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FINDMINE PRIVACY POLICY

INTRODUCTION

Welcome! The following privacy policy (the “Privacy Policy”) outlines the types of personal information that FINDMINE, Inc. (“we,” “our,” or “us”) collects when operating the FINDMINE platform (“FINDMINE Platform”) and our website at www.findmine.com (“Site”).

We provide award-winning “Complete the Look” technology to retailers and brands (“Retailers”). Our automation platform helps scale merchandising and product curation across every customer touchpoint. We help Retailers ensure shoppers see full outfits that answer the question “how do I wear this?” with ease across ecommerce, marketing, and messaging channels, and in store.

Retailers place a snippet of code on their sites or use the FINDMINE API to request relevant outfits and product sets from the FINDMINE Platform in real time. In this way, the Retailer can present the appropriate product set across any channel, such as on their websites, in their website product pages, checkout pages, other pages tied to that Retailer’s website, in chatbots, mobile apps, and our Retail partners’ emails and other communications and messaging platforms or other communications means with you (“Properties”). You may also see FINDMINE-powered product sets across your favorite retailers and brand websites, stores, and messaging channels.

Your privacy is important to us, and we work hard to protect your personal information and ensure that information we collect is kept private and secure. If you have any questions, please contact us at contact@findmine.com.

HOW YOU ACCEPT THIS POLICY

When you visit our Site, contact us for more information through our Site, interact online with the FINDMINE Platform on one of our Retail partners’ Properties, or otherwise provide us with any personal information, or if you log into the FINDMINE Platform (as an employee of a Retailer that deploys the FINDMINE Platform), you consent to the terms and conditions of this Privacy Policy.

INFORMATION WE COLLECT AND WHY

In order to provide you with high-quality services and verify your identity, we collect various types of information when you visit the Site or the Property of a Retailer using our FINDMINE Platform.

As a Visitor to Retailers’ Properties Deploying the FINDMINE Platform

We power “Complete the Look” services for several Retailers, who are our customers. When you interact with FINDMINE-powered Properties of our Retail partners, such as their website pages, chatbots, mobile apps, or emails, we may collect various types of information, including device-related information (e.g., the type of browser and operating system you use,) and server log information (e.g., date and time of your visit), in order to make better recommendations, to better understand our visitors, and to enhance the FINDMINE Platform. Where our Platform is operating on Retailers’ Properties, we collect information regarding the items that you purchase, the outfits you create and update, and the items that the FINDMINE Platform recommends based on what our Retail partners determine to be an appropriate outfit, as well as the items you purchase most frequently, together with a unique identifier that does not allow us to identify you personally. This data allows the FINDMINE Platform to identify items to “Complete the Look” for items that may be of interest to you, including items that you’ve purchased, and to keep track of your preferences so as to improve the FINDMINE Platform’s future recommendations for you and others.

Also, if a Retailer deploying the FINDMINE Platform would like to send you an email with an outfit from the FINDMINE Platform, the Retailer will enter your email address into the FINDMINE Platform. We then pass that email address and outfit data to the email service provider used by the Retail partner to send the email to you. We do not store the email address that we provide to the Retailer’s email service provider on behalf of that Retailer.

As a Visitor to Our Site

When you visit the Site, we collect information you enter on a contact form such as your name, email address, and telephone number. We may also collect various other types of personal information related to your use of the FINDMINE Platform. For example, we may ask for additional information if you contact us for technical support or if you apply for a job with us on the Site. We also collect information using Google Analytics, as described below in the “Analytics” section. We also collect other information automatically when you visit our Site. This may include information such as your IP address and domain name, your Internet service provider, the date and time of your visit, the URLs from the websites you visit before and after navigating to the Site, your computer’s operating system and browser type, your software and hardware attributes (including device IDs), and your general geographic location (e.g., your city, state, or metropolitan region).

As an Administrator of a Retailer’s Website where the FINDMINE Platform is Deployed

When we set up our Retail partners’ employees’ user accounts to interact with the FINDMINE Platform, we collect certain personal information such as the employee’s first and last name, email address, and password as part of their user profile to administer the FINDMINE Platform on their Properties, as well as login records. We use this information to validate identity and ensure that these Retailers’ employee administrators of the FINDMINE platform receive important information from the FINDMINE system. We also allow such employees to see the data we collect though the FINDMINE Platform, such as number of clicks on a particular outfit. Further, we track our Retailers’ employees’ engagement with the FINDMINE Platform, such as when they create outfits, update outfits, etc.

We may also collect various other types of personal information related to the use of FINDMINE Platform as an administrator. For example, we may ask for additional information if the administrator contacts us for technical support.

INFORMATION GATHERED BY OUR RETAIL PARTNERS

We do not control the collection, use, or disclosure of personal information by our Retailers that deploy the FINDMINE Platform on their Properties. We do not come into contact with, and specifically disclaim any association with, any personal information collected by these Retailers from their consumer end users. An individual who seeks access to, or who seeks to correct, amend, or delete inaccurate personal information should direct his or her request to the Retailer.

PIXELS, JAVASCRIPT, AND OUR API

We integrate our FINDMINE Platform on Retailers’ Properties through the use of JavaScript, pixels, or by way of the Retailer’s integration of our API. Our Pixels and API collect information regarding your transactions on Retailers’ Properties, including what you purchase, the transaction ID, the time of the transaction, the transaction price, total discounts involved in the transaction, the IDs, titles, quantities, and prices of products you purchase, and the state and zip code where the transaction took place.

ANALYTICS

We may use Google Analytics to help collect and analyze the usage of our Site. Although Google Analytics places a persistent cookie on your computer to identify you as a unique user the next time you visit, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected at the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Site by disabling cookies on your browser. You also can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on here.

