Frate Inc. Privacy Statement

Last Updated: June 1st, 2024

Preamble

Frate Returns orchestrates the return logistics for consumer goods acquired from a diverse array of retail entities. We oversee and streamline the entire returns procedure, including but not limited to, the initiation, receipt, and processing of merchandise returns. Our platform provides merchants with innovative return logistics solutions and presents consumers with various options for returning merchandise, be it digitally, onsite, directly, or through postal services. The subsequent Privacy Policy elucidates the protocols Frate Returns employs for the collection, retention, application, and disclosure of Personal Information from merchants and consumers. We encourage you to review this document to comprehend the privacy rights and options at your disposal.

Applicability of this Privacy Policy extends to:

  • Merchants with whom we currently collaborate or may partner in the future.
  • Consumers utilizing our services to return items to merchants. Your interactions with our services are subject to this policy, while the merchant’s own privacy policy may also govern the information we collect on their behalf.
  • Individuals visiting our digital properties or engaging with us through offline modes.

We reserve the right to modify this Privacy Policy to reflect changes in our operational practices, service offerings, or due to alterations in the law. Notice of any substantive changes will be communicated at least 30 days prior on our Privacy Policy webpage. Absent of such notice, changes become effective as stated in the update.

GDPR Compliance Commitment

At Frate Returns, we recognize the importance of privacy and are committed to adhering to the GDPR along with other applicable data protection laws. This commitment informs our practices for the secure, lawful, and transparent handling of personal information. By engaging with our services, you entrust us with your data, and we pledge to protect this trust through rigorous data protection measures. Frate Returns processes Personal Information primarily to facilitate merchandise returns between consumers and merchants, provide customer support, optimize our service offerings, and comply with legal requirements. Each processing activity is conducted with a clear, legitimate purpose in mind, ensuring alignment with our commitment to privacy and data protection.

Data Governance at Frate Returns

Frate Returns is domiciled within the United States at 5017 Miss Julie Lane, Austin TX, 78727, and can be reached at legal@frate.co. As recognized by GDPR and other applicable regulations, we act as the data controller, dictating the means and purpose of processing Personal Information.

Affiliated third parties, such as merchants and regulatory entities, may control your data independently; therefore, we advise you to peruse their respec tive privacy policies.

Categories of Data Collected by Frate Returns

Interaction with our organization, whether as a merchant or a consumer, guides the categories of Personal Information we amass, which could encompass:

  • Identifying particulars like names, communication data, online identifiers, along with merchant account setup requisites.
  • Transactional records, including order specifics, historical returns, and dispatch details.
  • Activity data from web engagements facilitated by cookies or analogous technology.
  • Location data procured with user consent to refine service provision.
  • Communications held with our client service teams across various mediums.
  • Vocational data pertinent to merchant account representatives.
  • Analytics-based insights drawn from user interface with our services.
  • Equipment-related data reflecting user preferences and configurations.

Data Sharing and Visibility

In facilitating returns and peer-to-peer resale, certain personal information, including names and addresses, must be exchanged between buyers and returners. This exchange is limited to the information necessary to complete the transaction. We are dedicated to ensuring this information is used responsibly and securely, with strict adherence to privacy laws. You agree to be legally liable for the contents of the return package you ship. Frate Returns is not responsible for any dangerous or prohibited items sent in return packages. It is your responsibility to ensure that all items shipped comply with applicable laws and regulations.

Rights of Data Subjects

As affirmed by GDPR, individuals have rights over their personal data, including the right to access, rectify, or erase their information, and to restrict or object to its processing. To exercise these rights, please contact us through the provided communication channels. We are committed to facilitating your rights in compliance with applicable laws. Individuals have the right to access their personal data, request correction or deletion of their data, object to or restrict processing of their data, and request portability of their data. Specific instructions on how to exercise these rights can be found in our dedicated section on 'Rights of Data Subjects,' or by contacting our legal department directly. If you are unsatisfied with how we handle your personal data, you have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO). Contact details and procedures can be found at www.ico.org.uk.

Origins of Personal Information

Our compilation of Personal Information is from diverse origins, including direct interactions, merchant exchanges, logistical collaborations, and openly available data, to ensure a tailored user experience while maintaining compliance.

Utilization and Legal Basis for Data Processing

We abide by jurisdiction-specific legal grounds for data processing. Ordinarily, we process Personal Information for:

  1. Provisioning of services in line with contractual commitments.
  2. Compliance with legal stipulations and enforcement of our terms.
  3. Fulfillment of valid business interests, counterbalanced by individual rights.
  4. Obtaining explicit consent where mandated by legal frameworks.

Our lawful bases for processing personal data include contractual necessity to fulfill our services, legal obligations we are required to meet, consent explicitly provided by our users, and legitimate interests pursued by Frate Returns such as improving user experience and offering personalized services, always balanced against the individual's rights and freedoms.

Disclosure Norms for Personal Information

Engaging in Selling or Sharing Personal Information for advertising predicated on user behavior is not our practice. We disclose information only for functional necessities, risk mitigation, promotional outreach, and adherence to legal obligations, inclusive of:

  • Corporate affiliates under the Frate Returns umbrella in alignment with this notice.
  • Third-party service collaborators and merchant platforms integral to return processing.
  • Legal bodies in compliance with judicial orders.

Retention Timeline for Personal Information

We retain Personal Information to the extent that it fulfills its collection purpose and as prescribed by legal injunctions. Criteria for retention are based on legal compliance, resolution of disputes, and other relevant operational exigencies.

Cookie and Tracking Methodologies

Cookies and parallel technologies serve to optimize service functionality, memorize user preferences, secure our digital interfaces, and monitor system performance. Users have discretionary control over these technologies, with the liberty to personalize settings or opt-out subject to regulatory consent.

Rights and Preferences of Users

We prioritize user agency over Personal Information. You possess the right to review, rectify, or obliterate your data, subject to location-specific rights. To invoke these rights, utilize the contact avenues provided, subject to necessary authentication protocols to safeguard your data.

Cross-border Data Considerations

For non-U.S. residents, it is pertinent to recognize that your data will be managed within the United States and as such, may be subject to differing data protection statutes. We apply measures such as Standard Contract Clauses to safeguard your data across international boundaries.

Safeguarding Personal Data

Our commitment to your data's security is unwavering, with strategic security protocols in place aimed at ensuring reasonable protection against loss, unauthorized access, and disclosure. Despite our rigorous measures, the absolute security of information cannot be guaranteed, and we encourage personal vigilance in protecting your own data.

Child Privacy Protections

Our services are designed for a general audience and are not intentionally directed towards children under the age of 18. We do not knowingly accumulate Personal Information from minors. Should any such data be inadvertently collected, we will take appropriate measures to ensure its removal, unless retention is mandated by law.

Glossary of Terms

A glossary is provided within Section 13 to demystify terms such as “Personal Information,” “Processing,” and “Services,” ensuring you have a clear understanding of our practices.

Communication Channels

Inquiries related to this Privacy Policy or about your Personal Information can be directed to our legal department via email at legal@frate.co or through postal correspondence to our Austin address.

State-Specific Privacy Disclosures

Inhabitants of California, alongside other pertinent states, are accorded specific disclosures regarding the nature of data collection, its utilization, and the potential disclosure to third parties, as comprehensively laid out in the respective sections of this Privacy Policy.