Refersion Privacy Policy


Last updated: October 27, 2021.


BECAUSE THIS PRIVACY POLICY CONTAINS LEGAL OBLIGATIONS WE ENCOURAGE YOU TO REVIEW THIS PRIVACY POLICY CAREFULLY.

Refersion Inc., a New Jersey corporation ("Refersion") owns and operates the Refersion business, including the Refersion platform, the Refersion Marketplace, and our analytics, information, applications, websites and other products and services (collectively, the "Services"). All references to "we", "us", this "website" or this "site" refer to Refersion. Capitalized terms used, but not defined, in this Privacy Policy are defined in the Terms of Service. This Privacy Policy is supplemented by and subject to the Terms of Service.

We are one of several affiliated companies offering solutions to e-commerce sellers under the corporate umbrella of Assembly Intermediate LLC ("Assembly"). Please note that aspects of this Privacy Policy address how you and we interact with Assembly and other affiliated Assembly companies (collectively, our "Affiliated Companies").

This Privacy Policy describes:

  • What information (including personal information) we collect
  • how we collect it
  • how we use it
  • how and when we share it;
  • how to change and/or delete data;
  • terms specific to certain types of users, such as European and California users; and
  • how to contact us.

For information on third-party interest-based advertising conducted through our Services, please see the "Targeted Advertising" section below.

Residents of the European Economic Area ("EEA"), which includes the member states of the European Union ("EU"), should consult the sections of this policy relating to the "EEA Residents" and "International Data Transfers" for provisions that may apply to them.

California residents should consult the section titled "Your California Privacy Rights" for rights that apply to them.


INFORMATION WE COLLECT
  • Personal Information. "Personal Information" is information that may be used to directly or indirectly identify an individual (which in some cases, may include certain device information). The Personal Information we collect may include your (a) name, postal address, email address, and phone number; (b) credit card and other payment information; and (c) information about your third party accounts ("Third Party Accounts") you may choose to provide us for integration and analytics purposes.

    In general, Personal Information we collect includes, but is not limited to:
    • Personal Information needed for you to be able to use the Services, including for establishing an account, logging in, paying for subscription to the Services, and linking your Third Party Accounts;
    • Personal Information to contact and respond to you, including to provide you with results of our Services, reply to your inquiries, and keep in touch with you regarding features or matters of interest regarding the Services;
  • Device Information. "Device Information" which is information relating to the computer or device you are using when you access our Services, such as your computer’s IP address, your mobile device identifiers and other persistent identifiers (including Apple IDFA or an Android Advertising ID), the type of browser and operating system you are using, the identity of your internet service provider, and your device and browser settings.
  • Usage Data. "Usage Data" is anonymized information passively or automatically collected by us pertaining to your visits to and use of the Services. Usage Data may be collected using cookies, web beacons, page tags or similar tools.  All Usage Data is anonymous transactional data that is not associated with any users as individuals. Such Usage Data may include: which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; the sites you use before or after visiting ours; your actions within the Services; your interactions with emails we send; WiFi connections; general geolocation information; date and time stamps, log files, and diagnostic, crash, website, and performance logs and reports.

We collectively refer to your Personal Information, Device Information and Usage Data as "Your Information."


HOW AND WHEN WE COLLECT INFORMATION
  • Personal Information. We collect Personal Information at the time you provide it to us, including through sign-up forms and as part of your registration for an account, product, or service, promotion, or contest from our Services. In addition, we collect personal information from communications with site visitors. Finally, in certain instances, we may collect personal information from our Affiliated Companies.
  • Device Information & Usage Data. Device Information and Usage Data may be passively or automatically collected when you use the Services (that is, gathered without your actively providing the information) using various analytics and reporting technologies, such as cookies, web beacons, locally stored objects, and mobile device identifiers and SDKs, and other similar methodologies as well as similar technologies developed in the future. Please note that we use cookies when you sign in to keep track of your personal session.
  • Payment Information. Please note that your credit card or other payment information will only be collected if you choose to purchase a subscription to our Services. If you do make such a purchase, our payment processing partner will collect your payment information and process your payment. We do not store any credit card information or share it with anyone other than our payment processor.

