PRIVACY POLICY OF RETURN QUEEN

Thank you for visiting Return Queen. It is our mission at Return Queen to make commerce easier and more efficient. We value and respect your privacy and are committed to protecting you through our compliance with this Privacy Policy. We at Return Queen created this Privacy Policy to give you confidence as you visit and use the Return Queen mobile application and website (the “Return Queen Platforms”).

Return Queen is owned and operated by Return Queen LLC. As explained below, we collect information from you (“you” “your” “consumer” or “visitor”) in various ways when you interact with the Return Queen application,website, and our other online services (collectively “Return Queen”).

By utilizing Return Queen, you agree to the terms set forth below in this policy. If you do not wish to agree to this Privacy Policy, you must refrain from using Return Queen. This policy may change from time to time. Your continued use of Return Queen after changes are made to this Privacy Policy is deemed to be acceptance of those changes. We will notify you, as the consumer, anytime changes or updates are made to the Privacy Policy.

I. Summary

As a consumer, you are free to explore Return Queen without providing any Personal Information, as defined below, about yourself, however, this may limit your ability to receive certain information from Return Queen and may limit access to Return Queen. To access certain features of Return Queen – you must first complete member registration where we may ask for certain Personal Information, as defined below.

When signing up for a Return Queen account you will be asked first to submit Personal Information such as location, age, and gender. Return Queen may also request, at your election, further information, including, without limitation, product photos, a profile picture, app usage reports, purchase history, and return history.

II. What Types of Information Does Return Queen Collect

“Personal Information”

Personal Information refers to any information that you voluntarily submit to Return Queen that directly or indirectly relates to, identifies, could reasonably be linked to, or describes a particular individual. Personal Information includes, but is not limited to; name, e-mail address, physical address, phone number, birth date, etc. Return Queen collects Personal Information when you sign up for an account, send us an email, or engage in a transaction through Return Queen, as well as information to which may also be contained on server logs, such as your Internet protocol (“IP”) address.

Personal Information can also include information about any transactions that you enter into with Return Queen, and information about you that is available on the Internet, such as from Facebook, LinkedIn, Twitter, and Google, or publicly available information that we acquire from service providers.

“Non-Personally Identifiable Information”

Return Queen may also collect Non-Personally Identifiable Information when you use Return Queen. Non-Personally Identifiable Information is information which, by itself, cannot be used to identify or contact you. Non-Personally Identifiable Information which we store may include, without limitation, website pages viewed, site visited before coming to the Return Queen website, browser type, operating system, device type (mobile, tablet or desktop), organization name, articles, presentation, and videos viewed, time spent viewing Return Queen website or using certain features of the website, demographic data such as server locations clickstream data, cookies existing on your computer, search criteria used and results, date and time of access or visits to the Website, frequency of visits to the Website, connection speed, and other information through automated tracking technologies, some of which are discussed below, and Return Queen may combine this automatically-collected information with other information Return Queen collects about you. Return Queen does this to improve the services it offers and to improve Return Queen services.

“Navigational Information”

Information collected automatically through Return Queen can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to Return Queen such as your IP address, geographical location, browser type, referral source, length of visit, and pages viewed.

“Third Party Information”

Return Queen may at times collect information and/or Personal Information from a third-party company that you have ordered from and are returning to. We may at times transfer information we have collected about and from you to third parties.

III. How Return Queen Collects Information

Return Queen collects information about you, as a consumer, when you voluntarily provide it through the App and Website, or in the manner such as those described below:

  • Web Beacons. Some pages of the Return Queen may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages of Return Queen and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Cookies (or browser cookies). A cookie is a small text file placed on the hard drive of your computer. You may refuse to accept cookies by activating the appropriate “Do Not Track” setting on your browser or delete or “flush” all cookies stored on your device. However, if you select this setting or delete all cookies you may be unable to access certain parts of Return Queen or certain features of Return Queen will be disabled. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to Return Queen. Cookies placed on your computer by Return Queen are called “first-party” cookies, and those placed by third parties would be “third-party” cookies. Return Queen uses cookies for authentication, session management, and personalization of your experience.
IV. How Return Queen Uses Information

Return Queen may process Personal Information relating to you if one of the following applies:

  • You have given your consent to Return Queen for one or more specific purposes. Under some legislations, Return Queen may be allowed to process Personal Information until you object to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Information is subject to European data protection law, where you must explicitly agree to the processing of your Personal Information.
  • Provision of Personal Information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
  • Processing is necessary for compliance with a legal obligation to which Return Queen is subject;
  • Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Return Queen;
  • Processing is necessary for the purposes of the legitimate interests pursued by Return Queen or by a third-party.

In any case, Return Queen will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

V. Purpose of Processing Personal Information

Personal Information concerning you is collected in order to allow Return Queen to provide its services, as well as for the following purposes: contacting you, analytics and managing contacts and sending messages, and processing and fulfilling your order(s).

