Willyou Privacy Policy

Introduction and Overview

This Privacy Policy explains what personal information Willyou.com, Inc.(“Willyou”, “we”, “our” or “us”) collects, why we collect this information, and how we use the information we collect as well as your rights and choices regarding such information. Our Privacy Policy applies to our collection of your information in our stores, on our website, our collection of your information via any channel that you may interact with us, including but not limited to, postal mail, email, phone, live or automated chat, SMS/MMS/text, social media platforms and your use of any Willyou online service location that posts a link to this Privacy Policy and all features, content, and other services that we own, control, or make available via any channel (collectively, the “Services”). For purposes of this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you.

By using the Services or interacting with us offline, you agree to our Terms and Conditions and to our collection, use, and disclosure practices and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Services.

Willyou encourages you to periodically review this Privacy Policy to learn about our privacy practices. If you are a California resident, Nevada resident or data subject in Europe, please see the “Additional Disclosures for California Residents,” “Additional Disclosures for Nevada Residents” and “Additional Disclosures for Data Subjects in Europe” sections. If you have questions or concerns about our Privacy Policy, please contact Willyou as set forth in the section entitled “Contact Us” below.

Information You Provide

We collect Personal Information you provide directly via the Services, including but not limited to when you register for an account, update your profile, access our content, make a purchase, participate in a sweepstakes, contest, survey, or other promotion (“Promotion”), contact customer support, sign up for our text messaging program, or apply for a job. We may use Service Providers (defined below) to collect this information.

• Contact Data. We collect your first and last name, e-mail address, postal address, phone number (and mobile carrier, if you enroll in our text messaging program), and other similar contact data.
• Credentials. We collect passwords and other information for authentication and account access.
• Demographic Data. We collect demographic information including your age, birth month and/or day, gender, and country.
• Payment Data.   We collect data necessary to process your payment if you make a purchase, including your payment instrument number (such as a credit card number or information identifying your financing account), and the security code and expiration date associated with your payment instrument.
• Profile Data.   We collect your interests, favorites, wish lists, ring size preferences, and other profile data.
• Contacts.   We collect data about your contacts in order to fulfill a request by you. For example, when you e-mail a product to a friend or refer a friend through the Services, we request that you provide names and e-mail addresses for you and your friend. This helps ensure that your friend will know that you have requested that Willyou send them an e-mail. The information Brilliant Earth collects from you and your friend will only be used as set forth in this Privacy Policy. By using this functionality, you acknowledge and agree that you have your contacts' consent for us to use their contact information to fulfill your request.
• Content.   We collect the content of messages you send to us, such as feedback and product reviews you write, messages sent through our text messaging program, messages sent through any live or automated chat feature, questions and information you provide to customer support or comments and content that you may post on social media channels. For example, if you contact a customer service representative or jewelry consultant and provide information to the consultant or submit a request through our Services, we will use your information to respond to your request and to provide you with additional information that we believe may be helpful to you. We may also collect content such as photos, videos or other materials that you submit to us. For example, if you use our Virtual Try On feature, we use the photo that you upload and superimpose a resizable rendering of the jewelry you view through the feature, and we enable you to download a copy of the photo or share it with a friend, contact a jewelry consultant about the jewelry, or save the jewelry to your wish list. Any feedback you submit is subject to the terms of this Privacy Policy and the Terms and Conditions.
• Employment Data.   We collect data as necessary to consider you for a job opening if you submit an application to us, including your employment history, resume, transcript, responses to questions listed on our job applications or other forms related to your application for employment, writing samples and references.
• Government Identification Data.   We may collect in certain circumstances other information such as an image of your driver's license or other government issued identification for fraud prevention purposes. We may also collect government issued identification numbers such as your social security number for tax reporting purposes in the event that you win a prize through a Promotion.

You may choose to voluntarily submit other information to us through the Services that we do not request, and, in such instances, you are solely responsible for such information.

Information Collected Automatically

• Service Use Data.   We collect data about the features you use, the pages you visit, the e-mails and advertisements you view, the products you purchase, the time of day you browse, your referring and exiting pages, and other similar information about your interactions with our Services.
• Device Connectivity and Configuration Data.   We collect data about the type of device or browser you use, your device's operating software, your internet service provider, your device's regional and language settings, and other similar information about the means through which you interact with our Services.
• IP Address and Device Identifiers.   Willyou collects your IP address and related location data, and other device identifiers, including mobile advertising identifiers, about the devices you use to interact with our Services. We collect this data for various purposes, including to assess and diagnose problems, improve the functioning of our Services, servers, and hosting providers, as well as to analyze trends and traffic patterns, gather demographic information, track the date, time, and duration of each session within our website, prevent fraud, and customize our Services and advertisements.

