Privacy Policy
Effective Date: September 11, 2024
At Rinse, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.
Remember that your use of Rinse's Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
You may print a copy of this Privacy Policy here. If you have a disability, you may access this Privacy Policy in an alternative format by contacting privacy@rinse.com.
Privacy Policy Table of Contents
- What this Privacy Policy Covers
- Personal Data
- How We Disclose Your Personal Data
- Tracking Tools, Advertising and Opt-Out
- Data Security and Retention
- Personal Data of Children
- California Resident Rights
- Colorado Resident Rights
- Connecticut Resident Rights
- Utah Resident Rights
- Virginia Resident Rights
- Exercising Your Right under the State Privacy Laws
- Other State Law Privacy Rights
- Changes to this Privacy Policy
- Contact Information
1. What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
2. Personal Data
2.1. Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties With Whom We Share this Personal Data: |
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Profile or Contact Data |
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Payment Data |
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Commercial Data |
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Device/IP Data |
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Web Analytics |
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App Analytics |
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Social Network Data |
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Consumer Demographic Data |
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Geolocation Data |
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Internet or other similar network activity information |
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Other Identifying Information that You Voluntarily Choose to Provide |
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2.2. Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
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You
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When you provide such information directly to us.
- When you create an account or use our interactive tools and Services.
- When you place an order for the Cleaning Services, we collect payment data, depending on the form of payment you choose.
- When you send in your garments or other items for the Cleaning Services, we may collect information on such items, including type, service requested, brand, color, size, and photos.
- When you voluntarily provide information in text messages or in free-form text boxes through the Services or through responses to surveys or questionnaires.
- When you choose to refer a friend through the Services, we will ask for your friend's contact information.
- When you send us an email or otherwise contact us.
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When you use the Services and such information is collected automatically.
- Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
- If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
- If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
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When you provide such information directly to us.
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Third Parties
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Vendors
- We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
- We may use vendors to obtain information to generate leads and create user profiles.
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Advertising Partners
- We receive information about you from some of our vendors who assist us with marketing or promotional services for the Rinse Services related to how you interact with our websites, applications, products, Services, advertisements or communications.
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Social Networks
- If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
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Vendors
2.3. Our Commercial or Business Purposes for Collecting Personal Data
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Providing, Customizing and Improving the Services
- Creating and managing your account or other user profiles
- Processing orders or other transactions; billing
- Providing you with the Cleaning Services, or other products, services or information you request
- Meeting or fulfilling the reason you provided the information to us, such as to message to your friend inviting him or her to sign-up for the Service
- Providing support and assistance for the Services
- Analyzing trends and consumers’ interactions with the Services
- Improving the Services, including testing, research, internal analytics and product development
- Personalizing the Services, website content and communications based on your preferences
- Doing fraud protection, security and debugging
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws,such as the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020 (the “CCPA”), the Virginia Consumer Data Protection Act (the “VCDPA”), the Colorado Privacy Act(the “CPA”), the Connecticut Data Privacy Act (the “CTDPA”), or Utah Consumer Privacy Act (the “UCPA”) (collectively, the “State Privacy Laws”).
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Marketing the Services
- Marketing and selling the Services
- Providing you with customized offers or promotions that we think might be interested to you
- Showing you advertisements, including interest-based or online behavioral advertising, and retargeted online and mobile advertisements to you across computers or devices you may use
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Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Rinse or the Services
- Sending emails and other communications according to your preferences or that display content that we think will interest you
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Meeting Legal Requirements and Enforcing Legal Terms
- Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities
- Protecting the rights, property or safety of you, Rinse or another party
- Enforcing any agreements with you
- Responding to claims that any posting or other content violates third-party rights
- Resolving disputes
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
3. How We Disclose Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Personal data collected through the short code/SMS program won’t be shared, sold or rented to unaffiliated or affiliated third parties for their own marketing purposes. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
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Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
- Hosting, technology and communication providers, such as AWS
- Security and fraud prevention consultants
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Analytics providers, such as Google Analytics, Facebook Pixel, and Microsoft Clarity
- We partner with Microsoft Clarity to capture how you use and interact with our website and our mobile applications through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website/app usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization and fraud/security purposes. For clarity, we do not use Microsoft Clarity for any advertising/marketing purposes. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement at https://privacy.microsoft.com/en-US/privacystatement.
