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Privacy Policy

1. OVERVIEW

1.1 Protecting your personal data and privacy is extremely important to us. We want to create a safe environment and be transparent in the way we deal with your information. In order to be a member of 99dresses you must first read and agree to the terms of this Privacy Policy. As part of the normal operation of our services we collect, use, process and, in some cases, disclose information about you to third parties to facilitate your use of the Site. This Privacy Policy governs the information we collect about you and your use of information we provide to you. By accepting this Privacy Policy and the Terms of Use agreement, you expressly consent to our use and disclosure of your personal information in the manner prescribed in this Privacy Policy. This Privacy Policy is incorporated into and subject to the 99dresses Terms of Use agreement. Defined terms used in this Privacy Policy have the same meaning as given to them in the Terms of Use agreement

2. Minors

2.1 Persons under the age of 15 years are not eligible to use our services and we ask that such children do not submit any personal information to us. If you are 15 years of age and over but under the age of 18 years, you can use this service only in conjunction with and under the supervision of your parents or guardians.

3. Information We Collect

3.1 Our primary purpose in collecting personal information is to provide you with a streamlined, smooth, efficient, safe and customised trading experience. This allows us to provide services and features that most likely meet your needs and to customise our services to make your experience safer and easier. We only collect personal information about you that we consider necessary for this purpose and to achieve this goal.

3.2 To fully use our services, you will need to register for our app, optionally using Facebook. We will retrieve from Facebook only profile details that we have your permission for. This streamlines the registration process in becoming a member of 99dresses. Also on the App members will be known by their own name to facilitate transparency and social networking. Under some circumstances we may require additional information such as your delivery address, if you are a winner, or necessary financial information if you are claiming an item. We use your financial information, including to verify your name, address, and other contact information.

3.3 We automatically track certain information about you based upon your behaviour on our Site. We use this information to do internal research on our users' demographics, interests, and behaviour to better understand and serve you and our community. This information is compiled and analysed on an aggregated or individual basis. This information may include the URL that you just came from (whether this URL is on our Site or not), which URL you next go to (whether this URL is on our Site or not), what browser you are using, and your IP address.

3.4 We use data collection devices such as "cookies" on certain pages of our Site. "Cookies" are small files placed on your hard drive that assist us in providing customised services. We also offer certain features that are only available through the use of a "cookie". We also use "cookies" to allow you to enter login details less frequently during a session. Cookies can also help us provide information which is targeted to your interests. Cookies are stored on your hard drive, not on our Site. Most cookies are "session cookies," meaning that they are automatically deleted at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Site and you may be required to re-enter your login details more frequently during a session.

3.5 Additionally, you may encounter "cookies" or other similar devices on certain pages of our Site that are placed by third parties. For example, if you view a web page created by a user, there may be a "cookie" placed within that web page. We do not control the use of cookies by third parties.

3.6 If you choose to trade on our App, we collect information about your trading behaviour. We also collect other users' comments about you in our feedback area.

3.7 If you choose claim items then we require your credit card information to process the payment. We do not ever see or store any of your credit card information ourselves. This information is stored securely by an accredited 3rd party, Stripe.

3.8 If you choose to post comments or leave feedback for other users, we will collect and store such information that you disclose to us and which is necessary for us to achieve our primary aim of facilitating trading.

3.9 If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Site, we may collect such information in a file specific to you.

3.10 If you register for 99dresses on another web site or use a web site providing a service for 99dresses or a web site that helps facilitate your activity on 99dresses, that web site may provide personal information about you and your transactions back to 99dresses.

3.11 If you win an item, your address will be printed on the shipping label which will be emailed to the giver. If your item is won, your address will be listed as the return address on the label.

3.12 Your full name will be displayed at times on 99dresses. We do not use usernames, as we believe our community will function better without anonymity. If you are concerned about privacy, you are permitted to change your last name to something different.

