REFINERY29 PRIVACY POLICY

Last updated: September 30, 2024

This Privacy Policy applies to R29, LLC, its subsidiaries and its affiliates (collectively, “Refinery29,” “we,” “us,” or “our”) and Refinery29’s websites that post this Privacy Policy, including any features, applications, widgets or online services that post a link to this Privacy Policy, whether accessed via computer, mobile device or otherwise (collectively, the “Sites”).

This Privacy Policy applies when you interact with us through the Sites. It also applies anywhere it is linked. It does not apply to third-party websites, mobile applications, or services that may link to the Sites or be linked to from the Sites. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

Please review this Privacy Policy carefully. In addition, please review the Terms of Use linked in the footer of the website, which govern your use of the Sites. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THE SITES OR PROVIDE US WITH ANY PERSONAL INFORMATION.

TABLE OF CONTENTS

• INFORMATION WE COLLECT
• HOW WE USE YOUR INFORMATION
• HOW WE SHARE YOUR INFORMATION
• OPTIONS AND RIGHTS REGARDING YOUR INFORMATION
• OTHER IMPORTANT INFORMATION
• ADDITIONAL STATE-SPECIFIC PRIVACY DISCLOSURES
• CHANGES TO THE PRIVACY POLICY
• HOW TO CONTACT US

INFORMATION WE COLLECT

We may collect information from you directly, from the devices you use to interact with us, and from third parties. We may combine information from the Sites together and with other information we obtain from our business records. We may use and share aggregate or de-identified information at our discretion, and other third parties, including third party advertisers, content providers and analytics providers, may themselves collect such information when you visit the Sites.

Information You Give Us

We collect information that you provide directly to us while using our Sites or interacting with us offline. This includes:

• Contact and demographic information when registering to use our Sites and services.

• Payment information and associated contact information when engaging in a transaction on our Sites.

• Email address information when subscribing to our email lists.

• Any information or data you provide by interacting in our online forums and chat rooms, or by commenting on content posted on our Sites. Please note that these comments are also visible to other users of our services and may be visible to anyone else on the internet.

• Information you provide when you submit a question or complete a survey.

• Information you provide to attend events and activations put on by us or our business partners.

• Information you provide when participating in a charity event or offering a donation.

• Information you provide when you participate in a contest or sweepstakes.

• If you contact us, we may keep a record of that correspondence, and any contact information provided.

• Any other information you submit to us.

Information We Collect Automatically

When you interact with and use the Sites, certain information about your use of our Sites is automatically collected. Much of this information is collected through cookies, web beacons, pixels, and other tracking technologies, as well as through your web browser or device. We also create records when you make purchases or otherwise interact with the Sites. This includes:

• Details of your visits to our Sites and information generated in the course of using our Sites (including the timing, frequency and pattern of service use), including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our Sites.

• Details regarding the device you use to access our services, including, but not limited to, your IP address, operating system, browser type, and mobile device ID.

• Information about how you interact with our ads and email newsletters, including whether you open or click links in any correspondence.

• Information that you make available to us on a social media platform (including by clicking on a social media icon linked from our services or by signing up for our newsletter through a social media service), including your account ID, email address, username, and other information included in your posts.

• Advertising information, including special advertising and other unique identifiers that enable us or third parties working on our behalf to target advertisements to you. Please be aware that our advertising partners may collect information about you when you visit third-party websites or use third-party apps. They may use that information to better target advertisements to you on our behalf.

• Business record information, including records of your purchases of products and services and use of our services.

For more information about our use of cookies, web beacons, pixels, and other tracking technologies on the Sites, please see our Cookie Policy linked in the footer of the website.

Information We Collect From Other Sources

We may collect the following information about you from third-party sources:

• Contact information, demographic information, and information about your interests and purchases, from consumer data providers.

• Information about your interests, activities, and employment history from social networks and other places where you choose to share information publicly.

