Privacy Policy

This Privacy Policy explains how information about you is collected, used, protected and disclosed by The Closet Trading Company or its affiliates or authorized operators (collectively, “The Closet Trading Co,” “our,” “we” or “us”). This Privacy Policy applies to information we collect when you use our website, and other online products and services, or when you interact with us in person at one of our stores (collectively, the “Services”).

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the bottom of the policy and, in some cases, we may provide you with additional notice, such as adding a statement to our homepage or sending you an email. We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

THE COLLECTION OF INFORMATION.

INFORMATION YOU PROVIDE

We collect information you provide directly to us or through our service providers. For example, we, or a third party acting on our behalf, collect information when you create an account, place an order or make a purchase, fill out a form, participate in contests, promotions or surveys, apply for a job, inquire about becoming an authorized operator (including, but not limited to, a franchisee), contact us about potential real estate locations, host a charity fundraiser at one of our stores or request charity donations from us, engage with us via third party social media sites, request customer support or otherwise communicate with us.

THE DIFFERENT TYPES OF INFORMATION WE MAY COLLECT

Your name, email address, phone number, postal address, ZIP code, birth date, The Closet Trading Company account username and password, Consignor Access, photographs, social media usernames; if you are applying for employment, your résumé information, such as employment and education history;

if you are inquiring about becoming our authorized operator, your net worth and relevant business operation experience;

if you are requesting our participation in a fundraising event or seeking charity donations from us, name and address of the charity organization, event details and tax-exempt ID; or any other information you choose to provide.

We may collect and store information about your transaction when you place an order or make a purchase through the website, mobile app, or in our stores, such as the items ordered, the transaction amount, the date and location of the store of your order, and limited payment information, such as payment card type, expiration date, and the last four digits of your card number; however, we do not collect or store full payment card numbers and all payment card transactions are processed by our third-party payment processors.

INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SERVICES

When you access or use our Services, we automatically collect certain information, including, but not limited to:

LOG INFORMATION:

We may collect log information about your access and use of our website, including but not limited to, your domain name, the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.

DEVICE INFORMATION:

We may collect information about the computer or mobile device you use to access our Services, such as the hardware model, operating system and version, unique device identifiers, mobile network information, and browsing behavior.

LOCATION INFORMATION:

When your device location identification setting allows, we may collect information about the precise location of your device each time you access or use our website or one of our mobile applications or otherwise configure your settings on your devices to allow the collection of this information. For more details, please see “Your Choices” below.

INFORMATION COLLECTED BY COOKIES AND OTHER TRACKING TECHNOLOGIES:

We and our service providers use various technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, device recognition technologies, and other tracking technologies now and hereinafter developed (“Tracking Technologies”) to collect information about you and our interaction with our Services or e-mails, including information about your browsing and purchase behavior, and as otherwise described in this Privacy Policy, including in Section 5.

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience on these Services, see which areas and features of our Services are popular and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Your Choices” below.

IN-STORE CAMERAS

We use in-store cameras for security purposes and for operational purposes such as improving the customer experience.

INFORMATION WE COLLECT FROM OTHER SOURCES

Certain functionalities on the Services permit interactions that you initiate between the Service and certain third-party services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Services and a Third-Party Service; “liking” or “sharing” The Closet Trading Company’s content; logging in to the Services using your third-party service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other third-party services, information you post or provide access to may be publicly displayed on the Services or by the third-party service that you use. Similarly, if you post information on a third-party service that references the Services (e.g., by using a hashtag or handle associated with The Closet Trading Company in social media post), your post may be used on or in connection with the Services or otherwise by The Closet Trading Company. Also, both The Closet Trading Company and the third party may have access to certain information about you and your use of the Services and any third-party service.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

INFORMATION WE COLLECT ABOUT OTHERS

In some cases, we may also collect information you provide about others, such as when you refer someone to our Services (such as for certain promotions), or when you make a purchase for others or specify items for others in your party. We will use this information to fulfill your requests and will not send marketing communications to your contacts unrelated to your requests, unless they separately consent to receive these communications from us.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We may use information about you for various purposes, including, but not limited, to:

provide, maintain and improve our Services, including your in-store, and online experiences;

provide and deliver the products and services you request, process orders, transactions and send you related information, including confirmations and receipts;

send you technical notices, updates, security alerts and support and administrative messages;

investigate and prevent fraudulent transactions and other illegal activities;

respond to your comments, questions, requests and provide customer service;

communicate with you about products, services, offers, promotions, rewards, and events offered by The Closet Trading Company and others, and provide news and information we think will be of interest to you (for information about how to manage promotional communications, please see “Your Choices” below);

monitor and analyze trends, usage and activities in connection with our Services (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;

process and deliver contest and promotion entries and rewards;

link or combine with information we get from others to help understand your needs and provide you with better service;

share information you provide to us during an online or in-store transaction to a third party who will assist us in providing offers and product recommendations that may be of interest to you.

assess and respond to employment, franchise/authorized operator, charity events or donations, or other applications; or

carry out any other purpose for which the information was collected.

