Privacy Policy

Last Updated date: September 15, 2023

Pollen Technologies, Inc. (“we,” “us,” “ours” or Pollen”) respects your privacy. This privacy policy (“Privacy Policy”) explains how we collect, process, store and share personal information in connection with our website located at https://pollenreturns.com/ (including all subdomains), our logistics and return services, and our other services (collectively, the “Pollen Services”) and the operation of our company. If you are an individual, this Privacy Policy also provides you with important information about your personal information rights with respect to personal information that we control and how to exercise them.

By visiting our website, using the Pollen Services, or otherwise providing personal information to us, you acknowledge that you have read, understand and accept our privacy practices and policies outlined below, and you consent that we may collect, process, store and share personal information as described in this Privacy Policy, subject to the exercise of individual rights as explained in this Privacy Policy.

1.    Notice at Collection of Personal Information

Definition of Personal Information

We collect, process, store and share information that identifies, relates to or could reasonably be linked, directly or indirectly, with a particular individual or household (“personal information”). Personal information does not include information publicly available from government records, or which is not personal, like anonymous, deidentified or aggregated data (even if it originally comes from personal information).

Categories of Personal Information We Collect

Depending on your relationship with us, we may collect, process and store, and share with third parties, the following categories of personal information:

  • Contact information, if you initiate a transaction or utilize Pollen Services, such as your name, address, phone number and details regarding your order
  • Account credentials, if you create an account on our website or in the Pollen Services, such as usernames, passwords and account preferences
  • Financial information, if you transact with Pollen, including bank account details, wire transfers,  transaction history, routing numbers and credit card and/or debit card information
  • Commercial information, such as the billing details we use to bill you for the Pollen Services, your billing and payment history, products or services you purchased, obtained or considered, or other of your purchasing histories or tendencies
  • Professional or employment related information, such as your job title, employer and related information
  • Internet and device information (including identifiers, activity and analytics), such as IP address from which you are accessing our website and other information we automatically collect through cookies and similar technologies used on our website and in connection with Pollen Services, including internet service provider, browser type, operating system and language, any website from which you linked to our website, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of our website you visit, number of links you click while on our website, search terms, and other data regarding your use of our website
    • For more information on our use of cookies, please see the below section called, Our Use of Cookies
  • Approximate geolocation when you are using our website and/or using Pollen Services
  • Preference information, including preferences related to marketing, privacy or communications
  • Inferences drawn from any of the personal information listed in this section; for example, to create a profile of an individual’s preferences and characteristics
  • Other information you choose to provide to us, such as how you heard about the website or Pollen Services, your views on the effectiveness and ease of use of our website, and other information you choose to provide when you communicate with us

Our Business Purposes for Collecting and Sharing Personal Information

We collect, process, store and/or share all of the categories of personal information identified above (unless a limited subset of categories is indicated) for our following business purposes, our legitimate interests and the legitimate interests of third parties to:

  • Provide our website and services, including the use of Pollen Services, facilitating transactions between you, us and our retailers
  • Administer, protect, support and improve our website and services, including to keep our website and the Pollen Services working, safe, and secure by troubleshooting, testing, conducting data analysis, making updates, and detecting and preventing fraud (including through identity verification, as applicable); improve or customize our website and Pollen Services, including to provide relevant content to you; develop new services or products; analyze and monitor usage, trends or other activities related to our website and services; respond to requests and inquiries from, or otherwise communicate with, you, retailers and third parties; contact you to ask for your views on our website or services and notify you about important changes, developments at Pollen and transactions involving you, Pollen, and/or retailers, as applicable
  • Support our business operations, which consist of conducting data analysis and research to support, improve and grow our business operations, billing and collecting payment for our services, preparing and filing tax forms and other documents, and sharing personal information with third parties who provide services that support our business operations to enable them to provide such services, including website hosting, email delivery services, text messaging services, customer service and auditing services
  • Market our and third-party products and services to you, including through targeted advertising, including to send you information we believe may be of interest to you, such as relevant announcements, promotional messages, notices and other information related to your current of future use of our website, the Pollen Services or your interests including targeted and cross-context behavioral advertisements; present products, services and offers tailored to you, relevant to your interests and geography; or invite you to participate in user testing and surveys, sweepstakes, competitions and similar promotions
  • Aggregate personal information, including aggregating, anonymizing and deidentifying personal information so that it is no longer personal information
  • Meet legal and compliance requirements, including to perform audits, monitoring and reporting; support information security and anti-fraud operations; investigate and respond to disputes; exercise and defend legal claims; protect the rights, property or safety of our users, retailers, you, us or a third party; act in the overriding public interest as permitted by law; respond to legal process (including subpoenas) and governmental, court or law enforcement requests, investigations or orders; and comply with and enforce applicable laws, regulations, policies, procedures and agreements
  • Evaluate or conduct business changes, including a merger, acquisition, sale, equity or debt financing, reorganization, dissolution, bankruptcy, or other transaction in which a third party invests in, finances or acquires control of our business or assets (in whole or in part), or any similar corporate event to any of the foregoing