• Information about your interaction with advertisements on our Sites, or ads that we place on third party websites, from online advertising companies.

• If you decide to invite others to the Sites, we will collect your and the other person’s names, email addresses, and/or phone numbers to send an email or text message and follow up with the other person. You agree that you will obtain the other person’s consent before giving us their contact information. You also agree that you will not send us the contact information of a minor. We will inform any other person you invite that you gave us their information in the invitation email.

Who Else May Collect Information From You On Our Sites?

We use analytics providers to provide us with information regarding the use of the Sites and the effectiveness of the advertisements that we place on the Sites and elsewhere on the Internet - for example, in third party applications. You may also see third-party ads on the Sites and those ads may be served by a third party.

These service providers may set and access their own tracking technologies on your computer or mobile device (including cookies and web beacons), and they may otherwise collect or have access to information about your visits to and activity on the Sites, as well as other websites or online services. Some of these third parties may collect personal information from you over time when you visit the Sites or other websites and services.

Cookies and web beacons, including those set by third-party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share usage information about visitors with third party advertising companies, analytics providers, Refinery29 partners and other vendors for the same purposes.

For more information about our use of cookies, web beacons, pixels, and other tracking technologies on the Sites, please see our Cookie Policy linked in the footer of the website.

What Happens If You Do Not Provide Us With The Information We Request Or Ask That We Stop Processing Your Information?

In some circumstances, if you choose not to provide certain information, we may not be able to provide the Sites or services requested by you. If you withdraw your consent for us to process your information, we will no longer process your information in that manner. For example, if you withdraw your consent to receiving marketing from us, we will no longer process your information for that purpose, and you will no longer receive marketing from us.

HOW WE USE YOUR INFORMATION

We may use any of the information we collect for the following purposes:

• Service Functionality. Operating our business and providing and maintaining our Sites and services, including processing commercial transactions and charitable contributions; creating content based on user submissions; tracking and monitoring attendance at online and offline events; providing customer service including responding to question submissions, feedback or suggestions; and conducting general business operations.

• Service Improvement. Improving our Sites and services and understanding how our Sites and services are being used, our customer base and purchasing trends, and the effectiveness of our marketing.

• Advertising and Marketing. Sending you newsletters and tailoring other content we display to you and offers we may present to you, both on the Sites and elsewhere online; audience targeting and running campaigns; conducting contests and sweepstakes; and verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

• Personalization. Tailoring content we display to you and offers we may present to you, both on the Sites and elsewhere online.

• Security. Protecting and securing our Sites, services, assets, network, and business operations; detecting, investigating, and preventing theft, unauthorized use, or abuse of the Sites or services and other activities that may violate our policies or be fraudulent or illegal.

• Legal Compliance and Other Lawful Purposes. Protecting and enforcing our and others’ interests, rights, and property; complying with legal process, such as warrants, subpoenas, court orders, and lawful regulatory or law enforcement requests and to comply with applicable legal and regulatory requirements.

We may also use information for other purposes disclosed to you at the time it is collected or otherwise with your consent.

Do We Use Technology To Build Profiles About You?

We may use signals on your browser which analyze the types of Refinery29 content you have consumed. We can then provide you with relevant Refinery29 content recommendations and other types of content that you might enjoy on the Sites. Types of input signals can include engagement, time spent on site, and social media interests. This activity requires your consent to the use of cookies while browsing our Sites.

For more information about our use of cookies, web beacons, pixels, and other tracking technologies on the Sites, please see our Cookie Policy linked in the footer of the website.

We do not use your personal data for solely automated decision-making, including profiling, which produces legal effects or similarly significant effects concerning you.

HOW WE SHARE YOUR INFORMATION

We may share any of the information we collect with the following recipients:

• Subsidiaries and Affiliates. We may share information with our affiliated brands, parent company, and other companies under common ownership, control or management for internal business reasons.

