INTRODUCTION AND OVERVIEW
Worthy, Inc. (“Worthy,” “we,” “us,” or “our”) is an online auction destination for individuals seeking to resell rings and other precious jewelry. Our mission is to provide a luxury auction marketplace for individuals to safely, conveniently, and transparently sell their jewelry with trust.
2. Information We Collect About You and How We Collect It
The types of personal information that we may collect about you include: information that you voluntarily provide to us, information collected automatically about your use of our Services, and information received from third parties.
a.Information You Voluntarily Provide to Us: The personal information that we collect directly from you in order to provide you with our Services includes:
Account Registration: information relating to the creation of an account as a seller or as a buyer, such as name, email address, mailing address, phone number, and a unique individual password. In some instances, you may optionally provide your gender, a profile photo, or a preferred pickup or drop-off location for goods. This information is used to register your account, allow you to log-in to your account and to provide you with the section of our website reserved for account holders;
Form Submissions: information that you provide by filling in forms that we make available, such as contact information (name, email, phone number) if you request Worthy information or assistance, sign up for a newsletter, or ask to join our mailing list, such activities may then be associated with your account. Such information is used in order to provide you with information about Worthy, to send you our newsletter and to add you to our mailing list;
Customer Service: records and copies of the correspondence we receive from you(including email addresses, content of the communications, name, and other information you choose to provide us with), if you contact us by telephone or in writing or via chat, including for customer support. Such information will be used to provide you with the assistance you request by contacting our customer service;
Promotions: information relating to your participation in a promotion, or an optional survey or questionnaire that we may ask you to complete for research purposes (name, email address, telephone number, and any other information you choose to provide us with);
Verification: as part of the sale procedure, you might be asked to provide your birth date, photo ID, home address, copies of your utility bills (for address verification) and a description of the valuable object you are looking to sell. For Anti-Money Laundering (“AML”) and Know Your Customer (“KYC”) purposes, we may also require government-issued identification that bears a photograph in order to verify your identity in compliance with legal requirements;
Payment Information: we may also collect your payment information in order to send you your payment as a seller. For example, if you wish to use an automated clearinghouse service (ACH), we will collect your bank account number and routing information provided to us in electronic form or by sending us a voided check; or if you wish to use wire transfer services, we will collect your customer name, account number, bank name and bank routing number (or ABA); or if you wish to use PayPal to receive payments, we will collect the email address associated with your PayPal account, and in some cases also a copy of your drivers license/passport/SSN and a proof of address; and
b. Information Collected Automatically:
In general, as you navigate through and interact with our Site or Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Information About Your Use of the Services: when you browse our Site, our systems automatically collect information such as your web request, Internet Protocol (“IP”) address, browser type, screen resolution, browser language, domain names, referring and exit pages and URLs, clickstream data, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, and the date and time of your request;
- Device Information: if you access our Services through a mobile device (e.g., a smart phone or tablet), we may be able to identify the general location of your mobile device, your mobile device’s brand, model, operating system, resolution, screen size, system version, mobile network information, and your mobile device’s advertising ID; and
- Performance Data: information about your preferences to make your use of the Services more productive.
c. Information from Third Parties:
When you interact with our Services or accounts on a social media platform, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service.
3. How We Use Your Information
The purposes for which we may use your personal information include:
a.To Provide You Our Services: providing any services that you request in connection with our Services, such as to allow you to sell your jewelry, add you to a mailing or newsletter list, register you as a buyer, perform verification to prevent fraud[, or to receive a professional evaluation of the value of your goods];
b.To Provide You with Service-Related Communications: contacting you from time to time with critical user or service updates or other information important to support the Services. We may contact you to ensure that the information we have in our records is accurate or when in need of additional information to complete your profile or requested Service;
c.To Provide Customer Support or to Respond to You: providing you with notices about your account and responding to your questions or other requests, including through online chat services or text messaging/SMS, or responding to your feedback and comments from you about our Services and inquiring about any features you would like to see in future offerings;
d.To Send You Advertising and Promotions: contacting you with newsletters, tailored advertising or promotional materials and other information that may be of interest to you based on the Services that you already use or the offerings that you have already purchased or inquired about, unless you have opted not to receive such information. We may also contact you to ask for your satisfaction rate, inform you of upgrades, technical issues, promotions and additional services that you may be interested in. We may communicate with you via phone calls, chat, and text messaging/SMS.
By signing up and providing your phone number, you agree to receive text messages from Worthy. Message and data rates may apply. Message frequency may vary. You may choose not to receive marketing SMS of this type by replying “STOP” to an SMS message you received or by contacting us at [email protected] and we will process your request within a reasonable time after receipt. Except as provided in Section 4 below, we will not share your mobile phone number;
e.For Internal Use and Services Improvement: accumulating and reporting aggregate, statistical information in connection with Site user activity, including determining which features and services users like best to help us operate, customize, measure and improve our Services. We also evaluate your use, preferences and trends for our own internal statistical and analytical purposes, which we may use in respect of operations and product development;
g.To Maintain Legal and Regulatory Compliance: processing personal information to pay our taxes, fulfill our business obligations, for compliance with Anti-Money Laundering requirements and Know Your Customer regulations, or as necessary to manage risk under applicable law;
h.For Customization: saving your user account, registration and profile data or other personal information (so you do not have to re-enter it each time you visit or use the Services); tracking your return visits to and use of the services; tailoring your experience on the Services; and/or otherwise customizing what you see when you visit and use the Services;
i.For Research Purposes: using personal information for audit, research and analysis purposes needed to operate and improve our technologies and Services;
j.With Your Consent: for any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction.
4. Sharing and Disclosure of Personal Information
We may share or disclose your personal information in the following circumstances:
a.Within Our Corporate Organization: we may share your personal information with any subsidiaries and affiliates in order to provide you with the Services and take actions based on your request, as well as for the purpose of management and analysis.
d.As Required by Law and to Protect Lawful Interests: we may share your information (i) if we are required to do so by law or when necessary to comply with a current judicial proceeding, a court order or legal process served on Worthy; or (ii) if we believe in good faith that disclosure of information is necessary to prevent imminent physical harm, financial loss or to report suspected illegal activity (all in accordance with applicable laws and regulations).
In addition to the above, we may provide aggregate statistics about users, sales, traffic patterns, and other information to third parties, but these statistics will not include any personally identifiable information.
5. Cookies and Other Tracking Technologies
As noted above, cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information.We use first-party and third-party cookies for the following purposes:
- to make our Services function properly;
- to improve our Services;
- to make login to our Services easier (such as by remembering your user ID);
- to recognize you when you return to our Services and to remember information you have already provided;
- to track your interaction with the Services;
- to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and
- to provide a secure browsing experience during your use of our Services.
Worthy may use both “session cookies” (which expire once you close your web browser) and “persistent cookies” (which stay on your computer until you delete them). While this information is not intended to identify you personally, it should be noted that if the foregoing is collected when you are signed in to the Service, it may be possible to associate it with the personal information we collected from you voluntarily.
Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.
First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Site may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
Third-Party Cookies. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:
- Google Chrome
- Internet Explorer
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
- Opera Mobile
We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.
- Behavioral Remarketing
- Other Tracking Technologies
To see how our Site is performing we sometimes use conversion beacons, tags, scripts and pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page. We also use these Tracking Technologies to analyze usage patterns of our Services. The use of these technologies allows us to record that a particular device, browser, or application has visited a particular webpage.
- Do Not Track
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
7. Communications Preferences
In order to provide service to you, we may send you communications related to your transactions, security, or the administration of our Services. From time to time, we may also send you other messages or updates about Worthy, our Site, and our other services and offerings.
Promotional Correspondence: When signing up for a Worthy account, you may choose whether you wish to receive promotional correspondence from us. You may modify such preference at any time by changing your account settings, by opting-out of this form of correspondence though the instructions in the applicable e-mail, by requesting this verbally during a promotional phone call, or by contacting us as described below. Please note that if you opt out of receiving communications from us, we may still send you technical communications such as emails about your account.
Technical Correspondence: Opting out of technical correspondence (which may relate to maintenance of our Site, changes to the Services and more) is only possible by terminating your member status. Choosing to terminate your member status may involve deletion of your information from our live databases, and by doing this you understand that Worthy will not be liable for any termination of your member account or related deletion of your information.
Please note as well that "opt-out" and "unsubscribe" requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior privacy settings.
8. Access, Correction, and Deletion of Your Personal Information
You have the right to access, correct, and delete your personal information that you shared with us on our Site or Services or through other written or oral means. We are committed so that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. In most cases, you can review and submit changes to your personal information by logging into the Site and visiting your member profile page. You may also notify us via the information in the “Contact Us” section below to request access to, or to correct any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would cause the information to be incorrect.
If you no longer wish to have your personal information processed, you may request us to delete your account (username and password), subject to certain limitations, by contacting us as described below. You may request that we delete or destroy your information provided that there is no ongoing transaction between us, and provided that such deletion is permitted by law. You understand that when we delete electronic information that we have collected from or about you, it will be deleted from our active databases but may remain in our archives.
