Privacy Policy

At URBN Caravan, we understand that your privacy is very important to you. We have made sure to design and offer our services in a way that allows you to fully trust what we have to offer and still enjoy using our services. While creating an enjoyable experience for customers is at the forefront of our model, we know that this cannot be done without ensuring you that we are responsibly using your information and protecting your privacy rights the best we can. We design all of our products and services with your privacy in mind. We understand that privacy policies can be difficult to understand and perhaps overwhelming. Therefore, we have tried to make our Privacy Policy as understandable as possible. It is important to us that you read and understand our policies when using the application.

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Welcome to URBN Caravan’s Privacy Policy. Thank you for taking the time to read it. We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

A. WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to websites, apps, events and other services operated by URBN Caravan. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services. Some services may require their own unique privacy policy. If a particular service has its own privacy policy, then that policy — not this Privacy Policy — applies.

B. INFORMATION WE COLLECT

It goes without saying, URBN Caravan cannot help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information automatically when you use the app and our services.

Information you give us: You choose to give us certain information when using our services. This includes:

When you create an account, you provide us with at least your login credentials and basic details necessary for the service to work, such as your gender and date of birth.
When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album.
Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials.
When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.

Information we receive from others: In addition to the information you provide us directly, we receive information about you from others, including:

Other Users: Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.

Social Media

You may be able to use your social media login (such as Facebook Login) to create and log into your URBN Caravan account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.

Other Partners

We may receive info about you from our partners, for instance where URBN Caravan ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).Information collected when you use our services
When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:

Usage Information
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
Device information
We collect information from and about the device(s) you use to access our services, including: o o hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); o information on your wireless and mobile network connection, like your service provider and signal strength; o information on device sensors such as accelerometers, gyroscopes and compasses.
Other information with your consent
If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.
Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).

C. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy For more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including URBN Caravan, do not currently respond to DNT signals.

D. HOW WE USE INFORMATION

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

We will use your information for various purposes, including but not limited to the following purposes:

Registering you as a user.
To send push notifications.
Facilitate communication between users.
When you submit information as part of a sweepstake or interact with our social media channels, we may publish the information you submitted, alongside your name and home country on our Website and social media channels
To manage sweepstakes (including publishing the names of winners where required).
To contact you about a submission you have made.
To provide to vendors, consultants and other service providers who require access to such information to carry out activities on our behalf.
For our own legitimate business purposes and needs.
To administer your account(s).
To send you service related communications.
To respond to your requests and provide feedback.
To analyze and/or improve our Services.
To personalize the way URBN Caravan content is presented to you online.
To deliver interest-based advertising based upon your browsing of our websites and others.
To investigate, prevent, or take action regarding illegal activities (including copyright infringement), suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Website or any policies thereof or as otherwise required by law.
To filter spam and other inappropriate content from our services.
To block disruptive users and protect the safety of users of our services.
To enforce our Terms of Service.
To send you newsletters, offers and promotions relating to our brands and services and special promotions from our trusted partners in accordance with your email preferences.
To manage our email suppression list.
To seek your feedback or to contact you in relation to the products and services offered on our Website.
To send you, from time to time, updates or advertisements.
To anticipate and resolve problems related to our services.
To inform you of any changes to our Website, or to send you additional information about us or our Website.
To respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
To protect and defend the rights or property of URBN Caravan or the users of our Website.
To anticipate and resolve problems related to our services.
In case of merger or acquisition with another company or entity, to transfer information about you to such entity.
To allow you to enter promotions or sweepstakes, if any.
To remove, if need be, all the personally identifiable information and use the rest for historical, statistical or scientific purposes.
Provide you with customer support and respond to your requests
Complete your transactions.
Communicate with you about our services, including order management and billing.
Analyze your profile and that of other users to recommend meaningful connections.
Show users’ profiles to one another.
Link the various devices you use so that you can enjoy a consistent experience of our services on all of them by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.
Administer focus groups and surveys.
Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior).
Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
Comply with legal requirements.
Assist law enforcement.

To process your information as described above, we rely on the following legal bases:

Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.

Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.

Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

E. DISCLOSURE OF PERSONAL INFORMATION

Since our goal is to help you make meaningful connections, the main sharing of users’ information with other users. We also share some users’ information with service providers and partners who assist us in operating the services, with other Match Group companies and, in some cases, legal authorities. Read on for more details about how your information is shared with others

We may share your Personal Information with third parties as set out in this Privacy Policy as follows:

1. If applicable, with vendors, consultants and other service providers who need access to such information to carry out work on our behalf, including for processing of payments.

2. In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process.

3. When you submit information as part of a contest or interact with our social media channels (for example you provide a review about URBN Caravan on our Facebook page) we may publish the information you submitted, alongside your name and home country on our Website and social media channels.

4. If we believe your actions are inconsistent with the spirit or language of our terms and conditions or Privacy Policy or to protect the rights, property and safety of URBN Caravan, our users or others.

5. In the event that there is a sale of the assets of URBN Caravan, any merger, financing or acquisition of all or portion of our business to another company, including sales in bankruptcy or liquidation, any third party to which URBN Caravan transfers or sells its assets will have the right to continue to use the personal and other information that you provide us in the manner set out in this Privacy Policy.

6. We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.

7. We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.

8. We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

9. We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

10. We share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share.

We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other Match Group companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.

F. CROSS-BORDER DATA TRANSFERS

Sharing of information laid out in Section 5 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.

G. YOUR RIGHTS

We want you to be in control of your information, so we have provided you with the following tools:

Access / Update tools in the service. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please send us a message info@urbncaravan.com.
Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
Deletion. You can delete your account by sending an email to info@urbncaravan.com with “Delete My Account” in the subject line. We will process your request within 48 hours.

We want you to be aware of your privacy rights. Here are a few key points to remember:

Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by sending us a message at info@urbncaravan.com.
Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us info@urbncaravan.com.

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact us to provide their written consent before the information is released. We may ask them to provide proof of identity before we can process the request.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

H. RESIDENTS OF CALIFORNIA

If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request via email to info@urbncaravan.com with “California Resident Request Notice” in the subject line. Please allow at least 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.

I. HOW WE PROTECT YOUR INFORMATION

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately.

We recommend you take utmost care when connecting over free public WiFi networks and understand it might not be completely a secure environment and that you do so at your own risk.

J. STORING YOUR INFORMATION

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 4) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will not be visible on the services anymore.

In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:

1. We must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);

2. We must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);

3. There is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

4. The information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints.

K. CHILDREN’S PRIVACY

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.

If we learn that we have collected or received Personal Information from a minor under 18 without verification of parental consent, we will delete that information.

L. PRIVACY POLICY CHANGES

Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

This privacy policy will help you to make an informed decision about whether to use or continue using URBN Caravan services. If you do not agree to our policy, please do not use the URBN Caravan Mobile App, Website and all related Services.

M. HOW TO CONTACT US

If you have questions about this Privacy Policy, here’s how you can reach us:

info@urbncaravan.com.

Effective from May 18, 2022