• Service Providers. We may use third-party service providers to perform certain services on behalf of the Sites and services, such as hosting the Sites, designing and/or operating the Sites’ features, analyzing users’ interactions with the Sites, sending communications, safeguarding against fraud, or performing other administrative services. We may provide these service providers with access to your information to carry out the services they are performing for you or for the Sites or services.

• Advertising and Marketing Partners. We may share information with social media networks and third parties that provide advertising, campaign measurement, online and/or mobile analytics, and related services.

• Other Businesses at Your Direction or With Your Consent. You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your information shared, it will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

You also may request, sometimes through your use of an interactive feature or third-party application, that we share information about you with a third party and we will typically do so under those circumstances. For example, if you “like” content on our Sites, information about you may transfer to the third party offering that application on our Sites and to the third-party website to which you are posting.

• Promotional Partners and Joint Marketing Partners. We may offer sweepstakes, contests, and other promotions (a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the terms, conditions or official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your information may be disclosed to third parties or the public in connection with the administration of such Promotion including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

• Government Entities and Other Third Parties for Administrative and Legal Reasons. We may also transfer and disclose information to government entities and other third parties: (i) in the event we are required to respond to subpoenas or other legal process or if in our opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation; or (iii) to protect and/or defend the Sites’ Terms of Use or other policies applicable to the Sites or to protect the personal safety, rights, property or security of any individual. This may include disclosure of certain information to a third party we engage to protect against fraud and the unauthorized use of credit and gift cards. We may also use device identifiers (e.g., IP addresses) to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, at our discretion. These disclosures may be carried out without notice to you.

• Other Businesses in the Context of a Commercial Transaction. We may disclose and transfer all information related to the Sites: (i) to a subsequent owner, co-owner or operator of the Sites or any component of the Sites, such as a database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of Refinery29’s ownership interests, assets, or both, or other corporate change, including, without limitation, during the course of any due diligence process.

We may also disclose information we have collected about you as described at the time you provided it or otherwise with your consent (to the extent required by law), and as described in this Privacy Policy.

OPTIONS AND RIGHTS REGARDING YOUR INFORMATION

Changing Your Subscriptions

You may cancel or modify your subscriptions to emails you have elected to receive from the Sites by following the instructions contained within an email you receive. Please note that we reserve the right to send you certain communications relating to your account or use of the Sites (for example, administrative and service announcements) and these transactional messages may be unaffected if you opt out from marketing communications. If you sign up to receive SMS or MMS messages that may be offered on the Sites, you may unsubscribe from any text messages received by replying “STOP.”

Do Not Track

Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Refinery29 does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Jurisdiction-Specific Rights

You may have certain rights with respect to your personal information depending on where you reside. Please see the “Additional State-Specific Privacy Disclosures” section below and contact us as described below to exercise your rights.

How We Respond To Global Privacy Control Signals (“GPC Signals”)

We receive and process GPC Signals for requests to opt-out of sales, sharing, or targeted advertising. We process the commonly used and industry standard GPC Signals. Please note that this is developing technology, and providers may offer solutions that our Sites do not recognize. We will do our best to recognize, process, and honor a GPC Signal that meets the legal standards and is widely adopted in the industry.

OTHER IMPORTANT INFORMATION

Data Retention

We will retain and use personal identifiers for as long as it is needed to complete the purposes, provide you with any services, communications, news/press releases you have requested, or access to the Sites, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We retain and use all other categories of personal information as long as necessary to complete the purposes for collection, unless otherwise instructed by you or otherwise disclosed at the time of collection, in accordance with applicable law.

Information You Choose To Publicly Display Through The Sites, And Posting Content To Third Party Sites

You may be able to submit comments, ideas, reviews, suggestions and other content (“User Content”) to the Sites and to post your User Content publicly on message boards, chat rooms, and other public areas (collectively, “Community Forums”).

