Welcome!

Welcome to vveave! We hope you will enjoy and appreciate using our “Services”, which includes (i) visiting our website at https://vveave.com/, including all subdomains, present and future (the “Website”); and (ii) using the “Platform” available on the Website as either a “Designer” or a “Consumer” to collaborate on “Projects” reinventing items of clothing or accessories (“Items”) to create one-of-a-kind, unique pieces. As further described in our Terms of Use, using the Platform, a Consumer can seek out a Designer on the Platform to work together on a Project and to upcycle Items from his/her/their wardrobe to create entirely new, custom pieces. We want you to know we take your privacy and protection of personal data very seriously. We are providing this Privacy Policy (the “Policy”) to tell you about who we are, what personal data we collect from you and about you, and what we do with your personal data, all while you use the Services or otherwise interact with us. The Policy also explains your rights under the law, and how you can contact us and the necessary authorities to enforce those rights. We ask that you please read it carefully.

Key Elements of this Policy

Here are the key elements of this Policy so you can know the important parts right away to make an informed decision about your consent for our collection, use and disclosure of your personal data. By submitting any personal data to us via any means, you consent to such collection, use and disclosure. You can find the details in the rest of the Policy.

Some Terms

Before we get started with the details, here are a few terms we think you should know as you read this Policy.

“Data Protection Laws” refers to the laws that are designed to protect your personal data and privacy in the place where you live. These include: (1) the “GDPR”, the European Data Protection Law which stands for “General Data Protection Regulation”, with the official name Regulation (EU) 2016/679 of the European Parliament and of the Council; (2) “PIPEDA” (Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our activities in Canada; and (3) the California Consumer Privacy Act (“CCPA”) which applies to our activities in the United States in certain circumstances. vveave is committed to adhering to all these applicable Data Protection laws.

“Personal data” – this is information we collect from you or about you and which is defined in the GDPR as “any information relating to an identified or identifiable natural person.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you. Under PIPEDA and the CCPA, the equivalent concept is “personal information”, which is roughly the same. Any mention of “personal data” in this Policy shall also mean personal information.

Other terms and definitions used in this Policy may be found in our Terms of Use and will have thesame meaning in this Policy as they do there.

About Us and Contacting Us

vveave Inc. (“vveave”) is a duly-incorporated company under the laws of Canada. Where this Policy refers to “vveave”, it may refer to vveave Inc., its subsidiary vveave USA, Inc. and / or their shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns, depending on the context.

Under the GDPR, vveave is a “data controller”. That means we collect personal data directly from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means collection, use, storage, transfer or any other action related to your personal data; it is used in this Policy in that way.

If you want to ask us anything about what’s in this Policy, or anything else privacy- or data- related, or exercise any of your available privacy rights, you can email:

vveave Privacy Officer

privacy@vveave.com

Here is the mailing address for you as well:

vveave Privacy Officer
1454 Crescent Street
Montreal, Quebec
H3G 2B6
Canada

Your Rights

You have the following rights regarding your personal data held by vveave, and other privacy rights. Please note that not necessarily all of these rights may be available to you; this depends on the Data Protection Laws where you are located that apply to you. These rights may be exercised without affecting the price you pay for any of the Services. Notwithstanding that, exercising certain of these rights may affect your ability to use some or all of the Services.

• The right to withdraw at any time your consent for vveave to process your personal data;
• The right to have your personal data erased from vveave’s records;
• The right to access your personal data and any relevant information around its processing and use;
• The right to have a copy of your personal data given to you in an easy-to-read format so that you can transfer it to another data processor;
• The right to have your personal data corrected or updated if you believe it is inaccurate or out of date;
• The right to opt out of marketing communications we send you, at any time;
• The right to know whether vveave sells or shares your personal data (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy Officer if you need additional information or clarifications;
• The right to demand that vveave not sell your personal data;
• The right to restrict the processing of your personal data if it is inaccurate or if our processing or use of it is against the law; and
• The right to refuse any marketing or advertising targeted at you by vveave.

If you wish to exercise any of these rights, please contact our Privacy Officer at the contact information above, or refer to certain relevant sections further in this Policy.

Personal Data Collected from You and What We Use It For

In the table below, please find all the personal data we may collect from you directly, what we use it for, and the legal basis under the GDPR for us having and processing this personal data. Under PIPEDA, the legal basis is your informed consent, and by submitting this personal data you acknowledge having granted this consent to vveave.

