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USER GENERATED CONTENT PRIVACY POLICY

User Generated Content Privacy Policy

Applicable To: All user-submitted content on woolrich.us official US website, product review sections, customer gallery pages, community boards, and brand-tagged customer fashion content submitted via our e-commerce platform.

1. Policy Overview & Purpose

This User-Generated Content (“UGC”) Privacy Policy supplements our main Website Privacy Policy and governs how Woolrich USA, Inc. (“we”, “us”, “our”) collects, uses, stores, shares, and protects personal information contained within user-submitted content specific to our e-commerce operations.

This policy is designed to comply with United States federal privacy laws and California CCPA/CPRA state privacy regulations, clearly defining user rights and our data handling rules for UGC.

By submitting, posting, or uploading any UGC on our website, you confirm that you have read, understood, and agreed to this UGC Privacy Policy and our main Privacy Policy. If you do not agree, do not submit any user-generated content to our platform.

2. Definition of UGC

For the purposes of our e-commerce business, UGC includes all non-commercial content voluntarily submitted by users related to our products, including but not limited to:

  • Customer product reviews, product fit feedback, size recommendation comments, and fabric/quality testimonials
  • User outfit photographs, mirror selfies, styling photos, and full-look images featuring our branded items
  • Short videos, try-on clips, product haul videos, and styling tutorial content uploaded to our site
  • User body type, fit experience, and sizing preference descriptions shared in review sections
  • User profile display names, public avatars, and user captions attached to apparel product posts
  • Voluntarily shared user social media handles submitted for brand reposting and feature campaigns
  • Any other text, visual, or video content created by users and associated with our branded products

3. Personal Data Collected From UGC

When you submit to UGC, we may collect personal information embedded within your content, limited only to data you voluntarily disclose. We do not extract hidden personal data from user submissions.

3.1 Voluntarily Disclosed Personal Information

  • Identifiable Information: Display name, username, visible facial features in outfit photos, and social media handles included in captions or content metadata.
  • Physical & Fit-Related Data: Voluntarily shared body measurements, height/weight details, body type descriptions, and personal clothing size preferences disclosed in reviews or UGC captions.
  • Behavior & Preference Data: User fashion style preferences, favorite product lines, seasonal styling habits, and fit feedback tied to our branded apparel.
  • Device & Submission Data: Upload timestamps, device identifiers, and basic metadata attached to photo/video UGC files.

3.2 Strict No Collection Rule

We do not collect or extract sensitive personal data (phone numbers, emails, addresses, payment details, or private demographic information) from UGC unless you explicitly and voluntarily provide it in your public submission.

4. Legitimate Uses of Your UGC & Embedded Personal Data

We only use your UGC and contained personal information for e-commerce business purposes consistent with your original submission intent, as follows:

  • Product Page Display & Social Proof: Publish customer reviews, fit photos, and styling content on corresponding product pages to help other shoppers evaluate sizing, fit, fabric, and style performance of our branded apparel.
  • Website Community Experience: Maintain public customer gallery sections, community styling boards, and review hubs for our e-commerce audience.
  • Brand Marketing & Promotion: Repost featured UGC on our official brand website, social media channels, email newsletters, and seasonal campaigns only with explicit user consent for promotional reuse.
  • Product Improvement & Merchandising: Analyze anonymous UGC feedback to optimize fit designs, fabric selections, and seasonal product assortments.
  • Customer Support & Shopping Guidance: Use public fit reviews and styling content to answer customer sizing and styling inquiries.
  • Platform Moderation & Safety: Review UGC to remove harmful, inappropriate, or non-compliant content and protect our shopping community.

5. UGC Sharing & Third-Party Disclosure Rules

We adhere to strict data sharing standards for UGC, fully aligned with CCPA/CPRA requirements:

  • No Sale of UGC Personal Data: We never sell your UGC content or embedded personal information to third-party advertisers, data brokers, or external commercial entities for monetary value.
  • Limited Trusted Vendor Sharing: We may share UGC with contracted third-party service providers who support our UGC functions, including content moderation tools, gallery hosting platforms, and review management systems. All vendors are bound by strict data protection contracts and may only process UGC to deliver services for our brand.
  • Publicly Available Content: UGC you post on public website sections will be visible to all website visitors. You acknowledge that public UGC may be viewed, shared, or saved by other users.
  • Legal Required Disclosure: We may disclose UGC and related personal data when required by US federal/state law, court order, or government regulatory request, or to protect our brand legal rights and user safety.

