Privacy Policy

At The Fluff, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of The Fluff’s services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

1. WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

2. PERSONAL DATA

2.1. CATEGORIES OF PERSONAL DATA WE COLLECT

This list details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data: Profile or Contact Data
Examples of Personal Data We Collect:

  • First and last name

  • Email

  • Phone number

  • Pick-up or Delivery address

  • IP address

Categories of Third Parties With Whom We Share this Personal Data:

  • Service Providers

  • Advertising Partners (such as Google and Facebook)

  • Parties You Authorize, Access or Authenticate

Category of Personal Data: Payment Data
Examples of Personal Data We Collect:

  • Payment card type

  • Last 4 digits of payment card

  • CVV, expiration date, and billing address

  • Phone number, and email

Categories of Third Parties With Whom We Share this Personal Data:

  • Service Providers (specifically our payment processing partner, currently Braintree (offered by PayPal, Inc.))

Category of Personal Data: Commercial Data
Examples of Personal Data We Collect:

  • Order history

  • Consumer profiles

  • Information about consumer’ garments and other items for The Fluff’s Cleaning Services

  • Records of date for The Fluff’s Cleaning Services

Categories of Third Parties With Whom We Share this Personal Data:

  • Service Providers

  • Advertising Partners

  • Parties You Authorize, Access or Authenticate

Category of Personal Data: Device/IP Data
Examples of Personal Data We Collect:

  • IP address

  • Device ID

  • Type of device/operating system/browser used to access the Services

Categories of Third Parties With Whom We Share this Personal Data:

  • Service Providers

  • Advertising Partners (such as Google and Facebook)

  • Parties You Authorize, Access or Authenticate

Category of Personal Data: Web Analytics
Examples of Personal Data We Collect:

  • Web page interactions

  • Referring webpage/source through which you accessed the Services

  • Non-identifiable request IDs

  • Statistics associated with the interaction between device or browser and the Services

Categories of Third Parties With Whom We Share this Personal Data:

  • Service Providers

  • Advertising Partners (such as Google and Facebook)

  • Parties You Authorize, Access or Authenticate

Category of Personal Data: Social Network Data
Examples of Personal Data We Collect:

  • Email

  • Phone number

  • User name

  • IP address

  • Device ID

Categories of Third Parties With Whom We Share this Personal Data:

  • Service Providers

  • Advertising Partners (such as Google and Facebook)

  • Parties You Authorize, Access or Authenticate

Category of Personal Data: Consumer Demographic Data
Examples of Personal Data We Collect:

  • ZIP code

Categories of Third Parties With Whom We Share this Personal Data:

  • Service Providers

  • Advertising Partners

  • Parties You Authorize, Access or Authenticate

Category of Personal Data: Geolocation Data
Examples of Personal Data We Collect:

  • Pick-up or Delivery address

  • IP-address-based location information

Categories of Third Parties With Whom We Share this Personal Data:

  • Service Providers

  • Advertising Partners

  • Parties You Authorize, Access or Authenticate

Category of Personal Data: Internet or other similar network activity information
Examples of Personal Data We Collect:

  • information on a consumer's interaction with website(s), application(s) or advertisement

Categories of Third Parties With Whom We Share this Personal Data:

  • Service Providers

  • Advertising Partners

  • Parties You Authorize, Access or Authenticate

Category of Personal Data: Other Identifying Information that You Voluntarily Choose to Provide
Examples of Personal Data We Collect:

  • Identifying information in text messages, emails or letters you send us

Categories of Third Parties With Whom We Share this Personal Data:

  • Service Providers

  • Advertising Partners

  • Parties You Authorize, Access or Authenticate

2.2. CATEGORIES OF SOURCES OF PERSONAL DATA

We collect Personal Data about you from the following categories of sources:

  • You

    • When you provide such information directly to us.

      • When you create an account or use our interactive tools and Services.

      • When you place an order for the Cleaning Services, we collect payment data, depending on the form of payment you choose.

      • When you send in your garments or other items for the Cleaning Services, we may collect information on such items, including type, service requested, brand, color, size, and photos.

      • When you voluntarily provide information in text messages or in free-form text boxes through the Services or through responses to surveys or questionnaires.

      • When you choose to refer a friend through the Services, we will ask for your friend's contact information.

      • When you send us an email or otherwise contact us.

    • When you use the Services and such information is collected automatically.

      • Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).

      • If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.

      • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

  • Third Parties

    • Vendors

      • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

      • We may use vendors to obtain information to generate leads and create user profiles.

