Privacy Policy
RENT THE RUNWAY, INC. PRIVACY POLICY

Effective Date: July 1, 2023

Candidate Privacy Notice

1. Overview

This Privacy Policy explains how Rent the Runway, Inc. (“Rent the Runway”, “we”, or “us”) collects, protects, uses and discloses information about you when you use www.renttherunway.com (“Website”), our mobile applications (“App”), and any of our other services that link to this Privacy Policy (collectively, including the Website and App, the “Services”), and whether you access the Services directly or through a third party.

Please understand that, except as specifically described below, this Privacy Policy does not apply to information collected by third parties, such as other companies, or third-party websites or mobile applications, even if any are linked to or accessible through the Services.

If you have any questions or concerns about our information practices, please contact us at privacy@renttherunway.com.

If you do not want information about you to be used as described in this Privacy Policy, you must stop, or refrain from, using the Services.

2. Information We Collect

“Personal Information,” as used in this Privacy Policy, is information that directly identifies an individual, such as a person’s name, or information that reasonably allows an individual to be identified indirectly, such as email or home address or a person’s mobile phone number.  Personal Information also includes information that is directly combined with such identifying information.

We collect Personal Information when people use our Services, including our App and Website. This information falls into two (2) general categories:

- Passive Data Collection. This refers to data automatically collected from customers when they use our Services.

- User-Submitted Information. This refers to information that customers actively submit to us, which may be provided voluntarily or as required to use our Services.

Customers also sometimes provide us with information about other individuals, such as when a customer sends a gift card or uses our referral services to tell a friend about us. In those cases, we may ask that customer to provide the recipient’s name and email address. (We may also collect Personal Information in any personalized message that is submitted with a gift card or referral.) We will automatically send the recipient email correspondence with the gift card or referral, and invite them to visit the Website or otherwise use the Services. If we receive Personal Information for a referral or gift card, we use that information for the sole purpose of sending this email correspondence, and for tracking the use of the gift card or the success of our referral program.

Passive Data Collection

As a general matter, we automatically collect certain information based on your use of and behavior in connection with the Services. We use this information to analyze our customers’ demographics, interests, and behavior to better understand and serve you and our customer base.  We also analyze this information for security purposes, to protect the Services and customer information that we hold.

If the information we collect automatically identifies you or could be reasonably used to identify you, then it is treated as Personal Information. Also, if we directly combine any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this Privacy Policy. But in many cases, the information that we collect passively is only used in de-identified or aggregated forms, which do not identify any individual.

We collect passive data in the following ways:

Mobile Device Information

When you download or use our App, we receive information about your mobile device. We register your device, and we may use the identifier to send you push notifications about your transactions via the Services.

Log Files

Like most websites, we automatically receive and record certain information about our customers’ behavior on our Website or App or when using our other Services. Our servers automatically gather technical information about our Website or App traffic and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and other clickstream data. We aggregate this information with other pieces of information to analyze trends, to administer and improve the Services, for example to understand customers’ use of the Website and to make inventory and purchasing decisions that will best serve our customer base. Information from log files may also be used to determine general location information such as city, state or geographic area.

Cookies, Web Beacons and Similar Technologies

A cookie is a small text file that is stored on a computer for record-keeping or tracking purposes. Web beacons (also known as pixel tags or clear GIFs), are graphics that can record whether a person has accessed particular content. We use these and other similar technologies on the Website and App and in connection with our Services.

Cookies we utilize may include session cookies, persistent cookies, or similar technologies. A session cookie expires when you close your browser. A persistent cookie is stored on your computer or device for an extended period of time. You can remove persistent cookies by following the directions provided in your Internet browser's "help" menu. You may also configure your browser to prevent cookies from being set on your computer. (Instructions should be provided in documentation for your browser.) If you reject cookies, your ability to use the Website, App and other Services may be limited, and you may not be able to use certain features of the Website, App or other Services. We may use cookies for the following purposes:

- Strictly necessary cookies. There are two categories of strictly necessary cookies that we consider necessary for customers to use the Services:

- Essential cookies. Essential cookies are required for providing you with features or services that you have requested. For example, certain cookies enable you to log into secure areas of our Services. Disabling these cookies may make certain features and services unavailable.

