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Privacy Policy for EU

The Retail Equation takes the utmost care in protecting the privacy and integrity of your personal information. This Consumer Privacy Notice provides you with information about how we collect, use, and share your personal information.

ABOUT THIS CONSUMER PRIVACY NOTICE

SUMMARY OF KEY POINTS

EXPLANATION OF OUR CORE PROCESSING SERVICE – RETURN AUTHORIZATION

TYPES OF PERSONAL DATA WE COLLECT
PERSONAL DATA YOU PROVIDE TO US
PERSONAL DATA PROVIDED BY A RETAILER

USING YOUR PERSONAL DATA
OUR USES AS A DATA CONTROLLER
OUR USES AS A DATA PROCESSOR

LEGAL BASES FOR COLLECTION AND PROCESSING OF EU PERSONAL DATA

SHARING YOUR PERSONAL DATA
EMPLOYEES AND SERVICE PROVIDERS
LEGAL PURPOSES

DATA RETENTION

LOCATIONS OF PROCESSING PERSONAL DATA

CHILDREN’S PRIVACY

YOUR DATA SUBJECT RIGHTS
HOW TO EXERCISE YOUR RIGHTS WITH A RETAILER REGARDING PERSONAL DATA
HOW TO EXERCISE YOUR RIGHTS WITH THE RETAIL EQUATION REGARDING PERSONAL DATA

DATA PRIVACY AND SECURITY

CHANGES TO THIS PRIVACY POLICY

CONTACT US

About This Consumer Privacy Notice

The Retail Equation takes the utmost care in protecting the privacy and integrity of your personal information. This Consumer Privacy Notice provides you with information about how we collect, use, and share your personal information.

This Consumer Privacy Notice (“Consumer Privacy Notice”) describes the privacy practices of The Retail Equation’s websites, applications (“apps”), and mobile platforms. Please read this Consumer Privacy Notice carefully to learn how we collect, use, share, and otherwise process personal information (“Personal Data”) relating to individual EU consumers, and your rights and choices regarding our processing of your Personal Data.

Customers of The Retail Equation are referred to here as “Retailers”. Any references to “The Retail Equation,” “we,” “us,” “our,” or the “Company” is a reference to The Retail Equation.

This Consumer Privacy Notice applies to the following activities and circumstances with respect to EU consumers:

  • Visiting our websites or using our web-based services, desktop apps, mobile apps, or mobile platforms which display or contain a link to this Consumer Privacy Notice;
  • Receiving communications from us, including emails, texts, phone calls, or faxes;
  • Requesting more information from The Retail Equation about our products and services, including a request for your Return Activity Report;
  • A Retailer or other organization with which you are employed or are a consumer provides us with certain Personal Data about you in connection with your merchandise return activity history;
  • We obtain publicly-available Personal Data about you through legally permissible means.

The activities listed above are collectively referred to in this Consumer Privacy Notice as our “Services.

Your relationship with The Retail Equation stems from the Retailers with which you interact, the Services you receive, and your location. This Consumer Privacy Notice applies to consumers located in the UK only. Certain data privacy laws and regulations applicable to the EU and the UK may apply, including but not limited to the General Data Protection Regulation (GDPR) (EU) 2016/679 and the UK Data Protection Act 2018 (DPA).

This Consumer Privacy Notice does not apply to the activities of any Retailers with which you interact, i.e. if Retailers create their own websites, apps, or mobile platforms, where Retailers may sell or offer their own products and services, when Retailers send electronic communications to individuals, or where Retailers collect and analyze Personal Data from individuals. The information practices of third-party services are governed by the third-party privacy statements, which we encourage you to review to better understand those privacy practices.