Pollen collects and processes personal information for the purposes of automated decision-making or profiling (meaning the automatic processing of your personal information to identify your preferences and interests).

Under the laws of some jurisdictions, we must be able to describe the legal bases on which we rely to process personal information. We primarily rely on the legitimate interests, described above, to process personal information when not overridden by an individual’s data protection interests or fundamental rights and freedoms. Other legal bases for our processing of personal information include when the processing is necessary to perform a contract with you, we have a legal obligation to process the personal information or we have your consent to process the personal information.

Categories of Third Parties Parties Whom We Share Your Personal Information

We share personal information with the following categories of third parties:

  • Our affiliates (“Affiliates”) for purposes consistent with this Privacy Policy, including to support marketing, sale and delivery of our website and Pollen Services  
  • Our vendors and service providers (“Vendors”) who provide us with services and products that help us provide services or operate our business but only to the extent needed to enable them to provide such services or products, including order fulfilment, billing, customer service, data storage, disaster recovery services and sales support companies; hosting, technology and communication providers; cyber security and other security providers; our attorneys, advisors, auditors and accountants; and our analytics providers
  • Advertisers (“Advertisers”), including our commercial partners, entities for which we are acting as an agent, licensee, application host or publisher and other third parties that wish to send you information about their products and services that may be of interest to you, as well as parties that help with our and third-party marketing and advertising, including ad networks, data brokers, marketing providers, and cooperative databases
  • Retailers (“Retailers”), including information disclosed by you to Pollen concerning your return, exchange and/or order generally, may be shared with the retailer, for the purposes of facilitating the return, exchange and/or transaction. We may also share information collected from you to retailers in order to improve our website and the Pollen Services, for marketing purposes, to customize products, services and offers provided to you by retailers, maintain our relationships with existing retailers and enhance our network of retail partners
  • Parties you access, authorize or authenticate (“Authorized Parties”), including third parties you access through the services, such as identity verification providers and payment processors, as applicable; information provided to such third parties are subject to such third parties’ privacy policies. Please consult the applicable third party’s privacy policy for more information on how the third party uses your personal information
  • Parties for legal purposes (“Legal Parties”), including governmental authorities, law enforcement, courts or other third parties in connection with any of the activities set forth in the bullet beginning with “Meet legal and compliance requirements” in the section above called, Our Business Purposes for Collecting and Sharing Personal Information
  • Parties for business changes, for example, personal information that we collect may be shared with or transferred to a third party if we consider or undergo a merger, acquisition, sale, equity or debt financing, reorganization, dissolution, bankruptcy, or other transaction in which a third party invests in, finances or acquires control of our business or assets (in whole or in part), or any similar corporate event to any of the foregoing

Notice of Right to Opt-Out of Sale/Sharing

We may share the personal information that we collect (except for financial information, such as credit card information, as applicable) for cross-context behavioral advertising or targeted advertising.  Depending on laws that may be applicable to you, when we share your personal information, it may constitute a “sale” of your personal information (for example, when we share your personal information in exchange for money or other valuable consideration).

Our business purposes for selling your personal information or sharing your personal information for cross-context behavioral adverting or targeted advertising are those purposes identified in the bullet beginning with ” Market our and third-party products and services to you, including through targeted advertising,” in the above section called, Our Business Purposes for Collecting and Disclosing Personal Information.

You have the right to opt out of our sale of your personal information or our sharing of your personal information for cross-context behavioral advertising or targeted advertising.

To opt out, click Do Not Sell or Share My Personal Information.

To make choices about interest-based ads from participating third parties, including to opt-out of receiving interest-based ads from participating third parties, please visit the Network Advertising Initiative at http://www.networkadvertising.org/choices/or the Digital Advertising Alliance at http://www.aboutads.info/choices.