- Functional cookies. Functional cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

- Performance/analytical cookies. Performance/analytical cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/analytical cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.

- Targeting cookies and other data trackers. Targeting cookies and other data tracking technologies record information such as your visit to our website, the pages you have visited and the links you have clicked. We will use this information subject to your choices and preferences to make your experience using our Services more relevant to your interests, such as keeping a record of the items you have hearted. We also work with third parties to serve targeted advertisements to people similar to our customer base and those who are similar to visitors to our Site or similar to those identified in one or more of our databases. We may use web beacons or similar technologies, which help manage content on the Website and in the Services by tracking what content is effective. These technologies may be used to track the online movements of customers, but in contrast to cookies, which are stored on a computer hard drive, these technologies are embedded in the Website or App. We may also use web beacons in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. For more information, see Targeted Advertising and Analytics.

To find out more information about cookies, including information about how to manage and delete cookies, please visit https://www.allaboutcookies.org/.

Targeted Advertising and Analytics

We engage others to provide analytics, serve advertisements, and perform related services across the web. These entities may use cookies, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of our Services and other websites and mobile apps, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information is used to deliver advertising targeted to your interests on other companies' sites and to analyze and track data, determine the popularity of certain content, and better understand your activity. Some of our advertising partners enable us to translate your email address or phone number into an identifier that cannot be used to identify you personally. Our advertising partners then use that unique identifier to show ads that are more relevant to you across the web and in mobile apps. Some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under certain laws. To learn more about the choices available to you with respect to these practices, see below.

You can also learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting https://www.aboutads.info/choices.

Audio and Video Recordings and Customer Support and Chat Conversations

If you contact customer support through our chat feature, we may monitor and retain the chat conversation, including for training purposes. We also capture audio and video recordings during video conference and audio calls with you. Please do not use the chat feature or participate in video conference or audio calls with us if you do not consent to our monitoring and retention of chat conversations and video conference calls with you.

User-Submitted Information

As a general matter, we may ask you for information, or retain information, that you provide to us in order to provide our Services to you, and to better serve you and our customer base. This category of information includes information submitted electronically, via phone, and in person through our stores. We may also combine this information with Personal Information to provide you with customized and personalized services.

We collect User-Submitted Information in the following ways:

Registration and Communicating with You

In order to use some features of the Website, App or other Services, including the rental of Rent the Runway’s inventory, you must first create an account with us and agree to the Terms of Service. To create an account, you must provide an email address and create a password. We may also ask you for your birthday. We use the email address you provide to contact you about the products and Services, and to begin to create a tailored experience for you.

You may also provide us your contact information, such as your email address, when you sign up to receive communications from us about the Services, events we offer, and news and information that we think will interest you.

Orders

If you order a product from us, we request certain Personal Information from you, whether you access the Services from our App, the Website or otherwise. You must provide contact information (including name, shipping address, telephone number) and a payment method. We use this information for billing purposes, to fill your orders and to communicate with you about your orders. If we have trouble processing an order, we will use this information to contact you.

We record what you order and associate it with your account profile. When you return an item, we may ask you for information about your experience, such as, if you wore it and for information regarding how it fit. We record that information to better personalize our Services for you and to improve our Services for others.

Personalization of Service

In order to improve your customer experience, we may request personal characteristics, such as your height, bust, dress size, style and fit preferences, your birthday, and the date and occasion for your rental. We may also ask for your feedback and rating of our products. All of this information is voluntary and helps us improve our Services by enabling us to create a tailored experience for you and our other customers.  Although we believe that providing this information will improve the Services we can offer to you, and your experience of the Services, we will not require you to provide it. (Also, although we may request information about personal physical characteristics, we do not ask for uniquely identifying biometric information.)  We may also collect approximate geolocation information from you.

Surveys or Contests

We may provide you the opportunity to participate in surveys or contests on our Website or in connection with our Services.  If you participate, we will request certain Personal Information. The requested information typically includes contact information (such as name and email address) and demographic information.

We may use this information to notify contest winners and to award prizes, to monitor traffic to our Services, to improve the Services, and to send participants an email newsletter.

