Privacy Policy
ÀLA.HAUSSE Limited (“ÀLA.HAUSSE”, “we”/”us”) has created this Privacy Policy to set out how we collect, use, and disclose Personal Information (defined in Section 1 below) collected through www.alahausse.ca, (the “Website”), and any sub-sites, the ÀLA.HAUSSE mobile application (“App”), ÀLA.HAUSSE digital marketplace platform (“Platform”) which allows users to purchase, sell and/or rent Fashion Items (as defined in our Terms of Use) to and from other users, including all features and applications in relation therewith, and any other related services offered by us and as further described below, (the “Services”, together with the “Website”, the ÀLA.HAUSSE “App”, and the “Platform”, the “Service”), as further described in our Terms of Use [https://www.alahausse.ca/ala-hausse-terms-and-conditions] and User Guide and FAQ located at [https://www.alahausse.ca/ala-hausse-user-guide](“User Guide”). Privacy is of great importance to us. Please review this Privacy Policy carefully. By visiting, accessing, or using the Website, the App, the Platform, or any other Services thereon (in whole or in part) and in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use, and disclosure of your Personal Information (as defined below) in accordance with this Privacy Policy. Capitalized terms not otherwise defined in this Privacy Policy will have the meanings attached to them in the Terms of Use and User Guide.
WHAT DOES THIS PRIVACY POLICY COVER?
Privacy Policy. This Privacy Policy covers our collection, use, and disclosure of Personal Information (defined below) which may be collected about Buyers, Sellers, Borrowers, Lenders and visitors to the Website and/or Users of the App as well as any individuals whose Personal Information is uploaded by a Buyer, Seller, Borrower or Lender (each a “User”, or otherwise referred herein as “you”). This Privacy Policy also applies to the Personal Information we collect when you engage with us on social media, or otherwise interact with us. This Privacy Policy does not apply to the practices of companies that we do not own or control.
What is Personal Information? Personal Information means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. We will not actively collect Personal Information for sale or marketing in a way that specifically identifies the individual. In other words, we don’t sell customer lists. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using any part of the Service (inclusive of the App, Website, and Platform).
A Note About Children. You must be at least 13 years old to use the Service. We do not intentionally gather Personal Information from visitors who are under the age of 13. If a child under 13 submits Personal Information to us and we learn that the Personal Information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Information from a child under 13, please contact us at hello@alahausse.ca.
A Note to Users Outside of the United States and Canada. If you are a non-U.S. or non-Canadian user of the Services, by visiting the Sites or App and providing us with data, you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Privacy Policy. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States and Canada, where laws regarding the processing of Personal Information may be less stringent than the laws in your country. By providing your data, you consent to such transfer.
Third-Party Disclaimer. Please note that this Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third-party websites, services, and applications, that you elect to access in connection with the Services or third parties that may resell our products. You are responsible for ensuring that you have obtained the necessary authorizations and consents for any Personal Information you make available to us for use in accordance with this Privacy Policy.
Lawful processing: We process your Personal Information only to the extent necessary for the performance of our obligations to you, which is in providing our products and the Service. We set out below the type of Personal Information that we collect and how we use it. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using the Services.
COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA
Information we Collect and Use. In order to use the Service as a Buyer, Seller, Borrower, or Lender and/or access certain features of the Service, you will be required to register for an account (a “User Account”) and provide us with your full name, email address, phone number, banking information (for Sellers and Lenders to remit payment) and address, and any other information that may be reasonably requested as part of our Know Your Customer (“KYC”) process, as required by our third-party payment provider. Given the nature of our Service as a community marketplace, to order to maintain the integrity security, and User experience of our Service and for all Users, and to assist our User community in preventing prohibited activities on the Service, a User wishing to register for a User Account will also be required to upload a clear, valid and recent profile photo for User Account verification purposes and our KYC process. For more information about the KYC process, please refer to our User Guide and Terms of Use. Users may also log in to use the Service through an existing integrated third-party account, such as Facebook, Google, or Apple. However, you are responsible for complying with each such third party’s terms of service/use or privacy policy. You may also provide us with Personal Information when you : (i) contact us through our online or email forms (including sending us queries, joining our subscriber list to be updated on releases of our products, or responding through the Services to listed job postings), as well as through any third party social media accounts connected to our Services from time to time (i.e. Instagram, Facebook, Twitter, or otherwise); (ii) make a purchase or proceed with a payment transaction through the Service for our products and services; (iii) use your computer or mobile device to access the Service; and (iii) to simply visit or browse the Service.
