PRIVACY POLICY
Last updated January 15, 2025
This Privacy Notice for Gear Lease, Inc. (doing business as Wha7, Inc.) (“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:
- Download and use our mobile application (Wha7) or any other application of ours that links to this Privacy Notice
- Use Wha7 (an AI Fashion Consultant and finder)
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at connor@wha7.com.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using the Table of Contents below to find the section you are looking for.
- What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about the personal information you disclose to us in Section 1.
- Do we process any sensitive personal information? We do not process sensitive personal information.
- Do we collect any information from third parties? We do not collect any information from third parties.
- How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information in Section 2.
- In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information in Section 4.
- How do we keep your information safe? We have appropriate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Learn more about how we keep your information safe in Section 8.
- What are your rights? Depending on where you are located geographically, applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights in Section 10.
- How do you exercise your rights? The easiest way is by visiting https://www.wha7.com/f/eac6ab97-f56b-447a-8d12-90ce7fe417d2 or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more? Review the Privacy Notice in full below.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE PROCESS YOUR INFORMATION?
- WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
- WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
- DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS NOTICE?
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- Phone numbers
- Usernames
- Photos
- Prompts
Sensitive Information. We do not process sensitive information.
Application Data
If you use our applications, we may collect information if you choose to provide us with access or permission, such as:
- Geolocation Information. We may request access or permission to track location-based information from your mobile device to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your device’s camera, SMS messages, storage, photos, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
- Push Notifications. We may request to send you push notifications regarding your account or certain features of the applications. If you wish to opt out, you may turn them off in your device’s settings.
This information is needed to maintain security, troubleshoot, and for internal analytics and reporting.
All personal information you provide must be true, complete, and accurate. Please notify us of any changes.
Information automatically collected
In Short: Some information—such as your IP address and/or browser and device characteristics—is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information, IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and other technical information. This is primarily needed for security and internal analytics.
Information we collect includes:
- Log and Usage Data. Our servers automatically collect service-related, diagnostic, usage, and performance data when you access or use our Services, recorded in log files. This may include IP address, device information, browser type, settings, and usage information (date/time stamps, pages viewed, etc.).
- Device Data. We collect device data about your computer, phone, tablet, or other device. This may include IP address or proxy server, device and application ID numbers, location, browser type, hardware model, internet service provider, mobile carrier, operating system, and system configuration.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We process your information so you can create and log in to your account and keep it in working order.
- To deliver and facilitate delivery of services to the user. We process your information to provide you with the requested service.
- To respond to user inquiries/offer support. We process your information to respond to inquiries and solve any issues.
- To request feedback. We process your information to request feedback and contact you about your use of our Services.
- To send you marketing and promotional communications. We may use your personal information for marketing if in accordance with your preferences. You can opt out of our marketing emails at any time.
- To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (legal basis) to do so under applicable law, such as with your consent, to comply with laws, to provide you with services, fulfill our contractual obligations, protect your rights, or fulfill our legitimate business interests.
If you are located in the EU or UK
We may rely on the following legal bases to process your personal information:
- Consent. You have given us permission to use your personal information for a specific purpose. You can withdraw consent at any time.
- Performance of a Contract. We process personal information where necessary to fulfill our contractual obligations or at your request prior to entering into a contract.
- Legitimate Interests. We may process your information where it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your rights and freedoms.
- Legal Obligations. We may process your information where necessary for compliance with legal obligations (e.g., cooperating with law enforcement).
- Vital Interests. We may process your information where necessary to protect your vital interests or those of a third party.
If you are located in Canada
We may process your information if you have given us specific or implied permission to use your personal information for a specific purpose. You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted to process your information without your consent (e.g., if collection is clearly in the interests of an individual and consent cannot be obtained in a timely way, for investigations/fraud detection, for business transactions, for witness statements, etc.).
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information you share with third parties that we may link to or that advertise on our Services but are not affiliated with us.
Our Services may link to third-party websites, online services, or mobile applications, and/or contain advertisements from third parties not affiliated with us. We make no guarantees regarding these third parties, and we are not liable for any loss or damage caused by their use. We cannot guarantee the safety and privacy of data you provide to these third parties; their data collection is not covered by this Privacy Notice. We are not responsible for the content or privacy practices of any third parties, including other websites, services, or applications that may link to or from our Services. You should review such parties’ policies and contact them directly for more information.
6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.
As part of our Services, we offer certain products, features, or tools powered by AI, machine learning, or similar technologies (“AI Products”). These tools are designed to enhance your experience and provide innovative solutions. The terms of this Privacy Notice govern your use of the AI Products within our Services.
Use of AI Technologies
We provide AI Products through third-party service providers (“AI Service Providers”), including OpenAI and Microsoft Azure AI. Your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in “WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?” You must not use the AI Products in violation of any AI Service Provider’s terms or policies.
