoring and prevention). This includes reviewing, scanning or analysing communications between Members on the Saritoria Platform, either by automated or manual methods.
• To enforce our Terms and policies for Business Purposes, Legal Obligations and/or possibly Contractual.
• To respond to legal requests and prevent harm for Legal Obligations. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• For other Business Purposes. We may use your Information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Saritoria Services, products, services, marketing and your experience.

Always think carefully before disclosing your Information or other information to other Users or Members or otherwise posting Information on the Saritoria Platform. It is important that you are aware that any data you choose to disclose on the Saritoria Platform may then be viewed and even used by other Users or Members. We do not control the contents of communications made between Users or Members, although you can make a complaint about a Member by contacting us using the information provided in paragraph 19 below.

You must respect the privacy of others and you must not disclose any personal details about other people that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior express permission in respect of any submission of their Information at any time.

7. Will your Information be shared with anyone?

Summary: We only share Information to comply with Contractual obligations, fulfil our Business Purposes, or with your Consent.

We only share and disclose your Information in the following situations:

• We may share some of your Information with Members to enable use of the Saritoria Platform, including the sale or purchase of items. We will never share your billing or payment information with other Members.
• Compliance with Legal Obligations. We may disclose your Information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests. We may disclose your Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• Third Party Service Providers. We may share your Information with third party vendors, service providers, contractors or agents who perform services and require access to such Information to do that work. Examples include: payment card providers, data analysis, email delivery, hosting services, customer services, search information providers, delivery services, analytic providers, credit reference agencies and marketing agencies. They will only have access to your Information to the extent that they need to perform those services. They are required to keep your Information confidential and may not use it other than as we ask them to and always in accordance with this Policy. The third parties we may use from time to time include Stripe, Inc. (and its affiliates), ViSenze, Pinterest, Shopify, Google Analytics, Instagram and Facebook. In some cases, the Information provided to us varies and is controlled by the specific service or as authorised by you via your privacy settings for that service. For more information on how these companies handle your personal data, please refer to their privacy policies.
• Business Transfers. We may share or transfer your Information in connection with, or during negotiations for, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Third Party Advertisers. We may use third party advertising companies to serve ads when you visit the Saritoria Platform. These companies may use information about your visits to the Saritoria Platform and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookies Policy for further information.
• Business Partners. Provided you have given us Consent to do so we may share your Information with our business partners to offer you certain products, services or promotions.
• With your Consent. We may disclose your Information for any other purpose with your Consent.

We may disclose aggregated, anonymous Information (i.e. Information from which you cannot be personally identified), or insights based on such anonymous Information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Saritoria Services. In such circumstances we do not disclose any Information which can identify you personally.

8. Information collected from other sources

Summary: We may collect limited data from public databases, marketing partners, social media platforms and other outside sources.

We may obtain Information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, birth date, gender, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links). The information provided to us varies and is controlled by the specific service or as authorised by you via your privacy settings for that service.

9. Is your Information transferred internationally?

Summary: We may transfer, store, and process your Information in countries other than your own but will take all reasonable steps to ensure it is protected.

Whenever we transfer your Information outside of the UK, we will take all reasonable measures that we can to protect your Information in accordance with this Policy and applicable law. If any transfer requires approved safeguards to be in place,we will ensure that they are in place (for example: if transferring outside of the European Economic Area, that the EU model contract clauses are in place;or if transferring to the USA, that the entity it is transferred to is EU/US Privacy Shield registered).

10. Third party websites

Summary: We are not responsible for the safety of any information that you share with third party providers who feature or advertise, but are not affiliated with, the Saritoria Services.

The Saritoria Platform may feature links to third party websites or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Saritoria Platform. You should review the policies of such third parties and contact them directly to respond to your questions.

Anything that you share on the publicly available part of the Saritoria Platform will also be catalogued by third party search engines. We are not responsible for their use of your information or the accuracy of it.

11. How long do we keep your Information?

Summary: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy, unless otherwise required by law.

We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing Business Purpose to process your Information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.

12. How do we keep your Information safe?

Summary: We aim to protect your Information through a system of organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any Information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Information, transmission of Information to and from the Saritoria Platform is at your own risk. You should only access our services within a secure environment. All of your payment information is encrypted.

It is explicitly prohibited to use our Member-to-Member communication system to send content that violates our Terms or spam of any kind. We reserve the right to scan internal messages to check for spam, phishing, viruses and other malicious, prohibited or illegal behaviours or content. Please note, the messages sent through internal systems are not stored indefinitely and you must not rely on the storage of those messages.