Summary of Key Points

  • Where your consent is required, we will obtain your permission before (i) sending you news and promotional material about The Retail Equation; (ii) accessing information stored on your computer or mobile device relating to your use of, and engagement with, our websites, apps, and mobile platforms; and (iii) using automated systems to analyze your content. You can withdraw your consent to online tracking and the receipt of promotional materials at any time.
  • This Consumer Privacy Notice explains when and for what purposes we utilize your Personal Data pursuant to contract or for our legitimate interests, as applicable. EU and UK residents have certain data subject rights related to our handling of your Personal Data.
  • We use your Personal Data to enable you to interact with The Retail Equation and to provide you with our websites, apps, and mobile platforms, and other products or services that you request, such as your Return Activity Report.
  • We use cookies and other technologies to track the use of our websites, apps, and mobile platforms.
  • We may process your Personal Data in the US and within other countries, any of which may be outside the country in which you reside. For transfers of Personal Data that originate in the EU and UK, we use European Commission approved Standard Contractual Clauses to help protect your Personal Data.
  • We may disclose your Personal Data to our legal affiliates. We also may share Personal Data with third parties we engage to process information on our behalf or when such sharing is required by law, or in certain other situations.

 

Explanation of Our Core Processing Service – Return Authorization

The Retail Equation offers a merchandise returns monitoring and authorization service to Retailers. The Retail Equation collects identifying and return transaction information from Retailers and uses that information to make recommendations about returns. When a consumer returns merchandise to a Retailer, he or she may either (a) supply a valid receipt of purchase for the merchandise; or (b) furnish acceptable (as determined by the Retailer) personally identifying information to the Retailer, such as a payment card or credit card, or a government-issued or other form of identification, such as a driving license. The Retailer forwards to The Retail Equation the receipt information and/or other identifying information, along with data for the return, and The Retail Equation adds the identifying and return transaction information to the return history for the consumer. The Retail Equation then reviews the consumer’s return history and, based on the Retailer’s own criteria, makes a recommendation about the return.

Types of Personal Data We Collect

Personal Data You Provide to Us

Where The Retail Equation collects Personal Data directly from you, we are the controller of your Personal Data and are responsible for the collection, processing, and use of your Personal Data as described in this Consumer Privacy Notice. The Personal Data that we collect directly from you may include the following: contact information, device and usage information, user submissions, and other as well as any other information type that we expressly ask you to enter and submit to any of our websites, apps, or mobile platforms:

  • Contact Information: If you express an interest in obtaining additional information about our products or services, request customer support, or request from us a copy of your Return Activity Report, we generally require you to provide us with your contact information, such as:
    • your name, interest, job title, company name, address, phone number, email address, communications preferences, or username and password;
  • Device and Usage Information: If you use and interact with The Retail Equation consumer website, we automatically collect device and usage information, through common information-gathering tools such as:
    • log files and other information about your computer or mobile device and your usage of our websites through cookies, web beacons, or similar technologies, such as IP-addresses or other identifiers, which may qualify as Personal Data;
  • User Submissions: If you post any personal or other information for public consumption to any of our websites, apps, mobile platforms, or any web-based or app-based online community that we host, which information may include your tips, updates, alerts, comments, feedback, or any other information that you voluntarily provide (your “Submissions”), we may display your Submissions on any of our websites, apps, mobile platforms, or any web-based or app-based online community that we host.

Personal Data Provided By A Retailer

If your Personal Data has been submitted to us by a Retailer, we operate as the processor of your Personal Data. The Retailer may be one with which you are employed or with which you have made a merchandise purchase or return, or with which you otherwise interact.

The Personal Data we collect about you from one or more Retailers may include, but is not limited to, the following:

  • Full name
  • Residential Address
  • Telephone Number
  • Date of Birth
  • Payment Card Information*
  • Driving license information
  • E-mail address
  • Reported allegations of fraud, theft, and similar criminal activities


*We encrypt all PCI-related information, such as payment card holder number and name.

Using Your Personal Data

Our uses as a data controller

When we are the controller of your Personal Data, we collect and process your Personal Data for one or more of the following purposes:

  • Providing, activating and managing your access to and use of the Services, where applicable;
  • Processing and fulfilling a request, order, download, subscription or other transaction related to the Services, including a request for your Return Activity Report;
  • Responding to your requests, inquiries, comments and concerns about the Services;
  • Identifying usage trends and developing data analysis, including for purposes of research, audit, reporting and other business operations, including determining the effectiveness of our services and evaluating our business performance, or in other ways pursuant to a customer agreement;
  • Complying with our legal obligations, resolving disputes, and enforcing our agreements.

