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Windup Closet,Inc ("Windup closet") processes the personal data of Users who visit and use our online shopping Site. This Privacy Policy describes exactly what personal data we process, how and why we process it, and what your rights are under the General Data Protection Regulation ("GDPR").
If you would like to know more about how we collect personal data using cookies or similar technologies, read our Cookie Policy. We have defined the capitalized terms we use in this policy in our Terms of Use.
1. The information we collect and process
When you use our Online Store, we collect the following information:
Account creation.
When you create an Account with us, we ask you to provide your email address and choose a secure password. You may also use a social network account, such as your Facebook account, to create an Account. If you create an Account using a social network, we will receive basic information about your account on the social network, which we use to create your Account. This includes the email address associated with your social network account. We may also receive information about your status updates or content that you viewed or clicked on while using that social network account. You can check and change the privacy settings on the relevant social network platform at any time, which will update our access to your data.
Create your Windup Closet profile.
After you create your Account, we will ask you for additional information before you can use all the features of our Online Store. This includes your full name, email address, phone number, date of birth and mailing address. We may also ask you for your bank account number and, if applicable, the VAT number and Chamber of Commerce registration number of your company (if you wish to become a Seller, for example). We need this information to ensure that you are at least 18 years old, to contact you, to ensure that the Lot(s) you purchased in an Online Sale can be shipped to you or picked up from your address, and to ensure that you can make or receive payments or refunds.
Provide you with customer service.
When you contact our Customer Experience team or when they contact you, we collect information about the nature of those interactions. We will also collect information that you provide to us by phone or email. This includes, for example, any communication we have with other Users about you or about Lots you have bid on or purchased. If you contact our Customer Experience team by phone, your call may be recorded for quality and training purposes if you have authorized us to do so. Finally, we may also collect information if you contact us via your social network account, such as via Facebook Messenger. But please note that we do not use this chat as an official channel to handle questions or complaints. Nevertheless, we try to respond to your messages in a timely manner and provide you with additional information or assistance if necessary. The privacy policy of the relevant social network provider applies when you use its services.
Provide you with customer service.
Verification of your identity.
If you want to sell on Windup Closet, we may ask you for a scan or photo of a valid form of identification (government-issued photo ID). We or our third-party payment providers may need to verify your identity to comply with financial regulations. For this reason, we require proof of identity, clearly indicating at least your full name, date of birth and ID number (on the document). For the U.S., please make sure your EIN is blanked out.
Your transaction information.
When you buy or sell something on Windup Closet, we keep transaction and payment information, such as the Lot(s) you bought or sold on our Online Store, invoices, price and payment date, payment method, payment status, bank account or credit card information. We keep this information secure for payment and billing purposes, as well as for our internal management. This may be more detailed than the concise overview you see in your Account.
Your Comments.
We may ask you to provide us with feedback via email or an online survey. In these cases, we will only process personal data (such as your email address or user ID) for our internal analysis, which helps us improve our Services. We may also process the opinions, experiences, preferences and interests, as well as comments that you provide or share with us online or through social networks.
Your communications with other Users.
We also process your data when you communicate with other Users in the context of an Online Sale, through the internal messaging system offered on our Online Sale Site.
Your cookie data.
Subject to your prior consent (to the extent necessary), when you visit Windup Closet, we collect electronic identification data from your browser or device using cookies (small text files that your computer sends each time you visit our Online Sale Site) and similar technologies on our (mobile) website and app. For example, we may collect access times, hardware and software information, information about the device you used, your IP address, MAC address, mobile device identifier (IDFA or GAID), cookie identifier, browsing behavior on our Online Shopping Site and the Lot(s) you like. Please read our Cookie Policy to learn more.