Our AI Products
Our AI Products may provide the following functions:
- AI search
- Image generation
- Image analysis
- AI applications
How We Process Your Data Using AI
We handle all personal information processed via our AI Products in line with this Privacy Notice and our agreements with third parties, ensuring the security of your data throughout the process.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We only keep your personal information for as long as necessary for the purposes set out in this Notice, unless a longer retention period is required or permitted by law. No purpose in this Notice will require us keeping your personal information longer than the period in which you have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it, or if not possible, securely store it until deletion is feasible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of personal information we process. However, no electronic transmission or storage technology can be guaranteed 100% secure, so we cannot promise or guarantee unauthorized third parties will not be able to improperly access or modify your information. You should only access our Services within a secure environment.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18, nor do we knowingly sell such personal information. By using our Services, you represent you are at least 18 or a parent/guardian and consent to your minor dependent’s use. If we learn personal information from users under 18 has been collected, we will deactivate the account and delete such data. If you become aware of any data we may have collected from children under 18, please contact us at connor@wha7.com.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some regions (such as the EEA, UK, Switzerland, and Canada), you have rights that allow you greater access to and control over your personal information.
In some regions, such as the EEA, UK, Switzerland, and Canada, you have certain rights under data protection laws. These may include the right to (i) request access to and obtain a copy of your personal information, (ii) request rectification or erasure, (iii) restrict processing, (iv) data portability, and (v) object to processing. You can make such a request by contacting us (see HOW CAN YOU CONTACT US ABOUT THIS NOTICE?). We will consider and act upon requests in accordance with applicable laws.
If you are in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to complain to your Member State data protection authority or the UK data protection authority. If in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent
If we are relying on your consent to process your personal information, you can withdraw it at any time by contacting us (see HOW CAN YOU CONTACT US ABOUT THIS NOTICE?). However, this will not affect the lawfulness of processing prior to withdrawal.
Opting out of marketing communications
You can unsubscribe from marketing communications at any time by replying “STOP” or “UNSUBSCRIBE” to SMS messages, or by contacting us as described below. You may still receive service-related communications necessary for administration and use of your account.
Account Information
If you would like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the information provided.
Upon your request to terminate your account, we will deactivate or delete it. We may still retain some information in our files to prevent fraud, troubleshoot, enforce legal terms, or comply with legal requirements.
If you have questions or comments about your privacy rights, you may email us at connor@wha7.com.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile systems include a Do-Not-Track (“DNT”) feature or setting to signal your privacy preference. No uniform technology standard for recognizing and implementing DNT signals has been finalized. We do not currently respond to DNT browser signals. If a standard is adopted in the future, we will inform you in a revised Privacy Notice.
California law also requires us to let you know how we respond to DNT signals. Because there is no industry or legal standard yet, we do not respond to them at this time.
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have certain rights over your personal information.
Categories of Personal Information We Collect
In the past twelve (12) months, we may have collected specific categories of personal information, as described in the table included in the original text (e.g., Category A: Identifiers; Category B: Personal information under California Customer Records statute, and so on). We may also collect other personal information in various contexts, such as customer support or surveys.
We will use and retain the collected personal information as needed to provide the Services or for as long as the user has an account with us.
Sources of Personal Information
See WHAT INFORMATION DO WE COLLECT? for details.
How We Use and Share Personal Information
See HOW DO WE PROCESS YOUR INFORMATION?.
Will your information be shared with anyone else? We may disclose your personal information to our service providers via written contracts. See WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months and will not sell or share personal information in the future.
Your Rights
Depending on your state, you may have rights such as the right to know, access, correct, delete, or obtain a copy of your personal data, and the right to not be discriminated against for exercising such rights. Some states also provide rights to opt out of certain uses of personal data. To exercise these rights, please contact us (see below).
How to Exercise Your Rights
You can contact us by visiting https://www.wha7.com/f/eac6ab97-f56b-447a-8d12-90ce7fe417d2 or by emailing connor@wha7.com.
Request Verification
We must verify your identity or authority to make the request. If you submit a request through an authorized agent, we may need additional information to verify identity.
Appeals
If we decline to act regarding your request, you may appeal by emailing connor@wha7.com. We will provide a written explanation of any action or inaction. If your appeal is denied, you may submit a complaint to your state’s attorney general.
California “Shine The Light” Law
California Civil Code Section 1798.83 permits California residents to request information about categories of personal information (if any) disclosed to third parties for direct marketing purposes. If you are a California resident wishing to make such a request, please contact us as described in HOW CAN YOU CONTACT US ABOUT THIS NOTICE?.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date, and if material changes occur, we may notify you via prominent posting or direct notification. We encourage you to review this Privacy Notice frequently to stay informed.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at connor@wha7.com or contact us by post at:
Gear Lease, Inc. 3323 La Cienega Blvd 229 Los Angeles, CA 90016 United States
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, correct any inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing. To request to review, update, or delete your personal information, please visit: https://www.wha7.com/f/eac6ab97-f56b-447a-8d12-90ce7fe417d2.
End of Privacy Policy
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