Revolv (“Revolv” or "we" or "us") takes data privacy seriously. This Privacy Policy describes how Revolv, as a controller within the meaning of the General Data Protection Regulation ("GDPR"), collects and processes the personal data and other information of users.
1. Categories of Personal Data and Processing Purposes
Metadata: You may use our website or app without providing personal data. Revolv collects metadata resulting from your usage, including referral page, date and time of access, data volume transmitted, status of transmission, type of web browser, IP address, operating system and interface, language, and version of browser software. Your IP address enables your access to our website or app and will be shortened once it is no longer necessary. The metadata, including the shortened IP address, are used to improve the quality and services of our website or app by analyzing user behavior.
Account: If you create an account on our website or app, you may be asked to provide personal data such as your name, postal address, email address, password, telephone number, bank account details, credit card details, invoicing and delivery address, interests in certain products/services (voluntary), and marketing email preferences (voluntary). Revolv processes this data to provide our services, send marketing materials as permitted by law, and analyze your interests for marketing purposes.
Product Orders: When ordering a product via our website or app, Revolv collects and processes personal data including your account data, type and amount of product, purchase price, order date, order status, product returns, and customer care requests. This data is used for carrying out the contractual relationship, providing customer care services, complying with legal obligations, defending legal claims, and tailored marketing.
Sweepstakes: Participation in sweepstakes involves collecting data such as your name, postal address, email address, date of entry, selection as winner, prize, and answer to quiz questions. This data is processed to carry out the sweepstakes, inform the winner, deliver the prize, and for marketing purposes.
Health Data: Ordering certain products may involve the collection and processing of health data. With your consent, this sensitive data is used solely for fulfilling the contractual relationship, providing customer care, complying with legal obligations, and tailored marketing.
2. Third PartiesTransfer to service providers
Revolv may engage external service providers, who act as a data processor of Revolv, to provide certain services to Revolv, such as website service providers, marketing service providers or IT support service providers. When providing such services, the external service providers may have access to and/or may process your personal data. We request those external service providers to implement and apply security safeguards to ensure the privacy and security of your personal data.
Other recipients Revolv may transfer - in compliance with applicable data protection law - personal data to law enforcement agencies, governmental authorities, legal counsel, external consultants, or business partners. In case of a corporate merger or acquisition, personal data may be transferred to the third parties being involve in the merger or acquisition.
International transfers of Personal Data The Personal Data that we collect or receive about you may be transferred to and processed by recipients which are located inside or outside the European Economic Area ("EEA"). The countries include those listed at http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm which provide an adequate level of data protection from a European data protection law perspective. The recipients in the US are partially certified under the EU-U.S. Privacy Shield and thereby recognized as providing an adequate level of data protection from a European data protection law perspective. Other recipients might be located in other countries which do not adduce an adequate level of protection from a European data protection law perspective. Revolv will take all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law. With respect to transfers to countries not providing an adequate level of data protection, we base the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority, approved code of conducts together with binding and enforceable commitments of the recipient, or approved certification mechanisms together with binding and enforceable commitments of the recipient. You can ask for a copy of the such appropriate safeguards by contacting us as set out in Sec. 7 (Contact us) below.
3. Legal basis for the processing
We may carry out the processing of your personal data on the following legal basis: You have given your consent to the processing of your data for one or more specific purposes - The processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract - The processing is necessary for compliance with a legal obligation to which we are subject to - The processing is necessary to protect your vital interests of you or of another natural person - The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us - The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data, in particular if you are a child - Other applicable legal basis for data processing, especially provisions set out by member state law - We may carry out the processing of your sensitive personal data on the following legal basis: You have given your explicit consent to the processing of your sensitive personal data for one or more specific purposes - The processing is necessary for the purposes of carrying out the obligations and exercising specific rights of Revolv or of the data subject in the field of employment and social security and social protection law - The processing relates to personal data which are manifestly made public by the data subject;The processing is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity - The provision of your personal data is required by a statutory or contractual obligation, or necessary to enter into a contract with us or to receive our services/products as requested by you, or simply voluntary for you. Not providing your personal data may result in disadvantages for you, e.g. you may not be able to receive certain products and services. However, unless otherwise specified, not providing your personal data will not result in legal consequences for you.
