Privacy policy

Privacy Policy

We take your privacy very seriously. Please read this privacy policy (“Privacy Policy”) carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use, and/or otherwise process certain personal information about you. When we do so we are subject to various laws, including in the United States, European Union, and the United Kingdom. Under both the UK General Data Protection Regulation (“UK GDPR”) and General Data Protection Regulation ((EU) 2016/679) (collectively, the “GDPR”), we act as “controller” of that personal information for the purposes of the GDPR.

1. Key Terms. As used in this Privacy Policy, the terms in the chart below have the following meanings

We, us, our	Recover Textile Systems, S.L. and its related affiliates, including, without limitation, Recover HoldCo, Inc., Recover US OpCo LLC, and Recover IPCo LLC.
Contact details	[email protected]
Personal information	Any information relating to an identified or identifiable individual.

2. Personal Information we collect. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Category	Examples	Examples
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics or samples (such as breath, blood, or urine), or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing provide products and/or services to you.

3. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

• Directly from you when you provide it to us, such as:
  • Information that you provide by filling in forms. This includes information provided at the time of registering for services or programs on our Website, entering a contest or promotion, subscribing to our mailing list or other services, posting material to one of our social media accounts, and/or requesting further services.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Information collected through email, text, or other electronic messages.

• Through your online activity, such as browsing our Website, interacting with Website features such as forms, or clicking on our advertisements, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
  • Information from tracking technologies, such as browser cookies, flash cookies, or web beacons.
  • Details of website visits, such as traffic data, location data, logs, resources used to access the website.
  • Information about the user’s computer and internet connection, such as IP address, operating system, or browser type.
  • From third parties, such as advertisers, ad networks and servers, content providers, application providers or data brokers.

• From cookies on our website—for more information on our use of cookies, please see our cookies policy; and
• Via our IT systems.

We may use Google Analytics to help analyze how our users use the Website. Google Analytics uses cookies to store information about your use of the Website, including your IP address. That information is sent to Google, where we access it for reports. We use these reports to review visitors’ use of the Website. We store your IP address associated with personal information if you submit that information through a form on our Website or when using our services. From time to time we may implement one or more of the following Google Analytics features based on Display Advertising:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• DoubleClick Campaign Manager integration Google Analytics Demographics and Interest Reporting

Third-party vendors, including Google, show our ads across the internet. We use ad-tracking along with third-party vendors. These use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie). Together, these cookies report if you have seen our ads (ad impressions) and how you have interacted with our ads and ad services. We want this information so we can make sure our advertising that you see is relevant to you.

4. How and Why We Use Your Personal Information. We use your personal information for a number of reasons, including the following:

1. To comply with our legal and regulatory obligations;
2. For the performance of our contract with you or to take steps at your request before entering into a contract;
3. For our legitimate interests or those of a third party; or
4. Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and/or services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or our organization	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
To display advertisements to our advertisers’ target audiences. User may opt out by visiting our Cookie Policy.	For our legitimate interests or those of a third party, i.e., to efficiently and accurately advertise to you so we can deliver the best service for you at the best price.
Processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligation.

5. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving promotional communications at any time by:

• Contacting us at [email protected]; or
• Using the “unsubscribe” link in emails or “STOP” number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With. We routinely share personal information with:

• Our affiliates, including our parent organization and its subsidiaries;
• Service providers we use to help deliver our products and/or services to you;
• Other third parties we use to help us run our business, such as our website host;
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
• Our attorneys and financial advisors.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7. Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have not sold your personal information to third parties.

8. Where Your Personal Information is Held. Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

9. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information.

10. Transferring Your Personal Information Out of the EEA. The European Economic Area (“EEA”), the United Kingdom (“UK”), and other jurisdictions outside the EEA have differing data protection laws, some of which may provide lower level of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the EEA. In those cases, we will comply with the applicable EEA laws designated to ensure the privacy of your personal data. We will transfer your personal data to:

• With our offices outside the EEA;
• With your and our service providers located outside the EEA;
• If you are based outside the EEA; or
• Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under the GDPR.

Non-EEA countries do not have the same data protection laws as the EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.

If you would like further information, please contact us (see “How To Contact Us” below).

11. Your Rights Under the GDPR.

Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

12. Your Rights Under the CCPA. If you are a resident of the state of California, you have the right under the California Consumer Privacy Act of 2018 (“CCPA”) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the CCPA and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your personal information. If you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and services to you, if that difference is reasonably related to the value provided to our business by your personal information.

13. Keeping Your Personal Information Secure. To protect your personal information in our custody or control from theft, unauthorized access, use, modification and disclosure, and to maintain its accuracy and integrity, we have implemented reasonable technical, physical and administrative security measures. These measures include computer safeguards, such as secured servers and firewalls and secured files and buildings.

Although we have implemented reasonable safeguards, please note that no electronic transmission of information can be guaranteed to be entirely secure. You acknowledge and agree that we are not responsible for the theft, destruction, or inadvertent disclosure of your personal information. In the unfortunate event that your personal information is compromised, we may notify you by e-mail (at our sole and absolute discretion) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation.

14. How to Exercise Your Rights. If you are a resident of the EEA, UK, and/or California and would like to exercise any of your rights as described in this Privacy Policy, please email us at [email protected]

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly, you will need to provide us with:

• Enough information to identify you;
• Proof of your identity and address; and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to comply with a request if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

15. How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.

The GDPR also gives you right to lodge a complaint with a supervisory authority, in the European Union (or EEA) state where you work, normally live, or where any alleged infringement of data protection laws occurred. For contact details of your local Data Protection Authority, please see: https://ec.europa.eu/justice/a...;

16. Changes to This Privacy Policy. This Privacy Policy was published on January 1, 2022 and last updated on January 1, 2022.

We may change this Privacy Policy from time to time–when we do, we will inform you via our website or other means of contact such as email.

17. How to Contact Us. Please contact us by email at [email protected] if you have any questions about this Privacy Policy or the information we hold about you.

18. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

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