- Support and customer service vendors
- Product fulfillment and delivery providers
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Payment processors
- Our payment processing partner Braintree (offered by PayPal, Inc.) (“Braintree”) collects your voluntarily-provided payment card information necessary to process your payment.
- Please see Braintree’s terms of service and privacy policy for information on its use and storage of your Personal Data.
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Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
- Ad networks
- Data brokers
- Marketing providers
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Parties You Authorize, Access or Authenticate
- Third parties you access through the services
- Social media services
3.1. Legal Obligations
We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
3.2. Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
3.3. Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
4. Tracking Tools, Advertising and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
- Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
- Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
- Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
4.1. Information about Interest-Based Advertisements
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
4.2. Opt-out Choices
We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices or www.aboutads.info/choices. To opt-out of the use of your mobile device ID for targeted advertising, see http://www.aboutads.info/appchoices.
We provide our consumers with the opportunity to opt-out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product or service. To opt-out of marketing communications, you may use one of these convenient methods:
- Electronic Promotional Offers. If you do not want to receive emails from us regarding special promotions or offers, you may click the unsubscribe link in the footer of any email, or contact us at privacy@rinse.com with “Unsubscribe Promotional Offers” in the subject line.
- Mobile Promotional Offers. When you provide us with your mobile number for marketing purposes, we may send you certain marketing alerts via text message. Standard data and message rates will apply. If you no longer wish to receive mobile alerts from us, you can follow the instructions provided in those messages or otherwise reply “STOP” to any Rinse alert.
Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable. Additionally, we are not responsible for informing third parties (including without limitation our third party service providers or partners) with whom we have already shared your personal information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.
5. Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
6. Personal Data of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@rinse.com.
7. California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@rinse.com.
7.1. Access
You have the right to request certain information about our collection and use of your Personal Data. In response, we will provide you with the following information in the past 12 months:
- The categories of Personal Data that we have collected about you
- The categories of sources from which that Personal Data was collected
- The business or commercial purpose for collecting or selling your Personal Data
- The categories of third parties with whom we have shared your Personal Data
- The specific pieces of Personal Data that we have collected about you
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.
You may request the above information beyond the 12-month period, but no earlier than January 1, 2022. If you do make such a request, we are required to provide that information unless doing so proves impossible or would involve disproportionate effort.
7.2. Deletion
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effect. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
7.3. Personal Data Sales and Shares Opt-Out
In this section, we use the term ‘sell’ and ‘share’ as it is defined in the CCPA. We sell and/or share your Personal Data, subject to your right to opt-out as described in this section.
As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, disclosing your data through third party Cookies for online advertising may be considered a “selling” or "sharing" of information. You can opt out of these sales by following the instructions in this section.
We sell or share your Personal Data to the following categories of third parties:
- Analytics providers, such as Google Analytics and Facebook Pixel
- Ad Networks
- Data brokers
- Marketing providers
Over the past 12 months, we have sold the following categories of your Personal Data to categories of third parties listed above:
- Profile or Contact Data
- Payment Data
- Commercial Data
- Device/IP Data
- Web Analytics
- Social Network Data
- Consumer Demographic Data
- Geolocation Data
- Internet or other similar network activity information
- Other Identifying Information that You Voluntarily Choose to Provide
We have sold or shared the foregoing categories of Personal Data for the following business or commercial purposes:
- Improving the Services, including testing, research, internal analytics and product development.
- Personalizing the Services, website content and communications based on your preferences.
- Doing fraud protection, security and debugging.
- Marketing and selling the Services.
- Showing you advertisements, including interest-based or online behavioral advertising.
You have the right to opt-out of the sale of your Personal Data by following the instructions in the “Exercising Your Rights under State Privacy Laws” section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
To our knowledge, we do not sell the Personal Data of minors under 16 years of age.
