This policy was published on November 16, 2020. It will take effect on November 16, 2020.
OutpostLE Terms & Conditions require all account owners to be at least 18 years of age. Minors under 18 years of age and at least 13 years of age are permitted to use OutpostLE's Services only if they have permission and direct supervision by the owner of the account. Children under age 13 are not permitted to use the Services. You are responsible for any and all account activity conducted by a minor on your account. We do not knowingly “sell,” as that term is defined under applicable law, including the California Consumer Privacy Act, the personal information of minors. By using the Services, you acknowledge that OutpostLE will use your information in the United States.
2. Information Collected or Received
In the course of providing our Services, we collect or receive your personal information in a few different ways. We obtain the categories of personal information listed below from the following sources: directly from you, for example, from forms you complete or during registration; indirectly from you based on your activity and interaction with our Services, or from the device or browser you use to access the Services; from our vendors and suppliers that help provide OutpostLE services you may interact with (such as, for example, for payments or customer support), and from our third party advertising and marketing partners. Often, you choose what information to provide, but sometimes we require certain information to provide you the Services. OutpostLE uses the personal information it receives and collects in accordance with the purposes described in this policy.
Registration, Account Setup, Service Usage: In order to use the Services, will need to submit a valid email address. If you register, you will need to submit a name associated with your account. You may modify that name through your account settings. You need to provide this information to enable us to provide you with the Services. Additional information, such as a vendor name, billing and payment information (including billing contact name, address, telephone number, credit card information), a telephone number, and/or a physical postal address, may be necessary in order for us to provide a particular service. For example, we need a physical postal address if you are buying something on the platform for delivery. As an OutpostLE seller, if you choose to use our payment service ("Stripe"), Outpost will not require any additional information as this information is collected directly by Stripe. For both buyers and sellers, OutpostLE requires information from you in order to provide you with the Services (including, to verify ownership of an account, to mitigate fraud and abuse, to comply with regulatory obligations, or to complete a transaction as a buyer or seller). We may store credit card information and other information provided to us during checkout, for billing and payment purposes, and to process your transaction. OutpostLE may contact individual shop owners confidentially to request more information about their shops or items listed through the Services, or may request information from buyers to ensure compliance with our policies and applicable law. In order to use certain products or services on OutpostLE, you may be required to complete an application; information that you submit through the application process will not be displayed publicly and will only be used internally by OutpostLE and its service providers, unless otherwise specified.
Profile: You may provide your name and other personal information (location) in connection with your account and activity. You can edit or remove this information through your account settings. The name associated with your account (which you may modify in your account settings) is publicly displayed and connected to your OutpostLE activity. Other members may see the date you joined; ratings, reviews and information relating to items you review, and related photos for items you purchased or sold; your profile information; items you listed for sale; your vendor pages and policies; your Favorites, followers, and those you follow; sold item listings and the number of items sold; comments you post in our community spaces; and information you decide to share via social networks. For Sellers, we may collect and use information about you in order to feature you in marketing and advocacy materials, and to feature you and your shop on and off the platform, as provided for in OutpostLE Terms & Conditions. From time to time, we may also ask you about certain demographic information, such as your race, ethnicity, sexual orientation, or gender identity, in relation to specific marketing and advocacy projects and campaigns. Providing this demographic information is entirely voluntary and at the time we ask we will also seek your consent to use it.
Automated Information: OutpostLE automatically receives and records information from your browser or your mobile device when you visit the Site, use the Apps, or use certain features of the Services, such as your IP address or unique device identifier, cookies, and data about which pages you visit and how you interact with those pages in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. OutpostLE may also receive similar information (like, for example, IP addresses and actions taken on the device) provided by a connected Internet of Things device such as a voice-activated assistant or Smart TV. We may combine this information from your browser or your mobile device with other information that we or our advertising or marketing partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for members and visitors, and to provide advertising, including across your devices, and a more personalized experience for members and visitors.
We also automatically collect device-specific information when you install, access, or use our Services. This information can include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, IP address, and device identifiers. For more information about these online tools and how we use them, see our Cookies & Similar Technologies Policy and “Information Uses, Sharing, & Disclosure” Section below.
Data from OutpostLE Vendors and Suppliers: We also receive information from our vendors and suppliers about you. This information can include customer service interactions, payments information, shipping information, and information shared in OutpostLE future forums.
Data from Advertising and Marketing Partners: As described below, OutpostLE receives information from our advertising and marketing partners about you. This information can include attribution information via cookies and UTM tags in URLs to determine where a visit to OutpostLE comes from, responses to marketing emails and advertisements, responses to offers, and audience information from partners who you have given consent to share that information with us.
