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Privacy Policy

RENT THE RUNWAY, INC. PRIVACY POLICY

Effective Date:  January 1, 2020


The previous version of this policy can be viewed  HERE.


1.   Overview

This Privacy Policy explains how Rent the Runway, Inc. (“Rent the Runway”, “we”, or “us”) collects, protects, uses and shares information about you when you use  www.renttherunway.com (“Website”), our mobile applications (“App”), and any of our services (collectively, the “Services”), and whether you access the Services directly or through a third party. 


Please understand that, except as specifically described below, this Privacy Policy does not apply to information collected by third parties, such as other companies, or third-party websites or mobile applications, even if any are linked to or accessible through the Services.


If you have any questions or concerns about our information practices, please contact us at  legal@renttherunway.com


If you do not want information about you to be used as described in this Privacy Policy, you must stop, or refrain from, using the Services.


2.  Information We Collect

“Personal Information,” as used in this Privacy Policy, is information that directly identifies an individual, such as a person’s name, or information that reasonably allows an individual to be identified indirectly, such as email or home address or a person’s mobile phone number.  Personal Information also includes information that is directly combined with such identifying information.


Most of the Personal Information we collect is from our customers. This information falls into two (2) general categories: 


Passive Data Collection. This refers to data automatically collected from customers when they visit the Website or use the Services.


User-Submitted Information. This refers to information that customers actively submit to us, which may be provided voluntarily or as required to use our Services.


Customers also sometimes provide us with information about other individuals, such as when a customer sends a gift card or uses our referral services to tell a friend about us. In those cases, we may ask that customer to provide the recipient’s name and email address. (We may also collect Personal Information in any personalized message that is submitted with a gift card or referral.) We will automatically send the recipient email correspondence with the gift card or referral, and invite them to visit the Website or otherwise use the Services. If we receive Personal Information for a referral or gift card, we use that information for the sole purpose of sending this email correspondence, and for tracking the use of the gift card or the success of our referral program.


Passive Data Collection


As a general matter, we automatically collect certain information based on your use of and behavior on the Website and in connection with the Services. We use this information to analyze our customers’ demographics, interests, and behavior to better understand and serve you and our customer base.  We also analyze this information for security purposes, to protect the Services and customer information that we hold.  


If the information we collect automatically identifies you or could be reasonably used to identify you, then it is treated as Personal Information. Also, if we directly combine any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this Privacy Policy. But in many cases, the information that we collect passively is only used in de-identified or aggregated forms, which do not identify any individual.


We collect passive data in the following ways: 


Mobile Device Information


When you download or use our App, we receive information about your mobile device. We register your device, and we may use the identifier to send you push notifications about your transactions via the Services.


Log Files


Like most websites, we automatically receive and record certain information about our customers’ behavior on our Website or App and when using our Services. Our servers automatically gather technical information about our Website or App traffic and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and other clickstream data. We aggregate this information with other pieces of information to analyze trends, to administer and improve the Services, for example to understand customers’ use of the Website and to make inventory and purchasing decisions that will best serve our customer base. Information from log files may also be used to determine general location information such as city, state or geographic area.


Cookies, Web Beacons and Similar Technologies


A cookie is a small text file that is stored on a computer for record-keeping or tracking purposes. Web beacons (also known as pixel tags or clear GIFs), are graphics that can record whether a person has accessed particular content. We use these and other similar technologies on the Website and App and in connection with our Services.

Cookies we utilize may include session cookies, persistent cookies, or similar technologies. A session cookie expires when you close your browser. A persistent cookie is stored on your computer or device for an extended period of time. You can remove persistent cookies by following the directions provided in your Internet browser's "help" menu. You may also configure your browser to prevent cookies from being set on your computer. (Instructions should be provided in documentation for your browser.) If you reject cookies, your ability to use the Website, App and Services may be limited, and you may not be able to use certain features of the Website, App or Services. We may use cookies for the following purposes: 


Essential cookies. Essential cookies are required for providing you with features or services that you have requested. For example, certain cookies enable you to log into secure areas of our Services. Disabling these cookies may make certain features and services unavailable.


Functional cookies. Functional cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).


Performance/analytical cookies. Performance/analytical cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/analytical cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. 


To find out more information about cookies, including information about how to manage and delete cookies, please visit  https://www.allaboutcookies.org/.