Additional information practices (and terms and conditions) may apply to any survey or contest, which will be made available with the survey or contest. Please carefully review any additional information provided.

Third-Party Account Credentials

If you choose to provide us with your third-party account credentials to such services as Google or Facebook, you understand that some content and/or Personal Information may be shared between the third-party service and us. Any information collected by a third-party service will be used in accordance with that third party’s privacy policy, which we encourage you to review and consider.

Public Feedback (Reviews) and Discussion Boards

If you choose to post messages to public message areas, such as submitting reviews about the items you have worn, or leave feedback for others, that information may become available to anyone. We are not responsible for the use by others of the information you publicly disclose. Additionally, we may, but are not obligated to, collect the information you post in public message areas to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

Please be careful and closely consider disclosing any Personal Information in public message areas.

3. How We Use Your Information

The purposes and ways that we may use Personal Information about you are described throughout this Privacy Policy, often in connection with the kinds of Personal Information we collect. Other uses of Personal Information are described below.

In addition, we may use aggregate, statistical, and de-identified data, which does not specifically identify any individuals, for any purpose.

General Uses of Your Information

We generally use the information we collect, including Personal Information about you, for the following purposes:

- To Provide Our Services. We use your Personal Information to provide our Services to you, including:

- To present you with products, information and content through the Services, including personalization of the Services;

- To process transactions, including financial transactions, related to your use of the Services;

- To assist you in finding a location to return an item, using location or geolocation information you provide to us; and

- To respond to your questions or requests.

- For Communications and Marketing. We use your Personal Information to communicate with you and provide you with information about Rent the Runway and our marketing partners.

- To Develop and Improve Our Services. We may also use your Personal Information as we work to continually improve our Services, our business and our operations. For example, by:

- Analyzing usage or interest in certain features, or identifying items and areas of interest to our customers.

- For Compliance, Fraud Prevention and Safety. We may use your Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to:

- Protect our, your or others’ rights, privacy, safety or property;

- Enforce the terms and conditions that govern use of our Services, including for legal claims; and

- To prevent, identify, investigate and deter any fraudulent, harmful, unauthorized or illegal activity.

- To Comply with Law. We may use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process.

- As Described or with Your Consent.  We may use your Personal Information for any other purposes that we describe at the time we collect your Personal Information, or otherwise with your consent.

Communications from Us

We use your contact information to communicate with you about Rent the Runway and our marketing partners in the following ways:

- To provide newsletters, marketing emails or push notifications with special promotional offers, updates and other relevant marketing content or news and information that we think will interest you;

- To provide announcements about the Services;

- To communicate with you about the Services and your account, including updates about the status of your orders; and

- To verify your identity and address for your orders and rentals.

We may communicate with you via phone, email, text messages and push notifications to your mobile device. Standard call, message and data rates charged by your mobile carrier may apply to text messages or other communications received on your mobile device. See the Your Choices section for more information on how to manage your communication preferences.

4. How We Disclose Your Information

We may disclose Personal Information about you, in general:

- As necessary to provide the Services;

- To service providers;

- To our corporate affiliates and business partners;

- For legal reasons or as required by law; and

- With your consent or at your direction.

The purposes and ways that we may disclose Personal Information about you are described below in more detail.

Service Providers

We may provide Personal Information to third parties for use in performing research and business functions (e.g., mailing, maintenance, security, data analytics, communications, CRM, database management services, credit card payment processing or data hosting) on our behalf (our “service providers”). These service providers agree to use your Personal Information only in accordance with our instructions, with information used only as described in this Privacy Policy and for no other purpose than to provide the contracted-for services.

Corporate Affiliate Parties

We may disclose some or all of your Personal Information with our affiliates (including a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us), in which case we will seek to require those affiliates to honor this Privacy Policy.

For Legal Reasons and As Required by Law

We may disclose Personal Information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Rent the Runway, our users, the public, or others. We may also disclose Personal Information if we have a good-faith belief that doing so is required under applicable law, for example if we receive a subpoena or other judicial or administrative order or otherwise required by law. This may include responding to legal requests from jurisdictions outside of the United States, where we have a good faith belief that the response is required by law in that jurisdiction.

In Connection with Business Transactions

We may disclose Personal Information in certain corporate transactions, such as in connection with an actual or proposed merger, acquisition, or other sale of or transfer of all or part of our business or assets, including as part of a bankruptcy, liquidation, or other insolvency proceeding.

In the event of a change in ownership of Rent the Runway, or a merger with, acquisition by, or transfer or sale of all or a portion of our assets to another entity, we reserve the right to transfer all of your Personal Information, including email addresses and other information about you collected by us (in accordance with this policy), to that entity.

To Protect Rights

Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of the Terms of Service or our other agreements; take precautions against liability; protect the rights, property, or safety of Rent the Runway, any individual, or the general public; maintain and protect the security and integrity of our Services or infrastructure; protect ourselves and our Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims or allegations; or assist government enforcement agencies.

With Your Consent or at Your Direction

We may disclose Personal Information when we have your consent or you direct us to do so. For example, if you decide to participate in certain interactive areas or features of our Services, such as writing a product review, you consent to the disclosure of any personal information you provide in connection with your post.

We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you. For example, Rent the Runway engages in marketing and promotional activities with carefully screened brands, or, “Partners,” during which we provide those Partners with aggregated or de-identified information. If Rent the Runway processes, maintains, or uses de-identified information, it will do so only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

5. Third Party Websites

In the event that we provide links to other websites that we do not control, whether or not those other websites refer to our branding, this Privacy Policy does not apply to those other websites. Visitors to those websites are advised to carefully read the policies on those individual websites.

6. Your Choices

Account Information

You can access, modify, and delete certain information stored within your online account by logging into your account and visiting the “Profile” or “Your Membership” sections.

Communications Preferences

You may opt out of receiving text messages or promotional emails from Rent the Runway by following the instructions in those communications or by updating your communication preferences in your customer account. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Cookies and Similar Tracking Technologies

Rent the Runway uses cookies and similar tracking technologies to analyze visits to our websites and interactions with our communications to help us improve our website, services, and marketing campaigns. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. You can also adjust certain cookie settings by clicking here . Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Mobile Push Notifications

With your permission, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

7. Security

We use reasonable security measures to protect against the loss, unauthorized access, misuse, alteration and destruction of Personal Information under our control, both during the transmission and once we receive it.

Although we make good faith efforts to maintain the security of such Personal Information, no method of transmission over the Internet or method of electronic data storage is 100% secure, and we cannot guarantee that the information will remain free from unauthorized access, use, disclosure, or alteration. While we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent hackers or other unauthorized persons from illegally accessing or obtaining this information.

8. Children’s Privacy

Rent the Runway and the Services are not intended for or directed toward children under 13 years of age, and children should not use the Services for any purpose unless they have the consent of, and are under the supervision of, a parent or guardian. We ask that individuals do not provide Personal Information through our Services, and if we learn that we have collected or received Personal Information from a child under 13 years of age, we will delete that information

Additionally, we may collect Personal Information from teenagers between the ages of 13 and 18, but only if such an individual is of legal age to enter into a binding contract under applicable law, or with the consent and supervision of a parent or legal guardians, as permitted by law.

If you are the parent or legal guardian of a child under 13 years of age who has registered on the Website or App or you believe has otherwise provided Personal Information to Rent the Runway without your consent, please contact Rent the Runway at legal@renttherunway.com to have the account terminated and information deleted.

If you believe that we may have inadvertently collected any Personal Information about a child aged 13 years or younger, please contact us at privacy@renttherunway.com or as provided in the “Contact Us” section below.

9. Additional Information for Customers Residing in Certain U.S. States

Certain U.S. states, including California, Colorado, Connecticut, Utah, and Virginia, have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Laws”). If you reside in such a state, this section applies to you.

Additional Disclosures

This Privacy Policy explains how we collect, use, and disclose information about you, as well as our Targeted Advertising and Analytics practices. Below, we use two different tables to summarize and explain this same information in accordance with the State Laws. The tables describe our information practices now and over the past 12 months.