9. Your California Privacy Rights
This section applies solely to individuals who reside in the State of California. The purpose of this section is to inform California residents (“consumers” or “you”), at or before the time of collection of personal information, about our data collection practices and your privacy-related rights under California law, including the California Consumer Privacy Act of 2018, as amended (“CCPA”). Your “right to know” about personal information collected, used, and disclosed by Worthy includes what categories of personal information we collect from you; the categories of sources from which the personal Information is collected and the business or commercial purpose for its collection, selling, or sharing personal information; how we use those categories of personal information; the categories of third parties to whom we disclose personal information, how we share the personal information you entrust to us, and the specific pieces of personal information we have collected.
In the preceding twelve months we have disclosed the categories of personal information described in section 2 above for the business purpose outlined in section 3 and shared and disclosed it as further described in section 4 above. For further clarity, we have disclosed the following information:
- Personal information detailed in section 2 above
- Sensitive information
- Commercial information
- Internet or similar network activity
- Inferences drawn
Category of Information / Personal data we collect
Sources of Information
Purpose of Information Collection
How we share it
Identifiers (name, alias, postal address, email address, phone number, account name, government-issued identification (such as Social Security number, driver’s license number and passport number), IP address, and any other information you choose to share with us).
We collect identifiers from the information you voluntarily provide to us, from the information we automatically collect, and from third parties, as outlined in Section 2 above.
We collect identifiers to provide our services; to communicate with you, including to conduct marketing activities; for research and development and services improvement; to comply with applicable laws; to enforce our terms, and as otherwise outlined in Section 3 above.
We share identifiers with our service providers; to protect lawful interests; and for any other purpose with your consent, as outlined in Section 4 above.
Sensitive Information (social security/driver’s license/passport number, name with financial account)
We collect sensitive personal information directly from you.
We collect sensitive personal information for the following purposes:
1. Performing the services or providing the goods reasonably expected by you.
2. Auditing related to transactions (including to provide internal business administration and operations and to provide you the payments).
3. Security detection, protection and enforcement (including to ensure the security of our business, to prevent or detect fraud or malicious activity, and to comply with legal obligations).
We share sensitive personal information with authorities and service providers in order to:
1. Perform the services or provide the goods reasonably expected by you.
2. To prevent, detect, and investigate incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
3. To resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible for those actions
We collect gender information of the sellers.
We collect gender information to provide our services, to send advertising and promotional emails, for internal services improvement, and for research and development and services improvement.
We share gender information with our service providers, as described in Section 4 above.
Commercial information (activity and transaction history, preference, etc.)
We collect commercial information from the information you voluntarily provide to us and from the information we automatically collect, as outlined in Section 2 above.
We collect commercial information to provide our services; to communicate with you; for research and development and services improvement; and to comply with applicable laws, as outlined in Section 3 above.
We share commercial information with our service providers; internally; and to protect lawful interests, as outlined in Section 4 above.
Electronic network activity information (browsing or search history, website interactions, advertisement interactions, etc.)
We collect network information through the information you voluntarily provide to us, from the information we automatically collect, and from third parties, as outlined in Section 2 above.
We collect network information to provide our services; to communicate with you; for research and development and services improvement; and to comply with applicable laws, and as otherwise outlined in Section 3 above.
We share network information with our service providers; to protect lawful interests; and for any other purpose with your consent, as outlined in Section 4 above.
Inferences (preferences, characteristics, behavior, attitudes, abilities, etc.)
We develop inference data through the information you voluntarily provide to us and from the information we automatically collect, as outlined in Section 2 above.
We develop inference data to provide our services; to communicate with you, and for research, development, and services improvement, as outlined in Section 3 above.
We share inference data with our service providers and to protect lawful interests, as outlined in Section 4 above.
a. Notice of Right to Opt-out of Sale/Sharing of Personal Information:
a.1 Our use of some third party technologies and vendors may be considered a “sale” or “sharing” under CCPA. Under the CCPA, you have the right, at any time, to direct us not to sell or share your Personal Information. Categories of Personal Information disclosed in the preceding 12 months that may be considered “sale” or “sharing” under CCPA are the following: Identifiers (as described in the table above, including your name, email address and phone number). Categories of third parties to whom Personal Information was disclosed that may be considered “sale” or “sharing” under CCPA are: marketing partners, data analytics providers, and cookies providers. The purposes for which Personal Information was “sold” or “shared” (as defined in the CCPA) in the past year are the following: In order to personalize the services we provide for you and/or our website, in order to analyze your use of our website, in order to establish a business connection with you.