HOW WE USE INFORMATION
  • In general, we use Your Information to:
    • operate, audit, improve, optimize and provide you with our Services;
    • provide customer service and support;
    • enhance security, monitor and verify identity or service access, combat fraud, spam, malware or other network and/or information security risks;
    • detect bugs, report errors and perform activities to maintain the quality or safety of our services;
    • conduct research and development;
    • understand you and your preferences to enhance and personalize your experience;
    • personalize ads and display and measure engagement with advertisements across different devices and sites (for more information, please see the "Targeted Advertising" section below);
    • maintain legal and regulatory compliance.
  • More specifically, we may use your Personal Information to:
    • respond to your requests and other communications;
    • send you information related to our Services, including confirmations, invoices, technical notices, updates, security alerts, training and support and administrative messages;
    • develop and send you marketing, sales and promotional communications about our Services and the products/services of our Affiliated Companies or third party partners (where this is in accordance with your marketing preferences);
    • process and deliver rewards and/or contest entries.
  • We may use any phone numbers you provide to call you or send you text or in-app messages related to certain features or your activity on this site.
  • We may use publicly available Personal Information posted on social media profile information including photos for purposes of assisting us, and our marketing partners with marketing and advertising activities and with contact management.
  • We may combine and use the Personal Information, Device Information and Usage Data we collect from all services and products offered by us and our Affiliated Companies over various websites to provide, protect, and improve them, and to develop and offer new services and products. We will treat you as a single user of these combined services and products.
  • We use anonymized Usage Data for any legitimate business purpose, including to help us develop and maintain the appropriate features, functionality and user experience and to create analytics reports and case studies.

HOW AND WHEN WE SHARE AND DISCLOSE INFORMATION
  • We will not transfer, license or sell your Personal Information to unaffiliated third parties for marketing purposes unless we have your express, prior consent.
  • We may share and disclose Your Information:
    • With trusted service providers that assist us with the operation and maintenance of the Services. For example, we may contract with third parties to facilitate purchases from the Services, process payments, host our servers, provide security, and provide production, fulfillment, optimization, analytics, reporting, and software maintenance and development services. Our service providers will be given access to your Personal Information only as is reasonably necessary to provide the services for which they are contracted.
    • With our Affiliated Companies which will only be used, disclosed and otherwise processed by such Affiliated Companies under the same terms as those applicable to us as set forth in this Privacy Policy.
    • Pursuant to a change of control, or sale or transfer of part or all of our business or assets to another organization, such as in the course of an acquisition, sale, consolidation, merger, bankruptcy or liquidation.
    • If we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request (such as for example, to comply with a subpoena or court order), (ii) to detect, prevent, and address fraud, any other illegal activity or harm to us or our users, and (iii) to investigate, respond to, or enforce violations of our rights or the security of our Services.
    • With your express consent or instruction.
    • As part of our participation with third party analytics partners to monitor and analyze Web traffic and to keep track of user behavior on this site.
  • We may share and disclose anonymized, aggregated Usage Data without restriction for any legitimate business purpose.
  • Transfer Outside Country of Residence. In general, any Personal Information we may collect may be stored and processed in our servers located in the United States or in any other country in which we, or our affiliates, subsidiaries, or agents maintain facilities. By using this site, you consent to any such transfer of Personal Information outside your country of residence to any such location.

