beststepwear

Privacy Policy

Beststepwear LLC ("Beststepwear") and its affiliates (collectively, "Beststepwear Group," "we," "us," "our") provides this Privacy Policy to inform you about how we collect, use, disclose, and otherwise process personal information when individuals ("you") access our websites (the "Sites"), and all related content, products, services, platforms, other functionalities offered on or through our services, and any other properties or locations that link to this Privacy Policy (collectively, the "Services"). This Privacy Policy does not address our privacy practices relating to job candidates, employees and other personnel.

TABLE OF CONTENTS
I. OUR COLLECTION AND USE OF PERSONAL INFORMATION

II. DISCLOSURE OF PERSONAL INFORMATION

III. CONTROL OVER YOUR INFORMATION

IV. DATA RETENTION

V. CHILDREN'S PERSONAL INFORMATION

VI. LINKS TO THIRD-PARTY WEBSITES OR SERVICES

VII. UPDATES TO THIS PRIVACY POLICY

VIII. CONTACT US

IX. REGION-SPECIFIC DISCLOSURES

I. OUR COLLECTION AND USE OF PERSONAL INFORMATION
We collect personal information in a variety of ways. For example, you may provide us with your personal information when you make a purchase, list an item for sale, send us messages, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use some other feature of our Services.

We may link or combine information collected from you on our Sites with information we have collected from you offline (e.g., in-person), information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to, for example, provide you with a personalized experience regardless of how you interact with us.

The personal information we collect, the way we collect it, and how we use it will depend on how you are interacting with us and the type of services you use.

Personal Information Collected from You

Account Information, including name, email address, phone number, username and password, location, profile information, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information, communicate with you regarding your account and your use of the Services, and for fraud prevention and customer support purposes. Please note that other users may see your username and/or location (if you enable location services and grant permission) on the Services.

Buyer Information, including name, email address, shipping and billing address, and payment card and billing information, if you choose to make a purchase. Please note that we use third-party payment processors to process credit card payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party payment processor. The payment processor's use of your personal information is governed by their privacy policy.

Seller Information, including name, email address, shipping and billing address, bank information and payment card and billing information, if you choose to list an item for sale on one of our platforms. Please note that we use third-party payment processors to process credit card payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party payment processor and may be kept on file with such third-party payment processor to cover certain applicable charges incurred by a seller. The payment processor's use of your personal information is governed by their privacy policy.

Identity and Compliance Information, including name, birthdate, address, phone number, email address, bank account information, government ID number, VAT ID number or other tax ID number, and copies of government ID or tax documents, along with a selfie image. We may use data collection and verification services provided by a third-party provider, Persona, to collect and verify such information in order to comply with our legal obligations and protect against fraud and abuse. Persona may use a combination of machine-learning tools and optical scans to verify your identity document and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provide to determine the likelihood that the images are a "match." We do not receive the biometric identifier generated from the images. It is generated and held by Persona until we inform them that the biometric identifier is no longer needed for the purposes described in this paragraph and must be destroyed. For identity verification and security purposes, we will have access to the selfie image and will receive the information extracted from the scan of the government ID document as well as the results of the verification process. We may use this process and associated information to verify your identity and your identity documents, comply with legal obligations and protect against fraud and abuse. We do not use, disclose or retain your biometric information for any other commercial purpose. Our third-party provider, Persona, processes this information on our behalf strictly in accordance with our contractual agreements. For more information on Persona's data processing practices, please see Persona's Privacy Policy.

User Generated Content, including content that you create, such as posts and/or comments, messages that you send and receive (including their content) and the metadata about content and messages.

Inquiry and Communications Information, including any information you submit to us through a "Submit Request" customer support form, such as contact information and any other information you provide in the request, information provided in chat messages, to one of our email addresses, in-person, or via phone. We use this information to investigate and respond to your inquiries, to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.

Newsletter and Marketing Emails Information, including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving emails from us, simply click "unsubscribe" at the bottom of the email. Note that you cannot unsubscribe from certain services-related emails (e.g., account verification, confirmations of transactions, technical or legal notices).

