Privacy Policy

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Last Updated and Effective Date: May 24, 2024


This Privacy Policy describes how Redo Tech Inc. (“Redo,” “we,” “our,” or “us”) collects, uses, and discloses personal information about you and your data privacy rights. Personal information is sometimes also referred to as personal data, personally identifiable information, or other like terms that mean any information that directly or indirectly identifies you or is reasonably capable of being associated with you or your household. This Privacy Policy applies to personal information we collect from: (1) merchants who install the Redo application on

their ecommerce websites (“Merchants”); (2) consumers who enroll in Redo’s streamlined process for returns and exchanges when purchasing products on Merchants’ websites and instant refund services (“Consumers”); (3) users of our website and other online properties (“Users”); (4) our business-to-business contacts who provide services to Redo (“B2B Contacts”); and (5) individuals who otherwise interact with us on the Redo application, website, and/or other third-party websites.

We may provide different or additional notices of our privacy practices with respect to other personal information collection practices not within the scope of this Privacy Policy, in which case this Privacy Policy will not apply.

We may also change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. We may also provide you with an additional notice (such as by sending you a notification), in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.


Contents

  1. NOTICE AT COLLECTION

    1. Collection of Personal Information

      1. Personal Information You Provide to Us

      2. Personal Information We Collect Automatically

      3. Personal Information We Collect From Other Sources

      4. Personal Information We Derive

    2. Purpose and Use of Personal Information

    3. Disclosure of Personal Information

    4. Retention of Personal Information

  2. ADVERTISING AND ANALYTICS

  3. TRANSFERS OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

  4. YOUR CHOICES

    1. Account Information

    2. Cookies

  5. CHILDREN

  6. SUMMARY OF PRIOR 12 MONTH PERSONAL INFORMATION PROCESSING ACTIVITIES

  7. Selling or Sharing of Personal Information

  8. “Do Not Track” Requests

  9. Sensitive Personal Information

  10. Your Privacy Rights

    1. Rights Available to US Residents

    2. Instructions on How to Exercise Your Privacy Rights

    3. Appealing a Denial of a Privacy Right Request

    4. Authorized Agents

    5. Shine the Light Disclosure for California Residents

  11. CONTACT US

  1. NOTICE AT COLLECTION

    This Notice at Collection describes how we collect, use, and disclose personal information we collect from or about you.

    1. Collection of Personal Information

      1. Personal Information You Provide to Us


        We collect personal information you provide directly to us. For example, we collect personal information directly from Merchants who register to use our application on their ecommerce websites, Consumers who subscribe for our services, B2B Contacts when we conduct business dealings with them, and generally from individuals who respond to our inquiries, surveys, communications, offers, or marketing. The types of personal information that we may collect directly from you include: (1) contact information, such as name, email address, phone number, and physical address; (2) individual characteristics, such as date of birth; and (3) commercial information, such as records of the products or services purchased, obtained, or considered by Consumers, or other purchasing or consuming histories or tendencies.


        Redo does not see your sensitive financial information, such as financial account, debit card, or credit card information. However, when subscribing to our services, you may transmit such

        information to third parties, such as banks, processing gateways, and merchant processors, in order to process transactions and payments.


      2. Personal Information We Collect Automatically

        We automatically collect certain personal information about your interactions with us or our services, including the Redo application and website:


      3. Personal Information We Collect From Other Sources


        We obtain personal information from other sources. For example, we may collect information from advertising networks, data analytics providers, operating systems and platforms, mailing list providers, social networks, and other advertising partners. This information includes your contact information and usage data collected through cookies and other trackers described in the ADVERTISING AND ANALYTICS section below.


      4. Personal Information We Derive

        We may derive personal information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.


    2. Purpose and Use of Personal Information

      We may use the categories of personal information identified in the Collection of Personal Information section above for the following purposes:

      • To facilitate Merchants’ registration for the Redo application on their e-commerce websites;

      • To provide order tracking, streamlined returns or exchanges, and instant refund services;

      • To process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices;

      • To conduct business dealings with our partners, services providers, contractors or processors;

      • To personalize and improve your experience on our services;

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

      • To respond to your comments and questions and provide customer service;

      • To communicate with you about products, services, and events offered by Redo and others and provide news and information that we think will interest you;

      • To monitor and analyze trends, usage, and activities in connection with our services;

      • To personalize the advertisements you see when you use our services based on information provided by our advertising partners;

      • To detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Redo and others;

      • To debug to identify and repair errors in our services;

      • To comply with our legal and financial obligations; and

      • To carry out any other purpose described to you at the time the information was collected.

