Last Updated: November 11, 2019 

We Take Your Privacy Seriously

At Chaos, your privacy is our top priority. This Chaos Privacy Policy (“Privacy Policy”) describes our privacy practices for the activities set out in this Privacy Policy. Please read this Privacy Policy carefully to learn how we collect, use, share and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding our processing of your Personal Data.

The terms “Chaos”, “we,” “our”, “us” or the “Company” shall refer to KL Worldwide Ventures LLC, and the relevant affiliate involved in the processing activity for the Chaos website https://101chaos.com and its SaaS custom clothing solutions platform (collectively, the “Platform”).

Introduction

Our Chaos Platform connects custom retailers, designers, fabric suppliers and manufacturers in real-time to simplify selling, eliminate redundancies and extend the possibilities of the custom clothing market.

Individuals use our Platform to sell custom and ready-to-wear products to their customers. Activities include payment processing, product management, clothing design, measurement management, fulfillment management, and fitting and alteration management.

PROCESSING ACTIVITIES COVERED

This Privacy Policy applies to the processing of Personal Data collected by us when you:

• Visit our website that display or link to this Privacy Policy;
• Visit our offices;
• Receive communications from us, including emails, phone calls, texts or fax; or
• Use our online Services (“Services”), available after logging in at https://101chaos.com/login, as an authorized user (for example, as an employee of one of our customers who provided you with access to our Services);
  

PERSONAL DATA WE COLLECT

The Personal Data we collect from you include the following:

• General Outreach: If you request customer support (including submitting or viewing helpdesk tickets online), or use our “Contact Us” feature, we require that you provide us your email address.
• Registration: In order to create an account, we require you to provide us a username, your full name, email address and password. In addition you can provide optional data such as your photo and biographical data (for example your occupation and social media profiles).
• Billing: After registering an account, in order to pay monthly subscription fee we require you to provide billing information including your full name, credit card details, and billing address.
• Feedback: If you voluntarily submit certain information to our Services, such as filling out a survey about your user experience, we collect the information you have provided as part of that request.
• Communications Data: If you contact us through email or chat, your emails and chat history may be stored for future reference.
• Information Collected by our Customers:
  • Our Customers control the personal data they collect, and Chaos will not use or disclose that personal data except as authorized or directed by the Customer in the course of our provision of the Services and as governed by our agreement with that customer. If your personal data is controlled by one of our Customers, and you have concerns about the way that data is managed or wish to exercise your rights with respect to such data (including your rights of access, amendment, or deletion), please contact that Customer directly.
  • Personal Data collected by our Customers include:
    • General Information: To add your customer to the Platform we require you to provide your customer’s full name and email address.
    • Billing and Shipping: To complete a sale to your customer using the Platform, you are required to provide your customer’s financial and billing information: full name, billing address, and payment (e.g. credit card).
    • Size Information and Style Preferences: To sell custom apparel to your customers you are required to provide your customer’s measurement information and other size related data. You also have the option to provide personal information about your customer such as birthdate, gender, height, weight, photos, style preferences (for example product interest, where he/she shops, and how he/she dresses), and clothing budget.
    • Social Media Information: You also have the option to provide your customer’s social media profiles.

If you provide us or our service providers with any Personal Data relating to other individuals, (e.g. your customers), you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Policy.

DEVICE AND USAGE DATA WE PROCESS

We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons and similar technologies to automatically collect information that may contain Personal Data from your computer or mobile device as you navigate our website, our Services or interact with emails we have sent to you.

• Device and Usage Data
  • As is true of most websites, we gather certain information automatically on connection with the use of the website by individual users. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our website and to guarantee their security and continued proper functioning. Some of the device and usage data collected within the Services, whether alone or in conjunction with other data, could be personally identifying to you. Please note that this device and usage data is primarily used for the purposes of identifying the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the Services to our customers (where we act as a processor).
• Cookies, web beacons and other tracking technologies on our website and in email communications
  • We use cookies and similar technologies such as web beacons, tags and JavaScript, alone or in conjunction with cookies, to compile information about the usage of our website and interaction with emails from us. When you visit our website, we, or an authorized third party may place a cookie on your browser and/or device, which collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track usage, determine your browsing preferences and improve and customize your browsing experience.
• You can control cookies through your browser settings and other tools.