4. How We Use Your Information

4.1 We use personal information about you (including but not limited to the information in the file we maintain about you, and other information we obtain from your current and past activities on the Site) to facilitate safe trading on the Site, resolve disputes, troubleshoot problems and enforce our Terms of Use agreement. We may look at multiple users to identify problems or resolve disputes and in particular we may peruse your information to identify users using multiple identities. We may also share your information with any related entities or affiliates, trading associates and joint venture partners to help coordinate the services we provide to you, enforce our terms and conditions, prevent fraud and promote trust and safety and allow 99dresses and these related entities and affiliates to provide better customer service to joint customers. Some of these parties are outside of United States of America, including PayPal Singapore (Private) Limited (in Singapore). By accepting this Privacy Policy you are consenting to the transfer of your personal information to the entities described in this section in accordance with this Privacy Policy.

4.2 You agree that we may use personal information about you to improve our marketing and promotional efforts, to analyse site usage, to improve our content and product offerings and customise our Site's content, layout, and services. These uses improve our Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safer and customised experience while using our services.

4.3 You agree that we may use your information to contact you and deliver information to you that, in some cases, is targeted to your interests, such as targeted banners, administrative notices, product offerings, and communications relevant to your use of the Site. By accepting the Terms of Use and the Privacy Policy you expressly agree to receive this information.

5. Disclosure of Your Information by Us

5.1 Although 99dresses uses industry standard practices to protect your personal information, due to technical limitations, we cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose information to the government or third parties under certain circumstances (further details of which are set out below in the "Legal Requests for Information" section), or third parties may unlawfully intercept or access transmissions or private communications. Therefore, although we use industry standard practices to protect your privacy, we cannot and do not guarantee, and you should not expect, that your personal information or private communications will always remain private.

5.2 As a matter of policy, we do not sell or rent any personal information about you to any third party. However, the following describes some of the ways that your personal information may be disclosed, and by agreeing to the Terms of Use including the Privacy Policy, you expressly agree that your personal information may be disclosed by 99dresses in the following ways: Advertisers. We can aggregate (gather up data across all user accounts) personal information and disclose such information in a non-personally identifiable manner to advertisers and other third parties for marketing and promotional purposes. However, in these situations, we would not disclose to these entities any information that could be used to identify you personally. Certain information, such as your name, email address, password, would never be disclosed to advertisers. 99dresses Community. Throughout the Site, you are identified by your full name. This offers transparency in trading with members. As a result, other users and third parties might send you unsolicited messages and emails and be able to personally identify all of your activities on the Site. Other people can see what you like and some of your dealings, your feedback rating and associated comments, your postings on the Site, and so on. External Service Providers. There may be a number of services offered by external service providers that help you use our Site (e.g., co-branded sites, authentication services, mediation facilities). If you choose to use such optional services, disclose personal information to the external service providers, and/or grant them permission to collect personal information about you, then their use of your personal information is governed by their privacy policy. We may, for your convenience, provide some of your personal information to the external service provider offering such services. However, before we disclose your personal information to an external service provider, you will have the opportunity to see what data is about to be sent and have the ability to approve the disclosure. To prevent our disclosure of your personal information to an external service provider, you can simply not use their services. Because we do not control the privacy practices of these third parties, you should evaluate their practices before deciding to use their services. Internal Service Providers. We may use internal service providers to facilitate our services (e.g., search, discussion boards, surveys) and therefore we may provide some of your personal information directly to them. In some instances, the internal service provider may collect information directly from you (such as the situation where we ask an internal service provider to conduct a survey for us). In these cases, you will be notified of the involvement of the internal service provider, and all information disclosures you make will be strictly optional. In all cases, these internal service providers' use of information we supply them is restricted by confidentiality agreements. If you provide additional information to an internal service provider directly, then their use of your information is governed by their applicable privacy policy. Other Corporate Entities. We share much of our data, including personal information about you, with other entities committed to serving your online trading needs and related services, throughout the world, as allowed by applicable law. In fact, the personal information we collect is stored by 99dresses on its servers located in the US. In particular, we share data with Stripe. We do this to assist in providing you with a secure and efficient experience on 99dresses. To the extent that these entities, including Stripe, have access to your information, we understand that they will treat it at least as protectively as they treat information they obtain from their other users. But you should still undertake due diligence in regard to the Privacy Policy of Stripe and any such other organisation. It is possible that 99dresses could merge with or be acquired by another business entity. Should such an event occur, you should expect that 99dresses would share some or all of your information in order to continue to provide the service. You will receive notice of such event (to the extent it occurs) and we will require that the new entity follow the practices disclosed in this Privacy Policy. Legal Requests for Information. 99dresses may lawfully disclose your personal information for law enforcement or regulatory purposes. 99dressses cooperates with law enforcement enquires and other third parties to enforce laws, intellectual property and other rights. We can (and you authorise us to) disclose any information about you to law enforcement or other governmental officials as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringements, piracy or other activity that is illegal or may expose us to legal liability.