We also use Mixpanel to collect information about your usage of the FINDMINE Platform on our Retailers’ Properties. Mixpanel collects information such as an ID of a shopper (which we are unable to use to identify an individual), and your interactions with the FINDMINE Platform, including your browsing of the Properties of Retailers using the FINDMINE Platform. We then aggregate this data and the data collected by our pixels and API to show our Retail partners’ statistical information regarding users’ behavior on the Retailers’ Properties. We may also aggregate some of this information and display it publicly or provide or sell it to others. When aggregating personal information, we make sure that the information is not identifiable to any particular user. You can opt out of Mixpanel’s analytics by clicking here.

As of right now, we do not combine the information collected through the use of Google Analytics or Mixpanel with any personally identifiable information. However, we reserve the right to do so in the future. If we do, we will inform you of this change as described in the “Changes to this Policy” section below.

HOW WE USE YOUR PERSONAL INFORMATION

Your personal information is used to enhance your user experience, to help us understand how the FINDMINE Platform and our Site are used, to protect the security of the FINDMINE Platform and the Site, such as by detecting unauthorized logins, and to send emails to our Retail partners and their employee administrators of the FINDMINE Platform and individuals who apply for a job on the Site.

HOW LONG WILL WE RETAIN YOUR INFORMATION AND YOUR CHOICES AS AN ADMINISTRATIVE USER

For administrators of the FINDMINE Platform on our Retail Partners’ Properties, we will retain your personal information until you request that we delete it by contacting us at contact@findmine.com. If you are a Retailer who submitted information on our “Contact Us” form, or if you sent us an email or applied for a job on the Site and you would like for us to delete your personally-identifiable information, contact us at contact@findmine.com and specify what information you would like for us to delete. We will respond within a reasonable period of time to your request.

For employee administrators of Retail partners that use the FINDMINE platform, once your FINDMINE Platform user account profile has been created, you can revise that information by contacting us at contact@findmine.com and specifying what information you would like to revise. In your request, please make clear what personal information you would like us to revise, and how you would like us to revise it. We will respond within a reasonable period of time to your request.

In your request, please make clear what personal information you would like us to delete or revise. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.

WHEN DO WE SHARE YOUR PERSONAL INFORMATION

As of right now, we do not sell, rent, or trade any information that you provide us or share any of your information with any third parties, except as provided below. However, we may do so in the future and, if so, we will update this policy as described in the “Changes To This Policy” section below.

We also may use or share your personal or non-personal information with third parties when we believe, in our sole discretion, that doing so is necessary:

  • to comply with applicable law or a court order, subpoena, or other legal process;
  • to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Terms of Service, or situations involving threats to our property or the property or physical safety of any person or third party;
  • to establish, protect, or exercise our legal rights or defend against legal claims; or
  • to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

We may disclose potentially personally identifying information to employees, contractors, and affiliated organizations that: (i) need to know your personal information in order to provide services available on the FINDMINE Platform and Site; and (ii) have agreed not to disclose your information to others. Some of these employees, contractors, or affiliated organizations may be located outside of your home country. By using the FINDMINE Platform or Site, you consent to the transfer of such information to them.

We reserve the right to disclose information to facilitate the licensing, merger, sale, assignment, acquisition, financing, securitization, insuring, bankruptcy, or other transfer of our technology or business, or a portion thereof, to third parties, as permitted by applicable law. By agreeing to the terms of this Privacy Policy, you are consenting to this disclosure.

CHILDREN’S ONLINE PRIVACY

The FINDMINE Platform and Site is not intended for and may not be used by children under the age of 18. We do not knowingly collect information from children under the age of 18 and our Site and Platform are not directed to children under the age of 18. We also do not incorporate the FINDMINE Platform in the Properties of Retailers that are directed to children under the age of 18. Individuals cannot sign up for an administrator account for the FINDMINE Platform if they are under 18. If you learn that a child under the age of 18 has created a user account with the FINDMINE Platform or provided us with personally identifiable information, please contact us at contact@findmine.com.

PROTECTION OF PERSONAL INFORMATION

We employ several physical, technical, and administrative safeguards to keep your information safe.

Even with all these precautions, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events such as, but not limited to, hardware or software failure or unauthorized entry or use.

HOW WE RESPOND TO DO NOT TRACK SIGNALS

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals, but you may opt out of interest-based advertising of companies within the Network Advertising Initiative here and for companies participating in the Digital Advertising by clicking on the icon labeled “Consumer Choice Page” here.

CHANGES TO THIS POLICY

We may modify this Privacy Policy at any time. Any changes to the Privacy Policy will be reflected on this page and will become effective immediately upon posting. If the changes are significant, we will do our best to notify you via email or through a notification on the site or mobile application. Please check the effective date below to determine if there have been any changes since you have last reviewed the Privacy Policy.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident under the age of 18 and a registered user of the FINDMINE Platform or Site, you may request that we remove content and information that you post on the FINDMINE Platform or our Site at www.findmine.com. To obtain removal of such content or information, please send an email with a detailed description of the specific content or information you would like removed to contact@findmine.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted, since the content and information may remain in our databases, may remain visible in a manner that does not identify you, or may have been re-posted by another user. There may be other circumstances in which applicable laws do not require or allow removal even if requested.

INTERNATIONAL USERS & VISITORS

FINDMINE is hosted in the United States. Because the Internet is global, you should note that by providing your personal information as an international visitor or user, you are: (i) permitting the transfer of your personal information to the United States which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this Privacy Policy.

QUESTIONS: EMAIL contact@findmine.com

MAILING ADDRESS

FINDMINE, Inc.

137 Varick St. 2nd Fl.

New York, NY 10019

EFFECTIVE DATE: Posted: August 31, 2017 Effective Date: September 30, 2017