Caratruman’s mission is to put people at the heart of commerce, empowering everyone to thrive. We strive to protect the privacy of our users and any personal data shared with us. This Privacy Policy describes the types of personal data Caratruman, Inc. and our subsidiaries and affiliates (collectively “Caratruman”, “we”, “us”, and “our”) obtain; how we may collect, use, and share it; and how you may exercise your rights and choices with respect to that data.

This Privacy Policy covers:

Scope
What Data We Collect
How We Use Your Data
How We Share the Information We Collect
How We Store and Maintain the Information We Collect
Legal Basis for Processing Your Information
Your Rights and Choices (including Region-Specific Information)
Additional Information

1. Scope

This Privacy Policy applies to personal data we obtain when users (“you” or “your”) interact with Caratruman services, products, tools, and features (collectively “Services”) through the use of our websites, mobile applications, or on any other medium used to access our Services and through other data collection points that reference this Privacy Policy.

We may provide additional information about our privacy practices at other points, for example, where this will help us provide more relevant and timely information.

2. What Data We Collect

We collect personal data about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.

Information You Provide to Us Directly: We collect information about you when you provide it directly to us as part of our Services, such as when you register for an account, set brand, style, and other preferences, and participate in any interactive feature, survey, promotion, or event. This information may include your name, address, phone number, email, username, sizing, social media accounts, gender, age, education history, and any other personal data you may provide.
Information You Provide when Using Our Services and Interacting with Other Users: We collect information and content when you create closets and listings, post stories, participate in a Posh Show, make purchases, search for items, and comment or otherwise interact with listings, closets, or other users. This includes any pictures, video and audio clips, closet descriptions, search terms, information about items you have listed, sold, or purchased, and any interaction with users and listings, such as likes, comments, replies, and offers.When you buy and sell on Caratruman, we will need to collect payment and billing information, such as credit card and bank account information to complete the transaction.
Information You Provide through Our Support Channels: We collect information when you contact Caratruman and our customer support for any reason, such as asking questions and sharing feedback, issues, or problems. You may be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving an issue.
Information You Provide when Verifying Your Identity: Identity verification may be required for fraud prevention and compliance purposes. We may collect certain identification information, such as driver’s license information, social security number, and passport number to verify your identity. We may also ask to verify your identity using photo verification.
Information We Collect Automatically when You Use the Services: We collect information about you when you use our Services, including when browsing or taking certain actions within the Services. This includes information about the features you may use, links or pages you click on, pages viewed, search and browsing history, IP address and device data (e.g. operating system, version, model, identifiers, etc.), referring and exit pages, and other analytics data about your usage or our Services.Cookies and other tracking technologies:We, our service providers, and other third-party partners may collect information such as device data, IP address, hashed emails, transaction data (such as order value) and online activity data through automated means such as cookies, web beacons, software development kits (SDKs), tracking URLs, and similar technologies. Cookies are used to store and receive identifiers and other information, such as the name of the domain from which the cookie originated and when the cookie expires. Cookies and similar technologies may enable Caratruman, as well as parties other than Caratruman, to collect information through our Services.We and the companies we work with may use cookies and similar technologies to improve the functionality and user experience of our Services, gather and store information about user preferences and past actions, perform analytics, detect fraud, measure our ad conversion and performance, optimize our ad campaigns, customize your experience, and bring you ads through interest-based advertising. Interest-based advertising enables us to provide you with more relevant advertising about products and services based on the information we and other parties may collect about your online activities over time and across different websites. For example, you can learn how Google collects and uses information when we use their services (including Google Analytics) and how Connexity and Taboola use cookies and similar technologies to optimize ads and recommend content to you.Most browsers will allow you to control cookies through the browser settings. View your browser developer’s support center, help menu, or website to learn whether or how you can manage cookies on your browser. Please note that, without cookies, you may not be able to use some or all of the features on or functionality of our Services.Our Service currently does not respond to “Do Not Track” (DNT) signals.To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Information We Collect from Social Media Platforms: You can connect your social media or other third-party account to your Caratruman account, such as Facebook, Twitter, Instagram, Pinterest, or Snapchat. If you choose to connect your social media accounts to our Services, we may collect information about you from these accounts, such as username, friend or following lists, and other profile information.
Information about Others: Prior to sharing any information about others for any purpose through the Service, you must satisfy any consents or other applicable legal and regulatory requirements. This includes, but is not limited to, the information or images you provide about any third parties on comments, listings, Posh Stories, or Posh Shows.