TARGETED ADVERTISING
  • We engage certain third-party service providers to serve advertisements on our behalf across the Internet and to provide analytics services. We may also participate in third-party affiliate advertising and allow third-party affiliate links to be encoded on some of our pages. This means that we may earn a commission when you click on or make purchases via third-party affiliate links.
  • Our advertisers or the ad networks that serve advertisements may utilize cookies or other similar tracking technologies (including within the ads) to collect anonymous Device Information and Usage Data. This information may be used by us, our service providers and their clients in aggregated, anonymous form to, among other things, analyze and track aggregated data, determine the popularity of certain content or products, measure the effectiveness of ad campaigns, determine the proper amount of repeat views of a given ad, and deliver advertising and content targeted to your interests on our Services and outside of our Services on other websites (also known as “interest-based advertising”). These service providers are prohibited from collecting any Personal Information from you and we do not share any of your Personal Information with them.
  • You have a choice about participating in interest-based advertising. If you wish to opt out of such participation, you have a few options:
    • On your mobile device, you can visit https://youradchoices.com/appchoices to learn about and download the Digital Advertising Alliance’s opt-out app, which allows you to opt your mobile device out of interest-based advertising from participating companies.
    • Your device settings may allow you to limit the use of information from your device in interest-based advertising through your browser’s settings (such as under the “Security & Privacy” settings of the Safari app on an iOS device) or an “Opt Out of Interest-Based Ads” setting (on an Android device).
    • You can learn more about advertising networks and interest-based advertising, and your ability to opt out, by visiting the Digital Advertising Alliance at www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/choices.
  • In providing you with transparency and choice regarding interest-based advertising, we are acting in accordance with our commitment to the Digital Advertising Alliance’s Self-Regulatory Principles. To learn more about these Principles, please visit http://www.aboutads.info/consumers.

YOUR CHOICES WITH RESPECT TO YOUR INFORMATION
  • Under certain laws, including as described below with respect to the GDPR and CCPA, you may have the right to: obtain confirmation that we hold Personal Information about you, request access to and receive information about the Personal Information we maintain about you, receive copies of the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, object to the continued processing of your Personal Information, and have the Personal Information blocked, anonymized or deleted, as appropriate. The right to access Personal Information may be limited in some circumstances by local law, including as described above under California law. If you qualify, in order to exercise these rights, please contact us as described under "Contact Us". Note: under certain laws, certain Device Information may qualify as Personal Information for the purposes of such laws.
  • You may opt out of promotional communications by sending us an email at the email address below under "Contact Us". We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.
  • Please understand, however, that we reserve the right to retain an archive of such Personal Information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such Information.
  • You can opt out of the collection and use of certain Device Information and Usage Data, which we collect about you by automated means (such as cookies) by changing the settings in the device or computer you use to access the Services. In addition, your browser may tell you how to be notified and opt out of receiving certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of the Services.
  • Some Web browsers have a "Do Not Track" feature that signals to websites that you do not want to have your online activity tracked. Because each browser communicates "Do Not Track" signals differently, we do not respond to "Do Not Track" signals at this time.

Security

We use commercially reasonable methods of protecting your Personal Information. Nevertheless, we cannot guarantee the safety or security of any Personal Information. Further, transmission of Personal Information cannot be made completely secure. For that reason, you agree to transmit Personal Information to us solely at your own risk. If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at [email protected].com.