Location Information: We collect information about your use of the Services for advertising, for analytics, to serve content, and to protect the Services. This can include your IP address, browser information (including referrers), device information (such as iOS IDFA, IDFV for limited non-advertising purposes, Android AAID, and, when enabled by you, location information provided by your device). When you use the Apps, you can choose to share your geolocation details with OutpostLE in order to use functions like our local marketplace, maps, and for in-person sales (although you don't need to share these details). You can choose to publish your location when you sell on OutpostLE.
We obtain location information you provide in your profile or your IP address. With your consent, we may also determine location by using other information from your device, such as precise location information from GPS or information about wireless networks or cell towers near your mobile device. We use and store information about your location to provide features and to improve and customize the Services, for example, for OutpostLE’s internal analytics and performance monitoring; localization, regional requirements, and policies for the Services; for local content, search results, and recommendations; for shipping and mapping services; and (using non-precise location information) marketing. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you may revoke your consent to the sharing of that information through the settings on the Apps or on your mobile device. Certain non-precise location services, such as for security and localized policies based on your IP address or submitted address, are critical for the Site to function. We will only share your geolocation details with third parties (like our mapping, payments, or, to the extent applicable, advertising providers) in order to provide you with the Services. You may also choose to enable the Apps to access your mobile device’s camera to upload photographs to OutpostLE.
Analytics Information: We use data analytics software to ensure Site and App functionality and to improve the Services. This software records information such as how often you use the Apps, what happens within the Apps, aggregated usage, performance data, app errors and debugging information, and where the Apps were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application. For more information, see OutpostLE's Cookies and Similar Technologies Policy and Disclosures.
Non-Member Information: OutpostLE receives or obtains information (for example, an email address or IP address) about a person who is not yet a registered OutpostLE vendor or cuatomer (a “non-member”) in connection with certain OutpostLE features, such as when a non-member chooses to subscribe to an OutpostLE newsfeed, a member invites a non-member to visit the platform, a member uploads non-member information using the contact uploader feature, a non-member engages in a transaction, a member sends a gift card code to a non-member, or a non-member uses Guest Checkout to make a purchase. Non-member information is used only for the purposes disclosed when it was submitted to OutpostLE for purposes necessary to the functioning of OutpostLEs Services or where OutpostLE has a legitimate interest or to facilitate action authorized by a member or the non-member.
Pattern by OutpostLE: We also collect certain information from both members and non-members who visit websites hosted by us. This information may include your IP address or unique device identifier, and cookies and data from the pages you visit.
3. Contact by OutpostLE
On occasion, OutpostLE will need to contact you. Primarily, these messages are delivered by email, OutpostLE Messages, or by push notifications for a variety of reasons, including marketing, transactions, advocacy, and service update purposes. If you no longer wish to receive push notifications, you can disable them at device level. You can opt out of receiving marketing communications via email or Messages in your account settings or by following the unsubscribe link in any marketing email you receive. To ensure you properly receive notifications, we will need to collect certain information about your device, such as operating system and user identification information. Every account is required to keep a valid email address on file to receive messages. OutpostLE may also contact you by telephone to provide member support or for transaction-related purposes if you request that we call you. Additionally, and with your consent where required by applicable law, OutpostLE may send you an SMS (or similar) message, or reach out to you by telephone, in order to provide you with customer support, for research or feedback, or to provide you with information about products and features that you may find of interest. You can update your contact preferences in your account settings.
Some messages from OutpostLE are service-related and necessary for members and Guest Checkout users. You understand and agree that OutpostLE can send you non-marketing emails, OutpostLE Messages, or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, notification of an order, service availability, modification of key features or functions, relaying Messages with buyers, and correspondence with OutpostLEs Support team.
When you register for an account, subscribe to a newsletter, or provide us with your email address or phone number such as for a Guest Checkout purchase, you receive notice of and agree (in some jurisdictions and situations, by an additional unambiguous consent) to receive marketing emails and messages from us. You can unsubscribe at any time from marketing emails or messages through the opt-out link included in marketing emails or messages. Members can also control which marketing emails or messages they receive from OutpostLE through their account settings. Please note that some changes to your account settings may take a few days to take effect.
OutpostLE is a marketplace and a community. We offer several features that allow members to connect and communicate in public or semi-public spaces. You don't have to use these features, but if you do, please use common sense and good judgment when posting in these community spaces or sharing your personal information with others through the Services. Be aware that any personal information that you choose to submit there can be read, collected, or used by others, or could be used to send unsolicited messages to you. We engage certain third parties to assist in providing community services to you and, in the context of that relationship, we need to share some of your information with such third parties in order to provide that service. This may include, for example, information from your OutpostLE account that is publicly available, your account’s status, your forum posts, your OutpostLE username and/or vendor name, the display name you’ve optionally chosen to share publicly in your OutpostLE account, avatar image, the date that you registered on OutpostLE, as well as your language and regional settings on the Site. If you close your OutpostLE account, which allows you to post in Forums, will also be closed and related personal information will be deleted. However, your posts may remain public after your account is closed, although your name will no longer be displayed alongside the post. You are responsible for the personal information that you choose to post in community spaces through the Services.