Where we need to collect and process Personal Data by law, or pursuant to a request you have made to us related to the Services, and you fail to provide that required Personal Data when requested, we may not be able to fulfill the request or comply with our legal obligations.

Our uses as a data processor

When we are the processor of your Personal Data, we may process your Personal Data to enable Retailers to achieve any one or more of the following purposes:

  • Complying with legal and regulatory obligations to conduct due diligence and other screening activities;
  • Conducting risk management activities for which there is a substantial public interest, including the prevention of retail fraud;
  • Providing information that may impact a Retailer’s organization, brand, or customer base;
  • Enabling informed commercial and business risk decisions.

Legal Bases For Collection And Processing of EU Personal Data

When we collect or otherwise process any Personal Data within the scope of data privacy laws and regulations applicable to the EU, including but not limited to the General Data Protection Regulation (GDPR) (EU) 2016/679, we do so where necessary under the following legal bases:

  • To provide one or more Services, fulfill a transaction or otherwise perform a contract with you or at your request prior to entering into a contract;
  • To comply with applicable laws or other legal obligations;
  • For the performance of a task carried out in the public interest;
  • To enable Retailers to comply with their legal obligations;
  • Where applicable, with your consent; and/or
  • To operate our business, protect the security of our systems, customers and users, detect or prevent fraud, or fulfill our other legitimate interests, except where our interests are overridden by your privacy rights.


Where we rely on your consent to process Personal Data, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.

Sharing Your Personal Data

The Retail Equation is absolutely committed to protecting the confidentiality of your Personal Data, including your history of purchases and returns contained in your Return Activity Report. We never share your Personal Data with anyone else unless absolutely necessary to perform the Services or to comply with our legal obligations, as in the circumstances described below.

Employees and Service Providers

Depending on the Services provided, we may share Personal Data with the following recipients and under the following circumstances:

  • Our contracted service providers, which provide services such as IT and system administration and hosting, research and analytics, customer support and data enrichment.
  • Employees and departments of The Retail Equation and its affiliated entities for the delivery of the Services, to the extent necessary to fulfill a request you have submitted via our websites, or for customer support, technical operations and account management purposes.

Legal Purposes

We also may also disclose your Personal Data with third parties if we have a good faith belief that such disclosure is necessary to:

  • meet any applicable law, regulation, legal process or other legal obligation;
  • detect, investigate and help prevent security, fraud or technical issues;
  • protect the rights, property or safety of The Retail Equation, our users, employees, affiliates, or others; and/or
  • as part of a corporate transaction, such as a transfer of assets to or an acquisition by or merger with another company.

Data Retention

Where The Retail Equation collects and controls your Personal Data, we may retain your Personal Data for a period of time consistent with the original purpose of collection. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of your Personal Data, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means, as well as the applicable legal requirements (such as applicable statutes of limitation).

Where The Retail Equation processes your Personal Data on behalf of a Retailer, the applicable retention period is usually determined by contract with the Retailer. We will usually retain your Personal Data as long as it is needed to fulfill the purpose of the contract, and, where applicable, will delete your Personal Data upon expiration of the contract, if not earlier. However, we may retain your Personal Data for a variable period of time consistent with the original purpose of collection, up to and including indefinite retention where appropriate and permissible.

Upon the expiration of any retention periods, your Personal Data will be deleted in a manner conforming to applicable laws, including but not limited to the General Data Protection Regulation (GDPR) (EU) 2016/679 and the UK Data Protection Act 2018 (DPA), regarding the disposal of such Personal Data. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, including such information stored in any offsite or otherwise archival databases to which access is limited, we will put in place appropriate measures to prevent any further use of such Personal Data.

Locations of Processing Personal Data

Your Personal Data may be stored and processed in your region or another country where The Retail Equation, its affiliates, and their vendors and service providers maintain servers and facilities, including but not limited to the US, Poland, India, and the UK.