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

CHILDREN UNDER THE AGE OF 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us via sb@theclosetsb.net

GENERAL DATA PROTECTION REGULATION (GDPR)

The Closet Trading Company is based in the United States, and as mentioned above, we use Shopify to power our online store and as such we are subject to the Shopify Data Processing Addendum (“Addendum”) amends the Shopify Terms of Service (the “Agreement”) by and between The Closet Trading Company and Shopify Inc., a Canadian corporation with offices at 150 Elgin Street, Suite 800, Ottawa, ON, K2P 1L4, on behalf of itself, its Singaporean affiliate Shopify Commerce Singapore PTE. LTD., and its Irish affiliate Shopify International Ltd. (collectively “Shopify”).

If you are located in the European Economic Area (EEA), please note that The Closet Trading Company does not intend to offer goods and services (including the Services) to EEA individuals. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of Personal Information to be processed by Shopify’s Irish affiliate, Shopify International ltd. As part of providing services, this Personal Data may be transferred to other regions, including to Canada and the United States. Such transfers will be completed in compliance with relevant Data Protection Legislation. All parties involved agree to the terms of the Shopify Data Processing Addendum and shall be governed by and interpreted in accordance with the laws of the Province of Ontario and the laws of Canada applicable therein, without regard to principles of conflicts of laws. The parties irrevocably and unconditionally submit to the exclusive jurisdiction of the courts of the Province of Ontario with respect to any dispute or claim arising out of or in connection with this Addendum where you may not have the same rights as you do under the law of the jurisdiction from which you access the Services. For more information you can access the Shopify Data Processing Addendum here: https://www.shopify.com/legal/dpa

Additionally, we note that Shopify generally processes your information in order to fulfill contracts they might have with The Closet Trading Company (for example if you make an order through the Site), or otherwise to pursue legitimate business interests, unless we are required by law to obtain your consent for a particular processing operation. In particular, Shopify processes your Personal Information to pursue the following legitimate interests:

To provide The Closet Trading Company and its Customer’s with their services and applications;

To prevent risk and fraud on the Shopify platform;

To provide communications, marketing, and advertising;

To provide reporting and analytics;

To help The Closet Trading Company find and integrate with apps through our app store;

To provide troubleshooting, support services, or to answer questions;

To test out features or additional services; and

To improve our services, applications, and The Closet Trading Company websites.

When we process personal information to pursue these legitimate interests, we do so where we believe the nature of the processing, the information being processed, and the technical and organizational measures employed to protect that information can help mitigate the risks to the data subject.

For more information about how your data is processed, visit: https://www.shopify.com/legal/privacy

The Closet Trading Company is not responsible for, and makes no representations regarding, the policies or business practices of third parties (including where information is maintained and processed), including, without limitation, service providers and third-party services (including Social Features) associated with the Services.

For additional GDPR requests or tools, please visit our GDPR Compliance page to rectify, view, and download the data we store for you.

SHARING OF INFORMATION

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above.  For example, we use Shopify to power our online store–you can read more about how Shopify uses your Personal Information here:  https://www.shopify.com/legal/privacy.  We also use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout.

We may share information about you as follows or as otherwise described in this Privacy Policy:

with our affiliates, subsidiaries and authorized operators to provide products and services you request and to support our business function and authorized operator network;

with third-party vendors, consultants and other service providers who need access to such information to carry out work on our behalf;

in response to a request for information if we believe such disclosure is required to comply with any applicable law, rule, regulation or legal process; or to otherwise protect our rights

if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of The Closet Trading Company or others;

in connection with, or during negotiations of any merger, acquisition, transfer, liquidation, restructure, sale of company assets, listing of our securities with a securities exchange, financing, reorganization, or acquisition of all or a portion of our business by another company; and

with your consent or at your direction.

We may also use and share aggregated or de-identified information, which cannot reasonably be used to identify you.

BEHAVIORAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

COMMON LINKS INCLUDE:

FACEBOOK – https://www.facebook.com/settings/?tab=ads

GOOGLE – https://www.google.com/settings/ads/anonymous

BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:  https://optout.aboutads.info/.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

SOCIAL SHARING

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We may allow others to serve advertisements on our behalf across the Internet and to provide analytics services. Some information about your use of the Services and certain third-party services may be collected using Tracking Technologies across time and services, and used by The Closet Trading Company and third parties (including our service providers) for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Services and certain third-party services. These entities may use Tracking Technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by The Closet Trading Company and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit aboutads.info/choices.

We may also work with third parties to serve you ads as part of a customized campaign on third-party platforms (such as Facebook, Instagram or Twitter). As part of these ad campaigns, we may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and to serve you advertisements customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized advertisements.

SECURITY

The Closet Trading Company takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Shopify, the data processor encrypts data sent to and from merchants and customers using the HTTPS protocol. Shopify also encrypts any sensitive stored information, and salts and hashes merchant and customer passwords using bcrypt.