  • Analytics. The services contained in this section enable Return Queen to monitor and analyze web traffic and can be used to keep track of visitor behavior.
  • Contacting You. Return Queen may use your information for notification and reminders such as:
    • Mailing Lists or Newsletters. By subscribing to the mailing list or for the newsletter, your email address will be added to the contact list of those who may receive email messages containing information of commercial or promotion nature concerning Return Queen. Your email address might also be added to this list as a result of signing up for an account with Return Queen or after making a payment to Return Queen.
    • Contact Form or Emails. By providing contact information on a contact form or email to Return Queen, you authorize Return Queen to use these details to reply to requests for information, quotes, or any other kind of request in your email and as indicated by the form’s header.
    • Managing Contacts and Sending Messages. This type of service makes it possible to manage a database of email contacts, phone contacts, or any other contact information to communicate with you. These services may also collect data concerning the date and time when the message was viewed by you, as well as when you interacted with it, such as by clicking on the links included in the message.
    • Platform Services and Hosting. These services have the purposes of hosting and running key components of Return Queen, therefore allowing the provision of Return Queen from within a unified platform. Such platforms provide a wide range of tools to Return Queen e.g. analytics, consumer registration, commenting, database management, e-commerce, payment processing – which require the handling of Personal Information. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Information is stored.
    • Selling Personal Information. Return Queen may at times sell your Personal Information, and other gathered information on you, to third parties in an anonymized form. Return Queen’s purpose of selling such information is to provide a benefit and reward to you and other Return Queen users. We use this information to help improve our services. Any Personal Information we sell shall be information you have previously agreed to share with Return Queen. Any Personal Information you agree to share with Return Queen, you also agree to sell to Third Parties. If you wish to opt-out then please notify Return Queen at the following “Do Not Sell My Personal Information” link here.
    • Aggregate Consumer Information. Return Queen may at times, sell “Aggregate Consumer Information” which is information relating to a group or category of consumers, from which individual consumer identities have been removed and is not linked or reasonably linkable to any consumer or household. Return Queen may sell Aggregate Consumer Information without your consent.
VI. Who does Return Queen Share Information With

Return Queen may share your information, including Personal Information as follows:

Service Providers. At times, Return Queen may disclose the information collected from you to a third party or other service provider. Return Queen utilizes third parties and service providers to help achieve our purpose and render services offered. The third parties and service providers, in order to benefit Return Queen, are allowed to access Personal Information stored with Return Queen in order to perform their functions and for no other purpose.

Commercial Partners and Third Parties. Return Queen may, in connection with its services, disclose and sell your Personal Information you provide to us, such as demographic information, to commercial partners and third parties as well as other types of information collected. Return Queen will ensure that all safety steps are taken to ensure that your information is protected and kept secure.

Affiliates. Return Queen may disclose the Personal Information to corporate affiliates or subsidiaries, their use, and disclosure of Personal Information is subject to this Privacy Policy.

Mergers. In the event of a merger with another company, or Return Queen is acquired by another company, we may transfer the information we have collected to the other company.

Protection. Return Queen may disclose collected Personal Information where it is reasonably necessary to investigate, prevent or take action regarding illegal activities, including but not limited to, fraud, threats to the safety of a person, or violations of this Privacy Policy or our Terms of Service.

VII. Where Information is Processed and Stored

Your information may be stored and processed on our servers located in the United States. Data is processed at the operating office of Return Queen and any other places where the parties involved in the processing are located. Any corporate affiliates or third parties your information is provided or sold to may additionally store your information on their servers either in the United States or another Country.

Depending on your location, data transfers may involve transferring your Personal Information to places other than your own. To find out more about the place of processing and storing of such transferred Personal Information, you can check the section containing details about the processing of Personal Information.

You are also entitled to learn about the legal basis of data transfers of Personal Information to a country outside the European Union or any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by Return Queen to safeguard your Personal Information.

If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with Return Queen using the information provided in the contact section.

Retention of Personal Information

Personal Information shall be processed and stored for as long as required by the purpose it has been collected for. Therefore, personal information collected for purposes related to the performance of a contract between Return Queen and you shall be retained until such contract has been fully performed and, personal information collected for Return Queen’s legitimate interests shall be retained as long as needed to fulfill such purpose. You may find specific information regarding the legitimate interests pursued by Return Queen within the sections of this Privacy Policy or by contacting Return Queen.

Return Queen may be allowed to retain Personal Information for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, Return Queen may be obliged to retain Personal Information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, all Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period.