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  • C. Disclosure of Personal Information

    We may disclose your personal information in the following circumstances or as otherwise described in this Privacy Policy. To learn more about the categories of personal information we may disclose and the categories of recipients, please see the SUMMARY OF PRIOR 12 MONTH PERSONAL INFORMATION PROCESSING ACTIVITIES section below, which describes our prior 12 month and going forward personal information disclosure practices.


    • Vendors. We may disclose or make available your personal information to service providers, contractors, processors, and other parties who provide services to Redo, Merchants and Consumers, such as shipping, customer relations software, customer communication, bug tracking, and other related services.

    • Transaction Processing. We may provide you access to banks, processing gateways, and merchant processors for you to provide personal information required to process transactions.

    • Advertising and Analytics. We may make your personal information available to advertising and analytics partners, as described in the ADVERTISING AND ANALYTICS section below.

    • Legal Disclosures. We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. We may also share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Redo, our users, the public, or others.

    • Disclosed to Advisors and Lawyers. We may disclose personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

    • Disclosed During Change of Ownership. We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

    • With Your Consent. We may disclose personal information with your consent or at your direction.

    • Disclosure of Non-Personal Information. We may also disclose aggregated or de- identified information that cannot reasonably be used to identify you. When doing so, we publicly commit to maintain and use the information in an aggregated or de- identified form and not attempt to re-identify the information, unless permitted or required by law.

  • D. Retention of Personal Information

    We store personal information for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

  • II. ADVERTISING AND ANALYTICS

    We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by us 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 www.aboutads.info/choices. Your device may also include a feature that allows you to opt out

    of having certain information collected through mobile apps used for behavioral advertising purposes.

    We may also work with third parties to serve ads to you as part of customized campaigns on third-party platforms. As part of these ad campaigns, we or the third-party platforms may convert information about you into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.


  • III. TRANSFERS OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES


    Redo is headquartered in the United States, and we have operations and/or service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of other countries. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

  • IV. YOUR CHOICES


    1. Account Information


      You may update and correct certain account information at any time by logging into your account or emailing us at support@getredo.com. If you wish to delete your account, please email us at support@getredo.com, but note that we may retain certain information as required by law or for our legitimate business purposes.

    2. Cookies

      Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our services.


  • V. CHILDREN


    This website is not intended for or directed at children under the age of 18. In addition, we do not knowingly collect personal information from children under the age of 18. We also do not knowingly sell, share, use for targeted advertising, or disclose the personal information of children under the age of 18.

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  • VI. SUMMARY OF PRIOR 12 MONTH PERSONAL INFORMATION PROCESSING ACTIVITIES


    In the preceding 12 months, we have collected the categories of personal information set forth in the table below. For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Personal Information above. We collect personal information for the business and commercial purposes described in Purpose and Use of Personal Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients, which we also describe in greater detail in the Disclosure of Personal Information section above:


  • Category of Personal Information we Collect Business Purpose for Disclosure and Processing Category of Recipients
    Identifiers, such as name, email address, phone number, physical address, date of birth, IP address, unique personal identifiers, and other similar identifiers
  • Providing our services to Merchants and Consumers;
  • Conducting business with and receiving services from B2B Contacts;
  • Facilitating payment and transaction processing;
  • Analytics, advertising, and marketing; and
  • Legal and other purposes described in greater detail in the Purpose and Use of Personal Information section above.
  • Service providers, contractors, and processors, who provide services to Redo, such as shipping, CRM software, customer communication, bug tracking, and other related services;
  • Banks, processing gateways, and merchant processors; and
  • Legal and other purposes described in greater details in the Disclosure of Personal Information section above.
  • Sensitive personal information, such as financial account, devit card, or credit card information.*
    *Please note that Redo does not see such information, but you may make this type of sensitive personal information available to banks, processing gateways, and merchant processors when receiving our services.
  • Providing our services to Merchants and Consumers;
  • Facilitating payment and transaction processing; and
  • Legal and other purposes described in greater detail in the Purpose and Use of Personal Information section above.
  • Banks, processing gateways, and merchant processors; and
  • Legal and other purposes described in greater detail in the Disclosure of Personal Information section above.
  • Characteristics of protected classifications under California or federal law, such as age.
  • Providing our services to Merchants and Consumers;
  • Conducting business with and receiving services from B2B Contacts;
  • Facilitating payment and transaction processing;
  • Analytics, advertising, and marketing; and
  • Legal and other purposes described in greater detail in the Purpose and Use of Personal Information section above.
  • Service providers, contractors, and processors, who provide services to Redo, such as shipping, CRM software, customer communication, bug tracking, and other related services;
  • Banks, processing gateways, and merchant processors; and
  • Legal and other purposes described in greater details in the Disclosure of Personal Information section above.
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Providing our services to Merchants and Consumers;
  • Conducting business with and receiving services from B2B Contacts;
  • Facilitating payment and transaction processing;
  • Analytics, advertising, and marketing; and
  • Legal and other purposes described in greater detail in the Purpose and Use of Personal Information section above.
  • Service providers, contractors, and processors, who provide services to Redo, such as shipping, CRM software, customer communication, bug tracking, and other related services;
  • Banks, processing gateways, and merchant processors; and
  • Legal and other purposes described in greater details in the Disclosure of Personal Information section above.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application or advertisement.
  • Providing our services to Merchants and Consumers;
  • Conducting business with and receiving services from B2B Contacts;
  • Facilitating payment and transaction processing;
  • Analytics, advertising, and marketing; and
  • Legal and other purposes described in greater detail in the Purpose and Use of Personal Information section above.
  • Service providers, contractors, and processors, who provide services to Redo, such as shipping, CRM software, customer communication, bug tracking, and other related services;
  • Banks, processing gateways, and merchant processors; and
  • Legal and other purposes described in greater details in the Disclosure of Personal Information section above.
  • Geolocation data, such as your physical address and approximate location based on IP address.
  • Providing our services to Merchants and Consumers;
  • Conducting business with and receiving services from B2B Contacts;
  • Facilitating payment and transaction processing;
  • Analytics, advertising, and marketing; and
  • Legal and other purposes described in greater detail in the Purpose and Use of Personal Information section above.
  • Service providers, contractors, and processors, who provide services to Redo, such as shipping, CRM software, customer communication, bug tracking, and other related services;
  • Banks, processing gateways, and merchant processors; and
  • Legal and other purposes described in greater details in the Disclosure of Personal Information section above.
  • Professional or employment-related information, such as your title and company you work for.
  • Providing our services to Merchants;
  • Conducting business with and receiving services from B2B Contacts;
  • Facilitating payment and transaction processing;
  • Analytics, advertising, and marketing; and
  • Legal and other purposes described in greater detail in the Purpose and Use of Personal Information section above.
  • Service providers, contractors, and processors, who provide services to Redo, such as shipping, CRM software, customer communication, and bug tracking;
  • Banks, processing gateways, and merchant processors; and
  • Legal and other purposes described in greater details in the Disclosure of Personal Information section above.
  • Inferences from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characteristics, predispositions, and behavrio, such as interests and purchasing habits.
  • Providing our services to Merchants and Consumers;
  • Conducting business with and receiving services from B2B Contacts;
  • Analytics, advertising, and marketing; and
  • Legal and other purposes described in greater detail in the Purpose and Use of Personal Information section above.
  • Service providers, contractors, and processors, who provide services to Redo, such as shipping, CRM software, customer communication, and bug tracking; and
  • Legal and other purposes described in greater details in the Disclosure of Personal Information section above.
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  • VII. SELLING OR SHARING OF PERSONAL INFORMATION


    Below, we describe the categories of personal information we may sell or share for targeted advertising currently and in the preceding 12 months. We also describe the third parties who received or may receive the personal information and the business or commercial purpose for the sale or sharing. We do not knowingly sell or share the personal information of children under the age of 16, and have not done so in the prior 12 months.


  • Category of Personal Information Sold or Shared Category of Third Party Business or Commercial Purpose for Sale or Sharing
    Identifiers, such as name, email address, phone number, physical address, date of birth, IP address, unique personal identifiers, and other similar identifiers This category of personal information may be sold or shared. We may have shared or sold such personal information with third party advertising, marketing, and cookie providers, and with merchants interested in marketing their products and services to you. We may have disclosed this category of personal information to provide advertising and marketing services
    Characteristics of protected classifications under California or federal law, such as age. This category of personal information may be sold or shared. We may have shared or sold such personal information with third party advertising, marketing, and cookie providers, and with merchants interested in marketing their products and services to you. We may have disclosed this category of personal information to provide advertising and marketing services.
    Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other pruchasing or consuming histories or tendencies. This category of personal information may be sold or shared. We may have shared or sold such personal information with third party advertising, marketing, and cookie providers, and with merchants interested in marketing their products and services to you. We may have disclosed this category of personal information to provide advertising and marketing services.
    Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application or advertisement. This category of personal information may be sold or shared. We may have shared or sold such personal information with third party advertising, marketing, and cookie providers, and with merchants interested in marketing their products and services to you. We may have disclosed this category of personal information to provide advertising and marketing services.
    Geolocation data, such as your physical address and approximate location based on IP address. This category of personal information may be sold or shared. We may have shared or sold such personal information with third party advertising, marketing, and cookie providers, and with merchants interested in marketing their products and services to you. We may have disclosed this category of personal information to provide advertising and marketing services.
    Inferences from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characterisitcs, predispositions, and behavior, such as interests and purchasing habits. This category of personal information may be sold or shared. We may have shared or sold such personal information with third party advertising, marketing, and cookie providers, and with merchants interested in marketing their products and services to you. We may have disclosed this category of personal information to provide advertising and marketing services.