Where you have provided personal data further to the contract between you and us, if you fail to provide such data or withdraw your consent to use such data, we will no longer be able to provide certain Services to you.

Personal Data Collected About You from Third Parties and What We Use It For

Sometimes we get personal data about you from third parties. This table explains the details about this personal data – what it is, where it came from, what we do with it, and the legal basis for us having and processing this personal data under the GDPR. Under PIPEDA, the legal basis is your informed consent.

To the extent that analytics identifiers are generated from third parties, these may be considered personal data collected from third parties, and you can find details about that further below in this Policy.

Note that all payments between a Consumer and Designer will take place directly on the Stripe website. As a Consumer, once you have commissioned a Designer and are proceeding to pay for the Project, the Platform will connect you, via hyperlink, to the Stripe website to complete your purchase. Consequently, vveave does not collect any payment or credit card information directly from Designers or Consumers. More information can be found in our Terms of Use.

Sensitive Personal Data

We do not collect any of what the GDPR considers sensitive personal data from you, unless you voluntarily submit it either via the Platform’s chat function, via a photo uploaded to your Platform profile or by email, which we encourage you not to do.

Who We Transfer Your Personal Data To

We routinely share some of your personal data with certain types of third parties who are identified in the table below along with what they do with it. Some of those third-party recipients may be based outside your home jurisdiction. If you are in the European Economic Area — please see the “Transfer of Your Personal Data Outside of the European Economic Area” further down in this Policy for more information including on how we safeguard your personal data when this occurs.

We will share personal data with law enforcement or other public authorities if: (1) we are required by applicable law in response to lawful requests, including to meet national security or law enforcement requirements; (2) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of vveave’s Terms of Use or other contract that governs your relationship with us; or (3) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the internet in general (such as voluminous spamming or denial of service attacks).

We may also share personal data: (1) to a parent company, subsidiaries, joint ventures, or other companies under common control with vveave (in which case we will require such entities to honour this Policy); (2) if vveave merges with another entity, is subject to a corporate reorganization, sells or transfers all or part of its business, assets or shares (in which case we will require such entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy).

We will never share your personal data with other third parties except under these circumstances. We do not sell your personal data to any third party for direct marketing purposes or any other purpose.

Tracking Technology (“Cookies” and Related Technologies)

vveave uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) in the Services and by interacting with the Services you agree to their use. Cookies are small text files placed on your computer or device when you visit a website or use an online service, in order to track use of the site or service and to improve the user experience by storing certain data on your computer or device.

Specifically, we use cookies and related technologies for the following functions:

• to enable your signing-in to the Platform;
• to facilitate the proper functioning of the Services;
• to facilitate online advertising, as described more fully below in this Policy;
• to provide general internal and user analytics on the Services and to conduct research to improve the content of the Services using analytics programs listed above in this Policy; and
• to assist in identifying possible fraudulent activities.

Your browser can be set to refuse cookies or delete them after they have been stored. You can refer to your browser’s help section for instructions, but here are instructions for the most commonly-used browsers and operating systems:

• Google Chrome Mozilla Firefox Microsoft Edge Microsoft Internet Explorer Opera Apple Safari iOS

Please note that deleting or blocking certain cookies may reduce your user experience by requiring you to re-enter certain information, including information required to use our Services. Furthermore, deleting certain cookies may prevent certain functions, or the entirety of the Services, from working at all.

Email Communications and Compliance with Anti-Spam Laws

vveave uses ActiveCampaign and SendGrid to manage our mailing list and to send out promotional emails and Auth0 to send out emails related to various Services functions (ActiveCampaign, SendGrid and Auth0, collectively the “Email Service Providers”). Personal data is transferred to the Email Service Providers in order to manage the mailing list and for the emails to be sent out properly. Your Contact Information is only used to send out emails; the Email Service Providers do not use this Personal Information for any other purpose and will not transfer or sell your Personal Information to any other third party. For more information, please refer to ActiveCampaign's Privacy Policy, Twilio's Privacy Policy, which applies to SendGrid or Auth0's Privacy Policy.

