Powder Lab Inc. owns and operates Closet Cycle, a Website providing users with a variety of resources to facilitate peer-to-peer sharing, lending, borrowing and renting of goods and services. This “Privacy Policy” describes the privacy practices of Powder Lab, Inc., and our subsidiaries and affiliates (collectively, “Closet Cycle”, “we”, “us”, or “our”) in connection with the closetcycle.com, and any other website or mobile application that we own or control and which posts or links to this PrivacyPolicy (collectively, the “Website”), and the rights and choices available to individuals with respect to their information. Closet Cycle may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

Closet Cycle understands that your information is very important to you therefore we will not share any of your personal information with other parties unless you specifically consent to it. To obtain the highest security for processing payments, we use stripe (www.stripe.com) to process your credit card transactions. We do not store any of your credit card information.

 If you have any questions, please contact us by sending an email to hello@closetcycle.com.

• Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, and company name.
• Content you choose to upload to the Website, such as text, images, audio, and video, along with the metadata associated with the files you upload.

• Any information you voluntarily share with Closet Cycle , such as by text message, email, through the mobile application, or through the website. If you are a Lender, we may also collect information about the items you choose to list with us. You may also have the opportunity to share your social media profile (along with associated information) with Closet Cycle.
• Account information, such as your username and password that you may set to establish an online account with us, photographs, clothing and shoe size information, height, and preferences (including, but not limited to, account preferences).
• Feedback or correspondence , such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online, or in any other capacity.
• Financial information, such as your financial account numbers, or bank account or payment card information.
• Transaction information, such as information about payments to and from you and other details related to products or services you have purchased or rented from us, if you are a Renter, or, regarding items you’ve listed on the Website, if you are a Lender.
• Government-issued identification numbers, such as a national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license of state ID number), and an image of the relevant identification card.

• Precise geolocation information, such as when you authorize our mobile application or website to access your location.
• Usage information, such as information about how you use the Website and interact with us, including information associated with any content you upload to the Website, or otherwise submit to us, and information you provide when you use any interactive features of the Website.
• Marketing information, such as your preferences for receiving communications about our Website and future offerings, and details about how you engage with our communications.

• Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from social media platforms. We may maintain pages for the Website on social media platforms, such as Facebook, LinkedIn, Twitter, Google, Instagram, TikTok, Snapchat, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the third-party platform, and we will treat such information in accordance with this Privacy Policy.

If you choose to login to the Website via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Website, we may collect information from that platform or network. For example, this information may include your Facebook, Google, Instagram or Apple username or user ID, or profile picture (as applicable). You may also have the opportunity to provide us with additional information via the third-party platform or network, including, but not limited to, a list of your friends or connections and your email address. You can read more about your privacy choices in the “Third-party platforms or social media networks” portion of the “Your Choices” section.

Information we obtain from other third parties. We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

Web browsers may offer users of our Website the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Website may not function correctly. 

Referrals

Users of the Website may have the opportunity to refer contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

How We Use Your Personal Information:

We may use your personal information for the following purposes and as otherwise described in this Privacy Policy or as described at the time of collection:

To operate the Website. We may use your personal information to:

• provide, operate and improve the Website;
• provide information about our products and services;
• establish and maintain your account on the Website;
• facilitate your to login to the Website via third-party identity and access management providers, such as Facebook;
• enable security features of the Website, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Website, including by sending you announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events or contests in which you participate;
• understand your needs and interests, and personalize your experience with the Website and our communications;
• provide support and maintenance for the Website, including by providing chat or messaging functionality; and
• to respond to your requests, questions and feedback.

For research and development.We analyze use of the Website to improve the Website and to develop new products and services, including by studying your use of the Website.

To send you marketing and promotional communications. We may send you ClosteCycle-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketingsection below.

To display advertisements.We work with advertising partners to display advertisements on the Website or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Website or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

To comply with law.We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to:(a)protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Website; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent.In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data.We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Website and promote our business.

We may share your personal information with the following parties and as described in this Privacy Policy:

Affiliates.We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers.We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the Website (such as customer support, payment processing, hosting, analytics, email delivery, marketing, identification checks, and data and/or database management services).

Third-party platforms and social media networks.If you have enabled features or functionality that connect the Website to a third-party platform or social media network (such as by logging in to the Website using your account with the third party or otherwise linking your account with the Website to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Other users of the website and the public.We may provide functionality that enables you to disclose personal information to other users of the Website or the public. For instance, you may be able to maintain an account with information about yourself or the entity you register that you can make available to other users or the public. You may also be able to submit content to the Website (such as comments, reviews, photos, and videos), and we may display your name, username, and a link to your user profile along with the content you submit. We may make available settings through the Website that enable you to exercise choice regarding certain information that is displayed publicly or to other users. We do not control how other users or third parties use any personal information that you make available to such users or the public.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety.We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

In this section, we describe the rights and choices available to all users.

Access or update your information.If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account. You may also have the opportunity to delete your account, or certain portions thereof, through the settings in your account on the Website.

Opt out of SMS communications. If you provide your phone number to us, Closet Cycle may send you notifications by SMS. You may opt out of SMS communications by texting “STOP” to the telephone number or short code we used to contact you.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt out or unsubscribe instructions at the bottom of the email, or by contacting us at hello@closetcycle.com You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message. You may also text STOP to the telephone number or short code we used to contact you.

Cookies & browser web storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Website and third-party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Website may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

Privacy settings and location data.We may make available certain privacy settings on the Website. Users of our Website may also choose whether to allow us to access your precise location data. Your device settings may provide the ability for you to revoke our ability to access location data.

Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Website may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide our services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive our services by designating it as required at the time of collection or through other appropriate means.

Third-party platforms or social media networks.If you choose to connect to the Website via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third party at the time you login to the Website using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.

The website may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third-party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

We are headquartered in the United States and may have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

As a general rule, children are not allowed to use the Website, and we do not collect personal information from them. We define "children" as anyone under 13 years old. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us.

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Website. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email (if you have an account where we have your contact information) or another manner through the Website.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Website (or as otherwise indicated at the time of posting). In all cases, your continued use of the Website after the posting of a modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Powder Lab Inc.