Privacy Policy

Last Updated: February 15, 2023

This Privacy Policy describes the privacy practices of SoleSavy Inc. (collectively, “we”, “us”, or “our”) and how we handle personal information that we collect through our website and any other sites or services that link to this Privacy Policy (collectively, the “Services”). By using the Service, you agree to the collection and use of information in accordance with this policy.

We provide additional information for the United Kingdom,, the European Economic Area (collectively, “Europe” or “European”) below.

Personal information we collect

Information you provide to us:

• Contact and account information, such as your first and last name, email and mailing addresses, phone number, username and password.
• Payment and transaction data. This information is processed by our payment service provider, Stripe, and we do not have access to payment card numbers.
• Information regarding purchases, such as merchandise, an exchange between you and another user, and promotional materials.
• Content you upload through the services, such as posts, images, social media information, and your interactions you wish to make publicly available to other users of the Services (for example, via Slack).
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, product reviews, or otherwise correspond with us online.
• Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit to us, and information you provide when you use any interactive features of the Services.
• Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
• Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from third parties:

• • Social media information. We may maintain pages on social media platforms, such as Facebook, LinkedIn, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy. 

• Other Sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers. 

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

• • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use your personal information

To operate our Services:

• Provide, operate, maintain, secure and improve our Services
• Fulfill a payment or return transaction initiated by you
• Provide information about our Services
• Communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative messages
• Understand your needs and interests, and personalize your experience with our Services and our communications
• Respond to your requests, questions and feedback

For research and development. To analyze and improve the Services and to develop new products and Services, including by studying use of our Services.

Marketing and advertising. We and our advertising partners may collect and use your personal information for marketing and advertising purposes, including:

• Direct marketing. We or our advertising partners may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via email and in-app notifications. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.

• Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the “Automatic data collection” section above) over time across our Services, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the “Online tracking opt-out” section below. 

To comply with law. As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. To: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

To create anonymous data. To create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

How we share your personal information

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate our Services (such as customer support, hosting, analytics, email delivery, marketing, identity verification, and database management services).

Advertising partners. We may share your personal information with third party advertising companies, including for the interest-based advertising purposes described above.

Other users of the Services, such as promoters (for example, we may share your contact and transaction information when you purchase merchandise or engage in our promotions); or other users of the Services (for example, when you post content you wish to make publicly available to other users on the platform, for example, via Slack or wish to exchange merchandise).

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above. 

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.

Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email.

Online tracking opt-out. There are a number of ways to opt out of having your online activity and device data collected through our Services, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our Services from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
• Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising:
  • Google: https://adssettings.google.com
  • Facebook: http://www.facebook.com/about/ads 
  • Twitter: https://twitter.com/settings/account/personalization?lang=en
• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance: http://optout.aboutads.info
  • Network Advertising Initiative: http://optout.networkadvertising.org/?c=1

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Payments

We provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.

The payment processors we work with are:

• Stripe: Their Privacy policy can be viewed here
• Apple: Their Privacy policy can be viewed here
• Google:  Their Privacy Policy can be viewed here
• Chargebee:  Their Privacy Policy can be viewed here

Other sites, mobile applications and services

Our Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security practices

We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information. 

Children 

Our Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

International users

By using our Services, you understand and acknowledge that your Personal Data will be transferred from your location to the facilities and servers of SoleSavy in the United States and Canada.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Services. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through our Services.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on our Services (or as otherwise indicated at the time of posting). 

How to contact us

Please direct any questions or comments about this Policy or privacy practices to [email protected]. You may also write to us via postal mail at:

14205 SE 36th Street Suite 100, Bellevue, WA 98006-1553

Notice to European residents

The information provided in this “Notice to European Residents” section applies only to individuals in Europe.

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. SoleSavy is the controller of the personal information we collect. For any questions you can contact our Data Protection Officer at [email protected]

Data Protection Representative. We have appointed VeraSafe as our representative in the UK for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. To contact VeraSafe, please visit their site. Alternatively, users may call VeraSafe at +420 228 881 031

Legal basis for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership). If you provide us with any sensitive personal information when you use our Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Services.

Retention. We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Cross-border data transfer. If we transfer your personal information from Europe to another country such that we are required to apply appropriate safeguards to your personal information under European data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.

Your rights. European data protection laws may give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to [email protected] or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.