The Closet Trading Company may also set up additional security features such as Enabling multi-factor authentication for staff. Define, to a certain extent, what personal data is collected from customers. View certain activity logs, including recent login activity by staff. Set role-based permissions for staff accounts.

The Closet Trading Company has picked Shopify as a web platform due to the robust, cross-functional organizational measures taken for data protection. Consisting of Internal Security, Legal, Operations, Production Security, and Processing Integrity.

SECURITY STANDARDS AND CERTIFICATIONS

The Closet Trading Company, and all online stores powered by Shopify are Level 1 PCI-DSS compliant.

Shopify uses third-party data centers with industry-standard certifications.

Examples include: Tier III, ISO 27001, PCI-DSS SOC reports for all facilities, which include physical protections and can be provided to The Closet Trading Company on request under an appropriate NDA.

Shopify performs annual audits to ensure our handling of your credit card information aligns with industry guidelines. Additionally, the Shopify platform is audited annually by a third-party qualified security assessor.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your personal information.

YOUR OPTIONS.

Account Information. You may update, correct or delete account information at any time by logging into your account. If you wish to deactivate your account, please send an email to sb@theclosetsb.net, and include your name, account name (if different), contact information, and a request to deactivate your account. Please note, however, that we may retain certain information that you provide through our Services as required or permitted by applicable law. We also may retain cached or archived copies of information about you for a certain period of time.

COOKIES AND OTHER TRACKING TECHNOLOGIES

YOUR OPTIONS

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to web sites you visit. Like many online services, we currently do not alter our practices (that is, honor the do-not-track signal) when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit https://allaboutdnt.com/, but we are not responsible for the completeness or accuracy of this third-party information.

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

You may choose whether to receive some interest-based advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us, and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit https://optout.aboutads.info/ for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/.

Please be aware that, even if you can opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective.

The Closet Trading Company is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

LOCATION INFORMATION

When you first or visit one of the pages on our website that collect location information, you may be asked to consent to the collection of location information. If you initially consent to our collection of location information, you can later stop this collection by changing the settings on your mobile device or Internet browser. If you do so, certain features of our Services may no longer function as intended.

PROMOTIONAL COMMUNICATIONS

You agree that we may send promotional and non-promotional notifications or alerts to you, including to your mobile device. You may opt out of receiving promotional communications from us by sending a letter to The Closet Trading Company at 2708 Main St, Santa Monica, CA 90405 (Attention: Customer Service) or in a manner that may otherwise be provided for in those communications or, if permitted through functionality, by editing the preferences of your account. If you opt out, we may still send you non-promotional communications, such as those about your account, your transactions or our ongoing business relations.

YOUR CALIFORNIA PRIVACY RIGHTS.

We provide California residents with the option to opt-out of sharing “personal information” as defined by California’s “Shine the Light” law with third parties, including The Closet Trading Company affiliates or our authorized operators, for such third parties’ own direct marketing purposes. California residents may exercise that opt-out, and/or request information about The Closet Trading Company’s compliance with the Shine the Light law, by sending a letter to The Closet Trading Company at 714 State St, Santa Barbara, CA 93101 (Attention: Customer Service). Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that The Closet Trading Company is only required to respond to one request per customer each year.

In addition to the rights in this section, California residents have certain rights under the California Consumer Privacy Act. Please see below for our CCPA Privacy Notice.

Any California residents under the age of eighteen (18) who have registered to use the Services, and who posted content or information on the Services, can request removal by contacting The Closet Trading Company at 2708 Main St, Santa Monica, CA 90405 (Attention: Customer Service). Requests must include “California Privacy Rights Request” in the first line of the description and include your street address, city, state, and ZIP code. Requests must detail where the content or information is posted and attesting that you posted it. The Closet Trading Company will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that The Closet Trading Company does not control.

YOUR NEVADA PRIVACY RIGHTS

Under Nevada law, Nevada residents may opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we don’t have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, please contact info@theclosetsb.net and provide your name and email address, in an e-mail with “Nevada Data Privacy” in the subject. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our plans change. At that time, we will create a process for verifying your identity and providing an opportunity to verified consumers to complete their opt-out. Please become familiar with our data practices as set forth in this Privacy Policy. We may share your data as explained in this Privacy Policy, such as to enhance your experiences and our services, and those activities will be unaffected by a Nevada do not sell request. You may also have other choices regarding our data practices as set forth elsewhere in this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at info@theclosetsb.net.

CALIFORNIA CONSUMER ACT PRIVACY NOTICE

This California Consumer Act Privacy Notice (“CCPA Notice”) applies to “Personal Information” we have collected about “Consumers” as a “Business”, as each of those terms is defined by the California Consumer Privacy Act (“CCPA”) in California.

We collect and share the following categories of Personal Information from the corresponding sources and for the corresponding purposes set forth in the table below.