2. Why we use this information
To fulfill our agreement with you:
In order to fulfill our contractual obligations to you, while ensuring that you can take advantage of all the great features of our Online Shopping Site, we use your personal data as described above to:
Provide you with our Services and the information you request. Provide you with access to all the features of our Online Store, including creating your Windup Closet Account and profile, to facilitate Online Sales, to facilitate communication between Users, and to facilitate payment and shipping of Lots. To assist you if you have any questions, complaints or problems with your Account or transactions. Send you updates, invoices and/or payment reminders via email, SMS, Whatsapp, any other direct messaging platform, or push notifications. Send you emails relating to services related to your Account, transactions or security. Examples of these service-related emails include email address confirmations, welcome emails when you sign up and create your Account and emails related to your Batch status, transactions or messages from other Users.
For our legitimate business interests:
In view of our or a third party's legitimate interests, we may use your personal data as described above to:
Contact you by e-mail, telephone, postal mail or otherwise for marketing or other business purposes, if you have not unsubscribed from receiving such communications. If you have not consented, we will only send you marketing communications by e-mail to provide you with our Services as an existing customer. If so, we may send you newsletters, surveys, inform you about additional Windup Closet services, events, offers, promotions and/or benefits. You may opt out of receiving such marketing communications at any time by sending an email to privacy@windupcloset.com or by following the instructions in any communication you receive from us.
To improve our Services and better understand you as a User, both in aggregate and on an individual basis. We analyze your use of our Services and use this information to better understand you (e.g., which pages you visit, which Lots you are interested in), to optimize navigation of our Online Store and to provide you with a better user experience. We also use your personal data as described above to enable us to provide, customize, measure and improve our advertising and marketing. For example, to send you personalized marketing communications, to show you suggestions (such as Interesting Lots) and targeted advertisements (on other websites) based on how you interact with our Online Store. We may also use the personal data described above to send you a gift, such as a year-end gift.
To ensure that Windup Closet is a secure and reliable platform for both Buyers and Sellers. We may process your personal data to prevent, track and counter any attempted fraud or other illegal or non-compliant use of our Online Store. For example, our fraud prevention team uses this data to identify Users who do not comply with our Terms of Use and, through our systems, may match various data to block (temporarily or permanently) such Users from accessing our Online Store. We may also process your personal data for system integrity purposes (e.g., to prevent hacking or credential stuffing), for the registration, mediation and resolution of possible disputes or irregularities, or to enforce our Terms of Use and other policies. For example, if a contract has been entered into between another User and you and a problem or dispute arises, we may provide you with certain information to help you resolve the issue directly with that User. We also use predictive models to determine whether we should ask certain Users for some form of payment guarantee or whether we should obstruct their Offer or payment. For example, we use your bidding, buying and selling history and location to predict the likelihood that the Sales Agreement will be cancelled. Based on what this model predicts, we may, as a security measure, ask you to verify your credit card before placing an Offer. When you use our internal messaging system to communicate with other Users via our Online Store, we may view, scan or analyze your messages for fraud prevention, risk assessment, investigation or support purposes.
To facilitate our business operations, generate aggregate statistics, perform market analysis, enforce company policies and procedures, respond to any claims against us, and, to protect the rights, property, or privacy of Windup Closet, our Users, or the public, to enable us to carry out corporate transactions, such as any merger, sale, reorganization, acquisition, bankruptcy, or similar event, and for any other lawful business purpose permitted by applicable law.
Subject to your prior consent
Subject to your prior express consent, we may use your personal data as described above to:
Send you personalized direct marketing communications via email, SMS and other electronic or other means. For example, to send you personalized recommendations, newsletters, tips and promotions or to provide you with updates regarding sales you are following, favorite Lots, sales categories or sales alerts. You may withdraw your consent at any time by using the unsubscribe link in these communications or by adjusting the "Emails and Notifications" settings in your Account.
Record your communication with our Customer Experience team by telephone for quality and internal training purposes.
Please note that you may withdraw your consent at any time (see Section 3. "Your choices regarding the use of your personal data", or Section 7. "Your rights" below).
To comply with legal obligations
Your personal data may also be used to maintain proper business records, to comply with legal requests from public authorities or court orders, or to comply with applicable laws and regulations (e.g., to verify your identity as a Seller in accordance with anti-money laundering requirements), or any other situation required by law.