VIII. Your Rights and Data Protection

You may exercise certain rights regarding your Personal Information processed and retained by Return Queen. In particular, you have the right to:

  • Be informed. You have the right to know what rights and protections are offered to you as a consumer and/or user of Return Queen.
  • Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information.
  • Object to processing of your data. You have the right to object to the processing of your Personal Information if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access your Data. You have the right to learn if your data is being processed by Return Queen, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
  • Verify and Seek Rectification. You have the right to verify the accuracy of your Personal Information and ask for it to be updated or corrected.
  • Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of your data. In this case, Return Queen will not process your data for any other purpose than storing it.
  • Have your Personal Information deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your Personal Information from Return Queen.
  • Receive your Data and have it transferred to another controller. You have the right to receive your data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on your consent, on a contract which Return Queen is part of, or on pre-contractual obligations thereof.
  • Lodge a complaint. You have the right to bring a claim before their competent data protection authority.
  • Not to be subject to automated decision-making including profiling.

Details about the right to object to Processing.

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Return Queen or for the purposes of the legitimate interests pursued by Return Queen, you may object to such processing by providing a ground related to their particular situation to justify the objection.

You must know that, should your Personal Information be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether Return Queen is processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise your rights can be directed to Return Queen through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by Return Queen as early as possible and always within one month. However, Return Queen may refuse or charge for any request that is unfounded or excessive. Return Queen will notify You of the refusal and the basis of that refusal and that you will have the right to complain to the supervisory authority and seek a judicial remedy within one month of the request.

IX. Data Breaches and Data Security

Return Queen takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of data. Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Return Queen, in some cases, data may be accessible to certain types of persons in charge involved with the operation of Return Queen (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary as Data Processors by Return Queen. The updated list of these parties may be requested from Return Queen at any time.

Return Queen safely secures Personal Information from misuse, unauthorized access, and disclosure and loss by ensuring a level of security appropriate to the risk of information. Such levels of security include encrypting and pseudonymizing personal data wherever possible and considering all other technical and administrative procedures, generally accepted practices in the industry. Personal Information is additionally stored on secured servers.

However, despite Return Queen’s best efforts, nothing can guarantee 100% security of your information. If you have any questions concerning the protection of your Personal Information, please contact Return Queen.

In the event of a data breach, Return Queen will notify the corresponding supervising authority within seventy-two (72) hours of learning of the breach or after 72 hours with an explanation for the delay, to the supervising authority.

X. Sensitive and Restricted Scopes for Google and other Similarly Situated Hosts

Certain web hosts, such as Google, require the use of scopes in order to access user data hosted on their platforms (“Restricted Scope Data”). In order for the Return Queen Application to function at its best, Return Queen uses Restricted Scope with Google and other similarly situated hosts. Accordingly, Return Queen:

  1. Represents that Return Queen seeks access to user data and has obtained client authorization through this Privacy Pliicy.
  2. Limits the use of data and does not use or transfer data for ads, in any way, and will not use the Restricted Scopes data for serve advertisements.
  3. Return Queen will only transfer Restricted Scopes Data if that transfer is: (a) necessary to provide or improve user-facing features that are prominent from the Return Queen App interface, (b) to comply with applicable laws or (c) a part of a merger, acquisition or sale of assets of Return Queen.
  4. Only uses the data gathered from Restricted Scopes to improve user-facing features, such as managing returns, and
  5. Will not allow humans to read the data unless first obtaining a user’s affirmative agreement (i.e. tech support); it is necessary for security purposes; necessary to comply with applicable law or the use of such data is limited to internal operations and data has been aggregated and anonymized.

Return Queen adheres to strict security practices and agrees to pass an annual security assessment as well as obtain a Letter of Assessment from a designated third party.

Return Queen agrees that it will not engage in any activity that may deceive or mislead either user of the Return Queen Platforms or Web Host, such as Google.com, as to the Return Queen Services.

XI. Miscellaneous

In addition to the information contained in this Privacy Policy, Return Queen may provide you with additional and contextual information concerning particular services or the collection and processing of Personal Information upon request.

California Consumers

California Civil Code Section § 1798.83 permits users of Return Queen that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. You make two requests per 12-month calendar year. To make such a request please see below Contact Information for Return Queen. Please allow up to thirty (30) day response.

Children’s Privacy Policy

Return Queens complies with all applicable laws, codes, and regulations related to the protection of children’s privacy, including, but not limited to the Children’s Online Privacy Protection Act of 1998 (COPPA). Return Queen is not intended for children under sixteen (16) years of age. No one under such age may provide information to Return Queen. We do not knowingly collect personal information from anyone under the age of 16. If you are under the age of 16 please do not provide any Personal Information to Return Queen. If we learn that we have collected or received Personal Information from an individual under 16 without verification of parental consent, we will delete that information. Please feel free to contact us if you believe we may have any information from or about an individual under the age of 16.

XII. Contact Information

If you wish to contact Return Queen with questions or comments about this Privacy Policy or privacy practices or, wish to exercise any of your rights detailed in the above Privacy Policy, please contact us at:

Return Queen LLC

581 Franklin Turnpike

Ramsey, New Jersey 07446

www.returnqueen.com

1-888-787-3027

V2 Updated 12/01/20

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