6. UGC License & User Consent Terms

By submitting UGC to our e-commerce site, you grant us a non-exclusive, royalty-free, worldwide license to use, display, and feature your UGC for website community and internal business purposes. For paid or commercial brand marketing reuse (social media ads, campaign materials, official lookbooks), we will obtain separate explicit opt-in consent from you before repurposing your content.

You confirm: (1) you own all rights to the UGC you submit; (2) your UGC does not violate third-party copyright, privacy rights, or public decency standards; (3) you are legally authorized to share the content; (4) your UGC contains no inappropriate, offensive, or harmful material related to fashion, body image, or community conduct.

7. Data Retention for UGC

We retain your UGC and associated personal data only for as long as necessary to fulfill the original collection purposes:

  • Public Posted UGC: Retained on our website indefinitely until you submit a removal request.
  • Consented Promotional UGC: Retained for active campaign duration plus a 12-month archive period for brand record-keeping, deletable upon user request.
  • Moderation Records: Retained for up to 24 months for platform safety and compliance auditing.
  • Anonymous UGC Analytics: De-identified UGC feedback data may be retained permanently for product design and merchandising improvement.

8. User Privacy Rights for UGC (CCPA/CPRA US State Compliance)

If you are a United States resident, especially California residents under CCPA/CPRA, you hold full privacy rights over your UGC personal data:

  • Right to Access: Request a full list of all UGC content and personal data we have collected from your submissions.
  • Right to Delete: Request permanent removal of your UGC, including outfit photos, reviews, and styling content from our website and archives.
  • Right to Correct: Request edits to inaccurate personal details or fit information contained in your public UGC.
  • Right to Opt-Out: Revoke prior consent for us to reuse your UGC for brand marketing and promotional purposes at any time.
  • Right to Non-Discrimination: Exercising your UGC privacy rights will never result in restricted website access, higher pricing, or reduced service quality for our clothing products.

All UGC privacy requests will be processed within 45 calendar days, with a lawful 45-day extension permitted for complex multi-content requests.

9. UGC Moderation & Content Safety Rules

We maintain industry-standard UGC moderation practices tailored for product e-commerce community safety:

  • We screen all photo, video, and text UGC before public display to remove explicit content, harassment, body shaming, discriminatory language, and inappropriate material.
  • We remove UGC that infringes third-party privacy rights, violates copyright laws, or harms our brand community environment.
  • We do not edit or alter user fit reviews or styling opinions without user consent, except to remove offensive or illegal language.

10. Children’s UGC Protection (COPPA Compliance)

Our branded e-commerce website and UGC features are intended for users aged 13 and older. We strictly comply with the Children’s Online Privacy Protection Act (COPPA). We do not knowingly collect, publish, or use UGC submitted by users under 13 years of age. If we discover UGC from a minor under 13, we will immediately remove the content and delete all associated personal data. Parents or guardians may contact us to request minor UGC removal at any time.

11. UGC Data Security Measures

We implement dedicated security protocols for user-generated content: encrypted UGC file storage, restricted internal team access, regular platform security audits, and secure content moderation systems. We protect your UGC personal data from unauthorized access, alteration, disclosure, or deletion. While we maintain rigorous safeguards, no electronic storage system is entirely risk-free, and we continuously update our security practices to protect user content.

12. Policy Updates

We may update this UGC Privacy Policy periodically to reflect changes in our community features, UGC usage practices, or US legal requirements. Material updates will be posted on our website with a revised effective date. Your continued submission of UGC after policy updates constitutes acceptance of the revised terms.

13. UGC Privacy Request Contact Information

For all UGC removal, consent revocation, data access, or privacy inquiry requests, contact our dedicated privacy team:

Email: privacy@woolrich.us , dpo@woolrich.us

Official Mailing Address: Woolrich USA Inc.

13656 39th Avenue, Suite 302A, Flushing, NY 10013

14. Governing Law

This UGC Privacy Policy is governed by the laws of the United States and the State of New York, excluding conflict of law principles.