Last Updated 10.24.2019
1. What information do we collect from you through Register and how do we use it?
“Personal information” is any information that identifies you or can be used to contact you. When you sign up for and use Register, we collect certain types of personal information from you, which generally can be categorized as follows:
Contact information—your name, email address, mobile number, home address, and your Register ID and password.
Purchase and product information—information you choose to share with us about the products included in your Register profile, for example the item(s) purchased, receipts, the date of purchase, the price paid, photos, and the purchase location.
Communications and preference information—your choices as to which brands you would like to communicate with you, support information you may provide via the app, and copies of correspondence and requests for information we have received from you.
We may also collect certain non-personal information regarding your use of Register, including the date and duration of your use of Register, the IP address used to access Register, the type and identifier number for any device used to connect to Register, and other similar information.
We reserve the right to delete any photos that we deem to be inappropriate or illegal.
2. How do we use the information we collect from you through Register?
We use the personal information we collect about you to (1) operate, maintain, and provide you with the services offered through Register; (2) optimize your experience as a user of Register; (3) respond to your inquiries regarding Register; (4) send you emails, messages, and updates relating to Register; (5) provide customer support and manage our relationship with you; and (6) perform other functions as otherwise described to you at the time of collection.
A participating brand is defined as a Registria client. When you add a product to Register, you grant us the permission to share that ownership information with the specific participating brand, or when a brand becomes a participating brand.
Please note that we may anonymize or aggregate the personal information you provide us so that it no longer identifies you. In that event, the information is no longer “personal information” and may be used for any purpose to the extent permitted by applicable law, as can any other non-personal information we collect from you.
3. Do we share your information with anyone?
We may share your information with the following entities:
• The brands that you identify through Register, including those from whom you choose to receive communications.
• Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets where the information is among the assets being transferred.
• Other parties for any purpose we disclose at the time you provide the information.
We reserve the right to disclose your information as necessary to enforce our Terms of Service or comply with a subpoena or investigative demand, court order, request for cooperation from law enforcement or other governmental agency, to exercise our legal rights, to defend against legal claims, or as otherwise required by law.
Please note that the brands you identify through Register and with whom we share your personal information may have their own practices regarding that information. Registria is not responsible for those practices. You should review the privacy policies of those brands.
4. What choices do you have regarding your personal information?
You can manage communications from brands for products you have purchased by selecting which specific brands you would like to communicate with you. And to the extent we ever send you promotional or informational emails, you can choose to stop receiving those emails by clicking the “unsubscribe link” in the email. We will endeavor to promptly process any such unsubscribe requests. You may not, however, opt out of receiving Register-related service emails. If you ask us to have your information deleted (see “how can you contact us” below), we will delete that information which can be used to identify you. We will retain aggregated, de-identified, or other information that does not, and cannot be used to, personally identify you.
Through Register, you can review and correct the contact information that you have provided. Further, you are free not to provide certain information we request, but that may result in you being unable to use certain features of Register or receive services from the brand via the app.
5. How do we safeguard your personal information?
We employ a multi-layered approach to ensure the security of personal information, which includes administrative, technical, and physical measures. Please be aware, however, that no system can be 100% secure. While we strive to protect your personal information, we cannot ensure or warrant the security of any information you provide to us and you do so at your own risk.
6. Where is your information processed?
We may process personal information in the United States or any other countries where we or our service providers have operations. The privacy laws in those countries may be less stringent than the laws in the country where you are located. You understand and agree that information you provide may be sent to and processed in the United States or a country that is different from the one where your information was collected.
7. What rights do Register users in the European Economic Area have regarding their information?
The General Data Protection Regulation (“GDPR”) is a privacy law that affords certain rights to individuals in the European Economic Area (“EEA”) regarding the processing of personal information. Specifically, if you are a resident of the EEA, you may request information regarding a company’s processing of your personal information, their purposes in doing so, how the personal information was obtained (if you did not provide it directly), who it may have been shared with, and how long it will be retained. Further, you have the right to request your personal information be corrected if it is inaccurate and, in certain circumstances, may ask that it be erased and withdraw your consent or object to further processing. Finally, subject to certain limitations, and when feasible, you may request a copy of your personal information or that it be transferred to another entity. If you have concerns about the processing of your personal data, you may have the right to make a complaint to the appropriate data protection authority in the EEA.
For the personal information collected through Register, we act as a “controller” under the GDPR. As discussed above, we use your personal information for a variety of different purposes. Under the GDPR we are required to have a lawful basis for these types of processing activities. Most of the time, that lawful basis will either be to (1) perform a contractual obligation with you, (2) fulfill our legitimate business interests, or (3) conduct processing to which you have specifically consented.
For example, we need to process your personal data and share it with brands in order to provide you with services through Register. In that circumstance, our lawful basis for processing your personal information will be to perform the contractual obligations we agreed to when you signed up to become a user of Register. Likewise, it may be necessary to our legitimate business interests of growing and continuing our services for us to use your personal information in order to provide you with promotional information regarding our services.
As indicated previously, your personal information may be transferred to our servers in the United States or elsewhere. We only transfer your personal information with your consent, to perform a contract with or an obligation to you, or to fulfill a compelling legitimate interest that does not outweigh your rights and freedoms. Because the United States has not received an “adequacy finding” from the European Commission, we may rely on derogations in Article 49 of the GDPR to transfer your information to the United States. We also enter into data processing agreements and model clauses with vendors whenever feasible and appropriate.
8. How can you find out about updates to this Policy?
We may change this Policy from time to time and will post changes here, as well as update the date at the top of this document. Continued use of Register after any changes is deemed to be acceptance of those changes. We encourage you to check the Policy periodically for updates.
9. How can you contact us if you have additional questions about our privacy practices?
If you have any questions about this Policy or our information-handling practices, please contact us at firstname.lastname@example.org.