Is there anything concerning with the following privacy policy?: This Privacy & Cookie Policy describes how Whaleco Inc. and its affiliates (“Temu,” “we,” “us” or “our”) handles personal information that we collect through our digital properties that link to this Privacy & Cookie Policy, including our website (www.temu.com), the Temu mobile application and Temu’s seller portal (collectively, the “Service”), as well as through social media, our marketing activities, and other activities described in this Privacy and Cookie Policy.
Index

Personal information we collect

How we use your personal information

How we share your personal information

Your choices

Retention

Other sites and services 

Security

International data transfer

Children

Changes to this Privacy & Cookie Policy

How to contact us

Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
Demographic Information, such as your city, state, country of residence, postal code, gender and age.
Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, redemption code, biographical details, photograph, links to your profiles on social networks, interests, preferences, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.
Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
User-generated content, such as profile pictures, photos, images, videos, audio recordings, comments, questions, messages, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
Government-issued identification numbers, such as national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card.
Payment information needed to complete transactions, including payment card information or bank account number.
Promotional information, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.
Other data not specifically listed here, which we will use as described in this Privacy and Cookie Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
Sellers, including businesses and individuals who sell products on Temu.
Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
Data providers, such as information services and data licensors that provide demographic and other information, as well as credit bureaus, which help us detect fraud and offer certain credit-based services. This data may include your credit history information.
Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
Marketing partners such as joint marketing partners and event co-sponsors.
Third-party services, such as
Social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. Exactly what information we receive will depend on your privacy settings with the applicable platform.
Logistics service providers, who help us calibrate our fulfillment services. This data may include your delivery address information.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area. We also collect service-related, diagnostic, and performance information, including crash reports and performance logs.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Location data, including your general location data (e.g. IP address) and, with your permission, the precise location data of your mobile device. Please note that for most mobile devices, you can manage or disable the use of precise location services for all applications in the settings menu of your mobile device.
Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:
Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.
Data about others. We may offer features that help you invite your friends or contacts to use the Service and, with your permission, we may collect information from your contacts list to help you make invitation. 
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery. We may use your personal information to:
provide, operate and improve the Service and our business;
establish and maintain your user profile on the Service;
facilitate your invitations to friends who you want to invite to join the Service;
enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
understand your needs and interests, and personalize your experience with the Service and our communications, including finding and recommending products that might be of interest to you or features that are available where you are located;
administer sweepstakes, contests and other promotions and activities and we may use your user profile picture and name information to identify you in such promotions and activities;
prevent, detect, investigate, and respond to fraud, unauthorized access or use of the Service, breaches of terms and policies, or other wrongful behavior; and
provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
Direct marketing. We may send you direct marketing communications and abandoned cart reminder (enabled by using cookies we collected as described above). You may opt-out of our marketing communications or abandoned cart reminder described in the Opt-out of marketing section below. We will not share your records of consent, opt-in and opt-out to our marketing mobile texts with any third parties other than text messaging service providers and aggregators.
Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section below.
Compliance and protection. We may use your personal information to:
comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
Functionality. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails.
How we share your personal information
We do not sell your personal information for money and we only share your personal information with the following parties and as otherwise described in this Privacy & Cookie Policy or at the time of collection.
Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy & Cookie Policy.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, order fulfillment and delivery, marketing, consumer research and website analytics).
Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors.
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with third-party advertisers with whom we are collaborating to offer you additional services such as sweepstakes, raffles and promotions. We will share personal information that is needed for these other companies to provide the services that you have requested.
Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Whaleco or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Sellers, other users, and the public.

We may share your personal Information with sellers to facilitate your transactions (including refunds and/or returns) on or through the Service. For example, when you purchase a product on or through the Service, we normally share your personal information required to fulfill the purchase, such as shipping address and phone number, with the seller (or its service providers).

We may also share your personal information with other users and sellers to facilitate your interactions with them on or through the Service. For example, a seller’s store information is generally made available to users.

Your profile and other user-generated content (except for messages) may be visible to other users of the Service and the public. This includes your name, photo, location, reviews you have written (including any photo/video you upload with such reviews), and the list of people you follow or that follow you, as well as your username if you send messages, make comments, or upload images or videos through the Service. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. Use caution and good judgment before sharing personal information in public areas of the Service.

Your choices
Access or update your information. If you have registered for an account with us through the Service, you may review and update or delete certain account information by logging into your account. Specifically, you can update your name, address, phone number, email address and password, payment methods, profile information and purchase history in the “my account” section of the app.
Opt-out of marketing communications. To manage your preferences or opt-out of marketing communications you can use any of the following methods.
Email Promotional Offers. If you do not want to receive emails from us regarding special promotions or offers, you may follow the unsubscribe options at the bottom of each email.
Mobile Promotional Offers. When you provide us with your mobile number for marketing purposes, we may send you certain marketing alerts via text message. Consent is not a requirement to use the services and standard data and message rates will apply. If you no longer wish to receive mobile marketing alerts from us, you can follow the instructions provided in those messages or otherwise reply STOP to any alert we send.
Push Notifications. When you use the mobile app, you may receive push notifications. If you prefer not to receive push notifications, you may adjust your settings on your mobile device to control whether you want to receive these alerts.
Cookies and similar technologies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.
Advertising choices. You can limit use of your information for interest-based advertising by:
Browser settings. Blocking third-party cookies in your browser settings.
Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising:
Google: https://myadcenter.google.com/
Facebook: https://www.facebook.com/about/ads
Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
Network Advertising Initiative: https://thenai.org/opt-out/
Digital Advertising Alliance: optout.aboutads.info.
AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
For iOS 14.5 or Higher: Go to your Settings > Select Privacy > Select Tracking > Disable the "Allow Apps to Request to Track" setting.
For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Ads > Enable "Opt out of interest-based advertising."
You will need to apply these opt-out settings on each device from which you wish to opt-out.