3. Your choices regarding the use of your personal data
Internal Messaging System
After Online Sales, you have the option to contact the Seller of an item using our internal messaging system. The availability of this internal messaging system may be subject to certain conditions. If you use the internal messaging system, you will receive an email each time you get a response. If you no longer wish to receive these emails, you can unsubscribe in the "Emails and Notifications" settings of your Account. If you are a Seller, you can choose not to receive these messages from potential Buyers by changing your Account settings.
Marketing e-mails
If you no longer wish to receive our marketing emails, you can unsubscribe by using the link in any of these marketing emails. You can also unsubscribe by changing the "E-mails and Notifications" settings in your Account. If for some reason you are unable to adjust these settings yourself, you can contact our customer experience specialists, who will be happy to assist you.
Push Notifications
If you use our app, push notifications are a great way for you to quickly find out about interesting sales or messages from our experts. You have the ability to enable or disable push notifications in our app.
Personalized ads
We want to make sure you always see the content that interests you. That's why we can personalize our ads based on your interests. If you don't want to see personalized banners or other ads on third-party websites, you can disable your marketing cookies and clear your browser history. Read our Cookie Policy to learn how to do this. Please note that you will still see ads from us, but those ads will no longer be personalized to your interests.
4. Cookies and Personalization
We use cookies and similar technologies to understand how you use our Online Store and to provide you with a better Windup Closet experience. For example, these methods help us recognize your device(s), maintain your language preferences, and keep you logged in so you don't have to log in every time you use Windup Closet.
We may also use the information we collect to personalize your experience on our Online Store and to provide you with targeted advertisements on other websites. In order to optimize our Services and marketing, we may use "cross-device tracking" from third-party service providers. We use cross-device tracking to track your activity on different devices that are linked using a unique user ID. This user ID is assigned to you when you register. By tracking your activity, we can deliver personalized content to you across all of your devices. For example, we may show you personalized content on your computer based on your activity on our mobile application. Please see our Cookie Policy to learn more about how and why we use cookies or to withdraw your consent at any time.
5. Sharing Information with Third Parties
We may need to share information with other Users
If you buy or sell Lots, we may need to share some of your information with other Users in order for you to complete the transaction. This may include your name, mailing address, email address and phone number. For example, if you purchase an item from another User and they need to ship it to you, we will share your address and contact information (including phone number and email address) with them so they can make the delivery. If there is a problem between you and another User, we may also provide this information to help you resolve the problem directly with that User. Please note that if you change your contact information during the course of a sale, dispute, or shortly after a dispute, we may still provide the "old" contact information to the other User if we have reason to believe that it is necessary for the other User to enforce his or her rights under the Sales Agreement.
With your consent
We may also provide your personal data to other Users if you have given us your consent. For example, if another User wishes to pay you directly, we will first ask for your permission to share your credit card information with that User. In some cases, we may need to share your data with other Users before you enter into a Sales Agreement. For example, if a User needs to view a Lot in person before entering into a Sales Contract, we may share this information so that a visit can be arranged.
For third party service providers
We may also use the services of third-party service providers. As part of their services, they may process your personal data. For example, service providers may provide us with payment, advertising, customer service or sales support services. They may also help us send e-mails or analyze feedback and help us protect the Online Store from fraud. In accordance with applicable legal requirements, these service providers are required to maintain confidentiality, may only use the specific data necessary to provide services to us, and may only use such data in accordance with our instructions.
For example, to ensure payment security, we use third-party payment service providers to securely process payments to us and other Users. For this purpose, we may share information such as your name, bank account number, date of birth and, if applicable, your Chamber of Commerce registration number and VAT identification number, over an encrypted connection. In performing its services, the payment service providers generally act as data processors on behalf of Windup Closet. However, payment service providers also have their own regulatory obligations. With respect to the latter, the privacy policy of the relevant payment service provider applies.