• Log Files.   Our servers collect logs that include the above information, which helps us understand website usage and trends.
• Cookies.   “Cookies” are small pieces of information that are stored by your browser on your device's hard drive. We use cookies on certain pages of our Services to, among other things, analyze our web page flow, measure promotional effectiveness, deliver you a more customized shopping experience, track visits from our affiliates and partners, allow users to share pages and content to third-party social networking sites, and enable the use of our shopping cart.
  Willyou uses cookies for various business and commercial purposes, including the following:
  • Necessary Cookies:   These cookies are essential for you to use our Services, such as our shopping bag, as well as to access password protected areas, such as your personal account.
  • Performance Cookies:   These cookies collect information about how you use our Services so that we can measure and improve the performance of our site.
  • Functional Cookies:   These cookies provide enhanced functionality and personalization. They allow us to gather information on how our Services are being used and remember the choices you make (such as your language or location) so that we can provide content that is relevant to you.
  • Targeting and Advertising Cookies:   These cookies help us deliver advertisements that are more tailored to you and your interests, as well as limit the number of times you receive the same advertisement. We also use these cookies to measure the effectiveness of our advertising campaigns. If you sign up for our text messaging program, cookies may be used to customize your experience by sending you personalized text messages such as shopping cart reminders.
• Web Beacons.   We may use electronic images known as web beacons (also known as pixels) on the Services. These pixels are small and invisible images placed on web page that load when the web page loads. When you access a website, video, e-mail, or advertisement that contains web beacon, the pixel will load and may permit us or another party to drop or read cookies on your browser. Pixels are used in combination with cookies to analyze activity by a particular browser on a particular device. We may incorporate pixels from third parties that allow us to analyze conversions, bring you advertising both on and off the Services, and provide you with additional functionality, such as the ability to connect our Services with your social media account.
• Device Fingerprinting.   We may use device fingerprinting, which is the process of analyzing and combining sets of information elements from your device's browser, such as JavaScript objects and installed fonts, in order to create a “fingerprint” of your device and uniquely identify your device and apps.
• Location-Identifying Technologies.   Location-aware technologies may be used to collect precise location data when you enable location-based services through your device. Location data may be used for purposes such as verifying your device's location and delivering or restricting relevant content and advertising based on that location.

Some information about your use of the Services and certain unaffiliated websites or services (described below) may be collected using Online Technologies across time and services and used by us and other parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Services and unaffiliated websites and services.

For further information on Online Technologies and your rights and choices regarding them, see the sections entitled “Other Parties” and “Your Rights and Choices” below.

Information from Other Sources

• Marketing companies from which we license demographic data to supplement the data we collect.
• Social networks when you reference our Services or grant permission to Willyou to access your data on one or more of these services.
• Financing providers with which we offer financing for purchases and financial services providers used for processing payments.
• Partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
• Advertising and marketing partners.
• Publicly-available sources such as open government databases or other data in the public domain.

Use of Information

We may collect and use Personal Information for the business and commercial purposes described in this Privacy Policy. Our business purposes for collecting and using information include to:

• Manage our Services, including your registration, account, and transactions.
• Perform services requested by you, such as to process and fulfill your order, help you visualize how jewelry might look on you through use of our Virtual Try On feature, respond to your comments, questions, and requests, and provide customer service. If you use our Virtual Try On feature, we do not collect, scan, or analyze the geometry or physical characteristics of any subject matter within the photos you upload through the feature, and we do not use such photos to identify you.
• Send appointment reminders and otherwise assist in confirming or scheduling interactions with us.
• Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
• Monitor and analyze trends, usage, and activities regarding our Services.
• Conduct Promotions, including to conduct surveys and/or research on our users' demographics, interests, behavior.
• Improve our marketing and promotional efforts, Service content and product and service offerings.
• Develop and send you direct marketing, including advertisements and communications about our and other party products, offers, promotions, rewards, events, and services, through different channels such as email and SMS/MMS text messaging, to the extent you have opted into such communications as may be required by law. Please see our Terms and Conditions for more information on our SMS/MMS text messaging programs.
• Verify your eligibility and deliver prizes in connection with Promotions you have entered.
• Prevent or take action regarding illegal activities, including suspected fraud; protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); enforce the terms and conditions that govern the Services; and conduct, complete, or respond to audits or audit results.
• Comply with any applicable law, regulation, legal process or governmental request.
• Review and evaluate your applications to work with or for us or otherwise respond to you regarding opportunity inquiries.
• Fulfill any other business or commercial purposes disclosed to you at your direction or with your consent.