Personal Information from Third Parties

We may also combine the information we receive from you with personal information we obtain from third parties. We may receive the same categories of personal information as described above from the following third parties:

Social Media. When an individual interacts with our Services through various social media platforms, such as when someone logs in through a social media platform, links their social media account, provides us with their social media handle, "Likes" us on a social media platform or follows us or shares our content on Google, Facebook, Twitter, Instagram or other social media platform, we may receive some information about individuals that they permit such social media platform to share with third parties. The data we receive is dependent upon an individual's privacy settings with the social media platform. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media platforms and services before sharing information and/or linking or connecting them to other services.

Service Providers. Our service providers that perform services solely on our behalf, such as payment processors, fraud prevention vendors, verification vendors, website hosting providers, or certain survey and advertising/marketing providers, collect personal information and may share some or all of this information with us.

Other Sources. We may also collect personal information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, our affiliated companies, brand partnerships, or through transactions such as mergers and acquisitions.

Personal Information Automatically Collected

As is true of many digital properties, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, as described in the list below:

Log data, including internet protocol (IP) address, operating system, device type and version, unique device identifier, browser type and version, browser ID, the URL entered and the referring page/campaign, date and time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services.

Analytics data, including the electronic path you take to our Services, through our Services and when exiting our Services, UTM source, as well as your usage and activity on our Services, such as the time zone, activity information (e.g., first and last active date and time), usage history (e.g., emails opened, total log-ins) as well as the pages, links, objects, services you view, click or otherwise interact with.

Location data, such as general location information we derive from your IP address. We and our third-party partners may use cookies or small data files that are stored on an individual's computer and other related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, "cookies") to automatically collect this information. We may also use this information to distinguish you from other users of our Services. This helps us monitor and analyze how you use and interact with our Services. It also helps us and our partners to determine products and services that may be of interest to you.

Additional Uses of Personal Information

In addition to the uses described above, we may use the personal information collected as described above for the following purposes:

Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions;
Manage our businesses and day-to-day operations;
Communicate with you and contact you via newsletters, email updates, marketing or promotional materials and other information that may be of interest to you. For more information on your choices about communications, see the Control Over Your Information section of this Privacy Policy;
Send you technical notices (including sending you an SMS text code for multifactor authentication), security alerts, and support and administrative messages and to respond to your and others' comments, questions, and customer service requests;
Personalize your experience on the Services and to tailor the Site and the Services to your interests;
Respond to requests, suggestions, questions, and comments, and provide other types of user support;
For internal business purposes, including analytics and marketing purposes;
Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
Help maintain the safety, security and integrity of our properties and Services, technology assets and business;
Enforce our Terms of Use, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
Comply with contractual and legal obligations and requirements;
To fulfill any other purpose for which you provide personal information; and
For any other lawful purpose, or other purpose that you consent to.
Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry or request and/or personal information we require fall outside the scope of this Privacy Policy. In that case, the additional privacy-related information will govern how we may process the information provided at that time.

Through the provision of our Services, we may process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. We will maintain and use such information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used satisfies the requirements under applicable law.

We may also aggregate data for reporting, analytics, and other business reasons, including to promote or describe the use of our Services.

II. DISCLOSURE OF PERSONAL INFORMATION
As part of our Services, we may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

Affiliated Companies. We may share personal information with other companies owned or controlled by Beststepwear, and other companies owned by or under common ownership as Beststepwear, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.

Other Users. When you create a profile on the Services, other registered users may be able to see the information that you include in your profile, including but not limited to your username and/or your location (if you enable location services and grant permission). If you purchase or list items for sale on certain of our Services, or interact with the Services, we may disclose your information to other parties. For example, if you make a purchase on one of our Sites, we may disclose your information to the Seller. You should exercise care in deciding what information to provide.

Service Providers. We may employ third-party providers and individuals to facilitate the Services, to provide the Services on our behalf, to perform Service-related functions (e.g., payment processing services, IT support services, maintenance services, shipping, database management, marketing, security and fraud prevention services, web or advertising analytics, and improvement of the Service's features) or to assist us in analyzing how the Services are used.

Third-Party Referral Partners. We may work with third-party referral partners. If you visit the Site by linking directly from a third-party website, we may provide the third party with select information about your individual transaction that you made after being referred. To track and credit your transaction, the third-party website may give you a unique code, cookie or graphic which will uniquely identify you. The presence of a third-party navigation bar at the top of any page on any website is an indication that the third-party website may have access to information about your activity on such website.