We may use web beacons or similar technologies, which help manage content on the Website and in the Services by tracking what content is effective. These technologies may be used to track the online movements of customers, but in contrast to cookies, which are stored on a computer hard drive, these technologies are embedded in the Website or App.


We may also use web beacons in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. 


Third Party Advertisers

Third-party advertising companies may also use cookies, web beacons or similar technologies on the Website to collect information (such as click stream information) during your visits to our Website and other websites, as well as during your use of our Services, in order to help us provide you with advertisements about our Services that we believe are likely to be of interest to you. 


User-Submitted Information


As a general matter, we may ask you for information, or retain information, that you provide to us in order to provide our Services to you, and to better serve you and our customer base. This category of information includes information submitted electronically, via phone, and in person through our stores. We may also combine this information with Personal Information to provide you with customized and personalized Services.


We collect User-Submitted Information in the following ways:


Registration


In order to use some features of the Website, App and Services, including the rental of Rent the Runway’s inventory, you must first create an account with us and agree to the Terms of Service. To create an account, you must provide an email address and create a password. We may also ask you for your birthday. We use the email address you provide to contact you about the products and Services, and to begin to create a tailored experience for you.


Orders


If you order a product from us, we request certain Personal Information from you, whether you access the Services from our App, the Website or otherwise. You must provide contact information (including name, shipping address, telephone number) and a payment method. We use this information for billing purposes, to fill your orders and to communicate with you about your orders. If we have trouble processing an order, we will use this information to contact you. 


We record what you order and associate it with your account profile. When you return an item, we may ask you for information about your experience, such as, if you wore it and for information regarding how it fit. We record that information to better personalize our Services for you and to improve our Services for others.


Personalization of Service


In order to improve your customer experience, we may request personal characteristics, such as your height, bust, dress size, style and fit preferences, your birthday, and the date and occasion for your rental. We may also ask for your feedback and rating of our products. All of this information is voluntary and helps us improve our Services by enabling us to create a tailored experience for you and our other customers.  Although we believe that providing this information will improve the Services we can offer to you, and your experience of the Services, we will not require you to provide it. (Also, although we may request information about personal physical characteristics, we do not ask for uniquely identifying biometric information.)  We may also collect geolocation information from your mobile device, if you give us permission through your mobile device to do so.


Surveys or Contests


We may provide you the opportunity to participate in surveys or contests on our Website or in connection with our Services.  If you participate, we will request certain Personal Information. The requested information typically includes contact information (such as name and email address) and demographic information.


We may use this information to notify contest winners and to award prizes, to monitor traffic to our Services, to improve the Services, and to send participants an email newsletter. 


Additional information practices (and terms and conditions) may apply to any survey or contest, which will be made available with the survey or contest. Please carefully review any additional information provided. 


Third-Party Account Credentials


If you choose to provide us with your third-party account credentials to such services as Google or Facebook, you understand that some content and/or Personal Information may be shared between the third-party service and us. Any information collected by a third party-service will be used in accordance with that third party’s privacy policy, which we encourage you to review and consider. 


Public Feedback and Discussion Boards


If you choose to post messages to public message areas or leave feedback for others, that information may become available to anyone. We are not responsible for the use by others of the information you publicly disclose. Additionally, we may, but are not obligated to, collect the information you post in public message areas to resolve disputes, provide customer support and troubleshoot problems as permitted by law. 


Please be careful and closely consider disclosing any Personal Information in public message areas.


3.  How We Use Your Information

The purposes and ways that we may use Personal Information about you are described throughout this Privacy Policy, often in connection with the kinds of Personal Information we collect. Other uses of Personal Information are described below. 


In addition, we may use aggregate, statistical, and deidentified data, which does not specifically identify any individuals, for any purpose.


General Uses of Your Information


We generally use the information we collect, including Personal Information about you, for the following purposes:
To Provide Our Services. We use your Personal Information to provide our Services to you, including:


    - To present you with products, information and content through the Services, including     personalization of the Services;

    - To process transactions, including financial transactions, related to your use of the     Services; 

    - To assist you in finding a location to return an item, using location or geolocation     information you provide to us; and

    - To respond to your questions or requests.


For Communications and Marketing. We use your Personal Information to communicate with you and provide you with information about Rent the Runway and our marketing partners. 