We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your Personal Information, please see the section entitled “Your Rights and Choices” below.

Sharing of Information

We may share your Personal Information in accordance with the practices described in this Privacy Policy. The types of entities to whom we may disclose and may have disclosed information within the last 12 months include the following:

• Service Providers.   We share your information with agents, contractors, and other service providers in connection with their work on our behalf (collectively “Service Providers”). Our Service Providers only receive your information if such information is needed to perform their function(s), and they are not authorized to use such information for any other purpose(s) other than the purpose(s) set forth by Willyou. We only provide Service Providers with the information necessary to complete the requested service, product or transaction and contractually prohibit them from retaining, using, or disclosing information about you for any purpose other than performing the services for us. Notwithstanding the above, we may permit our Service Providers to use aggregate information which does not identify you or de-identified data for other purposes.
• Affiliates:   We may share your information with our related entities including our parent and sister companies. For example, we may share your information with our affiliates for business purposes such as customer support, marketing, and technical operations.
• Business Partners:   We may share your information with our business partners in connection with offering you co-branded services, selling or distributing our products, or engaging in joint marketing activities. For example, we may share information about you with a business partner for purposes of providing you with co-branded products or services that we may offer.
• Special Events:   If you choose to participate in a special event (for example, a Promotion), Willyou may share your information with those organizations participating in the applicable event. Typically, these other parties do not use your information for any other purpose other than to manage the event. In some cases, these promotional partners may send you promotional materials regarding their products and services. By entering a Promotion, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness or other submitted content in advertising or marketing materials.
• Feedback, Testimonials and User Provided Content.   If you provide feedback or testimonials on the Services or on Willyou products or services, or provide other user provided content (such as photos or videos), we may post and share this feedback, testimonial or other user provided content, including your information, on the Services, with partners, or in marketing and promotional materials. We may, in our sole discretion, edit feedback, testimonials or user provided content for length and content. If you use our Virtual Try On feature, we also enable you to share content generated through use of the feature with third parties. California residents and data subjects in Europe have additional rights as set forth in “Additional Disclosures for California Residents” and “Additional Disclosures for Data Subjects in Europe” below.
• Facilitating Requests.   We may share your information with other parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Services).
• Vendors and Other Third Parties.   We share information with vendors and other third parties that assist us in operating our business and providing the Services. Our vendors include: web hosting companies, shipping and fulfillment companies (e.g., companies that ship or fulfill product orders), diamond or gemstone suppliers, jewelers, assemblers, insurance companies, data analysis firms, analytics and advertising technology companies (including digital advertising and SMS/MMS text messaging companies), affiliates, customer service providers, consulting or marketing firms/providers, accounting, bookkeeping or legal firms, financial services firms, and technology companies, such as, enterprise application firms, firms which provide technologies to enable electronic, live or automated chat, and SMS/MMS communications, and data storage providers. Additionally, if you use a credit card or other financing alternative to place an order with Willyou, we will use a payment processor to process your payment. We may also share information with other companies and organizations for credit fraud protection and risk reduction. These fraud prevention vendors may use this information to train and improve their products and may combine that information with information they receive from third-party data sources and other clients to assist those clients with the detection and prevention of fraudulent transactions on their platforms.
• Business Transfer.   Your information may be disclosed as part of, or in connection with, any investment in Brilliant Earth, any merger, sale of our assets, or acquisition, as well as in the event of an insolvency, bankruptcy or receivership, in which information would be transferred as one of the business assets of Willyou.
• Security, Compliance with Law, and Fraud Protection.   We may disclose your information as we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request. We also may share your information in order to investigate, prevent or take action regarding illegal activities, including suspected fraud, or as otherwise required by law. We may also share your information to protect the rights, property, life, health, security and safety of us, the Services or any person or party.
• Consent.   We may share your information for any other business or commercial purposes disclosed to you and with your consent.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with other parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.