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  • VIII. “Do Not Track” Requests

    Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the websites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the do not track signal, we currently do not respond to the browser do not track signals.


  • IX. Sensitive Personal Information

    Under United States privacy laws, certain types of personal information are considered “sensitive” personal information or data and require additional data privacy rights and obligations. Redo does not see any information that constitutes “sensitive” personal information or data, but you may provide to banks, processing gateways, and merchant

    processors your sensitive financial account, debit card, or credit card information when using our services. Redo facilitates your provision of this information to these parties in order to provide our services. This information may also be used to prevent, detect, and investigate security incidents, resist malicious, deceptive, fraudulent, or illegal actions and prosecute those responsible, and ensure physical safety of natural persons. Because this “sensitive” personal information is used for limited and permitted purposes, we do not offer a limit use and disclosure of sensitive personal information right.

  • X. Your Privacy Rights


    1. Rights Available to US Residents


      Data privacy laws afford consumers residing in the United States certain rights with respect to their personal information, subject to certain exceptions. If you reside in the United States, this

      section applies to you. Subject to certain limitations, you have the following rights in the United States:

      • Right to Delete. You have the right to request us to delete the personal information we have collected about you.

      • Right to Correct. You have the right to request us to correct inaccurate personal information we maintain about you.

      • Right to Confirm Processing, Know, and Access. You have the right to confirm whether we are processing your personal information and to know and access the personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you. You have the right to receive this information in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the personal information to a person without impediment or hindrance.


      • List of Specific Third Parties. You have the right, at our option, to receive a list of the specific third parties, other than natural persons, to which we have disclosed either: (1) your personal information or (2) any personal information.


      • Right to Opt-Out of Profiling. You have the right to opt out of the processing of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not engage in such profiling activities and therefore you do not need to take any further action.


      • Rights Related to Sharing for Targeted Advertising or Sale. You have the right to opt out of the sharing of your personal information for targeted advertising or the sale of your personal information.

      • Rights Related to Sensitive Personal Information or Data. Data privacy laws may provide additional protection for sensitive personal information or data. Please see the Sensitive Personal Information section above for more information.


      • Right to No Discrimination. You have the right not to be discriminated against for exercising any of your privacy rights. This includes us not: (a) denying you goods or services; (b) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing you a different level or quality of goods or services; (d) suggesting to you that you will receive

        a different price or rate for goods or services or a different level or quality of goods or services; and (e) retaliating against you for exercising your privacy rights.

      • Right to Appeal. If we decline to take action in response to your exercise of a privacy right, we will inform you of the reason for denying your request and provide you instructions on how to appeal the decision.


    2. Instructions on How to Exercise Your Privacy Rights

      You may exercise your privacy rights by calling our toll-free phone number at 801-405-9086 or emailing us at support@getredo.com. In some instances, we will need to verify your identity before honoring your privacy rights request. We will verify your identity by asking you to provide personal information related to your recent interactions with us. We will honor your privacy rights request within 45 calendar days of receipt, unless we request an extension as permitted by data privacy law. However, we will honor opt-out of sale and sharing requests within 15 business days. We do not need to verify your identity for opt-out of sale or sharing requests, but we may ask for additional information to find you on our services.


    3. Appealing a Denial of a Privacy Right Request


      You may appeal a denial of your privacy right requests by calling us at our toll-free phone number 801-405-9086 or emailing us at support@getredo.com. Within 45 days of receipt of an appeal, we will inform you in writing of any action taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may submit a complaint to the Attorney General of your state.

    4. Authorized Agents


      If permitted or required by applicable law, you may exercise your privacy rights through an authorized agent (which may include a guardian or conservator). If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us at support@getredo.com.


    5. Shine the Light Disclosure for California Residents

      California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at support@getredo.com.

  • XI. GOOGLE WORKSPACE API DISCLOSURE

  • Please note that for purposes of Google Workspace API, our application will not retain user data obtained through Workspace API to develop, improve, or train generalized artificial intelligence and/or machine learning models.

  • XII. CONTACT US

  • If you have any questions about this Privacy Policy, please contact us at support@getredo.com.