dressCODE Privacy Policy
Last Updated: March 9, 2021
dressCODE Inc. (“dressCODE”, “we”, “our”, or “us”) know that the privacy of your information is important to you. This Privacy Policy explains how we collect, use, and disclose your information. It also explains your privacy rights and how you can exercise those rights.
1. Acknowledgment
Your use of any of our Services, Website, and Application indicates your acknowledgement of the practices described in this Privacy Policy. We may update it from time to time, and we will provide notice of any changes if we believe it is necessary and as required by law. We encourage you to periodically review this Privacy Policy for changes. Unless we require your consent, you agree to those updates by continuing the use the Services and Website.
2. Information We Collect
dressCODE provides on-demand wardrobe styling and personal shopping (collectively, our “Services”). We collect Personal Information through the provision of our Services, through our website at thedresscodeapp.com (including any subdomains or versions, the “Website”), and through our mobile application available on the App Store (the “Application”). The information we collect and how we use it varies depending on the relationship we have with you (e.g. whether you are a Client, Stylist, applying for a role with us, or someone else). We will take the necessary steps to ensure your Personal Information is obtained and used in a fair and lawful way.
a. Personal Information: “Personal Information” means information about a person or household that identifies, relates to, describes, is reasonably capable of being associated with, could be reasonably linked with, or could be used to directly or indirectly identify that person or household (or from those and other information either in our possession or likely to come into our possession). It may also include other information that may be associated with Personal Information, such as Generic Information (defined below), location, preferences, or interests, if that information can be used to identify a person, household, or device.
b. Generic Information: “Generic Information” may include information that relates to a person but cannot be used to identify that person, like Website pages viewed and the duration, browser or operating system information, mobile device type, system settings, the language the system uses, the country and time zone where the device is located, and aggregate and/or deidentified data related to a person’s interaction with our Website. In some situations, Generic Information may be combined with other information in a way that identifies a person. In those situations, Generic Information will be treated like Personal Information.
c. Usage and Technical Information: Our Website and mobile application includes features that gather information about how users use it. This assists us with keeping track of preferences, creating a more tailored user experience, and better serving users’ particular interests and needs. We may use “cookies” (small data files stored on a user’s device containing information about the user) and other similar tracking technologies (collectively, “Tracking Technologies”) to collect information automatically as users interact with the Website, the Application, and social networking sites. See below for more information about these Tracking Technologies.
Some of the cookies we use are “strictly necessary” for the functionality of our Website and Application (such as by allowing us to securely serve the Website to you). Others improve the functionality of our Website and Application but are not strictly necessary (such as by gathering analytic data).
Examples of cookies we use include:
Session Cookies: We use Session Cookies to operate our Website. Session cookies are temporary, and are automatically deleted once you close your internet browser.
Preference Cookies: We use Preference Cookies to remember your preferences and various settings. Preference cookies are first party cookies that remain on your computer or device until you delete them or they are otherwise removed upon expiration.
Third-Party Cookies: We permit third-party Service Providers to use cookies or other similar technologies on our Website and Application. These companies may collect your information, track your behavior on our Website and Application, and gather information about your use of our Website, Application, and other online services over time and across different services. Additionally, some companies may use information collected to deliver targeted ads on behalf of us or other companies, including on other websites or online services. We are not responsible for the functioning of cookies and other technologies used and placed by third parties on your device.
d. Personal Information Collected Over the Last 12 Months
The following section describes the categories of Personal Information dressCODE may have collected in the preceding 12 months, the categories of sources from which that information may have been collected, the categories of third parties with whom that information may have been shared, and the commercial purpose for collecting that information. The Personal Information we collect depends on our relationship with you.
3. How We Collect Your Information
dressCODE collects information in a few ways: you voluntarily provide it to us; we obtain it through the provision of our Services, Website, and Application; and we obtain it through third parties.
a. Information You Give Us.
We collect information that you decide to share with us. At times, we may require you to provide certain information, including Personal Information, in order to provide you with Services you request. For instance, we will require you to provide your name, email address, and payment card information when you purchase our Services. We may require you to provide your name, email address, or other contact information when you contact us with a question or comment. In some circumstances, we will not be able to further our relationship with you (for example, to provide you with our Services if you are a client, recruit you, or engage you if you are a potential supplier) without certain Personal Information. We will inform you at the relevant time if this is the case.
b. Information We Obtain through the Use of Our Services, Website, and Application.
