Privacy Policy
Last Updated: 10/6/2024
1. Scope and Updates of this Privacy Policy
This Privacy Policy applies to your use of the PureChoice website and all PureChoice applications, services (including payment services), products, and tools (collectively the "Services")provided by PureChoice Inc. or its affiliates (PureChoice Inc. and the
companies it directly or indirectly controls are referred to as "PureChoice Affiliates").
This Privacy Policy applies regardless of how you access or use these Services, including access via mobile devices and apps.
PureChoice reserves the right to modify this Privacy Policy at any time. We will post any changes on this page and, if the changes are significant, we will provide a more prominent notice. The updated Privacy Policy will be effective 30 days after posting.
Your continued use of our Services after the effective date signifies your acceptance of the updated Privacy Policy.
2. Data Controller
2.1 General Use of Services
The PureChoice Affiliate responsible for the collection and processing of your personal data in connection with the provision of our Services (except payment services for sellers) depends on your region of residence:
USA: PureChoice Inc.
Canada: PureChoice Canada Limited.
European Union: PureChoice GmbH.
United Kingdom: PureChoice (UK) Limited.
For all other countries: PureChoice Global GmbH.
Your region of residence is determined based on your account registration address (for registered users) or your location (for non-registered users).
2.2 Payment Services for Sellers
For sellers using our payment services, the following PureChoice Affiliates are responsible for the collection and processing of your personal data:
USA: PureChoice Payments Inc.
European Economic Area (EEA) and Switzerland: PureChoice Payments S.à r.l.
UK: PureChoice Payments UK Ltd.
For all other countries: PureChoice Payments Inc.
As described in our Payments Terms of Use, your personal data may be processed by one or more of these entities depending on your location and the PureChoice website on which a user completes a transaction with you.
3. Data Protection Officer and Contact Information
We have appointed data protection officers in several countries to oversee the protection of your personal data. You can find the contact details of your data protection officer in our PureChoice Privacy Center.
If you have any questions or complaints regarding this Privacy Policy, our data protection principles, or our handling of personal data, you can contact the PureChoice Privacy Team or the controller responsible for processing your personal data at any
time. All necessary information and contact details can be found in our PureChoice
Privacy Center.
4. Personal Data We Collect and Process
We collect your personal data when you:
Use our Services
Create a new PureChoice account
Provide us with information via a web form
Add or update information in your PureChoice account
Participate in online community discussions
Otherwise interact with us
We also collect personal data from other sources, including:
Other PureChoice Affiliates
Credit agencies or bureaus
Data providers
Public databases
Social media platforms (if you choose to connect your PureChoice account with a social media account)
The types of personal data we collect include:
4.1 Information You Provide to Us
Identifying information (e.g., name, date of birth, government-issued identification)
Contact information (e.g., email address, phone number, postal address)
Account information (e.g., username, password)
Financial information (e.g., credit card details, bank account information)
Transactional data (e.g., purchase history, seller performance history)
Communications with us (e.g., customer support inquiries, chat logs)
User-generated content (e.g., product reviews, forum posts)
4.2 Information We Collect Automatically
Device information (e.g., IP address, browser type, operating system)
Usage data (e.g., pages visited, time spent on site, click-through rates)
Location data (e.g., general location based on IP address, precise location if permitted by you)
Cookie data (see Section 9 for more details)
4.3 Information from Third-Party Sources
Demographic data
Credit history information
Social media data (if you connect your PureChoice account with a social media account)
Public records
5. Purposes and Legal Basis for Data Processing
We process your personal data for various purposes and based on several different
legal bases that allow this processing. The main purposes and legal bases are:
5.1 Provision and Improvement of Services
Purpose: To provide, maintain, and improve our Services, including processing
transactions, authenticating users, and providing customer support.
Legal Basis: Performance of a contract; Legitimate interests
5.2 Personalization
Purpose: To provide a personalized user experience, including customized
product recommendations and search results.
Legal Basis: Legitimate interests; Consent (where required)
5.3 Communication
Purpose: To communicate with you about your account, transactions, and our
Services, including sending service updates and marketing communications.
Legal Basis: Performance of a contract; Legitimate interests; Consent (for
marketing communications)
5.4 Advertising and Marketing
Purpose: To deliver personalized advertising and marketing communications to you on and off our platform.
Legal Basis: Legitimate interests; Consent (where required)
5.5 Fraud Prevention and Security
Purpose: To detect, prevent, mitigate and investigate fraudulent or illegal
activities, and to ensure the security of our platform.
Legal Basis: Legitimate interests; Legal obligation
5.6 Legal Compliance
Purpose: To comply with legal obligations and respond to legal requests.
Legal Basis: Legal obligation
5.7 Analytics and Research
Purpose: To conduct analytics and research to improve our Services and user experience.
Legal Basis: Legitimate interests
6. Sharing of Personal Data
We share your personal data with the following categories of recipients:
6.1 PureChoice Affiliates
We share your personal data among PureChoice Affiliates to provide and improve our Services, and to fulfill our contract with you under the User Agreement and, if applicable, the Payments Terms of Use.
6.2 Service Providers
We share personal data with third-party service providers that perform services on our behalf, such as:
Payment processors
Cloud storage providers
Customer support services
Marketing and advertising partners
Analytics providers
Fraud prevention services
6.3 Buyers and Sellers
To facilitate transactions, we share some personal data between buyers and sellers, such as usernames, shipping addresses, and contact information.
6.4 Legal and Regulatory Authorities
We may share personal data with law enforcement agencies, courts, regulators, or other government authorities when required by law or to protect our legal rights.
6.5 Business Transfers
If we are involved in a merger, acquisition, or sale of assets, we may transfer your personal data as part of that transaction.