Machine Learning. Our processing of Personal Information for these purposes includes both automated and manual (human) methods of processing. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (AI), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do. To build, train, and improve the accuracy of our automated methods of processing (including AI), we manually review some of the predictions and inferences produced by the automated methods against the underlying data from which the predictions and inferences were made.
Use of Personal Information. We collect Personal Information to:
authenticate access to the Account and provide access to the Service;
provide, operate, maintain and improve the Service;
send technical notices, updates, security alerts, and support and administrative messages;
provide and deliver the Services and features you request, process, and complete transactions, and send you related information, including confirmations and invoices;
respond to comments, questions, and requests and provide customer service and support;
communicate with you about services, features, surveys, newsletters, offers, promotions, contests, and events, and provide other news or information about us and our select partners;
investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
personalize and improve the Service, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customize your experience on the Platform;
monitor and analyze trends, usage, and activities in connection with the Platform and for marketing or advertising purposes;
link or combine with other information we receive from third parties to help understand your needs and provide you with better service;
enable you to communicate, collaborate, and share files with users you designate; and
for other purposes which we will notify you about and seek your consent.
Please note that with the exception of Sellers and Lenders (for which we may collect banking information solely for the purposes of remitting any proceeds from the sale or renting of Fashion Item), we do not collect payment or credit information on our Service from our Users. We use Stripe as our third-party service payment provider (which may be subject to change from time to time) to process any payment transactions for any purchases you may make for the products or services we offer through our Service. You are responsible for reviewing any such third-party payment providers’ privacy policies and/or statements, as well as their terms of service and/use, and complying with them.
Cookies and Automatic Tracking (How we Collect your Information). We automatically collect certain statistical, system log data, and other data about traffic to our Service. This information includes IP addresses, your login data (registration ID and login password for future logins to our Service, i.e. “persistent cookies”), page views, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, type of device and platform and other technology you use to access and use the Services, how you use the Services (for instance, the buttons, controls, products, and ads you click on), pages of our Website that you visit, the time spend or have spent on those pages, your search queries, the dates and times of your visits, the webpage you were visiting before you accessed our Service, the webpages and app(s) you use after accessing and using our Service, and demographics such as gender and age of visitors and interest-based information (i.e. “session cookies”). A “cookie” is a small amount of data that is placed on your device, which may include a unique identifier. Cookies are sent to your browser from the Services and stored on your device. We use cookies to recognize devices and to collect information about Service users as described above. You may be able to set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. Various browsers may offer their own management tools for removing these types of tracking technologies. If you disable cookies, you may not be able to take advantage of all the features of the Services.
Google Analytics and Cookies. Some of the information we receive is obtained through the use of first-party and third-party beacons, scripts, and tags. The cookies we use on our Service are served by Google Analytics. When you visit our Service for the first time, you will have the option to enable or disable certain cookies. Information on how to opt-out of the Google Analytics browser add-on can be accessed at https://tools.google.com/dlpage/gaoptout/.
How Does Targeted Advertising Work? For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
Cookies, Trackers, and Targeted Advertising. You can opt-out of targeted advertising by using the links below:
Facebook: https://www.facebook.com/settings/?tab=ads
Google: https://www.google.com/settings/ads/anonymous
Instagram: https://www.facebook.com/help/instagram/2885653514995517?locale=en_US
Opting out of Targeted Advertising. Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION
We have put in place contractual and other organizational safeguards with our agents (see further below) to ensure a proper level of protection of your Personal Information. We store our data, including Personal Information, on servers located in the United States and Canada. By submitting information, you agree to this transfer, storing, or processing of your Personal Information in the United States and Canada. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada under lawful access regimes or court orders.
DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES
Disclosure of Statistical Data. We may disclose aggregate statistical data to our partners and clients, such as advertisers and other third parties, who may use the data for business purposes. This information does not include any Personal Information.
Service Providers and Business Partners. We may from time to time employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide information and services to you. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third-party companies and individuals employed by us to facilitate our business, including database management, web analytics, and general improvement of our products and services.
Other Users. In using the ÀLA.HAUSSE platform/service, your Information will be shared with other users, including to sellers/lenders when you make a purchase or rent on the Service, or to the broader user base when You upload Information publicly. We do not control how other users will utilize Your Information.