3. How We Use Your Data

We use the information we collect to provide, develop, enhance our Services, and for other business purposes needed to deliver our Services or as required for legal or compliance purposes. This includes to:

Personalize your experience. For example, we use your information, including profile, search, likes, and purchase histories, to suggest items, closets, offers, features, or events that we think you might enjoy. We may use the data collected through cookies and other tracking technologies (if enabled) to remember information so that you will not have to re-enter it during your visit or the next time you visit the site and to provide custom, personalized content and information.
Process and fulfill orders. This includes sharing your contact and shipping information with sellers and our shipping partners.
Provide you with customer support, communications, updates, promotions, announcements, and other news about relevant features and aspects of our Services. For example, we may send you communications responding to customer support questions, providing information about transactions, or notifying about user engagement. You may adjust your notification preferences through our app or website, or follow any opt-out instructions provided with the communication (e.g. at the bottom of an email).
Improve safety, security, and integrity and prevent fraud. This includes investigating suspicious activity, preventing the sale of counterfeit items, and fulfilling anti-money laundering and know-your-customer obligations. We use information about you to verify accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of our Services’ terms and policies.
Enable social features such as connecting you with other users.
Provide, analyze and improve the Services. This also includes research and development and creation of new features and may involve creating anonymous and aggregated data.
For advertising and marketing purposes. Depending on your location and any applicable rights or choices you may have exercised, this may include providing you with advertising and marketing related to our Services, measuring our ad performance and conversion, optimizing our ad campaigns, and showing you personalized and non-personalized ads on or off of the Services.
Where we believe it is necessary to fulfill or protect our legal rights, interests, and protect the interests of others. This includes complying with relevant laws, regulation, or other obligations in connection with legal claims, audit functions, an acquisition, merger, or sale of a business.
With your consent: We may use information about you where you have given us consent to do so for a specific purpose not listed above.

We share your information as described below:

Provide the Services: We will share your information with companies that provide a service to us or our users, such as shipping, identity verification, fraud monitoring, payment processing, storage, database maintenance, analytics, and hosting. For example, we may use Google Maps API to help autocomplete and validate your address.
Offers, Ads, and Promotions: We may share your information with partners and affiliates, which may include brands or other third parties, as well as advertising networks and related providers for advertising, marketing, and promotional purposes.
Complete Transactions: We may share information with others users when you make a purchase or a sale or otherwise conduct transactions on the Service.
Sharing Feedback: We may share feedback we receive from you. This may include, but is not limited to love notes, comments on listings, and survey responses. This feedback may be attributed to you, for example, with your username.
Law Enforcement or Legal Requests: We may share information about you with a third party if we believe that sharing is reasonably necessary to comply with the law and the reasonable requests of law enforcement, to enforce our Terms of Service or to protect the security or integrity of our Service, or to exercise or protect the rights, property, or personal safety of Caratruman, our users, or others.
Business Transaction: We may transfer the personal data we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation), or other business transaction.
With your consent: We may also share information about you with third parties when you give us consent to do so.

We may also share aggregated and anonymous information, including demographic info, survey results, market trends, and other analysis that we create based on the information we receive.