Note that anything you post to a Community Forum is public. Information you choose to post or make available in the Community Forums may be viewed, collected and used by others. If you choose to voluntarily disclose User Content, the protections of this Privacy Policy will not cover your disclosure of that information or content. Think carefully before you post and use caution before disclosing any personal information.

Refinery29 may publish User Content online or offline in any media or format (currently existing or later developed). Subject to applicable law, we may also publish your name, voice, likeness and other personal information with your User Content, and Refinery29 may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit, please review our Terms of Use linked in the footer of the website.

Also, if you choose to “like” content on one of the Sites, to tweet from the Sites or to otherwise post information from or via the Sites to a third-party website, feature or application, that information may be public, and the third party may have access to information about you and your use of our Sites.

Third Party Content, Widgets, And Links To Third Party Sites

The Sites may contain content that is hosted and served by third parties, which may include third party widgets (such as those that allow you to share content with third party websites and online services). The Sites may also contain links to other third-party websites that Refinery29 does not control. In addition, Refinery29 widgets may be included on web pages and websites that are not associated with us, and over which we have no control. These third parties may collect information about you through the use of their own cookies and web beacons, may independently collect data or solicit personal information, and may or may not have their own published privacy policies. Refinery29 is not responsible for the privacy practices employed by any third party.

Information About Children

The Sites are general audience websites and we do not knowingly collect any information from children younger than the age of thirteen (13). We will delete any personal information collected that we later determine to be from an individual younger than the age of 13. If a parent, guardian or anyone else becomes aware of personal information that has been collected from the use of the Sites by an individual under the age of 13, please contact us immediately at [email protected].

Security

We take commercially reasonable steps to help protect and secure information that we collect. However, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be completely secure. Please note that we cannot ensure or warrant the security of any information we collect, and that you use our Sites and provide us with your information at your own risk. We encourage you to use caution when using the Internet. This includes not sharing your passwords and making passwords that are hard to guess but easy for you to remember. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting us at [email protected].

Cross-Border Data Transfer

The Sites are primarily operated in the United States. If you are located in the UK, European Union, Australia, Canada or elsewhere outside of the United States, please be aware that information we collect might be transferred to and processed in the United States where the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. When we undertake such transfers, we ensure that appropriate safeguards are in place as required by relevant law, which may include standard contractual clauses approved by UK and EU regulators.

ADDITIONAL STATE-SPECIFIC PRIVACY DISCLOSURES

This section provides additional information required by certain state privacy laws.

California Privacy Rights; “Shine The Light” Law

We will give you the opportunity to decide whether you allow us to share your personal information with third parties for those third parties’ direct marketing purposes before we collect your personal information If you do not opt in or if you choose to opt out at the time we offer that choice, we will not share your information with the identified third party for its direct marketing purposes.

Notice At Collection

The Privacy Policy describes the personal information that we collect, the sources from which we collect it, the purposes for which we use it, and the circumstances in which we share it and with whom, and the criteria we use to determine the retention period for such information. The below table summarizes the categories of personal information - including categories of “sensitive” personal information - that we collect, the purpose for the collection as described above in the “How We Use Your Information” section, and whether we disclose, “sell,” or “share” that information to service providers or third parties as described above in the “How We Share Your Information” section. The categories we use to describe personal information are those enumerated in the California Consumer Privacy Act (“CCPA”).

Entities to whom we “sell” or with whom we “share” information are third parties. Under the CCPA, a business “sells” personal information when it discloses personal information to a company for monetary or other benefit. A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under the CCPA, or because its contract does not restrict it from using personal information for purposes unrelated to the service it provides to us. A business “shares” personal information when it discloses personal information to a company for purposes of cross-context behavioral advertising, as those terms are defined in the CCPA.

We retain the above categories of personal information as described in the “Other Important Information” section above.

Sensitive Personal Information

The categories of personal information that we collect and disclose for a business purpose include “sensitive personal information” as defined under the CCPA. We do not use or disclose sensitive personal information for any purpose not expressly permitted by the CCPA.