Therefore, your Personal Data may be processed outside the European Union (“EU”) and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection as in the EU. In this event, we will ensure that such recipient offers an adequate level of data protection — for instance, by entering into “Standard Contractual Clauses” — for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

Children’s Privacy

Our websites, apps, and mobile platforms are not directed at children. The Retail Equation does not knowingly collect or process Personal Data from children under the age of 13, and we do not target our websites, apps, or mobile platforms to children under the age of 13. Where a child is between the ages of 13 and 16 years, The Retail Equation will only undertake the collection or processing of his or her Personal Data if and to the extent that consent is given or authorized by the holder of parental responsibility over the child.

Your Data Subject Rights

If you are located in the EU, you have the right under European and certain other privacy and data protection laws, as may be applicable, including the General Data Protection Regulation (GDPR) (EU) 2016/679, and subject to certain exceptions and limitations, to request free of charge:

  • access to your Personal Data;
  • rectification or erasure of your Personal Data;
  • restriction of our processing of your Personal Data, or to object to our processing; and/or
  • portability of your Personal Data.

How to exercise your rights with a Retailer regarding Personal Data

If your Personal Data has been provided to The Retail Equation by a Retailer, and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the Retailer directly. As mentioned above in this Consumer Privacy Notice, the Retailer is the controller of your Personal Data, and as processor, The Retail Equation is restricted by law from performing any actions regarding your Personal Data other than as directed by a Retailer. If you are an employee of a Retailer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information.

How to exercise your rights with The Retail Equation regarding Personal Data

If you have directly provided your Personal Data to The Retail Equation in connection with our Services, you may contact us in accordance with the “Contact Us” section below. An example of directly providing information to us may include where you have directly provided your contact information to a customer service representative of The Retail Equation in connection with a request for more information, or a copy of your Return Activity Report. We are enhancing our existing online request portal to handle these requests and will also accept emails sent to Info@TheRetailEquation.com. If you are located in the EU, we will comply with the GDPR requirement to provide information without undue delay and, in any event, normally within one month of receipt of the request. We will contact you if we need additional information from you in order to process your request. Depending upon the complexity of your request and the overall number of requests we receive, it may take us longer than one month.

Data Privacy and Security

The Retail Equation implements a variety of data privacy and security measures, including organizational, technical, and physical measures, which are designed to protect the integrity, confidentiality, and availability of your Personal Data. While we follow generally accepted standards to protect Personal Data, no method of storage or transmission can be totally secure. You are solely responsible for protecting your password, limiting access to your computer and mobile devices, and signing out of websites, apps, and mobile platforms after your sessions. If you have any questions about the security of our websites, apps, or mobile platforms, please contact us at Info@TheRetailEquation.com.

Changes to this Privacy Policy

We will update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, and other factors. If we do, we will post the revised version here with an updated revision date. We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing and sharing of your Personal Data.

Contact Us

You may dispute the accuracy or completeness of any information contained in your Return Activity Report. To do so, please submit a written request to us and reference the transaction number for the return(s) you wish to dispute as listed in your Return Activity Report. Please mail your request to either of the following mailing addresses:

The Retail Equation/RAR
Box 112
155 Minories
London
EC3N 1AD
United Kingdom
Phone: +44 (0)800-689-0283

Or

The Retail Equation/RAR
Attn: RAR Administrator
P.O. Box 51373
Irvine, CA 92619-1373, USA

You may also contact our Customer Service toll free at +44 (0)800-689-0283. You can also visit our website at www.theretailequation.com, or send an e-mail to returnactivityreport@theretailequation.com.

If you have questions regarding this Privacy Policy or our privacy practices, please contact us at Info@TheRetailEquation.com, or write to us at either of the above mailing addresses.

The Retail Equation is a division of Appriss Inc., a Delaware corporation with headquarters in Louisville, Kentucky, USA. Our company is absolutely committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EU, you have the right to lodge a complaint with the competent supervisory authority.