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
Delete your content or close your account. You can choose to delete certain content through your account. You could delete your account in the “settings” section of the app.
Retention
We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

Information for California Residents
California residents have certain privacy rights as specified under California law, including the California Consumer Privacy Act of 2018 (“CCPA”), as amended and pursuant to its regulations and successors:
Right to know.
You may request details on the specific personal information, including sensitive information, we’ve collected about you, including how long we keep it or the factors we use to decide when to delete it. We provide this information in this policy, but you can also get this information by contacting us. In addition, you can request a copy of your personal information through contacting our online customer service or email our Data Protection Officer at <PRESIDIO_ANONYMIZED_EMAIL_ADDRESS>. We may require some additional information to authenticate your identity and ownership of your account.
You have the right to know who we sell or share your personal information, including sensitive information. We DO NOT sell your personal information, but we share your information with our affiliates, service providers, contractors for the provision of our services to you. For more details on third parties we share personal information with, see the “How we share your personal information” section above.
Right to Opt-Out of Selling. We do not sell your personal information as that term is generally understood but we recognize that the CCPA defines “personal information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” The CCPA broadly defines “personal information” and “selling” such that making available or sharing identifiers linked to you for a benefit may be considered a sale. In the previous 12 months, we were sharing identifiers and inferences about you with our service providers and partners in such a way that, under the CCPA, may be defined as selling. You have the right to opt-out of having your personal information sold. In addition, please see the “Cookies and Other Tracking Technologies” section above for a description of opting out of cookies and controlling browser settings.
Right to deletion. You may request deletion of your personal information, unless an exception applies. Examples of exceptions include when we need to keep personal information to meet legal obligations, detect fraud, investigate reports of abuse or other Terms of Service violations, or fix security issues. Upon your verified request, we’ll delete your personal information and will direct our service providers to do the same.
Right to request. You may request us to limit our use or disclosure of any sensitive personal information we collect. Specifically, you have the right to request that we use it only as is necessary to perform the services or provide the goods you expect.
Right to correction. You have the right to request that we correct any inaccurate personal information of yours.
You have the right to make two free requests in any 12-month period. We will respond initially to your request within 10 days, and then respond to your request fully within 45 days, but in more difficult cases we may extend our response time by another 45 days. Please see the “Cookies and similar technologies” section above for a description of opting out of cookies and controlling browser settings. We respect your choices and will not discriminate against you for exercising your rights. In some circumstances, we may have to explain if a certain functionality of our service will operate differently so that you can make an informed decision.
In the last 12 months, we’ve collected the following categories of personal information:
Identifiers, such as name, display name, postal address, unique personal identifier, online identifier, IP address, email address, username, or other similar identifiers.
Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law, and overlaps with other categories listed here.
Demographics, such as your gender.
Commercial information, such as products purchased or considered, or other engagement with our services. For example, we may keep this information when you purchase items through the Temu platform.
Internet or other electronic network activity information, such as session logs, search history, or your interactions with our services. For example, we may store your search history when you are searching for items on the Temu platform.
Location data at an IP address-based level, to tailor your experience in terms of displaying the appropriate local website or user experience.
Audio, electronic, visual, or similar information.
Inferences drawn from other personal information. For example, we’ll use this information to create a list of your interests and preferences to serve you more relevant items on the Temu platform.
We may collect the categories of personal information described above when you provide it to us, when you use our services, e.g., automatically and through cookies and other technologies, or when we receive it from third parties. For more details on the sources, see the “Personal information we collect” section above.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties.  In addition, our content may be integrated into web pages or other online services that are not associated with us.  These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party.  We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer
We may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children
The Service is not intended for use by anyone under 13 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy & Cookie Policy
We reserve the right to modify this Privacy & Cookie Policy at any time. If we make material changes to this Privacy & Cookie Policy, we will notify you by updating the date of this Privacy & Cookie Policy and posting it on the Service or other appropriate means.  Any modifications to this Privacy & Cookie Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy & Cookie Policy indicates your acceptance of the modified Privacy & Cookie Policy.

How to contact us
Email to our Data Protection Officer at <PRESIDIO_ANONYMIZED_EMAIL_ADDRESS>
Mail to Whaleco Inc., Suite 355, 31 St. James Avenue, Boston, Massachusetts 02116, USA