We collect certain information from you through your use of our Services, such as records of the Services we have provided to you. We may also collect information about you from our clients’ use of our Services.
Also, we collect information when you use our Website and Application, such as information about the device you use to access, use, and/or log into the Website or Application. We also may collect information through the use of cookies or other technologies, as described above.
c. Information We Obtain from Third Parties.
We may also obtain information about you from third parties, such as those that help us provide our Services to you. We may also obtain public information from sources like the press, public websites, social networking sites, or other databases of public information.
4. How We Use Your Information
We generally use your information for the following business and commercial purposes:
To provide our Services, including to answer any questions or inquiries you make to us, perform a contract with our clients or Service Providers, and provide customer support to you.
To market our Services, including to contact you directly with news about us and our Services, special offers, and other information we believe may be of interest to you if you have agreed to receive such communications. We may also engage in online advertising in which we use your usage and technical information to determine how to place advertisements and provide you with customized content. We may also provide your usage and technical information to a third party for targeting on a third-party platform. Sometimes, these third parties collect this information directly (e.g. a Facebook “Like” button).
For operational purposes related to our Website and Application, including monitoring and analyzing the effectiveness of our marketing activities, debugging and repairing errors that impair the functionality of our Website and Application, and detecting security incident and improving the security of our network.
With your consent, in accordance with that consent. For example, if you make a request through our website that we contact you, we will use the information you provide to evaluate your specific request and contact you.
To comply with applicable laws, in response to a lawful and enforceable request by a law enforcement, judicial, or other public authority, or in connection with an applicable legal obligation.
For another dressCODE business or commercial purpose. For instance, we may use your information to assist with fraud prevention, report suspected criminal activity to law enforcement, and to help prosecute individuals responsible for malicious, deceptive, fraudulent, or illegal activity.
a. How We May Share Information We Collect
dressCODE may share your information, including Personal Information, with third parties depending on the purpose for and context in which you provided the information. We generally share the information with the following types of recipients:
Clients and Stylists: To facilitate the Services, Clients and Stylists may have access to certain information about each other. When a Stylist and a Client are paired, they may be able to see each other’s names, email addresses, photos, and other identifying information. The Stylist may be able to see the Client’s self-described style and links to the Client’s social media accounts, like Pinterest. dressCODE allows Clients and Stylists to exchange text, audio, and video messages between each other within the Application.
Service Providers: We employ third-party Service Providers, companies, individuals, and agents to facilitate and help us provide our Services to you (“Service Providers”). Such Service Providers perform tasks or functions on our behalf, provide Services-related services, or assist us in analyzing how our Services are used or delivered. For instance, we may disclose information to our database and cloud storage providers that help us maintain our Website, Application, and other systems.
These third parties are granted access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Marketers: In order to deliver certain advertisements and develop better Services, we may from time to time provide your information to trusted third parties for marketing, advertising, or similar commercial purposes.
Corporate Transitions: Your Personal Information may be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Information may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
Legal Disclosures: In limited circumstances, we may, without notice or your consent, disclose your Personal Information, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of the terms of use for our Website, Application, and Services, or to protect the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Information as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Information to such parties.
b. Personal Information Shared Over the Last 12 Months
The following section lists the categories of Personal Information dressCODE may have disclosed and the categories of recipients of such information in the preceding twelve months:
5. Opting-Out of Certain Uses of Your Information
a. Marketing and Promotional Materials: At times, you may be presented with the option of whether to subscribe to receive, or be automatically entered to receive, certain marketing and promotional communications from dressCODE. Recipients of such communications can unsubscribe by following the specific instructions included in such communications, including by clicking “Unsubscribe” and following the related instructions.
b. Information that May be Collected by Tracking Technologies: Most browsers are initially set to accept cookies (other than Flash cookies) and allow local storage, but you may be able to set your browser to block or otherwise control what cookies your browser or mobile device accepts via your browser or mobile device settings. Additionally, you can choose to modify your settings and delete those cookies that are otherwise stored on your device at any time. Please consult the instructions provided by your browser or your mobile device’s manufacturer to determine how you can limit the placement of and/or remove cookies or other technologies. Please note, however, that limiting or disabling the use of cookies and other technologies may impact or adversely affect your ability to perform certain transactions on, use certain functionalities of, and access certain content on our Website.