 

Retention of Personal Information

We retain personal information for as long as we deem to be necessary or advisable for our business purposes described in the above section called, Our Business Purposes for Collecting and Sharing Personal Information (such as providing services to you and our retailers, as applicable). This may include keeping your personal information after you have stopped using our services; for example, we may retain your personal information to market products and services to you (unless you opt-out), comply with legal obligations, resolve disputes or collect fees owed. We may retain your personal information longer pursuant to a specific legal reason or requirement. When our retention period ends, we may either delete your personal information or retain it in a form such that it does not identify you personally.

2.    Applicability of this Privacy Policy

This Privacy Policy covers how we treat personal information that we acquire from you, or in connection with our website or services provided to you and our retailers, or in connection with our other business or interactions with you and our retailers, as applicable.

 

This Privacy Policy does not apply to information that we collect in connection with your employment or application for employment at Pollen.

Sources of Personal Information

We collect personal information from the following categories of sources:

  • Directly from you, such as when you initiate and/or authorize a transaction using our website, sign up to receive our newsletters, request a demo, request information about our services, contact us via our website, or when you otherwise communicate or interact with us in any way, including via mail, email, phone, chat, browser form, online request form, QR code or social media
  • Indirectly from you, for example, we collect cookie data and other information from your device, browser or activity on our website or when utilizing Pollen Services
  • From third parties or public sources, for example, from our analytics providers and social media pages, as applicable

Generally, you are not under a statutory or contractual obligation to provide personal information to us. However, if you do not provide the personal information required for us to provide certain services, verify your identity or process transactions, we may be unable to offer services or otherwise conduct business with you and/or facilitate certain transactions between you and our retailer partners.

Third-Party Links

Our website and Pollen Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal information about you. We do not endorse or control these third-party websites or applications and are not responsible for their privacy practices or any information on their websites or in their applications. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal Information of Others You Share with Us

You may not disclose the personal information of another individual to us unless you have their prior written consent or are otherwise authorized under applicable law to share their information with us. To the extent that you provide another individual’s personal information to us or we collect another individual’s personal information on your behalf, you acknowledge and agree that you are responsible for compliance with all applicable laws concerning such personal information, including:

  • providing all applicable notices
  • receiving the proper authority or consent to allow us to collect, store, process and share such personal information
  • responding to data subject requests

Aggregated Data

We may anonymize, deidentify and/or aggregate data so that it no longer constitutes personal information.  We may share anonymized, deidentified and/or aggregated data that does not identify you personally with third parties, including our Affiliates, Vendors, Advertisers and Retailers. We may also disclose aggregated user statistics in order to describe our Pollen Services and our website to current and prospective business partners and to other third parties for other lawful purposes.

We may disclose non-personal information to any third party for any reason in our sole discretion.

Personal Information of Children

We do not collect any personal information directly from children under 16 years of age.

If you are a child under the age of 16, please do not attempt to use our website or services or send us any personal information. If we learn we have collected personal information directly from a child under 16 years of age, we will delete that data as quickly as possible. If you believe that a child under 16 years of age may have provided personal information to us, please contact us at help@pollenreturns.com.

To our knowledge, we do not sell, or share for cross-contextual behavioral advertising or targeted advertising purposes, the personal information of children under the age of 16.

3.    Your Privacy Rights and Choices

Notice of Your Personal Information Rights

With respect to personal information that we control, subject to exemptions and limitations provided by applicable law, if you are an individual you have the right to:

  • Know or access – request that we disclose certain information to you about our collection and use of your personal information:
  • Whether or not we are processing your personal information
  • The categories of your personal information we have collected
  • The categories of sources for your personal information we have collected
  • Our business purposes for collecting, selling or sharing that personal information
  • The categories of third parties with whom we disclosed your personal information, identifying the personal information categories that each category of recipient obtained and the purposes for sharing your personal information
  • The types of personal information we shared with third parties for third parties’ direct marketing purposes and the identities of such third parties
  • The specific pieces of personal information we collected about you and access to that personal information
  • Data portability – request a copy of the personal information you provided to us in a portable, and, if feasible, readily usable format to be transferred to you or a third party
  • Deletion – request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions under applicable privacy law
  • Correction – request that we correct inaccurate or complete incomplete personal information
  • Sale opt out – direct us to not sell your personal information at any time
  • Behavioral advertising opt out – direct us to not share your personal information for cross-context behavioral advertising or targeted advertising
  • Third-party marketing opt out – direct us to not share your personal information with third parties for third parties’ direct marketing purposes
  • Limit use of sensitive information – request that we limit the use or disclosure of your sensitive personal information to just those actions necessary to perform specific purposes outlined by law
  • We do not use or disclose sensitive personal information (for example, complete account credentials, racial or ethnic origin, age) for purposes other than purposes that would continue to be allowable after the receipt of a limitation request, including to provide services to you
  • Non-discrimination – be free from unlawful discrimination for exercising your rights under applicable privacy law

How to Exercise Your Personal Information Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a written request (via the method described below) that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.”