13. How do we handle your Social MEDIA Logins?

Summary: If you choose to register or log into our website using a social media account, we may have access to certain Information about you.

The Saritoria Platform may offer you the ability to register and login using your third party social media account details (e.g. Facebook, Twitter, etc). Where you choose to do this, we will receive certain Information from your social media provider. The Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other Information that you choose to make public. If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. The Information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other users of those networks and we have no control over that viewing and use and cannot prevent further use of that Information by third parties.

If you choose to link your Saritoria profile with a social media account, Information that you provide to us in the process may be included on your Saritoria profile. Additionally, your contacts on the social media platform(s) (Friends) may be able to see your activity on the Saritoria Platform. A link to your public profile on the social media site may be added to your Saritoria profile and other Members and Users may be able to see any Friends or links (e.g. friends of Friends) via the social network(s) that you have in common with them.

When you interact with us through social media networks, you acknowledge that we may access your Information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any Information posted via social media through theSaritoria Platform, or any third party you allow to access your content, is done entirely at your own risk and that by posting to a public platform you make that Information visible to third parties who can use that Information at their discretion.

Please note that we do not control, and are not responsible for, other uses of your Information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your Information, and how you can set your privacy preferences on their sites and apps.

14. Do we collect information from minors?

Summary: We take steps to ensure that the Saritoria Services are only used by those over 16years of age and we do not knowingly collect data from, or market to, children under 16 years of age.

We do not knowingly solicit data from, or market to, children under 16 years of age. By using the Saritoria Services, you represent that you are at least 16 years of age. If we learn that Information from Users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under the age of 16, please contact us at info@saritoria.com.

15. Your Consent to processing

You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the Saritoria Services.

If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing info@saritoria.com.

If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal right

Please note that if we need to process your Information in order for you to use the Saritoria Services and you object or do not provide Consent to us processing your Information, the Saritoria Services will not be available to you.

16. Marketing and opting out

If you have given Consent to marketing we may contact you about our products, services, promotions and special offers. If you no longer wish to receive such information you can withdraw your Consent at any time by sending an email to info@saritoria.com or unsubscribe from the communications.

If you have given Consent, we may share your Information with carefully selected third party organisations and business partners and they may contact you directly. If you prefer not to receive direct marketing communications from the third party please contact them directly to withdraw the Consent.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of you buying or selling an item on the Saritoria Platform, or otherwise using the Saritoria Services.

17. Account Information

You may at any time review or change the Information in your Saritoria account by logging into the Saritoria Platform and going to the “my profile” section where you can review or change your Information. You can update your details, change your shipping preferences and also delete and amend your bank account details. Please contact us at info@saritoria.com if you need assistance with this.

If you wish to terminate your Saritoria account please contact us at info@saritoria.com and we can arrange this for you. Some Information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms, this Policy or the Cookies Policy and/or comply with legal requirements.

18. What are your privacy rights?

Summary: You have certain rights in respect of your Information.

You have certain rights in relation to the Information that we hold about you. Details of these rights and how to exercise them are set out below. We may need to request specific information from you to help confirm your identity and ensure your right to access your Information (or to exercise any of your other rights). This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up your response. To exercise or discuss any of your rights please contact us at info@saritoria.com.

• Right of Access. You have the right at any time to ask us for a copy of the Information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your Information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
• Right of Correction or Completion. If Information we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.
• Right of Erasure. In certain circumstances, you have the right to request that the Information we hold about you is erased e.g. if the Information is no longer necessary for the purposes for which it was collected or processed or our processing of the Information is based on your consent and there are no other legal grounds on which we may process the Information.
• Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your Information. For example, if we are processing your Information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests.

You may also have the right to restrict our use of your Information, such as in circumstances where you have challenged the accuracy of the Information and during the period where we are verifying its accuracy.

• Right of Data Portability. In certain instances, you have a right to receive the Information that we hold about you in a structured, commonly used and machine-readable format.

In such circumstances, you can ask us to transmit your Information to you or directly to a third party organisation.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal Information of others without their consent.

To make any such requests, please contact us at info@saritoria.com. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

19. Contact us

We welcome your feedback and questions on this Policy. If you wish to contact us about this Policy, about our Information or any other questions, please email us at info@saritoria.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues ( https://ico.org.uk/concerns/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.