Seel Inc. Privacy Notice


Last Updated/Effective Date
: March 27, 2023

Seel Inc. (“Seel,” “we,” “us,” or “our”) respects your privacy. This Privacy Notice describes the processing of Personal Information (defined below) that is provided, collected, or shared on https://www.seel.com/ (“Site”), applications, API integrations, social media pages, or other platforms or sites that link to this Privacy Notice, or that is otherwise provided to, or collected by, us in connection with the Seel Products (as defined below) and services we offer (collectively, our “Services”) from individuals who visit our Site and/or our use our Services (collectively, “Users”). It also describes your choices about the collection, sharing, and use of your Personal Information.

This Privacy Notice applies only to instances where Seel acts as a data controller. For purposes of data protection laws, Seel is the “data controller” (or similar term under applicable laws) and is generally responsible for and controls the processing of your personal information collected through your use of our Service. This includes, but not limited to: (a) website visitors, (b) consumer buyers (“Buyers”) who purchase any of Seel products, such as our return offerings and other post-purchase guarantee products (“Seel Products”) that are offered in connection with the purchase of any merchant products (“Merchant Products”) sold on our e-commerce partner sites (“E-Commerce Partners”); and (c) merchants who sell Merchant Products on E-Commerce Partner sites and who offer the Seel Products and services to Buyers in connection with any sale of Merchant Products (“Merchants”). 

We may modify this Privacy Notice at any time.  All changes will be effective immediately upon posting to the Site or via the Services.  Material changes will be conspicuously posted on the Site/via the Services, or otherwise communicated to you.

1. Personal Information We Collect
We may collect a range of Personal Information about you through your interactions with the Site and use of our Services.  “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. 

The types of Personal Information we may collect through a User’s interaction with the Services include:

· Contact Information – If you submit an inquiry, request a demo, or otherwise provide information through our Services, we may collect your contact information, such as your name, email address, demographic information, and phone number.  
· Financial and Transaction Information – If you make any purchases through our Services (including any purchases made by Merchants and Buyers), we may collect your name, billing address, payment information, and other transaction details connected to your purchases. In addition, we may require a User to provide certain financial information to process any refunds to Users who purchase or utilize certain Services. 
· Buyer Product Information- If you are a Buyer who has purchased any Seel Products, we may collect information such as your name, mailing address, email address, telephone number, date of Buyer’s purchase of a Seel Product, information related to the Merchant Product for which the Seel Product was purchased, shipping and delivery date of the Merchant Product, return date of the Merchant Product if returned, return operations processes, testing practices, and other related data collected through our Services related to Buyer’s purchase of the Seel Products. 
· Merchant Information- If you are a Merchant who offers any Seel Products in connection with Merchant’s sale of Merchant Product on an E-Commerce site, we may collect information such as, (a) Merchant’s name, mailing address, email address, telephone number (b) historical returns data for any Merchant Product listed on an E-Commerce Partner Site; (c) any product information for all Merchant Products listed on an E-Commerce Partner Site; and (d) any information related to the sale to Buyer of the Merchant Product and Seel Product. 
· Location Data – While navigating our Site your mobile device or browser may share your location data, both through WiFi and GPS. We will collect this information based on the settings of your phone and browser.  
· Usage Information – When you use our Services, our servers may automatically record information, including your Internet Protocol address (IP Address), browser type, referring URLs (e.g., the site you visited before coming to our Site), device information, domain names associated with your internet service provider, information on your interaction with the Site, website user statistics, and other such information. 
· Employment Information – If you apply for employment, we will collect your employment and work history, as well as other Personal Information related to your potential employment. This may include your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.  
· Communication Information – We may collect audio, electronic, or visual information, which includes screen sharing views; any data in any files uploaded, emailed or otherwise provided by you; the contents of your communications with us, whether via e-mail, text message, social media, telephone or otherwise, and inferences we may make from other Personal Information we collect.