Children

The Services are not directed to individuals under the age of 13 and such individuals are not permitted to use the Services, and Willyou does not knowingly collect Personal Information from children under the age of thirteen (13). If you are a parent or guardian and believe Willyou has collected such information in a manner not permitted by applicable law, please contact us as set forth in the section entitled “Contact Us” below, and we will remove such data to the extent required by applicable law. In addition, we do not sell the Personal Information of minors under 16 years old who are California residents. Please see our Terms and Conditions for terms related to individuals under 18 who wish to use our Services.

Other Party Websites And Services

Our Services may provide links to websites, locations, platforms, and services operated and owned by other parties which are outside our control and not covered by this Privacy Policy. We encourage you to review the privacy policies posted on these websites and services. There may be Online Technologies on unaffiliated websites and services used to independently collect information about you and may solicit information from you. The information collected and stored by other parties, whether through our Services, or their services or Social Features (defined below), remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Social Features

We may allow you to connect our Services to another website or offer our Services through another party's service (“Social Features”). If you use a Social Feature, both we and the applicable owner or operator of the Social Features may have access to and use information associated with your use of the Social Features, and you should carefully review their privacy policy and terms of use. Some examples of Social Features include the following:

• Liking and Sharing.   We may embed a pixel or use other technology on our Services that allows you to “like” or “share” content on your Willyou account through another website or service, including social networks such as Facebook. If you choose to interact with social networks through our Services, we may collect any information you have authorized the social network to share with us (such as your user ID, billing information, public profile information, e-mail address, birthday, friends list, and other account and profile data). Likewise, if you choose to interact with other websites or services through our Services or visit our Services while logged into another party's service, that other party may receive information about your activities on our Services and be able to associate that information with information the other party already has about you.
• Brand Pages.   We may offer our content on social networks such as Facebook and Twitter. Any information you provide to us when you engage with our content (such as through our brand page or via Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Services on another website or service including social networks (e.g., by using a hashtag associated with Willyou in a post), we may use your reference on or in connection with our Services.

Analytics and Interest-Based Advertising

Our Services contain Online Technologies owned and operated by vendors and other third parties. For example, we use Online Technologies from analytics provides, such as Google Analytics, to help us analyze your use of the Services, compile statistic reports on the Services' activity, and provide us with other services relating to Services activity and internet usage. We also work with ad serving services, advertisers, and other third parties to serve advertisements on the Services and/or on other websites and services. These third parties may use Online Technologies on our Services (including in e-mails and advertisements) and on other websites and services to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on our Services and other parties' services or devices after you have left the Services (“Interest-based Advertising”).

We may serve ads on other websites and services, which are targeted to reach people (or similar people) who have visited our Services or that are also identified in one of more of our databases (“Matched Ads”). For instance, we incorporate the Facebook pixel on our Services and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

As indicated above, vendors and other third parties may act as our Service Providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on Online Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.

Review and Update of Account Information

You may access, update, or remove certain account information that you have voluntarily submitted to us through the Services. If you would like to update or revise information in your account, you may do so through your account or by contacting us as set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents and data subjects in Europe have additional rights as set forth in the sections entitled “Additional Disclosures for California Residents” and “Additional Disclosures for Data Subjects in Europe” below.

Online Technology Choices

• Cookies and Pixels.   At all times, you may decline our cookies if your browser permits. Most browsers allow you to refuse cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. If you use multiple browsers on your device, or multiple devices, you will need to instruct each browser and device separately. Your ability to limit cookies is subject to your browser settings and limitations. You can find out more about cookies and how to decline them on about.cookies.org.
• Do Not Track.   Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit allaboutdnt.com.

Please be aware that if you disable or remove Online Technologies some parts of the Services may not function correctly.

Analytics and Interest-Based Advertising

You can opt-out of Google's use of your Personal Information in connection with Google Analytics through cookies by visiting tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

Some of the other parties that collect information from or about you on the Services in order to provide more relevant advertising to you may participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit aboutads.info/choices. In addition, some of these other parties may be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, please visit networkadvertising.org/choices. If you are in the EU, please also visit the EU online choices page at www.youronlinechoices.com. Please note that if you opt-out using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the 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) or non-targeted ads.

We are not responsible for effectiveness of, or compliance with, any other parties' opt-out options or programs or the accuracy of their statements regarding their programs.