7.4. Limit the Use of Sensitive Personal Information
Consumers have the right to request that we limit the use or sharing disclosure of their Sensitive Personal Information (“Right to Limit”). However, since our use and disclosure of Sensitive Information are limited to the purposes set forth in section 7027(m) of the CCPA regulations, including: 1) performing the services or providing the goods reasonably expected, 2) preventing, detecting, and investigating security incidents, 3) resisting malicious, deceptive, fraudulent, or illegal actions, 4) ensuring physical safety of natural persons, 5) for short-term transient use, 6) performing services on behalf of the business, 7) verifying or maintaining quality or safety of a product or service, and 8) collecting or processing Sensitive Personal Information but not for the purpose of inferring characteristics, we do not offer a way for you to submit such a request.
7.5. We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
8. Colorado Resident Rights
If you are a Colorado resident, you have the rights set forth under the Colorado Privacy Act (“CPA”). Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Colorado resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@rinse.com.
8.1. Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access and request a copy of your Personal Data in a machine-readable format, to the extent technically feasible, twice within a calendar year.
8.2. Correction
You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.
8.3. Deletion
You have the right to delete Personal Data concerning you.
8.4. Personal Data Sales and Targeted Advertising Opt-Out
In this section, we use the term ‘sell’ as it is defined in the CPA. We sell and process for the purposes of targeted advertising your Personal Data, subject to your right to opt-out of these sales.
As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CPA, disclosing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out of these sales by following the instructions in this section.
We sell and process for the purposes of targeted advertising your Personal Data to the following categories of third parties:
- Analytics providers, such as Google Analytics and Facebook Pixel
- Ad Networks
- Data brokers
- Marketing providers
We sell and process for the purposes of targeted advertising the following categories of your Personal Data to categories of third parties listed above:
- Profile or Contact Data
- Payment Data
- Commercial Data
- Device/IP Data
- Web Analytics
- Social Network Data
- Consumer Demographic Data
- Geolocation Data
- Internet or other similar network activity information
- Other Identifying Information that You Voluntarily Choose to Provide
We have sold or shared the foregoing categories of Personal Data for the following business or commercial purposes:
- Improving the Services, including testing, research, internal analytics and product development.
- Personalizing the Services, website content and communications based on your preferences.
- Doing fraud protection, security and debugging.
- Marketing and selling the Services.
- Showing you advertisements, including interest-based or online behavioral advertising.
You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the “Exercising Your Rights” section. If you are under 13 years of age, your parent or guardian must authorize us to sell or process for the purposes of targeted advertising your Personal Data.
8.5. Profiling Opt-Out
We do not process your Personal Data for ‘Profiling’ to make ‘Decisions’ under the CPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic situation, health, personal preferences, interests, reliability, behavior, location or movements. ‘Decision’ means any ‘Decisions that Produce Legal or Similarly Significant Effects Concerning a Consumer,’ as defined in the CPA that concern you.
8.6. We Will Not Discriminate Against You
We will not process your personal data in violation of state and federal laws that prohibit unlawful discrimination against consumers.
9. Connecticut Resident Rights
If you are a Connecticut resident, you have the rights set forth under the Connecticut Data Privacy Act (“CTDPA”). Please see the “Exercising Your Rights under State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Connecticut resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@rinse.com.
9.1. Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.
9.2. Correction
You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.
9.3. Deletion
You have the right to delete Personal Data you have provided to us, or we have obtained about you.
9.4. Portability
You have the right to request a copy of your Personal Data that is processed automatically in a machine-readable format, to the extent technically feasible.
9.5. Personal Data Sales and Targeted Advertising Opt-Out
In this section, we use the term ‘sell’ as it is defined in the CTDPA. We sell and process for the purposes of targeted advertising your Personal Data, subject to your right to opt-out of these sales.
As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CTDPA, disclosing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out of these sales by following the instructions in this section. You can opt out from these “sales” by following the instructions in the “Exercising Your Rights under State Privacy Laws” section.
Under the CTDPA, we disclose the Personal Data of minors under 13 years of age in a way that may be considered a sale, including processing for the purposes of targeted advertising. If you are under 13 years of age, your parent or guardian must authorize us to sell or process for the purposes of targeted advertising your Personal Data.