4. What rights do you have and how can you assert your rights?
If you have declared your consent regarding certain collecting, processing and use of your personal data, you can revoke this consent at any time with future effect. Further, you can object to the use of your personal data for the purposes of marketing without incurring any costs other than the transmission costs in accordance with the basic tariffs.Pursuant to the applicable data protection law you have the right (i) to request access to your personal data, (ii) to request rectification of your personal data, (iii) to request erasure of your personal data, (iv) to request restriction of processing of your personal data, (v) to request data portability, (vi) to object to the processing of your personal Data (including objection to profiling), and (vii) to object to automated decision making (including profiling).To exercise your rights please contact us as stated under Sec. 7 (Contact us) below. In case of complaints you also have the right to lodge a complaint with the competent data protection supervisory authority. 5. How long do we keep your Personal Data?
Your personal data will be retained as long as necessary to provide you with the services and products requested. Once our relationship has come to an end, we will either delete your personal data or anonymize your personal data, unless statutory retention requirements apply (such as for taxation purposes). We may retain your contact details and interests in our products or services for a long period of time if Revolv is allowed to send you marketing materials. Also, we may be required by applicable law to retain certain of your personal data for a period of 10 years after the relevant taxation year. We may also retain your personal data after the termination of the contractual relationship if your personal data are necessary to comply with other applicable laws or if we need your personal data to establish, exercise or defend a legal claim, on a need to know basis only. To the extent possible, we will restrict the processing of your personal data for such limited purposes after the termination of the contractual relationship.
6. Web Analysis Services
6.1 Google Analytics 4
This website uses Google Analytics 4, a service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), which can be used to analyze the use of websites.
When using Google Analytics 4, so-called "cookies" are used as standard. Cookies are text files that are stored on your terminal device and enable an analysis of your use of a website. The information collected by cookies about your use of the website (including the IP address transmitted by your terminal device, shortened by the last digits, see below) is usually transmitted to a Google server and stored and processed there. This may also result in the transmission of information to the servers of Google LLC, a company based in the USA, where the information is further processed.
When using Google Analytics 4, the IP address transmitted by your terminal device when you use the website is always collected and processed by default and automatically only in an anonymized manner, so that a direct personal reference of the collected information is excluded. This automatic anonymization is carried out by shortening the IP address transmitted by your terminal device by Google within member states of the European Union (EU) or other contracting states of the Agreement on the European Economic Area (EEA) by the last digits.
On our behalf, Google uses this and other information to evaluate your use of the website, to compile reports (reports) on your website activities or your usage behavior and to provide us with other services related to your website usage and internet usage. In this context, the IP address transmitted and shortened by your terminal device within the scope of Google Analytics 4 will not be merged with other data from Google. The data collected in the context of the use of Google Analytics 4 will be retained for 2 months and then deleted.
Google Analytics 4 also enables the creation of statistics with statements about age, gender and interests of website users on the basis of an evaluation of interest-based advertising and with the involvement of third-party information via a special function, the so-called "demographic characteristics". This makes it possible to determine and distinguish between groups of website users for the purpose of targeting marketing measures. However, data collected via the "demographic characteristics" cannot be assigned to a specific person and thus not to you personally. This data collected via the "demographic characteristics" function is retained for two months and then deleted.
All processing described above, in particular the setting of Google Analytics cookies for the storage and reading of information on the terminal device used by you for the use of the website, will only take place if you have given us your express consent for this in accordance with Art. 6 (1) lit. a GDPR. Without your consent, Google Analytics 4 will not be used during your use of the website.
You can revoke your consent once given at any time with effect for the future. To exercise your revocation, please deactivate this service via the "Cookie Consent Tool" provided on the website.
