Preloved Privacy Statement

Effective Date: [1^ST Oct 2025]  |  Last Updated: [1^ST Oct 2025]  

1. Introduction & Scope

This Privacy Policy explains how VeneBene (“VeneBene,” “we,” “us,” or “our”) collects, uses, shares, and safeguards personal information when you visit our websites, use our mobile applications, shop influencer‑curated collections, apply to become or participate as a creator/ambassador, interact with our social channels, or otherwise use our services (collectively, the “Services”). It also describes your privacy rights and choices. By using the Services, you agree to the practices described here. If you do not agree, please discontinue use.

2. Key Definitions

• “Personal Information” (or “PI”) means information that identifies, relates to, describes, could be reasonably linked, directly or indirectly, with a particular consumer or household. • “Sensitive Personal Information” (or “SPI”) includes certain categories defined by law (e.g., precise geolocation, government IDs, racial/ethnic origin, health data). • “Processing” means any operation performed on personal information (collection, use, disclosure, storage, etc.). • “Controller”/“Business” means the entity that determines the purposes and means of processing personal information. • “Processor”/“Service Provider” means an entity that processes personal information on behalf of the controller/business. • “Sale” and “Share” have the meanings provided in U.S. state privacy laws (e.g., “share” for cross‑context behavioral advertising).

  3. Notice at Collection (California/CPRA and Similar Laws)

  We collect the personal information categories listed below for the purposes stated, retain them for the periods shown, and disclose them to the types of recipients identified. We do not knowingly sell the personal information of minors under 16.

  Category (CPRA)	Examples	Purpose(s) of Use	Disclosed To	Sold/Shared?
  A. Identifiers	Name, username, email, phone; device IDs; IP address	Account creation; authentication; communications; fraud prevention	Service providers (hosting, support), analytics/advertising partners, affiliates	Shared for cross‑context advertising; not sold for monetary value
  B. Personal records	Billing address, limited payment details (tokenized), order history	Purchases; fulfillments; accounting; support	Payment processors; fulfillment partners; support providers	No
  C. Protected class info (optional/voluntary)	Gender/pronouns (if provided)	Personalization; creator program EEO compliance (where allowed)	Service providers; HR/compliance (creators/applicants)	No
  D. Commercial information	Viewed items, saved lists, purchase history	Personalization; attribution; analytics; marketing	Analytics/advertising partners; affiliates; service providers	Shared for cross‑context advertising
  F. Internet/network activity	Device data, app events, cookies, pixel data, referral URLs	Platform operations; security; analytics; attribution; advertising	Analytics/advertising partners; anti‑fraud vendors; service providers	Shared for cross‑context advertising
  G. Geolocation (coarse)	City/state inferred from IP	Localization; fraud detection; legal compliance	Service providers; anti‑fraud vendors	No
  I. Professional/employment (creators)	Public profile/handles, portfolio links, payout/tax info	Creator onboarding; payouts; compliance; promotion of shops	Payment processors; tax vendors; service providers; affiliates	No
  K. Inferences	Interests derived from browsing/purchase activity	Personalization; advertising; product improvement	Analytics/advertising partners; affiliates	Shared for cross‑context advertising

  Retention: We retain personal information only as long as necessary for the purposes above, consistent with Section 11 below.

  4. Sources of Personal Information

  • Directly from you (account signup, purchases, creator applications, communications with support). • Automatically from your device (cookies, SDKs, pixels, server logs). • From Retailers/brands regarding attributed transactions and fulfillments. • From social media platforms, if you connect your accounts or interact with our content. • From analytics, advertising, anti‑fraud, and payment partners.

  5. Purposes of Processing & Legal Bases (GDPR/UK GDPR)

  We process personal information for: (a) providing and improving the Services; (b) enabling creator shops and sales attribution; (c) processing transactions and payouts; (d) customer/creator support and communications; (e) security, fraud prevention, and integrity; (f) analytics, personalization, and research; (g) advertising/retargeting; (h) compliance with laws and tax obligations. Legal bases include: performance of a contract; legitimate interests (e.g., product improvement, fraud prevention, marketing to the extent permitted); consent (where required for cookies/ads or email/SMS marketing); and compliance with legal obligations.

  6. Cookies, SDKs, and Targeted Advertising

  We and our partners use cookies, pixels, local storage, and mobile SDKs to operate the Services, remember preferences, analyze engagement, attribute influencer‑driven sales, and deliver advertisements tailored to your interests (also called cross‑context behavioral or targeted advertising). You can manage cookies in your browser or device settings. Industry tools such as the Network Advertising Initiative and the Digital Advertising Alliance provide additional choices. Disabling cookies may affect functionality. Global Privacy Control (GPC): Where required by law, we honor browser‑ or device‑based GPC signals as an opt‑out of share/targeted advertising.

  7. Disclosure of Personal Information

  We disclose personal information to: • Service providers/Processors (hosting, cloud, analytics, customer support, security, anti‑fraud, payment, tax and payroll for creators). • Retailers/brands (to attribute and fulfill purchases, handle returns, and prevent fraud). • Affiliates and subsidiaries (for operations consistent with this Policy). • Advertising/analytics partners (to measure campaign performance and deliver targeted ads, subject to your choices). • Government, regulators, or law enforcement (when required by law or to protect rights and safety). • Successors (in connection with mergers, acquisitions, financing, or sale of assets).