9.6. Profiling Opt-Out
We do not process your Personal Data for ‘Profiling’ as defined under the CTDPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
9.7. We Will Not Discriminate Against You for Exercising Your Rights Under the CTDPA
We will not discriminate against you for exercising your rights under the CTDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CTDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CTDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
10. Utah Resident Rights
If you are a Utah resident, you have the rights set forth under the Utah Consumer Privacy Act (“UCPA”). Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Utah resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@rinse.com.
10.1. Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.
10.2. Portability
You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.
10.3. Deletion
You have the right to delete Personal Data you have provided to us.
10.4. Opt-Out of Certain Processing Activities
- You have the right to opt-out of the processing of your Personal Data for targeted advertising purposes. We process your Personal Data for targeted advertising purposes. You can opt out this processing of your Personal Data by following the instructions under the “Exercising Your Rights under the State Privacy Laws” Section.
- You have the right to opt-out to the sale of your Personal Data. UCPA defines sale as the exchange of Personal Data for monetary consideration to a third party. You can opt out this processing of your Personal Data by following the instructions under the “Exercising Your Rights under the State Privacy Laws” Section.
10.5. We Will Not Discriminate Against You for Exercising Your Rights Under the UCPA
We will not discriminate against you for exercising your rights under the UCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the UCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the UCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
11. Virginia Resident Rights
If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Virginia resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@rinse.com.
11.1. Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.
11.2. Correction
You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.
11.3. Portability
You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.
11.4. Deletion
You have the right to delete Personal Data you have provided to us, or we have obtained about you.
11.5. Opt-Out of Certain Processing Activities
- You have the right to opt-out of the processing of your Personal Data for targeted advertising purposes. We process your Personal Data for targeted advertising purposes.
- You have the right to opt-out to the sale of your Personal Data. VCDPA defines sale as the exchange of Personal Data for monetary consideration to a third party.
To exercise any of your rights for these certain processing activities, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section.
11.6. We Will Not Discriminate Against You for Exercising Your Rights Under the VCDPA
We will not discriminate against you for exercising your rights under the VCDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the VCDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the VCDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
12. Exercising Your Rights under State Privacy Laws
To exercise the rights described in this Privacy Policy, you or, if you are a California, Colorado or Connecticut resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
If you are a California, Colorado, Connecticut, Virginia, or Utah resident, you may opt-out from any “sales,” “shares,” or targeted advertising, by using the following methods:
- You can complete the online form found here: Do Not Sell or Share My Personal Information.
- Email us at privacy@rinse.com
- By implementing the Global Privacy Control or similar universal privacy control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does include Do Not Track signals.
If you are a California resident, you may exercise your Right to Limit by using the following methods:
- You can complete the online form found here: Limit the Use of My Sensitive Personal Information or
- Email us at privacy@rinse.com
If you are a Colorado resident, you may opt out from the processing of your Sensitive Data (or Sensitive Data Inferences) by using the following methods:
- Email us at privacy@rinse.com
If you are a Colorado Resident and have previously consented to a secondary use of processing your Personal Data you, revoke your consent by using the following methods:
- Email us at privacy@rinse.com
You may submit a Valid Request for any other rights afforded to you in this Privacy Policy by using the following methods:
- Email us at privacy@rinse.com
- Call us at: 888-850-2444
If you are a California, Colorado or Connecticut resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
13. Appealing a Denial
If you are a Colorado, Connecticut, or Virginia resident, and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the CPA, CTDPA, or VCDPA (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by the following methods:
- Email us at privacy@rinse.com (title must include “[STATE OF RESIDENCE] Appeal”)
- Call us at: 888-850-2444
If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: www.oag.state.va.us/consumer-protection/index.php/file-a-complaint (VA), www.coag.gov/resources/colorado-privacy-act/ (CO), and www.portal.ct.gov/AG/Sections/Privacy/The-Privacy-and-Data-Security-Department (CT).
14. Other State Law Privacy Rights
14.1. California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@rinse.com.
14.1. Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@rinse.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
15. Changes to this Privacy Policy
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Rinse website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
16. Contact Information
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
- 888-850-2444
- https://www.rinse.com/
- privacy@rinse.com
- 1000 Brannan St, Suite 100, SF CA 94103