Publicly. Most of the Personal Information you supply to us when you register or update your profile is displayed on your profile, and that information is intended to be shared with other users, in order to encourage trust, community building, and getting to know other ÀLA.HAUSSE users. Your images, postings, and other content on the Site are also meant to be seen by the general public. We may show this content on our Services and then distribute it to a larger audience via third-party sites and services. That information can be collected and utilised by others after it is placed on publicly available web pages. Because we have no control over who reads your posts or what other users do with the information you willingly give, it is critical that you do not include any sensitive, secret, or other information in your posts that you do not want to be shared. By using the LA.HAUSSE platform, you agree to share what you post online with a wider audience of LA.HAUSSE platform users and Third Parties as described in this agreement and our Terms of Service. While you will still be able to modify and remove publicly posted information on the Service, you will not be able to edit or delete information that has been cached, collected, and stored elsewhere by others.
Business Transfers. If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
With Your Consent. If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain your express consent as required under applicable privacy laws.
As Required by Law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by applicable law. We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to, satisfy any applicable law, regulation, legal process, or governmental request; enforce our contracts or user agreement, including investigation of potential violations hereof; and detect, prevent, or otherwise address fraud, security or technical issues. This disclosure of information may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of our Privacy Policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.
Feedback. Any feedback/reviews we receive from you may be shared and published. Your user name and home city may be used to identify you. From time to time, we may post any feedback/reviews on the Service. If you leave comments on a blog, APP store reviews, Google Reviews, or forums associated with LA.HAUSSE, or on the LA.HAUSSE Service, you should be aware that you have no reasonable expectation of privacy, and that any Personal Data you submit there can be read, collected, or used by other users of these forums, or the Service, and could be used to send you unsolicited messages. We are not responsible for any personally identifiable information you provide in your comments or reviews.
SECURITY
The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect the Personal Information that you provide to us. We have implemented procedures designed to limit access, input, transmission, security of availability, separation, and dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you. Employees and members of ÀLA.HAUSSE and/or Board of Directors are required to sign a confidentiality agreement binding them to maintaining the confidentiality of all personal information to which they have access.
RETENTION
We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.
ACCESS, CORRECTION, AND ACCURACY
You have the right to access the Personal Information we hold about you to verify the Personal Information we have collected with respect to you and to have a general account of our uses of that information. Upon receipt of your written request, ÀLA.HAUSSE reserves the right to verify any such requests, and may charge you a fee for such request, where allowable. After verification, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances, we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner. We shall not store your personal information for any longer than is necessary for the purposes for which it is processed. We may keep your information for as long as necessary to comply with applicable government laws, regulations, investigations, or processes, or for backup, archiving, audit, legal, or other similar purposes. We will make every reasonable effort to keep your Personal Information accurate and up to date, and, if applicable, we will provide you with mechanisms to update, correct, delete or add to your Personal Information. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
WITHDRAW CONSENT. You have the right to revoke any consent you have given to ÀLA.HAUSSE at any time. We will verify your information and process your request to withdraw permission after we get your written request. Revocation of such consent, on the other hand, may limit or restrict Your use of or access to our Services.
DATA ABOUT OTHERS. Through the Service, you can recommend friends, share information, and post third-party contact information. You agree and indicate that you have the legal authority to post such information when you offer it. We rely upon you to obtain whatever consents may be required by law to allow us to use such information. You or the third party to whom you’ve submitted information may contact us to request that this information be removed from our database.
CALIFORNIA PRIVACY RIGHTS This Section 8 provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (the “CCPA”). For more details about the Personal Information ÀLA.HAUSSE has collected over the last 12 months, please see the section “Information you provide us” above. We collect this Personal Information for commercial purposes described above. ÀLA.HAUSSE does not sell (as that term is defined in the CCPA) the Personal Information we collect. Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this Personal Information), to delete their Personal Information, to opt-out of any “sales” or “sharing” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information below. We will verify your request using the information associated with your account, if available, including your email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used, or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Service or sending you an email prior to the change becoming effective. You are bound by any changes to this Privacy Policy when you use the Services after such changes have been first posted.
ADDITIONAL INFORMATION, REQUESTS, AND QUESTIONS:
Questions regarding this Privacy Policy or our privacy practices should be directed to hello@alahausse.ca.
Last Updated: January 22nd, 2022