Google Signals On this website, the "Google Signals" service can also be used as an extension of Google Analytics 4. With Google Signals, cross-device reports can be created by Google (so-called "cross-device tracking"). If you have activated "personalised ads" in your Google account settings and you have linked your internet-enabled devices to your Google account, Google can analyse user behaviour across devices and create database models based on this, provided you have given your consent to the use of Google Analytics in accordance with Art. 6 Para. 1 letter a GDPR (see above). The logins and device types of all page visitors who were logged into a Google account and performed a conversion are taken into account. The data shows, among other things, on which device you first clicked on an ad and on which device the associated conversion took place. Insofar as Google Signals is used, we do not receive any personal data from Google, but only statistics compiled on the basis of Google Signals. You have the option of deactivating the "personalised ads" function in the settings of your Google account and thus turning off the cross-device analysis. To do this, follow the instructions on this page: https://support.google.com/ads/answer/2662922?hl=de Further information can be found here: https://support.google.com/analytics/answer/7532985?hl=de
User IDs As an extension of Google Analytics 4, the "UserIDs" function can also be used on this website. By assigning individual UserIDs, we can have Google create cross-device reports (so-called "cross-device tracking"). This means that your usage behaviour can also be analysed across devices if you have given your corresponding consent to the use of Google Analytics in accordance with Art. 6 Para. 1 letter a GDPR, if you have set up a personal account by registering on this website and are logged into your personal account on different end devices with your relevant login data. The data collected in this way shows, among other things, on which end device you clicked on an ad for the first time and on which end device the relevant conversion took place.
We have concluded a so-called data processing agreement with Google for our use of Google Analytics 4, by which Google is obliged to protect the data of our website users and not to pass it on to third parties.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
6.2 This website uses the "Google Tag Manager", a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: "Google").
The Google Tag Manager provides a technical basis for bundling various web applications, including tracking and analysis services, and for calibrating, controlling and attaching conditions to them via a uniform user interface. Google Tag Manager itself does not store any information on user end devices or read them. The service also does not perform any independent data analyses. However, the Google Tag Manager transmits your IP address to Google when you visit a page and may store it there. Also a transmission to servers of Google LLC in the USA is possible.
All processing described above, in particular the reading or saving of information on the end device used, is only carried out if you have given us your express consent in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the "cookie consent tool" provided on the website.
We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
6.3 Hotjar This website uses the web analysis service of the following provider: Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta
Using cookies and/or comparable technologies (tracking pixels, web beacons, algorithms for reading device and browser information), the service collects and stores pseudonymized visitor data, including information about the device used such as the IP address and browser information, in order to use it for to evaluate statistical analyzes of usage behavior on our website and to create pseudonymized usage profiles. Among other things, this makes it possible to evaluate movement patterns (so-called heatmaps), which show the duration of page visits as well as interactions with page content (e.g. text input, scrolling, clicks and mouse-overs). Pseudonymization fundamentally excludes any direct personal reference. It will not be merged with clear personal data collected about you in any other way.
All processing described above, in particular the reading or storage of information on the device used, will only be carried out if you have given us your express consent to this in accordance with Article 6 Paragraph 1 Letter a of the GDPR. You can revoke your consent at any time with future effect by deactivating this service in the “cookie consent tool” provided on the website.
We have concluded an order processing agreement with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
7. Retargeting/Remarketing/ Referral Advertising
7.1 Meta Pixel without extended data synchronisation
Within our online offering, we use the "Meta Pixel" service of the following provider: Meta Platforms Ireland Limited, 4 Grand Canal Quare, Dublin 2, Ireland ("Meta")
If a user clicks on an advert placed by us on Facebook and/or Instagram, "Meta Pixel" is used to add a parameter to the URL of our linked page. This URL parameter is then entered into the user's browser after redirection by a cookie that our linked page sets itself.
This makes it possible for Meta to determine the visitors to our online offering as a target group for the display of adverts. Accordingly, we use the service to display the Facebook and/or Instagram ads placed by us only to those users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Meta (so-called "custom audiences").
On the other hand, the "Meta Pixel" can be used to track whether users have been redirected to our website after clicking on an advert and what actions they take there (so-called "conversion tracking").
The data collected is anonymous to us and therefore does not allow us to draw any conclusions about the identity of users. However, the data is stored and processed by Meta so that a connection to the respective user profile is possible and Meta can use the data for its own advertising purposes.
