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Privacy Statement

Last updated on June 1, 2023

At Renow, we take data protection seriously and are committed to protecting our customers' privacy. This Privacy statement describes the key principles and practices we follow to ensure that your privacy is respected when you use our services.

In this privacy statement, the word "user" or "you" refers to the users of the Renow services together, and "Trading Company" refers to the seller company from which you have purchased the products that you are returning through the Renow services.

With this privacy statement, we inform our users about the processing of their personal data. The user must read and understand the terms of this privacy statement in order to use Renow services.

This privacy statement may be updated from time to time to reflect changes in our data processing practices or other changes. We will not make significant changes to this privacy statement or reduce users' rights under this privacy statement without notice.

Controller and contact information

The controller of the processed personal data is:

Renow Oy
Business ID: 3322228-3
Vilhovuorenkatu 12
00540 Helsinki

Data protection officer: Renow has appointed a data protection officer, who you can reach via the above contact information or by sending an email to privacy@renow.ai.

Personal data to be processed and their sources

We process personal data only to the extent that it is necessary and appropriate for a specific processing purpose. The personal data we collect and process can be divided into two general categories: user data and usage data.

User Data

User data is personal data that is collected either directly from you or from the Trading Company whose order you are returning. We can collect user data from our users and the Trading Company in variety of ways, including after making a service contract with the Trading Company or when users make a return in the Renow service.

The following personal data collected and processed by us is necessary in order for a proper performance of the contract between you and us as well as for our legitimate interest whilst fulfilling our contractual obligations towards the Trading Company and for the compliance with our legal obligations. After conclusion of the service contract between Renow and the Trading Company, the Trading Company gives us the following information in connection with your return:

  • full name
  • Your email address
  • Order delivery address
  • Line-specific product information related to the order you are returning, including price of products
  • Existing returns, their status and reasons

When you make the return to Trading Company in Renow service, we ask you for the following return related information.

  • Reason of returning
  • Condition of returned products and product packages
  • Images of returned products and product packages
  • Other return history

We may also process other information you voluntarily provide, such as:

  • Information you provide when you submit ratings, comments or respond to surveys
  • Information you provide by phone or email

Usage Data

Usage data arises from the User's interaction with Renow services. Although we generally do not use usage data to identify you as an individual, under certain circumstances you may be identified from it either alone or combined or linked to user data. In such situations, usage data may also be considered personal data under applicable laws and we treat such data as personal data.

We may automatically collect the following usage data when you visit or interact with the Renow services:

  • Information that describes your device or browser, its versions, features, capabilities and settings
  • Information about your operator, Internet service provider and network connection type, including your IP address
  • Identifiers provided by your device or third parties for application vendors or advertisers, or identifiers we create ourselves
  • Country, region, time zone and geo-IP level location data
  • From where you followed the link to Renow services
  • Information about your interaction with Renow services and their use. This includes, for example, usage patterns, which features you use and information about returns.

For more information on managing advertising and analytics identifiers on your device, see "Cookies and other technologies".

Cookies and other technologies

Renow uses cookies and other similar technologies, such as the browser's local data storage. Cookies are small text files between the end device's browser and the server. Cookies and other identifiers have a defined validity period, after which the browser deletes the identifier. We use these technologies to run our operations and services and for analytics.

Functional cookies and local data storage are used e.g. for customer identification, language selection and returns functionality. To use this functionality acceptance of cookies and local data storage is mandatory. Functional cookies set by the server and variables of the local data warehouse remain in the browser for 15 min-24 months, unless they are separately deleted from the browser settings. Visiting the website resets cookies and variables of the local data storage, if the browser allows it.

The partners and technologies we use for analytics help us better understand our customers' behavior and provide us information which products, functions and services our customers are interested in. The information used is anonymized whenever possible. Otherwise, we treat the information as personal to the extent that the identifier contains customer specific information, such as an IP address. Identifiers that can be connected to the customer in some way are also treated as personal information. The validity period of identifiers is 30s-24 months.

We use the Google Analytics service for usage analytics of our site, trends and return statistics and Amazon Web Services CloudWatch service for telemetry and technical monitoring of our services. The information sent to Google and Amazon CloudWatch contains only anonymized or pseudonymized information.

You can manage your cookie settings through the cookie banner on our website.

Purposes and grounds of processing

We process personal data only to the extent that it is necessary and appropriate for the specific processing purposes. Personal data is used:

  • To provide Renow services to you and Trading Companies
  • To process and archive product returns for Trading Companies
  • To determine the condition of products purchased from the Trading Company
  • To improve the customer experience of Renow services
  • To develop Renow services and operations
  • For analytics and statistical purposes
  • To prevent abuses

Information is processed based on the agreement between the user and Renow, the use of the site, the user's separate consent or legal obligations.