5. Information Uses, Sharing, & Disclosure
We respect your privacy. OutpostLE will not disclose your name, email address, or other personal information to third parties without your consent, except as specified in this policy. We or our sellers may advertise our Services or our sellers’ products through a variety of different mediums and rely on your consent to do so off-site.
When you access or use the Services, we collect, use, share, and otherwise process your personal information for the purposes described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:
- You have consented to the processing, which you can revoke at any time;
- Necessary to comply with a legal or regulatory obligation, a court order, or to exercise or defend any impending or asserted legal claims;
- Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners (described in more detail below);
- You have expressly made the information public;
- Necessary in the public interest, such as to prevent crime; and
- Occasionally necessary to protect your vital interests or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury).
We principally rely on consent (which can be withdrawn at anytime) (i) to send marketing messages, (ii) for third-party data sharing related to advertising, and, to the extent applicable, (iii) for the use of location data for advertising purposes.
We or our sellers may advertise our Services or our sellers’ products through a variety of different mediums and rely on your consent to do so off-site. As part of this, we may work with advertising partners such as Facebook, Google, and other partners. These partners have their own privacy policies and consent mechanisms for their customers, in addition to OutpostLE's controls. You may see the privacy policies and privacy choices for these partners, and the information you share with them.
OutpostLE may also use first party data (e.g. your prior shopping and browsing patterns on our platform), and may combine it with other data collected from you, such as your location, or publicly available information, to permit us to create targeted audiences based on your known or inferred demographic and/or interests to provide you with more relevant and useful advertising on our site, in our direct marketing channels (like email), or with our off site marketing partners, like Google and Facebook, subject to their terms and privacy notice you agreed to with such partners .
Our Legitimate Interests
Where we process your information on the basis of legitimate interests, we do so as follows:
Providing and Improving our Services: We use your information to improve and customize our Services, including sharing your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help sellers find the best ways to market and sell their products on OutpostLE.
Providing Marketing Communications: We rely on our legitimate interest to send you marketing messages (where permitted independent of consent) and for OutpostLE's advertising programs (including OutpostLE’s on-site advertising and marketing).
Keeping our Services Safe and Secure: We use your information for safety and security purposes, which can include sharing your information for such purposes, and we do so because it is necessary to pursue our legitimate interests or those of a third party in ensuring the security of our Services, preventing harm to individuals or property, or crime, enforcing or defending legal rights, or preventing damage to OutpostLE’s systems, or those of our users or our partners. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kinds. We use your information to provide and improve the Services, for billing and payments, for identification and authentication, and for general research and aggregate reporting. For example, we may use information you provide to resolve disputes with OutpostLE or other members.
Site Customization: We may learn about the types of products that you’re interested in from your browsing and purchasing behavior on (and off) the Site or Apps and use such information to suggest potential purchases as a result. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help sellers find the best ways to market and sell their products on OutpostLE.
If OutpostLE receives a lawful, verified request for a member’s records or information in one of the limited circumstances described in the previous paragraph, OutpostLE may disclose personal information, which may include, but may not be limited to, a member’s name, address, phone number, email address, company/trading name and, where appropriate, bank account and transaction details. Find out more about how OutpostLE responds to requests for records or information about members of OutpostLE’s community.
Aggregated Information: OutpostLE may share demographic information with business partners, but it will be aggregated and de-personalized so that personal information is not revealed.
Service Providers: OutpostLE also needs to engage third-party companies and individuals (such as research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to OutpostLE not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Service operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.
This policy does not apply to the practices of third parties (such as other members who sell using the Services, certain third-party providers on whom we rely to provide certain services, or API users) that OutpostLE does not own or control or individuals that OutpostLE does not employ or manage, except as otherwise provided for in the Terms or as required by law. If you provide your information to such third parties in connection with your use of the Services, different practices may apply to the use or disclosure of the information that you provide to them. While OutpostLE requires these third parties to follow OutpostLE’s privacy and security requirements, OutpostLE does not control the privacy or security policies of such third parties. To the full extent applicable in your jurisdiction, OutpostLE is not responsible for the privacy or security practices of these sellers, API users, or other websites on the internet, even those linked to or from the Services. We encourage you to read the privacy policies and ask questions of third parties before you disclose your personal information to them. For the purposes of European law, these sellers, third party providers, and API users are independent controllers of data, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the Services.