When we are (legally) obliged to do so or need to enforce our Terms and Conditions
We may also disclose your personal data to third parties:
In connection with a business transaction
In addition, your personal data may be disclosed in connection with any merger, (partial) sale or (partial) transfer of our capital. We will always ensure that you are informed in good time if a corporate transaction involving your personal data takes place.
6. International transfers of personal data
Please note that in some cases, the third parties with whom we share your personal data (as described above) may be located outside the U.S. Economic Area or may use servers located outside the U.S. Economic Area. The laws of these countries may not provide the same level of protection for your personal data. Therefore, we ensure that your personal data is protected in accordance with applicable law. This means that we have entered into legally required contracts with the recipients of your personal data, including standard contractual clauses approved by the U.S. Commission where applicable, and ensuring that appropriate technical and organizational information protection measures are in place.
7. How we secure your personal data and how long we keep it
The security of your personal data is a very important issue for us. Therefore, we take reasonable steps to ensure that your personal data is protected by appropriate technical, physical and organizational measures against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or unlawful destruction and loss. In addition, we take steps to limit access to your personal data to those employees who need access for any of the purposes listed in this Privacy Policy.
In addition to the security measures we take on our end, such as encrypting your personal data, we strongly recommend that you carefully choose a secure password and ensure that your login information remains secret.
We retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy (for example, as long as your Account remains active or as long as necessary to provide you with our Services), unless a longer retention period is required to fulfill our legal obligations or to respond to a complaint. The length of time we retain your personal data may vary depending on the purpose of the processing (for example, for payment services or fraud prevention) and our legal obligations. For example, in the USA, we are legally obliged to keep information about your purchases and sales (for tax purposes) for a period of 10 years.
8. Your rights
Subject to the conditions set out in the applicable legislation, you have the following rights with respect to your personal data: right of access, right of rectification, right of deletion, right to restrict data processing, right to object to profiling or processing based on our legitimate interests, right to withdraw consent and right to data portability.
If you wish to exercise any of these rights, you may do so by sending an email to privacy@windupcloset.com. Please specify the nature of your request in the subject line of the e-mail. In addition, please note that you can adjust the information associated with your Account in your Account settings. In addition, you may delete your Account using the "Delete My Account" button in your Account settings.
If necessary, we may request additional information to verify your identity, such as a copy of your ID, before we can begin processing your request. In this case, please make sure that you have blacked out any information that is not necessary to identify you (social security number, photo, etc.).
If you have asked us to delete your personal information, please note that this is not an absolute right. We will erase your personal data when (i) the data is no longer necessary for the purposes for which it was collected; (ii) you withdraw your consent and there is no other lawful ground for processing; (iii) you object to the processing in the case of direct marketing purposes, or - in any other case - there is no overriding legitimate ground for processing your data; (iv) we have processed your personal data unlawfully.
As such:
If you have asked us to delete your personal information, please note that this is not an absolute right. We will erase your personal data when (i) the data is no longer necessary for the purposes for which it was collected; (ii) you withdraw your consent and there is no other lawful ground for processing; (iii) you object to the processing in the case of direct marketing purposes, or - in any other case - there is no overriding legitimate ground for processing your data; (iv) we have processed your personal data unlawfully.
9. Privacy Violations
If you believe that we have violated your privacy rights, please notify us by sending an email to privacy@windupcloset.com. We will investigate as soon as possible after receiving your e-mail. You may also file a complaint with the relevant national supervisory authority.
10. Changes to our Privacy Policy
We may update this Privacy Policy from time to time. If we do, we will post the updated version on our Online Store. We will also notify you by e-mail if an update materially affects the way you use our Online Store. In the event of any inconsistency between the English version of our Privacy Policy and any of the translations into other languages, the English version shall prevail.
11. Contact
If you have any questions about this Privacy Policy, you may contact Windup Closet's Data Protection Officer at any time via privacy@windupcloset.com. You can also contact us using the contact information below or by contacting our Customer Experience team ("Contact Us" button) :
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