To Develop and Improve Our Services. We may also use your Personal Information as we work to continually improve our Services, our business and our operations. For example, by:

    - Analyzing usage or interest in certain features, or identifying items and areas of interest     to our customers.


For Compliance, Fraud Prevention and Safety. We may use your Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: 

    - Protect our, your or others’ rights, privacy, safety or property;

    - Enforce the terms and conditions that govern use of our Services, including for legal     claims; and 

    - To prevent, identify, investigate and deter any fraudulent, harmful, unauthorized or     illegal activity.


To Comply with Law.  We may use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process.


As Described or with Your Consent.  We may use your Personal Information for any other purposes that we describe at the time we collect your Personal Information, or otherwise with your consent.


Communications from Us


We use your contact information to communicate with you about Rent the Runway and our marketing partners in the following ways:


    - To provide newsletters, marketing emails or push notifications with special promotional offers, updates and other relevant marketing content;

    - To provide announcements about the Services; 

    - To communicate with you about the Services and your account, including updates about     the status of your orders; and

    - To verify your identity and address for your orders and rentals. 


We may communicate with you via phone, email, text messages and push notifications to your mobile device. Standard call, message and data rates charged by your mobile carrier may apply to text messages or other communications received on your mobile device.


4.  How We Disclose Your Information

We may disclose aggregate, statistical, and deidentified data, which does not specifically identify any individuals, for any purpose.


We may also share Personal Information about you, in general:


- As necessary to provide the Services; 

- With service providers;

- With our corporate affiliates and business partners; and 

- For legal reasons or as required by law.


The purposes and ways that we may share Personal Information about you are described below in more detail.


Rent the Runway Partners


Rent the Runway engages in marketing and promotional activities with carefully screened brands, or, “Partners,” which we think will appeal to our customer base. From time to time, Partners may also be provided with non-personally-identifying or aggregate information demographic information of customers on our Services and statistical information about buying behavior, and Partners may be given opportunities to market to select segments of our customer base indirectly. When we share aggregate or non-personally identifiable customer data, we do so in a way that we believe cannot reasonably be linked with a customer’s Personal Information.


Service Providers


We may provide Personal Information to third parties for use in performing research and business functions (e.g., mailing, maintenance, security, data analytics, communications, CRM, database management services, credit card payment processing or data hosting) on our behalf. These service providers agree to use your Personal Information only in accordance with our instructions, with information used only as described in this Privacy Policy and for no other purpose than to provide the contracted-for services.


Corporate Affiliate Parties


We may share some or all of your Personal Information with our affiliates (including a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us), in which case we will seek to require those affiliates to honor this Privacy Policy.


As Required by Law 


We may disclose Personal Information if we have a good-faith belief that doing so is required under applicable law, for example if we receive a subpoena or other judicial or administrative order or otherwise required by law. This may include responding to legal requests from jurisdictions outside of the United States, where we have a good faith belief that the response is required by law in that jurisdiction.


In Connection with Business Transactions


We may disclose Personal Information in certain corporate transactions, such as in connection with an actual or proposed merger, acquisition, or other sale of or transfer of all or part of our business or assets, including as part of a bankruptcy, liquidation, or other insolvency proceeding.  


In the event of a change in ownership of Rent the Runway, or a merger with, acquisition by, or transfer or sale of all or a portion of our assets to another entity, we reserve the right to transfer all of your Personal Information, including email addresses and other information about you collected by us (in accordance with this policy), to that entity.


To Protect Rights


Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of the Terms of Service or our other agreements; take precautions against liability; protect the rights, property, or safety of Rent the Runway, any individual, or the general public; maintain and protect the security and integrity of our Services or infrastructure; protect ourselves and our Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims or allegations; or assist government enforcement agencies.


5.  Third Party Websites

In the event that that we provide links to other websites that we do not control, whether or not those other websites refer to our branding, this Privacy Policy does not apply to those other websites. Visitors to those websites are advised to carefully read the policies on those individual websites.


6.  Your Choices


Accessing and Requesting Changes to Your Personal Information

If you are a customer of Rent the Runway, you may review and change your Personal Information through your customer account.  