You may unsubscribe from vveave’s mailing list at any time, by following the link at the bottom of all vveave emails. Other types of emails, such as transactional, relational, and other emails related to the Services will not have an opt-out option as they are necessary for the use of the Services.

vveave’s practices with regard to its emails are designed to be compliant with anti-spam laws, specifically the CAN-SPAM Act of 2003 and the law unofficially called “CASL”, or Canada’s Anti-Spam Law (S.C. 2010, c. 23). If you believe you have received any email in violation of these laws, please contact us using the contact information further up in this Policy.

vveave Advertising and Opting Out

vveave uses certain advertising networks to provide advertising to you. Specifically, we use Google AdWords and Display Network, Facebook Ads, Instagram Ads, TikTok Ads, Snapchat Ads and Pinterest Ads and by visiting the Website, you consent to their use. Specifically, vveave uses the remarketing features of Google AdWords’ interest-based advertising, which displays vveave advertisements that should be of particular interest to you based on your browsing and activity history interacting with the Website. These advertisements will appear on third-party websites around the web. Google uses specific cookies to allow them to serve these advertisements to you. Additionally, vveave also uses Facebook Ads, Instagram Ads, TikTok Ads, Snapchat Ads and Pinterest Ads to serve you advertisements for vveave when you are on each of those social media platforms, respectively. You may prevent this type of advertising by deleting the appropriate Google, Facebook, Instagram, TikTok, Snapchat and Pinterest cookie through your browser, though this may not be permanent. For a more permanent solution, you may opt out of such Google, Facebook, Instagram, TikTok, Snapchat and Pinterest advertising by adjusting your Google and Facebook ad settings or by using the WebChoices online opt-out tool.

How We Protect Your Personal Data

We have implemented very strict technical and organisational procedures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed by us. These procedures prevent your personal data from being lost; or used or accessed in any unauthorised way.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws require us to do so, and within the time frame required by the applicable Data Protection Law.

vveave uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal data) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Services, and these third parties have been selected for their high standards of security, both electronic and physical. For example, vveave uses Amazon Web Services, a recognized leader in secure data, for hosting of the Services and related data, and storage of data including personal data.

Finally, all information, including personal data, is transferred with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for internet data transfer and transactions. You can use your browser to check vveave’s valid SSL security certificate.

Transfer of Your Personal Data Outside of the European Economic Area (EEA)

For our European users, we endeavour to keep your personal data inside the EEA. However, certain of our data processors (and vveave) are in other countries where your personal data may be transferred. However, these countries are limited to countries with particular circumstances that protect your data, specifically:

• Canada. Canada has been determined to have an “adequate level of protection” for your personal data under European data protection law.
• The United States. Your personal data is only transferred to companies in the United States that: (1) have signed agreements with us or have informed us that they are GDPR-compliant; and (2) have concluded the Standard Contractual Clauses for the transfer of personal data outside the EEA.

That’s it! You have the right, however, to refuse to have your data transferred outside the EEA. Please contact our Privacy Officer to make that request. Please note that making this request may prevent you from being able to use a portion or all of the Services.

Supervisory Authorities and Complaints

If you are in the EEA, under the GDPR you have the right to make a complaint to the appropriate supervisory authority. If you are not satisfied with the response received or the actions taken by our Privacy Officer, or if you would like to make a complaint directly about vveave’s data practises, we invite you to contact the supervisory authority in your country. If you are in the U.K., you should contact the Information Commissioner’s Office who is the supervisory authority. You can reach them in a variety of ways, including by phone (0303 123 1113 in the UK) and mail (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF). If you are in France, you should contact the Commission Nationale de l'Informatique et des Libertés who is the supervisory authority there. Their contact information can be found here.

The full listing of all Data Protection Authorities (the supervisory authorities) across the EEA can be found here.

Data Retention

Your personal data will only be kept for as long as it is necessary for the purpose needed for that processing. For example, we will only retain your Account Information for as long as you have an account with us.

Automated Decision-Making

vveave does not use any automated decision-making processes in providing the Services.

Children’s Privacy Statement

The Services are not intended for children under the age of 18. We do not knowingly collect any personal data from a child under 18. If we become aware that we have inadvertently received personal data from a person under the age of 18 through the Services, we will delete such information from our records.

Changes to This Privacy Policy

The date at the top of this page indicates when this Policy was last updated. Every now and then, we will have to update this Policy, and we will update it no less than once every 12 months. You can always find the most updated version at this URL, and we will always post a notice on the Services if we make significant changes. If you have a vveave account, we will also email you to tell you the Policy has been updated, and what the important changes are.