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received, for example encryption is used for certain information (such as credit card numbers) using TLS (transport layer security). Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.
Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services.
If you have any questions about the security of your personal information, you can contact us at email@example.com.
OutpostLE will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your OutpostLE member account), or as needed to provide the Services to you. If you no longer want OutpostLE to use your information to provide the Services to you, you may close your account. OutpostLE will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, OutpostLE sellers may also be required to retain and use your information in order to comply with their own legal obligations. Please note that closing your account may not free up your email address, username, or vendor name (if any) for reuse on a new account. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.
8. Your Rights & Choices
Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), provide users with rights related to their personal information. Consistent with those laws, OutpostLEgives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your OutpostLE account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. You can also request to permanently close your account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.
- Right to Access & Portability: You can access certain personal information associated with your account by visiting your account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used. See this Help Center article for more information.
- Right to Correction: You have the right to request that we rectify inaccurate information about you. By visiting your account settings, you can correct and change certain personal information associated with your account.
- Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
- Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of OutpostLE. See this Help Center article for more information.
- Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.
- Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your mobile device. This is without prejudice to your right to generally permanently close your account and delete your personal information. The CCPA provides California residents with the following additional rights:
- Right to Know: California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.
- Right to Opt-Out: To the extent that OutpostLE “sells” personal information(as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time (see below for more information).
If you would like to manage, change, limit, or delete your personal information, you can do so via your OutpostLE account settings. Alternatively, you can exercise any of the rights above by contacting us by submitting a message through our contact us form. Once you contact us to exercise any of your rights, we will confirm receipt of your request.
Limiting use of, or deleting, your personal information may impact features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services. If you need further assistance, you can contact OutpostLE through one of the channels listed below under “Contact”. We will respond to your request within a reasonable timeframe.
Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requestor's valid government issued identification, and the authorized agent’s valid government issued identification, and we may verify the authenticity of the request directly with you.
Email & Messages
You may also control the receipt of certain types of communications from OutpostLE in your account settings. OutpostLE may send you messages about the Services or your activity. Some of these messages are required, service-related messages for members (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive by changing your account settings. If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may close your account.
We use both technically necessary (for the functioning and security of the Services) and non-technically necessary cookies and similar technologies.
Additional Disclosures for California Residents
Notice of Collection
In addition to the Rights & Choices described above, the CCPA requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail in the “Information Collected or Received Section above, the categories of personal information that we have collected – as described by the CCPA – are:
- Identifiers, including name, email address, shop name, IP address, and an ID or number assigned to your account.
- Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories listed here.
- Demographics, such as your age or gender, or, where you have provided such information to OutpostLE voluntarily, demographic information about your race, ethnicity, sexual orientation, or gender identity, provided in relation to specific marketing and advocacy projects and campaigns.This category includes data that may qualify as protected classifications under other California or federal laws.
- Commercial information, including purchases and engagement with the Services.
- Internet activity, including your interactions with our Services and what led you to our Services.
- Sensory visual data, such as pictures posted on our Service.
- Geolocation data provided through location enabled services such as WiFi and GPS.
- Inferences, including information about your interests, preferences and favorites.
The Purposes for Our Collection
We collect and use these categories of personal information for our business and commercial purposes described in the “Information Uses, Sharing and Disclosure” Section above, including providing and improving the Services, maintaining the safety and security of the Services, processing purchase and sale transactions, and for advertising and marketing services.
Third Party Marketing and Advertising and Your Rights (Opt-Out of “Sale”)
OutpostLE does not sell personal information to third parties for monetary value. However, the term “sale” is defined broadly under the California Consumer Privacy Act. To the extent that “sale” under the CCPA is interpreted to include interest based advertising or other data uses described in the “Information Uses, Sharing and Disclosure” Section above, we will comply with applicable law as to those activities.
To opt-out of receiving interest based advertising, you can exercise your choice by using your account privacy settings, or the general privacy settings link located at the footer of our homepage and most pages of the Site. The right to opt-out of interest based advertising is available to all OutpostLE users.
Do Not Track Signals
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.
Shine the Light
California law entitles residents to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes. Other than to Sellers on OutpostLE (see “Buying and Selling” under the “Information Uses, Sharing and Disclosure” Section above), who must obtain your separate consent for their own marketing off of OutpostLE, or unless you request us to or consent to it, OutpostLE does not share any personal information to third parties for their own direct marketing purposes. If you have questions about these practices, you can contact us through one of the channels listed in the “Contact US” section on the Home screen.
If you have a disability and would like to access this policy in an alternative format, please contact us using one of the channels listed in the “Contact Us” section on the Home screen.
We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes, or (iii) posting an update in the version notes on the Apps’ platform. We encourage you to check back regularly and review any updates.