Communications

To opt out of receiving e-mail promotions from Willyou, please follow the unsubscribe instructions in our promotional e-mail correspondence or contact us as set forth in the section entitled “Contact Us” below. If you have signed up for our text messaging program and wish to opt out, you may do so at any time by texting “STOP”, “END”, “CANCEL”, “UNSUBSCRIBE” or “QUIT” to our shortcode. Please note that opting out of promotional communications from Willyou does not affect our non-promotional communications with you, including those related to your account, orders placed with Willyou, or our ongoing business relations.

Data Security And Retention

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Despite the measures we take, transmission via the Internet is not completely secure and we cannot guarantee the security of your information.

We retain your information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of providing you the Services and support for Services provided to you, satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes, and otherwise as permitted by law.

To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require your Personal Information, we will either delete or anonymize or otherwise de-identify it or, if this is not possible, securely store it in accordance with this Privacy Policy and cease use of the information until deletion is possible. If we anonymize your information (so that it can no longer be associated with you), we may retain this information for longer periods.

International Transfer

Willyou.com is based in the U.S. and the information we collect is governed by U.S. law. Your information may be stored and processed in the United States or any other country in which Willyou or its partners, affiliates, service providers, subsidiaries or agents maintain facilities and by using this website, you consent to any such transfer of information outside of your country. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Services or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy. If your data is collected in Europe, we will transfer your personal data subject to appropriate or suitable safeguards.

Changes to the Privacy Policy

This is our entire and exclusive Privacy Policy and it supersedes any earlier version. We may occasionally update this Privacy Policy to reflect changes in our operations, and we reserve the right to do so at any time. When a revision is made, we will revise the date of last update on this page and any changes will be effective immediately upon posting of the revised Privacy Policy. Willyou encourages you to periodically review this Privacy Policy to learn how we are protecting your information. Your continued use of our Services indicates your consent to the Privacy Policy then posted. If any changes are material, we may provide you additional notice, such as to your e-mail address.

Contact Us

If you have questions about this Privacy Policy, or our Personal Information practices, please contact us as follows:

By email: [email protected]

If you have a disability and would like to access this Privacy Policy in an alternative format, please email us at [email protected].

Additional Disclosures For California Residents

These additional disclosures for California residents apply only to individuals who reside in California. The California Privacy Rights Act (“CPRA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

California Notice Of Collection

We may collect, and may have in the past 12 months collected, the following categories of Personal Information enumerated in the CPRA:

• Identifiers,   such as name, email address, phone number, account name, IP address, and an ID or number assigned to your account.
• Customer records,   such as billing and shipping address, and credit or debit card data.
• Demographics,   such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
• Commercial information,   such as products or services history and purchases.
• Internet activity,   such as your interactions with our Services.
• Audio or visual data,   such as photos or videos you share with us or post on the Services.
• Geolocation data,  
• Employment and education data,   such as data you provide when you apply for a job with us.
• Inferences,   such as information about your interests, ring size preferences and favorites.

For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section in our Privacy Policy. We collect and use these categories of Personal Information for the business purposes described in the “Use of Information” section.

We use and partner with different types of entities to assist with our daily operations and manage our Services. Please review the “Sharing of Information” section for more detail about the parties to whom we disclose or “share” (as defined by the CPRA) information.

Right To Know, Correct, And Delete

If you are a California resident, you have the rights to know certain information about our data practices, delete the Personal Information we have collected from you, and correct certain Personal Information, each as more fully set forth below. In particular, you have the right to request the following from us:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information was collected;
• The categories of Personal Information about you we disclosed for a business purpose, sold, or shared, and the categories of third parties to whom the Personal Information was so disclosed, sold or shared, by category or categories of Personal Information for each category of third parties or persons to whom the Personal Information was disclosed, sold, or shared;
• The categories of third parties to whom the Personal Information was disclosed for a business purpose, sold, or shared;
• The business or commercial purpose for collecting, selling, or sharing the Personal Information; and
• The specific pieces of Personal Information we have collected about you.

You may request deletion of Personal Information by contacting us and providing the required verification information and other details we need in order to process the request appropriately. We may, to the extent permitted under applicable law and regulations, retain and continue to process data where a CPRA or other exception applies. We will inform you if such an exception applies.

You may request that we correct inaccurate Personal Information. We may, to the extent permitted under applicable law and regulations, decline to correct data where a CPRA or other exception applies. We will inform you if such an exception applies. We may also elect to delete information instead of correcting it if such deletion does not negatively impact you or you consent to the deletion.