2. How We Collect Your Personal Information
· Directly From You – For example, if you visit our Site, request information from us, or purchase and/or use our Services.
· From E-Commerce Partners or Merchants – For example, as a Buyer when you purchase our Seel Products from a Merchant on an E-Commerce Partner site, or when you use our Services to request a return or refund for any Merchant Products.
· From Third Parties – For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.
· Through Online Tracking Technologies – We and our service providers may use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect usage and browser information about how you use the Services.  We process Personal Information collected through such technologies to help operate certain features of the Services, to enhance your experience through personalization, and to help us better understand the features of the Services that you and other users are most interested in.  
Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Services may not be available, or some functionality may be limited or unavailable.  Please review the help pages of your browser or mobile device for assistance with changing your settings.
We do not respond to Do Not Track (“
DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.
Online Behavioral Advertising.  We may use your Personal Information to serve advertisements that are customized based on predictions about your interests generated from your visits to websites (including this Site) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites, and may be sent to you via email.  
· Through Analytics – We use analytics services, including Google Analytics, to assist us with analyzing our website traffic through cookies and similar technologies. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.


3. How We Use Personal Information
To the extent permitted by applicable law, we may use Personal Information to:
· operate the Services and provide support to our business functions;
· fulfill your requests, such as to complete your purchases of our Services, product returns, or product refunds;
· protect against criminal activity, claims and other liabilities;
· send you information about Seel, our products, services, and promotions;
· respond to reviews, comments, or other feedback provided to us;
· support and personalize the Services and our advertising efforts;
· protect the security and integrity of the Services;
· provide customer support;
· the extent required for benchmarking, data analysis, audits, developing new products, enhancing the Services, facilitating product, software and applications development, improving the Services or our services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
· meet our contractual requirements;
· comply with applicable legal or regulatory requirements and our policies;
· respond to inquiries related to employment opportunities;
· market, advertise, and provide the Services; and
· the extent necessary for any other lawful purpose for which the Personal Information is collected.

4. Sharing of Personal Information
We may share your Personal Information in the following circumstances:

· For Legal or Safety Reasons – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Seel, its users, or the public against harm.
· In the Case of a Merger or Sale – If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.  Personal Information may be transferred along with the business.  Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.
· To Service Providers – When we hire a service provider to help operate the Services or our business, we may give access to Personal Information as necessary to perform the service on our behalf.  This may include service providers that operate our Site, send our communications, or run our promotions. 
· To Our E-Commerce Partners– We may share certain Personal Information about you with our E-Commerce Partners, such as your Product Information and Merchant Information, in each case to better facilitate our Services.
· To Business Partners – We may share Personal Information with our trusted business partners.  For example, we may share your Personal Information with a company when we co-sponsor a promotion or service.  These partners and affiliates may use your Personal Information to, among other things, send you information or contact you about their services and products.

5. How Long Do We Keep Your Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Notice, or any longer retention period required by law.

6. How We Protect Your Personal Information
We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process. However, despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information. 

7. Your Choices and Controls
Depending on where you live, you may have the right to exercise certain controls and choices regarding our collection, use, and disclosure of your Personal Information. If you believe you may the right to exercise certain controls and choices, please submit a request to privacy@seel.com. Please note that we may need to verify your identity before considering a request and that we may deny certain requests, or only fulfill some in part, as permitted or required by law.

To opt-out of marketing communications please email us at privacy@seel.com or by following the instructions included in the email or text correspondence.  Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.  Additionally, if you withdraw your consent or object to processing, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our Services to you.

8. International Use of the Site
This Site is hosted in the United States. If you are visiting this Site from outside of the United States, please note that by providing your Personal Information it is being transferred to, stored, collected, or processed in the United States, where our data center and servers are located and operated. 

9. Children’s Privacy 
We do not target our Services to children under the age of 13.  If we learn that we have collected Personal Information from a child, we will promptly take steps to delete that Personal Information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at privacy@seel.com or contact us using the information listed in Section 12.

10. Links to Third-Party Websites
We are not responsible for the practices employed by any websites or services linked to or from the Services, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s Privacy Notice.

11. Changes to this Privacy Notice
Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. We may provide you with an updated Privacy Notice if material changes are made. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to the Services.  

12. Contact Us
If you have any questions about our practices or this Privacy Notice, please contact us at privacy@seel.com.