7. Cross-Border Data Transfers
Some recipients of your personal data may be located in countries other than your own, which may have different data protection laws. When transferring personal data internationally, we implement appropriate safeguards, such as:
Standard Contractual Clauses approved by the European Commission
Binding Corporate Rules for transfers within the PureChoice group of companies
Adherence to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (where applicable)
By using our Services, you acknowledge and consent to these cross-border transfers of your personal data.
8. Data Retention and Deletion
We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:
The length of time we have an ongoing relationship with you
Legal obligations we must comply with
The existence of any legal claims or potential disputes
The nature of the information and its sensitivity
Generally, we retain personal data for the following periods:
Account information: For the duration of your account plus 7 years
Transaction data: 10 years from the date of the transaction
Communication records: 3 years from the date of the last communication
Log data and analytics: 13 months
When we no longer need to retain your personal data, we will either delete it or anonymize it. If deletion or anonymization is not possible, we will securely store your personal data and isolate it from any further use until deletion is possible.
9. Cookies and Similar Technologies
We use cookies and similar technologies (collectively referred to as to provide, customize, evaluate, improve, and secure our Services.
9.1 Types of Cookies We Use
Essential cookies: Necessary for the operation of our website and Services
Analytical/performance cookies: Allow us to recognize and count the number of visitors and analyze website use
Functionality cookies: Used to recognize you when you return to our website
Targeting cookies: Record your visit to our website, the pages you have visited, and the links you have followed to deliver personalized advertisements.
9.2 Your Cookie Choices
You can manage your cookie preferences through your browser settings. However, please note that disabling certain cookies may impact the functionality of our Services. For more detailed information about the cookies we use and your choices regarding cookies, please see our Cookie Policy.
10. Your Rights as a Data Subject
Depending on your jurisdiction, you may have the following rights regarding your personal data:
Right to access: You can request a copy of the personal data we hold about you.
Right to rectification: You can request that we correct inaccurate or incomplete personal data.
Right to erasure: You can request that we delete your personal data in certain circumstances.
Right to restrict processing: You can request that we restrict the processing of your personal data in certain circumstances.
Right to data portability: You can request a copy of your personal data in a structured, commonly used, and machine-readable format.
Right to object: You can object to our processing of your personal data in certain circumstances.
Right to withdraw consent: Where we rely on consent as the legal basis for processing, you can withdraw your consent at any time.
To exercise these rights, please contact our Privacy Team through the PureChoice Privacy Center. We will respond to your request within the timeframe required by applicable law.
Please note that these rights may be limited in some circumstances by local law requirements.
11. Data Security
We implement appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:
Encryption of sensitive data in transit and at rest
Access controls and authentication mechanisms
Regular security assessments and penetration testing
Employee training on data protection and security
Physical security measures for our data centers
While we strive to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.
12. Children's Privacy
Our Services are not directed to children under the age of 18, and we do not knowingly collect personal data from children. If you believe we have inadvertently collected personal data from a child, please contact us immediately, and we will take steps to
delete such information.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post the updated Privacy Policy on our website and update the date at the top of this policy.
For material changes, we will provide notice through our Services or by other means, such as email. We encourage you to review this Privacy Policy periodically to stay informed about our data practices.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our
data practices, please contact our Privacy Team or Data Protection Officer through the
PureChoice Privacy Center.
15. Dispute Resolution
If you have a complaint about our privacy practices, please contact us first, and we will do our best to resolve the issue. If you are not satisfied with our response, you may have the right to lodge a complaint with a supervisory authority in your jurisdiction.
By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal data as described herein.
16. International Users
Our Services are controlled and operated from the United States. If you access or use our Services from other regions of the world with laws governing data collection and use that may differ from U.S. law, please note that you may be transferring your personal data to the United States and other countries around the world. By providing your personal data, you consent to the transfer of information to countries outside your
country of residence, which may have different data protection rules than those of your country.
17. California Privacy Rights
If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) and other state privacy laws. Please see our California Privacy Notice for more information about these rights and how to exercise them.
18. Do Not Track Signals
Some web browsers may transmit signals to the websites and other online services with which the browser communicates. There is no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise our policy on responding to these signals.
19. Third-Party Links and Services
Our Services may contain links to third-party websites, products, or services. We are not responsible for the privacy practices or the content of these third-party sites. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators' policies governing privacy and security. We encourage you to learn about third parties' privacy and security policies before providing them with personal data.
20. Data Protection Impact Assessments
Where required by law or where we believe it is appropriate, we conduct Data Protection Impact Assessments (DPIAs) for processing activities that are likely to result in a high risk to the rights and freedoms of individuals.
21. Privacy by Design and Default
We implement privacy by design and default principles in the development and management of our Services. This includes implementing appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of the processing are processed.
22. Employee Training
We provide regular training to our employees on data protection principles and practices to ensure they understand their responsibilities in handling personal data.
23. Data Breach Notification
In the event of a personal data breach, we will notify the relevant supervisory authority without undue delay and, where feasible, not later than 72 hours after having become aware of it, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the breach is likely to result in a high risk to the rights and freedoms of natural persons, we will also notify the affected individuals without undue delay.
24. Automated Decision-Making and Profiling
We may use automated decision-making and/or profiling in certain aspects of our Services, such as fraud prevention or personalized recommendations. Where we use such techniques, we will provide meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
25. Data Protection Addendum for Business Customers
For our business customers, we offer a Data Processing Addendum (DPA) that reflects our compliance with GDPR and other applicable data protection laws. This DPA is incorporated into and forms part of the commercial agreement between PureChoice and the business customer.