HOW WE USE YOUR PERSONAL DATA AND THE LEGAL BASES ON WHICH WE RELY

We collect and process your Personal Data for the purposes and on the legal bases identified in the following:

• Authorizing Access
  • We process your Personal Data to authorize access to our website and Services.
• Securing our Website and Services
  • We process your Personal Data by tracking use of our websites and Services, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the Services, systems and applications and in protecting our rights and the rights of others.
• Providing Our Website and Services
  • We process your Personal Data to perform our contract with you for the use of our website and Services and to fulfill our obligations under applicable terms of use/service; where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our website and to provide you with content you access and request (e.g., to download content from our website).
• Providing functionality
  • We process your Personal Data to provide you with the necessary functionality required during your use of our websites and Services;
• Customer Support
  • We process your Personal Data (which may include your communications) to perform our contract with you to investigate, respond to and resolve complaints and Service issues.
• Managing payments
  • If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you.
• Developing Services and Research
  • We process your Personal Data to analyze trends and to track your usage data in order to improve our website and Services. We also use feedback and helpdesk ticket analysis to improve our Services.
• Sending Service Messages
  • We will send messages such as system issues that may affect your account access, security and legal notices. In addition, we will send billing/invoice notifications with respect to your subscription. You cannot opt-out of these service messages.
• Sending Marketing Communications
  • We will send various marketing messages to your email. These may notify you of new site features, new content we added to the website or new services. You may change your marketing email preferences at any time by clicking unsubscribe in the footer of any marketing email.

HOW WE SHARE INFORMATION

We may share your Personal Data as follows:

• Service Providers
  • With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment for the purposes and pursuant to the legal bases described above.
• Professional Advisers
  • In case by case bases we may share your Personal Data with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data.
• Legal Disclosures
  • It is possible that we will need to disclose your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
• Sale or Change in Control
  • We can share your Personal Data if we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sale. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.

We may also share anonymous usage data with our service providers for the purpose of helping us in such analysis and improvements. Additionally, we may share such anonymous usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our services.

INTERNATIONAL TRANSFER OF PERSONAL DATA

To facilitate our global operations, we may transfer and access Personal Data both inside and outside of the United States. Therefore, your personal information may be processed outside your jurisdiction, and in countries that may not provide for the same level of data protection as your jurisdiction.

In this event, we will ensure that the recipient of your personal information offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data.

We do not share your personal information with third parties, unless it is necessary to carry out your request, for our professional or legitimate business needs, or as required or permitted by law. Where we do transfer your personal information to third parties or service providers, appropriate arrangements will be made in order to ensure correct and secure data processing in compliance with applicable data protection law.

CHILDREN

The Chaos Platform is not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contacting us” section, below, and we will take steps to delete such Personal Data from our systems.

HOW LONG WE KEEP YOUR PERSONAL DATA

Where Chaos is the data controller of Personal Data (for example, personal information relating to Website Visitors, and individuals who register to use our Services – our Customers), then we retain the personal information we collect where we have an ongoing legitimate business need to do so (for example, to provide you with our Services, and to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or aggregate it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

YOUR RIGHTS RELATING TO YOUR PERSONAL DATA

Upon request, we will provide you with details regarding your personal data that has been collected by us or which is under our control. If you would like to change information that we maintain about you, you may log into your account and change it or submit a support request for any information to which you don’t have access or the ability to change yourself.

Information covered by this Privacy Policy may be deleted upon your request, provided that such deletion does not impact our ability to provide you with the Services.

You may opt-out of receiving most e-mails from us by following the “unsubscribe” instructions provided in the e-mails. Alternatively, you may contact us as described herein. If you are our customer, you may not be able to opt out of all emails, including certain administrative or billing communications which are important to the ongoing maintenance of your account.

SECURITY OF YOUR PERSONAL DATA

We have put in place reasonable measures and appropriate procedures for implementing these policies and for safeguarding the Personal Data we collect. However, we cannot guarantee that personal data we collect will never be disclosed in a manner inconsistent with this Privacy Policy. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received.

CHANGES TO THIS PRIVACY POLICY

We will update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements and other factors. If we do, we will update the “effective date” at the top of this Privacy Policy. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.

We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing and sharing of your Personal Data.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

CONTACTING US

To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Policy or our privacy practices please contact us online or by physical mail.