    • Advertising Partners

      • We receive information about you from some of our vendors who assist us with marketing or promotional services for the The Fluff Services related to how you interact with our websites, applications, products, Services, advertisements or communications.

    • Social Networks

      • If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

2.3. OUR COMMERCIAL OR BUSINESS PURPOSES FOR COLLECTING PERSONAL DATA

  • Providing, Customizing and Improving the Services

    • Creating and managing your account or other user profiles

    • Processing orders or other transactions; billing

    • Providing you with the Cleaning Services, or other products, services or information you request

    • Meeting or fulfilling the reason you provided the information to us, such as to message to your friend inviting him or her to sign-up for the Service

    • Providing support and assistance for the Services

    • Analyzing trends and consumers’ interactions with the Services

    • Improving the Services, including testing, research, internal analytics and product development

    • Personalizing the Services, website content and communications based on your preferences

    • Doing fraud protection, security and debugging

    • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”)

  • Marketing the Services

    • Marketing and selling the Services

    • Providing you with customized offers or promotions that we think might be interested to you

    • Showing you advertisements, including interest-based or online behavioral advertising, and retargeted online and mobile advertisements to you across computers or devices you may use

  • Corresponding with You

    • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about The Fluff or the Services

    • Sending emails and other communications according to your preferences or that display content that we think will interest you

  • Meeting Legal Requirements and Enforcing Legal Terms

    • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities

    • Protecting the rights, property or safety of you, The Fluff or another party

    • Enforcing any agreements with you

    • Responding to claims that any posting or other content violates third-party rights

    • Resolving disputes

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

3. HOW WE SHARE YOUR PERSONAL DATA

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Personal data collected through the short code/SMS program won’t be shared, sold or rented to unaffiliated or affiliated third parties for their own marketing purposes. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

  • Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

    • Hosting, technology and communication providers, such as AWS

    • Security and fraud prevention consultants

    • Analytics providers, such as Google Analytics and Facebook Pixel

    • Support and customer service vendors

    • Product fulfillment and delivery providers

    • Payment processors

      • Our payment processing partner Braintree (offered by PayPal, Inc.) (“Braintree”) collects your voluntarily-provided payment card information necessary to process your payment.

      • Please see Braintree’s terms of service and privacy policy for information on its use and storage of your Personal Data.

  • Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:

    • Ad networks

    • Data brokers

    • Marketing providers

  • Parties You Authorize, Access or Authenticate

    • Third parties you access through the services

    • Social media services

3.1. LEGAL OBLIGATIONS

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

3.2. BUSINESS TRANSFERS

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

3.3. DATA THAT IS NOT PERSONAL DATA

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

4. TRACKING TOOLS, ADVERTISING AND OPT-OUT

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. 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 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 device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

  • 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. They do this 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. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

  • Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”

You can decide whether or not to accept 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. 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 Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

4.1. INFORMATION ABOUT INTEREST-BASED ADVERTISEMENTS

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

4.2. OPT-OUT CHOICES

We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. 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 http://www.networkadvertising.org/choices or www.aboutads.info/choices. To opt-out of the use of your mobile device ID for targeted advertising, see http://www.aboutads.info/appchoices.

We provide our consumers with the opportunity to opt-out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product or service. To opt-out of marketing communications, you may use one of these convenient methods:

  • Electronic Promotional Offers. If you do not want to receive emails from us regarding special promotions or offers, you may click the unsubscribe link in the footer of any email, or contact us at support@thefluff.app with “Unsubscribe Promotional Offers” in the subject line.

  • Mobile Promotional Offers. When you provide us with your mobile number for marketing purposes, we may send you certain marketing alerts via text message. Standard data and message rates will apply. If you no longer wish to receive mobile alerts from us, you can follow the instructions provided in those messages or otherwise reply “STOP” to any The Fluff alert.

Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable. Additionally, we are not responsible for informing third parties (including without limitation our third party service providers or partners) with whom we have already shared your personal information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.

5. DATA SECURITY AND RETENTION

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

6. PERSONAL DATA OF CHILDREN

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at support@thefluff.app

8. OTHER STATE LAW PRIVACY RIGHTS

8.1. CALIFORNIA RESIDENT RIGHTS

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@thefluff.app.

8.2. NEVADA RESIDENT RIGHTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@thefluff.app with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

9. CHANGES TO THIS PRIVACY POLICY

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the The Fluff website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

10. CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: