Privacy Policy 1

Privacy policy.

LAST UPDATED September 1st, 2023

This Privacy Policy describes how Zelia App Ltda. (“ZELIA”, “we”, “us”, “our”) use personal information collected in the United States, including information you provide to us and information we obtain based on your choices, and explains your rights and how you can manage your personal information. This notice only applies to the personal information we collect in the United States, including when you access or use our website available at https://www.zeliaapp.com/, native mobile applications, or any other applications, services, or features that link to this Privacy Policy (collectively, “Sites”); interact or communicate with us in any way or using any media (“Communications”); purchase or use our products, services, or features (“Products”); engage with us on social media; interact with our advertisements or marketing materials; or participate in any of our programs or events. For information about our usage of personal information collected outside of the United States, please see our Privacy Policy available at www.zeliaapp.com.

Additional privacy disclosures may apply for certain products, services, features, activities, programs, and offerings. We may also provide additional “just-in-time” notices that supplement or clarify our privacy practices or provide you with additional choices regarding your personal information.

1. Information we collect

We may collect your information directly from you, automatically from you and your devices, and from third parties.

Information you provide to us

We collect your information when you directly interact with us, including when you:

access and use our Sites;
create an account;
purchase our Products;
engage in Communications with us;
participate in a promotion, such as a sweepstakes or contest;
sign up for our loyalty program;
communicate with us on a third party social network;
post a comment, question, or other information, such as a testimonial, on the Sites;
sign up for our newsletters or attend one of our events;
or otherwise interact with us.

When you interact directly with us, we may collect the following categories of your information:

Identifiers, such as your first and last name, date of birth, email address, and telephone number.
Certain demographic Information, such as your age, gender, profession, zip code, and country.
Transaction Information as necessary to process your order. All payment and billing data, including your name, credit card information, billing address, and zip code, is provided directly to our payment processing partner. For security purposes, we do not collect or store such payment processing data.
Certain information about your past engagement with our Sites or Products, such as your interests, preferences, email preferences, and purchasing history.
Information about your physical characteristics and personal tastes based on your interactions with and use of our Sites and/or Products.
Communications, such as any messages you send to us through feedback and questions to customer service, reviews you post on our Sites, information you publicly post on our Sites, e-mail messages, communications during our events, and recordings of telephone calls with ZELIA representatives.

Information we automatically collect from you

When you interact with our Sites and engage in certain Communications with us, we automatically receive certain information about you, including:

Usage Information. Information such as the features you use on our Sites, the links you click and the items you view, pages you visit, emails and advertisements you view, the time of day you browse, and your referring and exiting pages.
Device Information. Information about the device you are using, including but not limited to the type of device you use, the temporary or persistent unique device identifier placed by us or our service providers, the IP address of your device, your operating system, the type of browser you use, and data from the way you use our Sites.
Location Data. Information such as imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level). Our Sites may also collect information about the location of your device. We and our service providers may use this approximate location along with other information submitted by you, to provide you with location-based services like search results, special offers, and other personalized content. Your device should require you to provide permission before our Sites obtain precise geolocation information from a browser's geolocation API or from technologies like GPS, WiFi, and/or cell towers. Most browsers and mobile devices allow users to enable or disable precise geolocation using pop-ups or controls located in the settings menu.
Cookies and similar tracking technologies. The Sites may use cookies, tracking pixels and other technologies (collectively, “Cookies”) to provide users an efficient experience in using the Sites. We may also use these Cookies to better understand, customize and improve the user experience of our Sites. Cookies are small data files stored on your device that act as a unique tag to identify your browser. We may use two types of cookies on our Sites: session cookies and persistent cookies. Session cookies make it easier for you to navigate our Sites and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Sites. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.] To learn more about your choices relating to Cookies, see Your Choices section below.

Internet-based advertising / Do Not Track

We may, from time to time, collect information about users over time and across different websites when you use the Sites. Our third-party partners may also collect information in this manner. For example, we may use one or more third-party online advertising networks to serve ads on our behalf on third-party websites. The third-party ad network may collect information about your visits to our Sites and your interaction with our online ads. This is primarily accomplished using technology such as cookies, action tags, web beacons, and/or GIF tags which are placed in various places within our Sites and our online ads. Some browsers have a 'do not track' feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so our Site is not currently designed to respond to those signals unless otherwise stated in this Privacy Policy.

Information we receive from third parties

In some circumstances, we may collect information about you from third parties, such as our service providers and governmental agencies. This may include collecting certain demographic information and purchase preference information. We may use this information to supplement or update our records, improve the quality or personalization of our Communications with you, and help prevent or detect fraud.

Children under 13 years of age

The Sites and Products are intended to be appropriate for general audiences and are not directed to children (usually considered to be under 13, depending on where you reside). ZELIA does not intentionally collect personal information from children without seeking any required parental approval in accordance with applicable legal and regulatory obligations, such as the U.S. Children’s Online Privacy Protection Act (“COPPA”).

We may ask you to provide age-related information in order to help us comply with laws like COPPA. For example, we may request your date of birth to determine whether COPPA requires us to obtain verifiable parental consent from your parent or guardian before allowing you to access the Sites and/or Products. If a user indicates they are a COPPA minor, we’ll require that user to complete a parental approval process before continuing to access the relevant Sites or Products. This process is designed to notify parents that their child has requested access to the Sites or Products, inform them about ZELIA’s privacy practices, offer them the opportunity to approve ZELIA’s collection and use of their child’s information as described in this Privacy Policy, and describe the controls that we make available to them.

Once a parent provides their consent, we’ll give them an opportunity to review and change important account settings that control how their child can interact with the Sites and Products. Parents are also generally free to change or revoke the choices they’ve previously made, and can review the personal information associated with their child’s account or request that we delete it from our systems. To submit these requests or ask us any other questions you may have about how we handle your child’s personal information, please see Contact Us section below.

2. How we use your information

We may use your information to:

Fulfill your requests, such as orders and responses to email questions;
Alert you about new features on our Sites, terms, Products, or related information;
Send you emails or provide you with other personalized content;
Support our core business functions, such as internal business process management, authentication, loss and fraud prevention, and public safety functions;
Communicate with you about our Sites and Products;
Provide the Sites and Products to you, including providing personalized outfit and brand recommendations;
Improve our Sites and Products;
Provide personalized advertising;
Improve our marketing and promotions;
Statistically analyze the usage of our Sites;
Contact you;
Process and respond to your inquiries and reviews;
Analyze your preferences and interests;
Resolve disputes, investigate problems, and enforce our terms;
Help diagnose problems with our server, manage our Sites, and to enhance our Products and Sites; and
Perform a business transaction, such as a merger, acquisition, sale of assets, bankruptcy, or related transactions.

3. How we share your information

We may share your information in the following circumstances:

With Your Consent. We may disclose, share, or make available your information with your consent, which may be obtained in writing, online, through “click-through” agreements, when you accept our terms for our Sites, orally (including over the telephone), or by other means.
With Service Providers & Business Partners. We may disclose, share, or make available your information with third parties, such as service providers, affiliates and subsidiaries, business partners, credit / debit card processing partners, third-party auditors and law firms, marketing and advertising networks, third parties for targeted advertising purposes, internet service providers, data analytics providers, companies that help debug and identify and repair errors that may impair the functionality of our Sites, and third parties that help protect against malicious, deceptive, fraudulent, or illegal activity. We may also share your information in connection with co-branded Product offerings.
In A Business Transfer. We may disclose, share, or make available your information as part of a business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to third parties as a business asset in the transaction.
For Legal Process & Protection. We may disclose, share, or make available your information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (1) enforce or apply agreements; (2) protect our rights or interests, property or safety or that of others; (3) in connection with claims, disputes, or litigation - in court or elsewhere; (4) protect users of our Sites and other carriers, providers, or partners from fraudulent, abusive, unlawful, or otherwise improper use of our Sites; (5) facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government.

4. How we secure your information

Although no system or website can guarantee the complete security of your information, we take all commercially reasonable steps to ensure your information is protected in accordance with all applicable laws and regulations, as appropriate to the sensitivity of your information.

5. Links to third-party sites

Our Sites may include links to websites/applications that are owned or operated by third parties. Please note these links are provided for your convenience and information, and may operate independently from us and have their own privacy policies and/or notices. This Privacy Policy does not cover the practices of those websites/applications. We encourage you to review the privacy policies on those websites/applications to see how they collect and use information.

6. Your Choices

Right to Know. Depending on where you live, you may have a right to know details about what information ZELIA has collected about you. If eligible, you may exercise this right by clicking the link here or calling +1 312 960 9552. To process these requests, we must be able to verify your identity. In order to do so, you must provide the information we request as part of the verification process, such as your contact information and an additional identifier based on your relationship with us.
Right to Delete. Depending on where you live, you may have a right to ask that ZELIA delete your information, subject to exceptions recognized under law. If eligible, you may exercise this right by clicking the link here or calling +1 312 960 9552. To process these requests, we must be able to verify your identity. In order to do so, you must provide the information we request as part of the verification process, such as your contact information and an additional identifier based on your relationship with us.
Right to Correct. Depending on where you live, you may have a right to ask that ZELIA correct the information it has about you, subject to exceptions recognized under law. If eligible, you may exercise this right by clicking the link here or calling +1 312 960 9552. To process these requests, we must be able to verify your identity. In order to do so, you must provide the information we request as part of the verification process, such as your contact information and an additional identifier based on your relationship with us.
To submit a request pursuant to your rights noted above please click Data Request.
Opt-Out of Receiving Communications. We may send you e-mail messages, direct mail offers, or other communications regarding our Products unless you ask us not do so. At any time, if no longer want to receive certain communications from us via email or text message, simply click the “unsubscribe” link in the email or reply STOP (or as otherwise instructed) to the message. Please note, you may not be able to unsubscribe from service-related correspondence from us, such as message relating to your account and use of our Sites.
Opt-Out of Push Notifications. You may opt-out from allowing ZELIA to send push notifications by adjusting the permissions on your device.
Changing Cookie / Related Technology Settings. Web browsers allow some control of most cookies through browser settings. To find out more about cookies, including how to manage and delete cookies through browser settings, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Sites. In addition to adjusting your browser and device settings, as outlined above, you may also control how cookies and related technologies are set and used on your device by visiting the following sites:

7. Notice for California Residents

Definitions

Personal information. Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household.
Sensitive personal information. Social security number, driver’s license number, state identification card, passport number, account log-in and password, financial account and password, debit or credit card number and access code, precise geolocation information, race, ethnic origin, religious or philosophical beliefs, union membership, the content of your mail, email or texts other than those communications with us, genetic data, biometric information, health information, and information that concerns your sex life or sexual orientation.
Sell, sale, or sold. Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for money or other valuable consideration.
Share, shared, or sharing. Shearing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

Your Rights

You may designate an authorized agent to make the below requests on your behalf. When you use an authorized agent, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

We may take steps to verify your identity by matching the information you provide with your request with the information we have on file about you. Depending on the sensitivity of the information at issue, we may utilize more stringent verification methods, including but not limited to requiring you to sign a declaration under penalty of perjury.

Right to Know: You have a right to request that we disclose, up to two times per year, what personal information we’ve collected about you. The process for exercising this right is described above in Your Choices.

Right to Delete. You have a right to request deletion your personal information, subject to certain exceptions. The process for exercising this right is described above in Your Choices.
Right to Correct. You have a right to ask that we correct the personal information we have about you, subject to certain exceptions. The process for exercising this right is described above in Your Choices.
Right to Opt-Out of the Sale or Sharing of Your Personal Information. You have a right to opt-out of the sale or sharing of your personal information. The process for exercising this right is described at Do Not Sell or Share My Personal Information below.
Right to Non-Discrimination. You have a right to exercise the above rights without being discriminated against.

Notice of Collection

Below is a list of the categories of personal information we have collected about California residents in the 12 months preceding the date this Privacy Policy was last updated. This list includes information about: (1) the categories of sources from which the information was collected; (2) the business or commercial purpose for collecting, selling, or sharing the information; and (3) the categories of third parties with whom we share the information.

Identifiers: Includes information such as your name, telephone number, online identifier, IP address, email address, or other identifying information.
Personal Characteristics: Includes information such as your age and gender.
Internet or other Electronic Network Activity Information: Includes information described above as automatically collected.
Commercial Information, such as records of your Products considered and purchased.
Geolocation Information, such as your zip code and general location.
Audio, Electronic, Visual, Thermal, and Related Information: Includes information such as photographs, video recordings, recorded messages, and other related information.
Inferences, derived from the above information.