6. Disclosure of Other Users' Information by You

6.1 In order to facilitate interaction among all 99dresses members, our service allows you limited access to other users' contact information. As a seller you have access to the contact information of the buyer and as a buyer you have access to the profile information of the seller.

6.2 By entering into our Terms of Use agreement, you agree that, with respect to other users' personal information that you obtain through the Site or through a related communication or transaction, 99dresses grants to you a license to use such information only for facilitating the trading transaction and related matters.

6.3 In all cases, you must give users an opportunity to remove themselves from your database and a chance to review what information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personal information about another user to any third party without our consent and the consent of such other user after adequate disclosure.

6.4 We and our users do not tolerate spam. Therefore, without limiting the foregoing, you are not licensed to add a 99dresses user, even a user who has purchased an item from you, to your mail list (email or physical mail) without their express consent after adequate disclosure.

7. Using Email Tools

7.1 You may not use any email forwarding services that we offer to send spam or otherwise send content that would violate our Terms of Use agreement or Privacy Policy. If you forward an email through our services we do nothing other than send the email. We do not rent or sell these email addresses. We do not permanently store the email messages or the email addresses.

8. Control of Your Facebook Login

8.1 You are responsible for all actions taken with your Facebook login, including any liabilities incurred. Therefore we do not recommend that you disclose these details to any third parties. If you choose to share such details with third parties, you agree that you are responsible for all actions taken on your behalf and therefore you should review that third party's privacy policy. If you lose control of these details, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your Facebook login has been compromised for any reason, you should immediately change your password details.

9. Accessing, Reviewing and Changing Your Personal Information

9.1 In “My Profile” you must promptly update your personal information if it changes. Once posted, you cannot change or remove any public postings made in our comment areas or the feedback area.

9.2 Upon your request, we will deactivate your account, contact information, and financial information from our active databases. We will retain in our files information you have requested us to remove in some circumstances, such as to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, and enforce our Terms of Use agreement, and to comply with legal requirements. Furthermore, such prior information is never completely removed from our databases due to technical constraints and the fact that we back up our systems. Therefore, you should not expect that all of your personal information will be completely removed from our databases in response to your requests. However, such information will be deactivated from public viewing and usage by other members of 99dresses and will only be available to select 99dresses personnel.

10. Other Information Collectors

10.1 Except as otherwise expressly discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are winners or givers on our Site or other sites throughout the internet, different rules may apply to their use or disclosure of the personal information you disclose to them. To the extent that we use third party advertisers (if any), they adhere to their own privacy customs and policies. Since 99dresses does not control the privacy policies of third parties, you are subject to the privacy policies of that third party. We encourage you to ask questions before you disclose your personal information to others.

11. Security

11.1 Your Information is stored on 99dresses’ server located in the United States. We use industry standard efforts to safeguard the confidentiality of your personal information, such as firewalls and Secure Socket Layers. However, "perfect security" does not exist on the Internet and the user acknowledges this risk.

12. Notice

12.1 We may change this Privacy Policy from time to time based on your comments and our need to accurately reflect our data collection and disclosure practices. It is your responsibility to regularly check this Privacy Policy and if you are not in agreement with any changes then you should discontinue your membership and not use the Site. All changes to this policy will be effective immediately and any significant policies affecting member’s rights and responsibilities will also be notified to you separately on the Site.

Last reviewed 20 September 2013