Sale And Sharing

We have no actual knowledge of “selling” or “sharing” personal information of consumers under the age of sixteen (16), as those terms are defined under the CCPA, in the past twelve (12) months.

Advertising

We process personal information for the purposes of “targeted advertising,” as that term is defined under certain state privacy laws.

De-Identified Data

We may use de-identified data in some instances. We either maintain such data without attempting to re-identify it or treat such data as personal information subject to applicable law.

Profiling Disclosure

We do not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under certain state privacy laws.

Your Privacy Rights

Residents of the state of California have the following rights:

• Know and Request Access to and Correction or Deletion of Personal Information. You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it, subject to certain exceptions. You also have the right to request in certain circumstances that we correct personal information that we have collected about you and to delete personal information that we have collected directly from you. To exercise this right, please contact us at [email protected].

• Limit the Use of Sensitive Personal Information. You have the right to limit the use of their sensitive personal information to only the purposes for which it was collected if we use such information to infer characteristics about you. We do not use such information to infer characteristics about you.

• Opt Out of Sale or Sharing of Personal Information. You have the right to opt-out of the sale or sharing of your personal information, as those terms are defined in the CCPA. To exercise this right, please click the “Do Not Sell My Personal Information” link in the footer of the website or set your browser Global Privacy Controls to send this signal when you visit our Sites.

Residents in other states may have the following rights:

• Confirm Processing of and Access to Personal Information, under certain circumstances.

• Obtain a Copy of Personal Information in a Portable Format, under certain circumstances.

• Correct Personal Information, under certain circumstances.

• Delete Personal Information, under certain circumstances.

• Request the Specific Third Parties to Which Personal Information Has Been Disclosed, other than natural persons.

• Opt Out of “Sales” of Personal Information, as that term is defined under applicable law. To exercise this right, please click the “Do Not Sell My Personal Information” link in the footer of the website or set your browser Global Privacy Controls to send this signal when you visit our Sites.

• Opt Out of Use of Personal Information for “Targeted Advertising,” as that term is defined under applicable law. To exercise this right, please click the “Do Not Sell My Personal Information” link in the footer of the website or set your browser Global Privacy Controls to send this signal when you visit our Sites.

• Opt Out of “Profiling,” as defined under applicable law, under certain circumstances.

If you have the right to appeal a denial of our request, you may do so by contacting us as described in the notice of denial.

Residents of Nevada have a limited right to opt out of certain personal information sales. To exercise this right, please submit a request to this designated address: [email protected]. However, please know we do not currently sell data triggering this opt out right.

The controller entity that is subject to this Privacy Policy is R29, LLC.

How To Exercise Your Privacy Rights

If you would like to exercise one or more of the above rights, please submit a request to [email protected] or write to us at the following mailing address:

R29, LLC
34 35th Street, Suite 5A
Brooklyn, NY 11232
United States
Attention: Legal Department

You must put the statement “Privacy Rights Request” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information to allow us to respond to you.

In certain circumstances, you may designate an authorized agent to make a request on your behalf.

We may need you to provide additional information to verify your request, such as providing certain data elements so that we can confirm they match the personal information already maintained by us. We will not use this additional information for anything other than handling your request.

We will endeavor to respond to all such requests within forty-five (45) days, although there may be a brief delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If we require more time, we will inform you of the reason and extension period in writing. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

You have the right to not be discriminated against for exercising any of these rights.

CHANGES TO THE PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time without notice to you. The revision date appearing on the first page of this Privacy Policy underneath the title will identify the date of the last update or revision. Any changes will be effective immediately upon the posting of the revised Privacy Policy. However, we will not, without your consent, use your personal information in a manner materially different than what was stated at the time it was collected.

HOW TO CONTACT US

If you would like to contact us for any reason concerning our privacy practices or have further questions on the processing of your personal information, contact us at [email protected].

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