You can manage the use of Flash technologies with the Flash management tools available at Adobe’s website.
c. Do-Not-Track Signals: We do not take action in response to Do-Not-Track Signals. Do Not Track is a preference in some web browsers that is intended to inform websites that you do not want to be tracked. How this feature is used and activated varies from browser to browser. Because there currently is no industry or legal standard for recognizing or responding to Do-Not-Track Signals, we do not respond to them at this time. dressCODE takes your privacy and security very seriously, and we will continue to reassess our Do-Not-Track Policy as technology and related guidance develops.
6. Data Retention
dressCODE will retain your Personal Information only for as long as is necessary to accomplish the purposes set out in this Privacy Policy. We will retain and use your Personal Information to provide our Clients with Services, the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, and as required by essential, internal business needs.
7. Data Transfer
Your information, including Personal Information, may be transferred to, and maintained on, computers located outside of your state, province, country, or other jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside of the United States and choose to provide information to us, your information, including Personal Information, may be transferred to the United States. The United States does not provide the same legal protections as other countries and territories.
If we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a merger or other business transaction, we may transfer your Personal Information to a third party as part of that transaction. If such transaction materially affects the manner in which your Personal Information is processed, we will notify you of such change prior to its implementation.
8. Children’s Privacy
All of our Services, our Website, and our Application are intended for adults, and are not meant to address anyone under the age of 18 (“Children”). As such, Children may not use our Website, Application, or Services. If you are under 18, do not attempt to use Website, Application, or Services, and do not provide us any Personal Information about yourself.
We do not knowingly collect or sell the Personal Information of Children. If you are a parent or guardian and you are aware that your child has violated this Privacy Policy and provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Children without verification of parental consent, we will take steps to remove that information from our systems.
9. Your Rights
dressCODE aims to take reasonable steps to allow individuals from whom it has collected Personal Information to access or delete it. For example:
Access: The information we collect, use, disclose, and sell about you is set out in this Privacy Notice, together with any other specific notices that are provided to you at the time of collection of your Information. Additionally, if you are a Client or Stylist and have set up an account within our Application, you can log in to your account and see all of the information that we have collected about you.
Deletion: If you are a Client or Stylist, you can delete your Personal Information that we have about you from your Account within the Application, or, if you are not a Client or Stylist, you can ask us to delete Personal Information we have about you.
Non-Discrimination: dressCODE does not discriminate in the Services or quality of Services you receive from us for accessing, deleting, or withholding your Personal Information. Please note that we may not be able to provide some Services to you without certain Personal Information; for example, we will not be able to charge your payment card for a service if you withhold your billing address.
Disclosure of Direct Marketers: You can ask us to provide the categories of information we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year; the names and addresses of the third parties that received the information; and if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
10. Contact Us
If you have questions about this Privacy Policy or our practices related to the collection and use of Personal Information, or you need to submit a request to us to access or delete your Personal Information, please contact dressCODE by email: support@thedressCODEapp.com
11. Security
While no data transmission of the internet is 100% secure from intrusion, we maintain reasonable physical, electronic, and procedural safeguards to protect your information. However, it is possible that third parties may unlawfully intercept or access transmissions or private communications despite our efforts to prevent this, and we therefore make no guarantees regarding the security of user information.
12. Third-Party Platforms and Services
The Services, the Website, and the Application may be linked to, rely on, and/or be integrated with websites, applications, interfaces, services, and/or platforms operated by third-party companies, including Service Providers. This Privacy Policy does not govern the practices of third parties, including our partners, third-party Service Providers, and/or advertisers, even when those services are branded as, or provided on behalf of, dressCODE. We are not responsible for the privacy practices of any websites, applications, interfaces, services, and platforms operated by such third parties that you linked to, or that rely on, and/or are integrated with the Services. dressCODE is not responsible for and does not control the security or privacy when you engage with third parties. dressCODE encourages you to visit the privacy notices governing those websites and services.
13. Changes to this Policy
This Privacy Policy is subject to revision. If we make any changes to this Privacy Policy, we will change the “Last Updated” date above.
14. Difficulty Accessing Our Privacy Policy?
Individuals with disabilities who are unable to usefully access our privacy policy online may contact us at the above-listed email address to inquire how they can obtain a copy of our policy in another, more easily readable format.