We may ask for information to verify your identity and process your Valid Request, such as name, phone number, email and address. For a request to opt out of sale or behavioral advertising, we do not require a verifiable request.  If applicable, we recommend that you submit the email that you used when you registered for and/or used in connection with our website or the Pollen Services. We will only use personal information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request promptly within the timeframes required by applicable privacy law (usually between 15 to 45 days depending on the type of Valid Request, with the right for us to extend the response time as necessary). We will not charge you a fee for making a Valid Request unless your Valid Request is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following method:

  • Send an email to: help@pollenreturns.com
  • To exercise your rights to opt out of sale and behavioral advertising, you may also click Do Not Sell or Share My Personal Information.

You may also authorize an agent (an “Authorized Agent“) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

In some instances, we may not be able to honor your request. For example, we may not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. We may not honor your request if we are not the controller of your personal information (for example, when our retailer partner is the controller and we are the processor or service provider for our retailer partner). Additionally, we may not honor your request where not required to do so under applicable privacy laws. For example, we may deny a deletion request if the information is necessary for us to provide our services to you or comply with our legal obligations. We may deny certain right to know requests made more than twice in a 12-month period or for information collected and disclosed more than 12 months ago. We will advise you in our response if we are not able to honor your request.

You have the right to appeal our decision to not honor your request or our refusal to take action on a request within a reasonable period of time by contacting us at the email listed above and clearly stating that the purpose of the contact is an “appeal of privacy rights.”   Within 45 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

4.  Our Use of Cookies

Our Use of Cookies and Other Tracking Technology

Our website uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “cookies”). Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our website.  We use cookies to gather data about visitors to our website, analyze trends and operate and improve our website and services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own cookies on your devices.

We allow third parties to set and collect cookies through our website. Please review such third parties’ privacy policies and other terms for information on their privacy practices and uses of personal information, including whether they use cookies to provide targeted and cross-contextual behavioral advertising and your options to opt-out.

Do Not Track

Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Our website is not currently configured to respond to Do Not Track signals or other mechanisms that provide users the ability to exercise choice regarding the collection of personal information about a user’s online activities over time and across third-party websites or online services.

Disable or Delete Cookies

Disable or Delete Cookies from Your Browser or Device

You can decide whether or not to accept certain cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. To explore what cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu.

You can also delete all cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the website and functionalities may not work.

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

5.    Our Uses of Personal Information in the Last 12 Months

The below chart summarizes the categories of personal information we have collected, disclosed for our business purposes, sold or shared for cross-context behavioral advertising (or targeted advertising) to the identified categories of third parties in the last 12 months.  See the above section called, Categories of Third Parties with Whom We Share Your Personal Information, for more details on the categories of third parties.

Our business purposes for disclosing your personal information are all of the business purposes in the above section called, Our Business Purposes for Collecting and Sharing Personal Information. Our business purposes for selling your personal information or sharing your personal information for cross-context behavioral adverting or targeted advertising are those purposes identified in the bullet beginning with ” Market our and third-party products and services to you, including through targeted advertising,” in the above section called, Our Business Purposes for Collecting and Sharing Personal Information.

Category of Personal Information

 