Right To Non-Discrimination and Non-Retaliation

You have the right not to receive discriminatory or retaliatory treatment by us for the exercise of any your rights. If you believe you have received discriminatory or retaliatory treatment by Willyou for exercising your CPRA rights, please contact us.

Right To Opt Out of “Sale” or “Sharing”

We do not as a matter of course “sell” Personal Information, as that term is commonly understood. However, Personal Information collected on our Services by third parties for purposes of Interest-Based Advertising may be considered "sharing" under the CPRA, and you have the right to opt out. To exercise your opt-out right, visit the "Do Not Share My Personal Information (California residents)" section of our website and follow the steps provided.

California “Shine The Light” Law

If you are a customer in California, in addition to the rights set forth above, you have the right to request information from Willyou regarding the manner in which Willyou shares certain categories of Personal Information as defined by California's “Shine the Light” law with third parties and/or affiliates for their own direct marketing purposes. To receive this information, send us a request at the address set forth in the section entitled “Contact Us” above. Requests must include “California Shine the Light Privacy Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Willyou may provide this information in a standardized format that is not specific to you and is not required to respond to requests made by means other than through the provided e-mail address or mail address.

California Minor Postings Removal

Any California residents under the age of eighteen (18) who have registered to use the Services and posted content or information on the Services, can request that such information be removed from the Services by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view. Please note that such requests do not ensure complete or comprehensive removal of the content or information, as, for example, some of the content may have been reposted by another user.

Additional Disclosures For Nevada Residents

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of Personal Information that the business has collected or will collect about the consumer. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at [email protected]

Additional Disclosures For Data Subjects In Europe

The below information is provided as a supplement to our Privacy Policy to provide additional information to individuals in the European Economic Area, United Kingdom, and Switzerland (collectively, “Europe”).

Lawful Basis

European data protection law requires a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or another party, and your interests and fundamental rights and freedoms do not override those interests, where such legitimate interests may include (1) to communicate with you in response to your requests, questions, inquiries, and submissions; (2) to conduct advertising, marketing and promotional activities in connection with operating our business; (3) for research and development, and security and optimization of our Services, including fraud prevention; and (4) to process a job application, conduct recruiting activities, develop and improve our recruiting process, and communicate with you regarding your interest in current or future employment opportunities with us.

Data Subject Rights

If you are a data subject in Europe, you have the right to access, rectify, or erase any Personal Information we have collected about you through the Services. You also have the right to data portability and the right to restrict or object to our processing of Personal Information we have collected about you through the Services. In addition, you have the right to ask us not to process your Personal Information (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

Certain other details regarding the processing of Personal Information that individuals located in Europe may be entitled to receive are contained in other provisions of the Privacy Policy. The Services are hosted in and provided from the United States, and your use of our Services is governed by United States law. If you are using the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our systems are located. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Services, you consent to your information being transferred to our systems and facilities, and to the systems and facilities of those third parties with whom we share information as described in this Privacy Policy. If Personal Information is transferred to a recipient in a country that does not provide an adequate level of protection for Personal Information under the laws of your country in Europe, we will take measures designed to adequately protect your Personal Information, such as ensuring that such transfers are subject to the terms of the applicable Standard Contractual Clauses or their equivalent.

Requests

If you are resident of California or Nevada, or an individual in Europe who wishes to exercise any of the rights described above, please email us at [email protected]. In your request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request. You can designate an authorized agent to submit requests on your behalf.

However, we will require written proof of the agent's permission to do so and verify your identity directly.

When you submit a request, do not send us, directly or indirectly, any sensitive or special categories of Personal Information (e.g., social security numbers or other national or state identifiers, health information, biometric data or genetic characteristics, criminal background information, financial account numbers, payment card information, and so on).

We will evaluate and respond to your request to the extent required by law (or in our discretion if not required by law) in the time required by law, and as permitted by our contracts, confidentiality obligations, and applicable laws and regulations. We may not be able to provide all of the information requested or fulfill your request due to certain exceptions enumerated under applicable law. In such a case, you will inform you of the reasons we cannot fulfill all or parts of your request. If the request submission methods above do not enable you to submit your request, please contact us as set forth in the section entitled “Contact Us” above and specify which right you intend to exercise.

For individuals in Europe, if you have any concerns with our data protection law compliance, you also have the right to lodge a complaint with a European supervisory authority.

Last Updated: April 10, 2024