Part of Renow's operations is based on the legitimate interest of the data controller, so that we can offer the best possible service experience. Such functions include customized content of the service, surveys, and notifications and messages based on customer relationship. With these functions, we offer e.g.

  • Content related to guide new users in using the service
  • We ask users' opinions about our service
  • Information about relevant services and changes in services
  • Useful content and information about additional services related to past history

In addition, we may process your personal data to administer and fulfill our legal obligations. This includes information that is processed to comply with our accounting obligations and to provide information to relevant authorities such as tax authorities or law enforcement authorities in accordance with mandatory legal obligations.

Transfer to countries outside Europe

Renow stores your personal data primarily in the European Economic Area and the data centers we use are located in the European Economic Area. However, we have service providers outside the European Economic Area. Consequently, our service providers may transfer your personal data or process it in countries outside the European Economic Area or the user 's domicile.

We take appropriate measures to ensure that users ' personal data is adequately protected. We provide appropriate and adequate protection for the transfers of personal data to countries outside of the European Economic Area through agreements with our service providers based on the standard contractual clauses or through other appropriate safeguards.

For more information about transfers of personal data, please contact us at any of the addresses mentioned above.

Data recipients

We share your personal data within the Renow organization only if and to the extent that it is reasonably necessary for the purposes of this Privacy statement.

We will not share your personal data with third parties outside the Renow organization unless one of the following conditions is met:

For the purposes presented in this privacy statement and for the processing of your return to the Trading Company

To the extent that we are obliged to provide Renow services to the Trade Companies and to process your return and for the Trading Company to reimburse it requires, we will provide your information to the Trade Company where you purchased the returned products. This includes the information about the return, reason for the return, returned products, condition information about the products and packaging, pictures, comments and the feedback you have given about the return.

We also use user data with third parties for analytics and statistical purposes. Information used for analytics and personalization purposes is always anonymized or pseudonymized whenever possible. Only we can connect the used pseudonymized information to your name.

Partners to implement Renow services

To the extent that third parties (such as the partners who check, process, service and store your return and courier and delivery partners who ship your return) need access to personal data in order for us to perform the Renow Services, we provide your data to such third parties. We provide your personal data to such partner company and where applicable to its parent company or franchise operator that are necessary to process your return.

Depending on the role of the partner, this may include your name, delivery address and information about your return, including venue details, order number, order and delivery time, delivery method, returned products and packaging and their condition information, comments and feedback you have given about the return. This information is shared so that the partner can process the return and comply partner 's legal obligations. Where partner processes such details for purposes of fulfilling its own rights and obligations, such as its legal obligations towards you, partner is independent controller of the personal data and responsible for the lawfulness of its processing operations.

We may also share your phone number and name with the partner preparing the return if it is necessary, for example, to ask you for more information about the return or for other necessary purposes related to process your return.

For legal reasons and legal processes

We may share your personal data with third parties outside Renow if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Renow, the users or the public as far as in accordance with the law. When possible, we will inform you about such processing.

For other legitimate reasons

If Renow is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the users concerned when the personal data are transferred or become subject to a different privacy statement.

With your explicit consent

We may share your personal data with third parties outside Renow when we have your explicit consent to do so. You have the right to withdraw this consent at all times free of charge, for example, by contacting us.

Storage period

Renow does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Renow services or the relevant parts thereof. In addition, some information may be stored longer to the extent that it is necessary to fulfill the obligations set by law, such as accounting and the responsibilities that Trading Companies have regarding consumer trade. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.

We assess regularly the storage period for personal data to ensure the data is stored only for the necessary time period.

Your rights

As a user, you have the right to:

  • Get access to your personal data, including the right to receive a copy of your personal data
  • Requests correction or deletion of personal data about you
  • Under certain conditions, request restriction of processing or object processing of your personal data

In addition, if the processing is based on a separate consent, you have the right to withdraw your consent at any time. Please note that withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

You can make a request to exercise your rights by contacting our customer service. The request must be sufficiently specified so that our customer service can verify your identity. We will notify you if we are unable to implement your request in some respects, such as deletion of all information for which we have a legal obligation or right to keep.

In case you consider our processing of personal data is inconsistent with the applicable data protection laws, you may lodge a complaint with the local supervisory authority for data protection in Finland (https://tietosuoja.fi/).

Information security

We use good care and administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. With processing personal data and respective technical solutions, we follow best practices for information security, for example encryption, anonymization, pseudonymization and firewalls.

Renow ensures that stored data as well as server access rights and other information critical to the security of personal data are handled confidentially and only by those employees whose job description it is.