If you do not have a customer account with Rent the Runway, or if you cannot access or change any of your Personal Information through your account, but you still wish to inquire about, access, correct, update or delete Personal Information that we may hold about you, please email us at  privacy@renttherunway.com. Please understand that, before responding to your request, we may ask you for additional information in order to verify your identity, or take other actions that we believe are appropriate in order to verify your identity.


Please also understand that we may not be obligated or able to alter or delete your Personal Information and may retain information to provide you with requested services or fulfill obligations to you, for security reasons, if we are required under applicable law or regulations, for internal business use or for other valid reasons. We are also not obligated to comply with requests that are unreasonably burdensome or expensive, or with requests that would interfere with the rights of another individual.  In some circumstances, we may charge a reasonable fee to fulfill your request.


Communications Preferences


If you would like to change the types of communications you receive from us or how you receive communications from us, or if you would like to opt out of promotional communications, you may do so at any time by updating the communication preferences provided in your customer account. 


If you do not have a customer account, you may also use the unsubscribe links and instructions that will be present in any promotional emails or other communications that we send. 


Please understand that, even if you opt out of marketing or promotional communications, we may continue to send non-promotional communications such as confirmations of transactions, changes to the Services or other information about your use of the Services.


“Do Not Track” Settings


Our Website and Services are not at this time configured to read or respond to “do not track” settings or signals in your browser headings.


Tailored Advertisements and Passive Data Collection


Rent the Runway also partners with advertising companies to place our advertising on third-party websites that we believe will be of interest to you. As described elsewhere in this Privacy Policy, these advertising companies may collect information about your visits to our Website using cookies, web beacons and similar technologies, and these advertising companies may collect information over time and across other websites. In using tailored advertising, we comply with the Network Advertising Initiative (“NAI”) self-regulatory 2018 Code of Conduct, Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising (“OBA Principles”).  


To make choices about Interest-Based Ads from participating third parties, including to opt out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt out pages, which are located at  https://www.networkadvertising.org/choices/ https://optout.networkadvertising.org/ or  https://www.aboutads.info/choices/.  


You may also learn more about your choices with respect to data collection by third parties, including about opting out or changing your preferences, at those third parties’ websites. For Google, please see  www.google.com/privacy_ads.html, or you may have the option to opt out of Google's use of cookies using the Google Analytics Opt-out Browser Add-on at  https://tools.google.com/dlpage/gaoptout/. Information about Facebook advertising may be available at  https://www.facebook.com/help/568137493302217


7.  Security

We use reasonable security measures to protect against the loss, unauthorized access, misuse, alteration and destruction of Personal Information under our control, both during the transmission and once we receive it. 


Although we make good faith efforts to maintain the security of such Personal Information, no method of transmission over the Internet or method of electronic data storage is 100% secure, and we cannot guarantee that the information will remain free from unauthorized access, use, disclosure, or alteration. While we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent hackers or other unauthorized persons from illegally accessing or obtaining this information.

 

8.  Children’s Privacy

Rent the Runway and the Services are not intended for or directed toward children under 13 years of age, and children should not use the Services for any purpose unless they have the consent of, and are under the supervision of, a parent or guardian. We ask that individuals do not provide Personal Information through our Website or Services, and if we learn that we have collected or received Personal Information from a child under 13 years of age, we will delete that information 


Additionally, we may collect Personal Information from teenagers between the ages of 13 and 18, but only if such an individual is of legal age to enter into a binding contract under applicable law, or with the consent and supervision of a parent or legal guardians, as permitted by law. 


If you are the parent or legal guardian of a child under 13 years of age who has registered on the Website or App or you believe has otherwise provided Personal Information to Rent the Runway, please contact Rent the Runway at  legal@renttherunway.com to have the account terminated and information deleted.


If you believe that we may have inadvertently collected any Personal Information about a child aged 13 years or younger, please contact us at  privacy@renttherunway.com or as provided in the “Contact Us” section below.


9.  Notices to California Residents

If you are a resident of the state of California, California’s “Shine the Light” law permits you to request information regarding the disclosure of your Personal Information by us to a third party for the third party's direct marketing purposes. To make such a request, please send an email to legalinfo@renttherunway.com  privacy@renttherunway.com.