Collected in Last 12 Months Disclosed for Our Business Purposes in Last 12 Months to Categories of Third Parties Sold or Shared for Cross-Contextual Behavioral Advertising in Last 12 Months to Categories of Third Parties
Identifiers (for example, name, postal address, email address, IP address, unique personal identifiers) Yes Yes to our Affiliates, Vendors, Advertisers, Authorized Parties and Legal Parties No
Personal information (for example, name, address, telephone number, credit card number) Yes Yes to our Affiliates, Vendors, Advertisers, Authorized Parties and Legal Parties No
Characteristics of protected persons (for example, age, race, national origin, citizenship, religion, sex/gender) No* Not applicable Not applicable
Commercial information (for example, records of products or services purchased or considered) Yes Yes to our Affiliates, Vendors, Advertisers, Authorized Parties and Legal Parties Yes to our Affiliates, Vendors and Advertisers
Biometric information (for example, fingerprints and voiceprints) No* Not applicable Not applicable
Internet or other electronic network activity (for example, browsing history, search history, website interactions) No Not applicable Not applicable
Geolocation data (for example, device location) No Not applicable Not applicable
Sensory data (audio, electronic, visual, thermal, olfactory, or similar information) No* Not applicable Not applicable
Professional or employment-related information Yes Yes to our Affiliates, Vendors, Advertisers, Authorized Parties and Legal Parties Yes to our Affiliates, Vendors and Advertisers
Non-public education information No* Not applicable Not applicable
Inferences drawn from other personal data to create a consumer profile No Not applicable Not applicable
Other non-sensitive information you choose to provide (for example, you may choose to provide information in any of the above categories even if we do not specifically collect it) Yes Yes to our Affiliates, Vendors, Advertisers, Authorized Parties and Legal Parties No
Sensitive Personal Information
Category of Sensitive Personal Information

 

Collected in Last 12 Months Disclosed for Our Business Purposes in Last 12 Months to Categories of Third Parties Sold or Shared for Cross-Contextual Behavioral Advertising in Last 12 Months to Categories of Third Parties
Government identifying numbers (social security, driver’s license, state ID, or passport numbers) No* Not applicable Not applicable
Complete account credentials (account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account) No No No
Precise geolocation No* Not applicable Not applicable
Racial or ethnic origin, religious or philosophical beliefs, or union membership No* Not applicable Not applicable
Mail, email, or text message contents not directed at us No* Not applicable Not applicable
Genetic data No* Not applicable Not applicable
Biometric information processing for the purpose of uniquely identifying an individual No* Not applicable Not applicable
Health, sex life, or sexual orientation No* Not applicable Not applicable
Other sensitive information you choose to provide (for example, you may choose to provide information in any of the above categories even if we do not specifically collect it) Yes No No

*Not specifically collected by us, but may be included in the category of “other information you choose to provide”.

6.   Data Security and Processing

Security of Personal Information

We will maintain reasonable technical and organizational safeguards for the protection of the security and confidentiality of personal information from unauthorized access, use, disclosure or transfer. Despite our efforts to ensure security, we cannot guarantee or warrant that personal information will not be accessed, acquired, disclosed for an improper purpose, altered or destroyed by an unauthorized person or as a result of a breach of our security safeguards or those of our hosting provider or other vendors or service providers.  We cannot ensure the security of any data transmitted to us over the internet. To the fullest extent permitted by applicable law, we accept no liability for any unintentional disclosure by us of personal information. Therefore, we urge you to take adequate precautions to protect personal information as well, including, without limitation, never sharing your account username or password.

International Transfer, Storage and Processing

The personal information we collect or receive is stored and processed in the United States. You consent to the transfer, processing and storage of personal information in the United States. You also consent to the transfer, processing and storage of personal information by us, our affiliated entities, our vendors or third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world subject to the provisions of this Privacy Policy.

If you are located in the European Economic Area or other regions with laws governing data collection and use that may differ from United States law, please note that we may transfer data, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction and may afford materially less privacy protections for your personal information than your jurisdiction. You consent to the transfer of data to the United States or any other country in which we, our affiliates, or vendors maintain facilities and the use and sharing of information about you as described in this Privacy Policy.

7.    Changes and Amendments to Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we do, we will post the revised policy on our website with a new “Last Updated” date. We may, but are not required to, also provide you with notice of the amended Privacy Policy via any others means we consider reasonable, including, without limitation, email, posting on in our services, or updates to our services. Your continued use of our website or services or your provision of personal information to us following the posting of changes (or other notice we provide in our sole discretion) constitutes your acceptance of such changes and the Privacy Policy as amended. We may, but are not required to, also provide you with alternative means of accepting any changes to or amended version of this Privacy Policy. We encourage you to visit this page regularly for any changes.

8.    Contact Us

Contact Us

You may contact us with questions, concerns, complaints or disputes related to this Privacy Policy and our privacy policies and practices.

Pollen Technologies, Inc

  • Address: 3355 Lenox Rd. NE Atlanta GA 30326
  • Email: help@pollenreturns.com

Disability Access

If you have a disability, you may access this Privacy Policy in an alternative format by contacting us at:

  • Email: help@pollenreturns.com