  8. Sale/Share of Personal Information (U.S. State Laws)

  We do not sell personal information for money. We may “share” certain categories of personal information (Identifiers, Commercial Information, Internet Activity, and Inferences) with advertising/analytics partners for cross‑context behavioral advertising. You can opt out at any time via your browser settings, GPC signals where recognized, or by contacting us as described in Section 17.

  9. Data Retention

  We retain personal information for as long as necessary to: (i) provide the Services; (ii) support legitimate business purposes (e.g., accounting, analytics, fraud prevention); and (iii) comply with legal obligations. Typical periods include: account data for the life of the account and up to 24 months after closure; transaction records for 7 years for tax/audit; creator payout/tax records for the period required by law; logs and security data for 12–24 months, unless longer retention is required for investigations.

  10. Security

  We implement administrative, technical, and physical safeguards designed to protect personal information (including access controls, encryption in transit, monitoring, and vendor due diligence). No system is 100% secure; you use the Services at your own risk.

  11. International Transfers

  If you access the Services from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries where we or our service providers operate. Where required, we use approved transfer mechanisms such as Standard Contractual Clauses (SCCs).

  12. Your Rights & Choices

  • Email Marketing: Opt out via the unsubscribe link or by contacting us. • Cookies/Ads: Manage through browser/device settings and industry tools. • Access/Deletion/Correction: Request access to, correction of, or deletion of your information by contacting us. We may need to verify your identity.

  13. U.S. State Privacy Rights (CA, VA, CO, CT, UT, NV)

  If you are a resident of these states, you may have the right to: (i) know/access specific pieces and categories of personal information; (ii) delete personal information; (iii) correct inaccuracies; (iv) opt out of targeted advertising (share); (v) opt out of sale; (vi) opt out of profiling in furtherance of decisions that produce legal or similarly significant effects (where applicable). To exercise rights, contact privacy@venebene.com. We will not discriminate against you for exercising your rights. Authorized Agents: California residents may use authorized agents; we may require proof of authorization and identity verification. Appeals: Virginia/Colorado/Connecticut residents may appeal a rights decision by replying to our response email; we will inform you in writing of any action taken.

  14. EEA/UK Data Protection (GDPR/UK GDPR)

  Controller: VeneBene is the controller for processing described in this Policy. Legal bases include contract, legitimate interests, consent, and legal obligations. Individuals in the EEA/UK have rights to access, rectify, erase, restrict, object (including to direct marketing), and data portability, and to lodge a complaint with a supervisory authority. Where we rely on consent (e.g., cookies/ads in some jurisdictions), you may withdraw consent at any time. Data Protection Officer (DPO): [Insert if appointed]. EU/UK Representative: [Insert if appointed]. Contact details in Section 17.

  15. Children’s Privacy

  Our Services are not directed to children under 13, and we do not knowingly collect personal information from children. If we learn that we have collected such information, we will delete it. For California residents under 16, we do not sell or share personal information without affirmative authorization.

  16. Third‑Party Sites & Services

  The Services may link to or integrate with third‑party sites, apps, or services (including Retailers and social platforms). We are not responsible for their privacy practices. Review their policies before providing information.

  17. Submitting Privacy Requests & Contacting Us

  To exercise your privacy rights or submit questions, contact us: • Email: privacy@venebene.com • Mailing Address: [Insert Address] • Toll‑Free Number (CA): [Insert Number] Verification: We may request information to verify your identity (e.g., email confirmation, ID match) and may deny requests where verification fails or where exceptions apply.

  18. Do Not Track & Global Privacy Control

  Our Services do not respond to browser “Do Not Track” signals. However, we honor Global Privacy Control (GPC) signals as an opt‑out of share/targeted advertising where required by law.

  19. De‑Identified & Aggregated Data

  We may de‑identify or aggregate personal information and use it for research, analytics, and business purposes. We commit to not attempting to re‑identify such data, except as permitted by law.

  20. Changes to This Privacy Policy

  We may update this Policy from time to time. If we make material changes, we will notify you (e.g., by email, in‑app notice, or posting an update on the Services) and update the Effective Date above.

  21. California Privacy Notice (CCPA/CPRA Supplement)

  This section supplements the Policy for California residents. It describes our collection, use, disclosure, and share of personal information and your CPRA rights. You have the right to: (1) know/access categories and specific pieces of PI collected; (2) delete PI; (3) correct PI; (4) opt out of sale/share; (5) limit use of SPI (we generally do not use SPI for purposes requiring the right to limit); and (6) non‑discrimination. You may designate an authorized agent. We will confirm receipt of requests within 10 business days and respond within 45 calendar days (or as permitted by law).

  22. Nevada Privacy Rights

  Nevada residents may submit a verified request to opt out of the sale of personal information by emailing privacy@venebene.com. We do not sell personal information as defined under Nevada law.

  23. Applicants, Contractors, and Creators

  If you apply to become a creator/ambassador, contractor, or employee, we process the information you provide (e.g., resumes, portfolios, tax forms, payout details) to evaluate eligibility, onboard, manage payouts, and comply with legal obligations. Additional notices may apply at onboarding. — End of Policy —