In accordance with the California Consumer Privacy Act of 2018 (“CCPA”), please see the following summary of Personal Information that we have collected in the past twelve (12) months (preceding the effective date of this Privacy Policy), as well as the sources of that Personal Information, the purposes of collection, and third parties with who we have shared such Personal Information in the past twelve (12) months.  


(This information is provided based on the categories of Personal Information and business and commercial purposes defined within the CCPA.) 


Categories of Personal Information

Sources of Personal Information

Purposes of Collecting Personal Information

Third Parties with Whom We Share Personal Information

Identifiers (such as name, email, postal address, phone number, other unique identifying codes)

User-submitted information


Passive data collection

Provide the Services


Internal research, including to maintain and develop the Services 


Marketing

Security and detection of unauthorized activities

Service providers


Affiliates


Partners

Financial, medical or insurance information (such as payment cards and financial account numbers)

User-submitted information 

Provide the Services, including payment processing


Security and detection of unauthorized activities

Service providers

Characteristics of protected classifications under California or federal law (such as age, gender, race, citizenship)

User-submitted information

Provide the Services


Internal research, including to maintain and develop the Services

Service providers


Affiliates


Partners

Commercial information (such as purchases and transaction history)

User-submitted information


Passive data collection

Provide the Services


Internal research, including to maintain and develop the Services 


Marketing


Security and detection of unauthorized activities

Service providers


Affiliates


Partners

Internet and network activity information (or usage data, such as browsing or search history or interaction with websites)

Passive data collection

Provide the Services

Internal research, including to maintain and develop the Services 


Marketing


Security and detection of unauthorized activities

Service providers

Geolocation data

Passive data collection (with permission)

Provide the Services


Internal research, including to maintain and develop the Services 


Marketing

Service providers

Sensory information (such as photos or other audio or visual recorded electronic information)

User-submitted information

Provide the Services (public feedback and discussion boards)

Service providers


Publicly available 

Inferences drawn from any Personal Information collected

User-submitted information

Passive data collection

Provide the Services


Internal research, including to maintain and develop the Services 

Service providers


Affiliates


Partners


In addition to those purposes described above, we may use or disclose any Personal Information that we collect as necessary to comply with applicable law or legal obligations as described in this Privacy Policy.


Sale of Personal Information. We do not “sell” your Personal Information, as defined under the CCPA, and we have not sold your Personal Information in the past twelve (12) months (preceding the effective date of this Privacy Policy).


California Residents’ Rights under the CCPA. Under the CCPA, California residents have certain rights regarding their Personal Information.  Subject to certain exceptions, California residents have or may exercise the following rights:


Right to Know about Personal Information Collected, Disclosed or Sold. A California resident has the right to be informed about the information practices of a business, and the specific pieces of Personal Information that a business holds about that resident.


Right to Request Deletion of Personal Information. A California resident may request that a business delete their Personal Information. 


Right to Opt-Out of the Sale of Personal Information. A California resident has the right to opt-out of the sale of their Personal Information by a business.


Right to Non-Discrimination for Exercise of Consumer Privacy Rights. A California resident has the right not to receive discriminatory treatment by a business for the exercise of privacy rights provided by the CCPA.


To submit requests to Rent the Runway to exercise these rights, California residents may use the following methods:


1)  Call us at +1 (888) 914-9661 and enter PIN: 996 984

2)  Submit an online request using  this webform 


Please understand that we are only obligated to respond to verifiable consumer requests.  If we receive a request for information about you, we need to know that it is actually coming from you, or somebody legally authorized to act for you.


We may implement authentication procedures that are appropriate to the nature of the personal information requested. We may also use any information that we have already collected about you in order to verify your request. Also, if we collect any personal information to verify your request, we will only use that information to verify your request.


Please remember that we are only obligated to respond to a request for access twice within a 12-month period.


10.  Changes to this Privacy Policy

We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the Website, with the effective date posted at the top of the Privacy Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make material changes to our Privacy Policy or how we handle your Personal Information, or if we are going to use any Personal Information in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will try to notify you of such changes reasonably in advance. By using our Website or Services after the effective date, you are deemed to consent to our then-current Privacy Policy.


11.  Contact Us

If you have questions, concerns or feedback regarding this Privacy Policy or our information practices, you can send an email to us at  legal@renttherunway.com or by postal mail at:


345 Hudson St, Floor 6, New York, NY 10014

Attn: Legal Department




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