In addition, please note that we are not responsible for the personal data you choose to submit on pages and content accessible to the general public, including but not limited to, your profile, closet, listings (including any “Meet the Posher” listings), photos, comments (including on our blog), love notes, Posh Stories, or Posh Shows. Once displayed on a publicly accessible location, that information can be collected, used, and shared by the public at large both on and off our Services (e.g. a listing could be shared to social media).

5. How We Store and Maintain the Information We Collect

The information we obtain will be retained to provide the Services to you and to fulfill the business and commercial purposes for which they are collected or as needed to satisfy applicable governmental laws, regulations, investigations, proceedings or for reasonable backup, archival, audit, legal, tax, accounting, compliance, or other similar purposes. For example, requirements related to financial transactions and anti-money laundering purposes often require us to keep certain information for 7 years but may vary depending on your location.

Security:

Caratruman employs organizational, technical, and physical safeguards intended to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Depending on the circumstances, our safeguards to protect personal data may include facilities access restrictions, system access controls, firewalls, data encryption, and other security best practices.

No internet, email, or other electronic transmission is ever fully secure or error free, however, so you should take special care in deciding what information you send to us in this way. Your information may be stored with third-party cloud service infrastructure providers.

International Data Transfers:

We are headquartered in the United States and may share your information with service providers and other recipients in the United States and worldwide. If you are located in a region with laws governing data collection and use that may differ from U.S. law, please note that we may transfer personal data to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. We use appropriate transfer mechanisms where required.

6. Legal Basis for Processing Your Information

Caratruman may collect and process your information on the basis of different legal grounds, depending on the nature of the information being provided, the type of processing involved, and your location of residence, as follows:

Performance of a contract: By using our Services or otherwise purchasing or selling on our platform, you are agreeing to our Terms of Service which constitutes a valid legal contract. We process your data in order to fulfill any obligations, such as completing transactions between you and other users and you and Caratruman.
Legitimate interest: Such legitimate interests will include where Caratruman sends you marketing about our products and services where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf or where such processing is necessary for fraud detection and prevention. Caratruman will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products, and features to you.
Legal obligations: Where the processing is necessary for compliance with a legal obligation.
Consent: Finally, in certain situations, Caratruman relies on your consent in order to process your Personal Data such as marketing communications.

7. Your Rights and Choices

Depending on your location, you may have certain rights, choices, and means available to you when it comes to your information, including the use and disclosure of that data. Below is a summary of the choices you may have and how to exercise them.

Access, Correct, or Delete Your Personal Data:

You may access, correct, or delete your personal data in your account settings. When you make a request, we may need information from you to help us confirm your identity and verify your right to access, correct, or delete your personal data (or to exercise any of your other rights), and may charge you a fee for such request, where allowable. Please note, if you delete your information, your account will be terminated.

Your requests and choices may be limited in certain cases, such as the following examples: if fulfilling your request would reveal information about another person, or if you ask to delete information which we are required by law or have compelling legitimate interests to keep.

Withdraw Consent:

Where allowed by law, you may withdraw such consent at any time; however, withdrawing such consent may limit or restrict your use or access of our Services. Please direct your request to helpdeskline@caratruman.com unless a different means of making the request is listed in a region-specific section.

8. Additional Information

Links to External Content:

The Services may also include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third-party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.

Children's Privacy:

Caratruman does not knowingly collect or solicit any information from anyone under the age of 13 through this Service. If you believe that a child under 13 years of age may have provided us with personal data, please contact us at helpdeskline@caratruman.com.

Your Acceptance of this Privacy Policy:

By accessing or using our Services, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal data as described in this Privacy Policy. If you do not agree, you should discontinue use of the Services immediately.

Your Acceptance of this Privacy Policy:

Changes to this Privacy Policy:

We reserve the right to revise this Privacy Policy from time to time. We will post changes on this page and indicate the “Effective Date” at the top of this page. Please check back often for any updates. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and that your continued use of our Services after any change in this Privacy Policy will constitute your acceptance of such change.

If you have any questions about this Privacy Policy, you may contact us at helpdeskline@caratruman.com.