Privacy Policy
Effective date: 12/4/2023
At Two Boxes, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.
Privacy Policy Table of Contents
What this Privacy Policy Covers
Personal Data
Categories of Personal Data We Collect
Categories of Sources of Personal Data
Our Commercial or Business Purposes for Collecting Personal Data
How We Share Your Personal Data
Tracking Tools and Opt-Out
Data Security and Retention
Personal Data of Children
Other State Law Privacy Rights
Changes to this Privacy Policy
Contact Information
What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
Personal Data
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
You
When you provide such information directly to us.
When you use our interactive tools and Services.
When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
When you send us an email or otherwise contact us.
When you use the Services and such information is collected automatically.
Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
If you use a location-enabled browser, we may receive information about your location.
If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services.
Third Parties
Merchants
We may obtain information about you and your purchases from merchants in order to provide our Services to our customers and/or the merchants.
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Services
Processing orders or other transactions; billing.
Providing you with the products, services or information you request.
Meeting or fulfilling the reason you provided the information to us.
Providing support and assistance for the Services.
Improving the Services, including testing, research, internal analytics and product development.
Personalizing the Services, website content and communications based on your preferences.
Doing fraud protection, security and debugging.
Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
Marketing the Services
Marketing and selling the Services.
Meeting Legal Requirements and Enforcing Legal Terms
Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
Protecting the rights, property or safety of you, Two Boxes or another party.
Enforcing any agreements with you.
Responding to claims that any posting or other content violates third-party rights.
Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
Hosting, technology and communication providers.
Security and fraud prevention consultants.
Support and customer service vendors.
Business Partners. These parties partner with us in offering various services. They include:
Businesses that you have a relationship with, such as merchants that you make purchases from.
Product fulfillment and delivery providers, such as logistics providers who process returns for merchants.
Companies that we partner with to offer joint promotional offers or opportunities.
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
Tracking Tools and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
We do not knowingly collect or solicit Personal Data about children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at support@twoboxes.com.
State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@twoboxes.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@twoboxes.com with the subject line “Nevada Do Not Sell Request” and providing us with your name. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
EUROPEAN DATA SUBJECTS DISCLOSURE & RIGHTS
Residents of the United Kingdom ("UK") and European Economic Area ("EEA") are provided certain privacy rights under the UK and EU General Data Protection Regulations ("GDPR"). If you are located in Switzerland, the Swiss Federal Act on Data Protection ("FADP") applies to our processing of personal data.
Our role
Two Boxes is a returns processing platform used by third-party logistics providers ("3PLs") and brands. In most cases, when personal data of end consumers (such as names, shipping addresses, or order information associated with a return) is processed through our platform, Two Boxes acts as a processor on behalf of the 3PL or brand, who is the controller of that data. If you are an end consumer seeking to exercise your rights with respect to a return you initiated, please contact the brand or retailer you purchased from in the first instance; we will assist them in responding to your request as required under our Data Processing Agreement.
Where Two Boxes collects personal data directly — for example, from prospective customers, account users, or website visitors — we act as the controller of that data, and the rights described below apply directly against us.
Legal basis for processing
We process personal data under the following legal bases:
Consent: Where you have provided consent to process your personal data. You may withdraw your consent at any time.
Legitimate interest: We process personal data to provide and improve our Service, communicate with you, provide customer support, market our offerings, analyze and operate our business, and protect our website and platform.
Contract fulfillment: We may process personal data to enter into or perform a contract with you or the organization you represent.
Legal obligation: Where processing is necessary to comply with our legal obligations.
Data subject rights
Subject to any exemptions provided by law, EEA, UK, and Swiss data subjects have the right to request:
the right to be informed about the types of personal data being processed and the legal basis for processing;
the right to access and see the personal data being processed;
the right of rectification and to make corrections to personal data;
the right to erase personal data;
the right to restrict processing of personal data;
the right of data portability of personal data;
the right to object to the processing of personal data; and
the right not to be subject to automated decision-making.
Some of these rights apply only in certain circumstances and depend on the legal basis relied upon to process the data. For example, the right to object applies to processing carried out on the basis of our legitimate interests, and only if we cannot demonstrate compelling legitimate grounds which outweigh your rights, interests, and freedoms. The same right does not apply to processing which is necessary for us to comply with our legal obligations or to perform a contract with you. These rights may extend to personal data we collect through cookies or similar tracking technologies. Where processing is based on your consent, you may withdraw that consent at any time, although any processing previously carried out will remain lawful.
International data transfer
Two Boxes is a US-based company, and our customers contract with our US entity. If you are located outside the United States and choose to provide your information to us, or if your information is processed through our platform, you consent to our transferring your information to countries other than the country in which it was originally collected, including the United States, in order for us to process it there. Those countries may not have equivalent data protection laws as the country in which you provided the data.
When we transfer personal data outside the EEA, UK, or Switzerland, we protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for such transfers. Where required, we rely on Standard Contractual Clauses ("SCCs") approved by the European Commission, the UK's International Data Transfer Addendum to the SCCs, and equivalent Swiss safeguards.
For more information on cross-border transfers of your personal data or the safeguards in place, please contact us at eurep@twoboxes.com.
EU Representative
Two Boxes has designated an internal point of contact based in Germany to handle inquiries from data subjects and supervisory authorities in the EU regarding our processing of personal data. You can reach our EU point of contact at eurep@twoboxes.com.
Complaints
We encourage you to raise any concerns by emailing us in the first instance so that we can investigate and attempt to resolve any complaints regarding our use and disclosure of personal data.
European, UK, and Swiss data subjects may contact us at eurep@twoboxes.com.
Changes to this Privacy Policy
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Two Boxes website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
Contact Information:
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
https://www.twoboxes.com/
support@twoboxes.com
250 Fillmore St., Suite 150
Denver, CO 80206