Online Advertising Partners. We may also share personal information with advertising networks or permit these partners to collect information from you directly on our Sites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms.

Business Transaction or Reorganization. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during the negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.

Legal Obligations and Rights. We may disclose personal information to third parties, such as legal advisors, law enforcement and tax authorities:

in connection with the establishment, exercise, or defense of legal claims;
to comply with laws and our tax obligations (e.g., to respond to claims, lawful requests and legal process, including but not limited to subpoenas);
to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
to detect, suppress, or prevent fraud;
to protect the health and safety of us and others or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, harmful, unethical or legally actionable activity; or as otherwise required by applicable law.
With Your Consent. We may disclose personal information about an individual to certain other third parties or publicly with your consent or direction.

Aggregated and Deidentified Information. We may share aggregated or deidentified information without limitation. This includes sharing the types of technical information that we collect as described above (including information that identifies a device), to the extent permitted by law.

III. CONTROL OVER YOUR INFORMATION
You may control your information in the following ways:

Account and Profile Information and Settings. If you have created an account, you may review, update, correct or delete certain information in your profile within the Site (as applicable). If you would like us to delete your record in our system, please contact us at privacy@Beststepwear.com with a request that we delete your personal information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Newsletter and Marketing Emails. You can opt out of receiving marketing emails from us by clicking the "unsubscribe" link at the bottom of each email. Note that you cannot unsubscribe from certain services-related emails (e.g., account verification, confirmations of transactions, technical or legal notices).

SMS Text Messaging and Telephone Calls. With your prior express consent, we may use personal information we collect to communicate with individuals via text message and telephone calls, including to send you an SMS text code for multifactor authentication. You can unsubscribe from text messages at any time by replying STOP or clicking the unsubscribe link (where available) in one of our messages. For more information, please see our Terms of Use. We do not share SMS consent and the related phone numbers with third parties, except where required to facilitate the text message or phone call.

IV. DATA RETENTION
We will usually store the personal information we collect about you for no longer than necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

For example, if you reside in the European Economic Area, the United Kingdom or the State of California, your personal information may be subject to certain laws and regulations that define the criteria used to determine the period for which personal information about you will be retained, which varies depending on the legal basis under which we process the personal information:

Contract. Where we are processing personal information is based on contract, we generally will retain your personal information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.

Legitimate Interests. Where we are processing personal information based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account your fundamental interests and your rights and freedoms.

Consent. Where we are processing personal information based on your consent, we generally will retain your personal information until you withdraw your consent, or otherwise for the period of time necessary to fulfill the underlying agreement with you or provide you with the applicable service for which we process that personal information.

Legal Obligation. Where we are processing personal information based on a legal obligation, we generally will retain your personal information for the time necessary to fulfill the legal obligation.

Legal Claim. We may need to apply a "legal hold" that retains information beyond our typical retention period where we face threat of legal claim or intent to establish a claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

When an individual discontinues the use of our Services, we will retain their personal information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as for any additional purpose based on the choices they have made, such as to receive marketing communications. We will retain personal information supplied when joining our Services, including complaints, claims and any other personal information supplied during the duration of an individual's contract with us for the Services until the statutory limitation periods have expired, when this is necessary for the establishment, exercise or defense of legal claims.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (e.g., because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or deidentification is possible.

V. CHILDREN'S PERSONAL INFORMATION
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child's parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

VI. LINKS TO THIRD-PARTY WEBSITES OR SERVICES
Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy policies.

VII. UPDATES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

VIII. CONTACT US
If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to privacy@Beststepwear.com.

Alternatively, inquiries may be addressed to:

Beststepwear Group

Attn: Privacy Department

P.O. Box 91258

Los Angeles, CA 90009-1258

IX. REGION-SPECIFIC DISCLOSURES
We may choose or be required by law to provide different or additional information relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

For residents of U.S. States that have enacted applicable and enforceable data privacy legislation, please click here for additional US-specific privacy disclosures.
For residents of Canada, please click here for additional Canada-specific privacy disclosures.
For residents of the European Economic Area ("EEA"), Switzerland, and the United Kingdom ("UK"), please click here for additional region-specific privacy disclosures.