All processing described above, in particular the setting of cookies for reading information on the terminal device used, will only be carried out if you have given us your express consent to do so in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the "cookie consent tool" provided on the website.
We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorised disclosure to third parties.
The information generated by Meta is usually transferred to a Meta server and stored there; in this context, it may also be transferred to servers of Meta Platforms Inc. in the USA.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
7.2 Google Ads Remarketing
This website uses the online advertising program "Google Ads" and, within the scope of Google Ads, the conversion tracking of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). We use Google Ads to draw attention to our attractive offers on external websites with the help of advertising media (so-called Google Adwords). We can determine how successful the individual advertising measures are in relation to the data of the advertising campaigns. In this way, we pursue the concern of showing you advertising that is of interest to you, making our website more interesting for you and achieving a fair calculation of the advertising costs incurred
The conversion tracking cookie is set when a user clicks on an ad placed by Google. Cookies are small text files that are stored on your terminal device. These cookies usually lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize if the user has clicked on the ad and has been directed to this page. Each Google Ads customer receives a different cookie. Cookies therefore cannot be tracked across Google Ads customers’ websites. The information obtained using the conversion cookie is used to create conversion statistics for Google Ads customers who have chosen conversion tracking. Customers learn the total number of users who clicked on their ad and who were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users. The use of Google Ads may also result in the transmission of personal data to the servers of Google LLC. in the USA.
Details on the processing operations initiated by Google Ads conversion tracking and on Google's handling of data collected from websites can be found here: https://policies.google.com/technologies/partner-sites?hl=en All processing described above, in particular the setting of cookies for the reading of information on the end device used, will only be carried out if you have given us your express consent to do so in accordance with Art. 6 (1) point a GDPR. Without this consent, Google Conversion Tracking will not be used during your visit to the website.
You can permanently disable the setting of cookies by Google Ads Conversion Tracking for advertising preferences. You may download and install the browser plug-in available at the following link: https://support.google.com/ads/answer/7395996? Please note that certain functions of this website may not be available or may be restricted if you have deactivated the use of cookies.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
8. Site Functionalities
8.1 Vimeo
This website uses plugins to display and play videos from the following provider: Vimeo.com, Inc., 330 West 34th Street, 10th Floor, New York, NY 10001, USA
When you call up a page of our website that contains such a plugin, your browser establishes a direct connection to the provider's servers to load the plugin. This involves certain information, including your IP address, being transmitted to the provider.
If the playback of embedded videos is started via the plugin, the provider also uses cookies to collect information about user behavior, to create playback statistics and to prevent abusive behavior.
If you are logged into a user account maintained by the provider during your visit to the site, your data will be directly assigned to your account when you click on a video. If you do not wish to have your data assigned to your account, you must log out before clicking on the play button.
All the above-mentioned processing, in particular the setting of cookies for reading out information on the end device used, only takes place if you have given us your express consent in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service via the "cookie consent tool" provided on the website.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
8.2 Google Web Fonts
This site uses so-called web fonts from the following provider to display fonts in a uniform manner: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Data is also transferred to: Google LLC, USA
When you call up a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly and establishes a direct connection to the provider's servers. In this process, certain browser information, including your IP address, is transmitted to the provider.
The processing of personal data while establishing the connection with the provider of the fonts is only carried out if you have given us your express consent to do so in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service via the "cookie consent tool" provided on the website. If your browser does not support web fonts, a standard font will be used by your computer.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
9. Tools and Miscellaneous
This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "cookie consent tool" is displayed to users in the form of an interactive user interface when they access the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box.
Using the tool, all cookies/services requiring consent are only loaded if the respective user provides the corresponding consent by ticking the corresponding box. This ensures that such cookies are only set on the respective end device of the user if consent has been granted.
The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed. If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) point GDPR based on our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website. Further legal basis for the processing is Art. 6 (1) point c GDPR. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent. Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.
10. Contact us If you have concerns or questions regarding this Privacy Policy, please contact us via email at: hello@revolv.vc