TERMS FOR SPECIFIC TYPES OF USERS
  • EEA Residents
    • This section of the Privacy Policy is applicable to residents of the EEA. The EEA consists of the member states of the EU, i.e., Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the United Kingdom, and Iceland, Liechtenstein, and Norway. This section also applies to residents of Switzerland and the United Kingdom. Residents of the EEA, Switzerland and the United Kingdom are referred to here as "EEA Residents".
    • Since May 25, 2018, all processing of Personal Information of EEA Residents is performed by us in accordance with the General Data Protection Regulation (2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of Personal Information and on the free movement of such data ("GDPR").
    • Under the GDPR, we are the controller and a processor of the Personal Information of EEA Residents. Our purpose for collecting and processing Personal Information from EEA Residents is to obtain contact information, to substantiate such information and to provide the Services. The legal basis for collecting Personal Information is your consent. You may withdraw consent for obtaining such communications by following the "Unsubscribe" instructions on any communication or by contacting us at [email protected].
    • If you are a resident of the EEA and believe that we have Personal Information about you, and you wish to access or correct the Personal Information that we have about you or have any questions relating to the processing of your Personal Information, please contact us at [email protected] with the subject line "GDPR Data."
    • International Data Transfers. If you are resident outside the United States, including in the EEA, we transfer Personal Information provided by you for processing in the United States. Under the GDPR, we are considered a "controller" and a "co-processor" of the Personal Information of EEA Residents. By providing Personal Information to us for the purpose of setting up an account, obtaining Services, or adding yourself to our contact lists, you consent to the transfer of your Personal Information to the United States. The transfer of your Personal Information to the United States is necessary for the performance of a contract between you and us for obtaining Services.
  • California Consumers
    • This section pertains to the rights of individuals or households in California ("California consumers").
    • Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer’s Personal Information with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes.
    • The CCPA (California Civil Code Section 1798.100 et seq.) provides California consumers with additional rights regarding Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household. The categories of Personal Information we collect are generally described above but differ for individual consumers depending on the services used by such consumers.
    • Under the CCPA, qualifying California consumers may have the following rights:
      • Right to Know and Right to Delete.
        • A California consumer has the right to request that we disclose what Personal Information we collect, use, disclose and sell. A California consumer also has the right to submit requests to delete Personal Information.
        • When we receive a valid request to know or delete from a California consumer, we will confirm receipt of the request within 10 days and provide information about how we will process the request, including our verification process. We will respond to such requests within 45 days.
      • Right for Disclosure of Information.
        • A California consumer may also submit requests that we disclose specific types or categories of Personal Information that we collect.
        • Under certain circumstances, we will not provide such information, including where the disclosure creates a substantial, articulable and unreasonable risk to the security of that Personal Information, customers’ account with us, or the security of our systems or networks. We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, or account passwords and security questions and answers.
    • Submitting Requests. If you are a California consumer and would like to make any requests under the CCPA, please see the “Changing and Deleting Personal Information” the section.
    • Verifying Requests. If we receive any request we will use a two-step process for online requests where the California consumer must first, clearly submit the request and then second, separately confirm the request. We will use other appropriate measures to verify requests received by mail or telephone.
    • To verify a request, a California consumer must provide a business with sufficient information to identify the consumer, such as name, e-mail address, home or work address, or other such information that is on record with us so that we can match such information to the Personal Information that we maintain. Do not provide social security numbers, driver’s license numbers, account numbers, credit or debit card numbers, medical information or health information with requests. If requests are unclear or submitted through means other than outline above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If we cannot verify the identity of the requestor, we may deny the request.
  • Children under 13
    • We are committed to preserving online privacy for all of its website visitors, including children. Consistent with the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect any personal information from children under the age of 13, and we delete any such information we become aware of. If you are a parent or guardian and you believe your child has provided us with Personal Information, please contact us at “please contact our site as provided below under “Contact Us," and be sure to include in your message the same login information that your child submitted.

THIS POLICY IS APPLICABLE TO OUR BUSINESS CLIENTS

Our Services are designed for our Customers, Affiliates, Partners and Merchants, which are businesses. The Services are not intended for personal, family or household use. This Privacy Policy sets forth how we collect, use and disclose Your Information as you provide it to us in connection with your interaction with our Services on behalf of the business you represent.

On behalf of your business, you may direct us to access, collect and process data related to your business. This data may include information and data regarding you, your employees, Affiliates and End Users, and any of their use of your services, including certain personal information ("Your Business Data"). We will only process such Your Business Data solely to the extent necessary to provide you with the features you have requested.

You are solely responsible for the collection and use of Your Business Data and for ensuring that you have in place, and abide by, a valid privacy policy relating to that Your Business Data. It is your privacy policy, not this Privacy Policy, that will apply to your collection and use of your own Your Business Data. As set forth in more detail in our Terms of Service, you represent and warrant that all Your Business Data was collected by you in accordance with your privacy policy and all applicable laws and that you have the right to provide us with such Your Business Data for the purposes set forth in the Terms of Service.

If you are an end user of one of our clients, and not one of our clients, please consult that company’s privacy policy for information on how they collect, use, disclose and otherwise process your information.


CHANGES

We reserve the right to change this Privacy Policy at any time.   We may inform you about any material revisions.  All changes are effective on the date listed at the top of this page and will apply to all information that we have about you.  Your continued use of the Services after any change is posted indicates your acceptance of this Privacy Policy and your continued consent to our processing of your Personal Information in the manner set forth herein.  If at any point you do not agree to any portion of the Privacy Policy, you should immediately stop using the Services.


CONTACT US

If you have any questions regarding this Privacy Policy, or our information collection, storage and disclosure practices, please contact us at [email protected]efersion.com or by mail to:

Refersion Inc.
242 West 38th St.
New York, NY 10018