a.2 You can opt-out of these “sale” and “sharing” to third parties by clicking on the “Do Not Sell My Info” link at the bottom of our website or contacting us at [email protected]. In addition to the “Cookies and Other Tracking Technologies” Your Choices section above’s description for opting out of interest-based advertising and controlling browser settings, California consumers may also use the Digital Advertising Alliance’s tool to send requests under the CCPA for a web browser to opt out of the sale of personal information by some or all of that framework’s participating companies by accessing the DAA’s tool here: https://www.privacyrights.info/.
a.3 We do not knowingly sell or share the Personal Information of consumers under 16 years of age.
b. Rights Under the CCPA:
b.1 Access to Specific Information and Data Portability Rights: Subject to certain exceptions, if you are a California resident you have the right to request a copy of the personal information that we collected about you during the 12 months before your request. Once we receive your request and verify your identity, we will disclose to you:
- The categories of personal information we have collected about you;
- The categories of sources for the personal information we have collected about you;
- Our business or commercial purpose for the information collection, selling, or sharing;
- The categories of third parties with whom we share that personal information; and
- The specific pieces of personal information we collected about you.
b.2 Right to correct inaccurate personal information: You have a right to correct inaccurate Personal Information we have about you;
b.3 Deletion Request Rights: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
b.4 Right to know whether your Personal Information is sold or disclosed and to whom (see section 9(a) above);
b.5 Right to Opt Out of the selling and/or sharing of your personal information: As described in “Sale of Personal Information Under the CCPA” section above, California residents have the right to opt-out of having their personal information sold.
b.6 Right to limit the use or disclosure of sensitive Personal Information.
c.7 Right of no retaliation following opt-out or exercise of other rights: We recognize and respect that you have the right to not receive discriminatory treatment by the business for exercising any of your CCPA rights. You have the right to equal service and price, even if you exercise your privacy rights.
b.8 Exercising Access, Data Portability, and Deletion Rights: To exercise the access, data portability, and deletion rights described above as a California resident, please submit a verifiable consumer request to us by contacting us as described in the “Contact Us” section below.
b.9 Use of an Authorized Agent to Submit a Request: Only you or a person you formally authorize to act on your behalf, may make a verifiable consumer request related to your personal information as a California consumer. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution. You can exercise your rights by contacting us at [email protected]. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
c. Direct Marketing:
c.1 If you are a California resident, you can request a notice disclosing the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes. To request a notice, please submit your request by postal mail to the contact information listed below.
c.2 Marketing emails – opt-out: You may choose not to receive marketing email of this type by unsubscribing from the link that you can find at the bottom of the email to opt out of receiving future emails and we will process your request within a reasonable time after receipt.
c.3 Marketing SMS – opt-out: You may choose not to receive marketing SMS of this type by replying “STOP” to an SMS message you received or by contacting us at [email protected] and we will process your request within a reasonable time after receipt.
c.4 Deletion of your account: You may choose to delete your account by contacting us at [email protected] and we will process your request within a reasonable time after receipt.
10. Important Notice for Non-U.S. Residents
The Services and their servers are operated in the United States. Please be aware that your information, including your personal information, may be transferred to, processed, maintained, and used on computers, servers, and systems located where the privacy laws may not be as protective as those in your jurisdiction. If you choose to use our Website while located outside the United States, you hereby irrevocably and unconditionally consent to such transfer, processing, and use of your information in the United States. If you do not wish for your information to be transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately cease accessing our Services.
11. Data Security
Worthy does its utmost to secure your information by putting in place commercially reasonable and appropriate physical, electronic, and managerial procedures to safeguard and secure such information. Such measures include using Secure Socket Layer (SSL) technology (or comparable technology) to provide security when transmitting sensitive information via our Site, placing our servers in a secure facility, and only allowing access to those of our employees who require such information in order to provide you the Services.
The safety and security of your information also depends on you. We recommend that you do your part in protecting yourself from unauthorized access to your account by ensuring no one else uses your computer when you are logged in, by logging off from the site when it is not in use and by keeping your password confidential. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services. If you believe that any of your personal information held by Worthy has possibly been compromised, please contact us immediately as described in the “Contact Us” section below.
12. Integration of Third-Party Platforms and Services
Worthy Services are not directed towards children under the age of 18, and we do not knowingly collect any personal information from individuals under the age of 18. If a child under 18 provided our Services with personal information, we ask that a parent or guardian contact us as described below so that we may promptly delete the child’s information from our records.
14. Contact Us
We welcome your questions, comments, and concerns about privacy. You can contact us anytime via our website at https://www.worthy.com/about/contact, or as follows:
25 W 45th St, 2nd Floor, New York, NY 10036
1 (888) 222-0208