Personal Information that We “Share,” “Sell,” or Use for “Targeted Advertising”

Some of our advertising and analytics activities may constitute “sharing”, ” “selling,” or “targeted advertising” under State Laws. In order to advertise our products to you and better understand, improve, and personalize our interactions with you, we have shared, sold, or disclosed for targeted advertising purposes the following categories of Personal Information to the following categories of third parties:

Other Details about Our Information Practices

● We collect Personal Information directly from you (such as when you create an account with us) and through passive data collection methods (such as information collected from your mobile device or through cookies), each as described in more detail in the “Information We Collect” section above.

● We do not knowingly collect, sell, or share Personal Information about consumers under the age of 16.

● We do not collect information that is considered “sensitive” under State Laws.

● We store Personal Information associated with your account as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy. For example, we retain a record of your transactions with us to protect ourselves in the event of a legal dispute; consequently, we generally retain this data for at least the statutory limitation period on contractual claims.

Your Privacy Rights

Opt Out of Sales, Sharing, and Targeted Advertising

You have the right to opt out of sharing, sales, and targeted advertising at any time by clicking here . If you are a resident of California, you can also opt out of certain targeted advertising, sharing and sales by visiting our Services with a legally-recognized opt-out preference signal enabled (such as the Global Privacy Control). Please note that, depending on which legally-recognized opt-out preference signal you use and whether you are logged into your account with us, our processing of the signal may be limited to the specific browser or device that you are using. You may need to renew your opt- out choice if you use a different browser or device to access our Services or if you clear your cookies because your opt-out choice may be linked to your browser only.

Access, Correction, and Deletion

You have the right to (1) request to know more about and access your Personal Information, including in a portable format, (2) request deletion of your Personal Information, and (3) request correction of inaccurate Personal Information.

To request access, correction, or deletion of your Personal Information,  visit this webpage  or call our toll-free number at +1 (888) 914-9661 and enter PIN: 996 984. You can also access, correct, or delete certain information stored within your online account by logging into your account and visiting the “Profile” or “Your Membership” sections.

We may verify your request by asking you to provide information related to your recent interactions with us, such as your name, email and mailing address.

Appeals

If we deny your request, you may appeal our decision by contacting us at legal@renttherunway.com. If you have concerns about the results of an appeal, you may contact the attorney general in the state where you reside.

Nondiscrimination

We will not discriminate against you for exercising your privacy rights.

Authorized Agents

If you reside in California, Colorado, or Connecticut, you can designate an authorized agent to submit a privacy rights request on your behalf. We may ask authorized agents to submit proof of their authority to make the request, such as a valid power of attorney or proof that they have signed permission from you. In some cases, we may be required to contact you to verify your identity or confirm you have granted the authorized agent permission to submit this request. If you are an authorized agent seeking to make a request, please contact us at legal@renttherunway.com

Notice of Financial Incentive

We may offer various financial incentives. For example, we may provide discounts, coupons, or other benefits to customers who sign up to receive our marketing messages, such as emails. When you participate in a financial incentive, we collect Personal Information from you, such as identifiers (like your email address), commercial information (like your purchase preferences and interests or purchase history), inferences drawn about your preferences, and other categories of personal information that relate to or are reasonably capable of being associated with you. You can opt into a financial incentive by following the sign-up or participation instructions provided, and, for any ongoing benefits, you can opt-out at any time, such as by following the unsubscribe instructions in the applicable program’s terms and conditions, promotional emails, or contacting us at legal@renttherunway.com. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your Personal Information is reasonably related to the value of the offer or discount presented to you.

10. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the Website, with the effective date posted at the top of the Privacy Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make material changes to our Privacy Policy or how we handle your Personal Information, or if we are going to use any Personal Information in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will try to notify you of such changes reasonably in advance. By using our Services after the effective date, you are deemed to consent to our then-current Privacy Policy.

11. Contact Us

If you have questions, concerns or feedback regarding this Privacy Policy or our information practices, you can send an email to us at privacy@renttherunway.com or by postal mail at:

Rent the Runway

10 Jay Street, Brooklyn, NY

Attn: Legal Department

Candidate Privacy Notice
RENT THE RUNWAY, INC. CANDIDATE PRIVACY NOTICE

Effective Date: November 1, 2023

As part of our candidate application and recruitment process, Rent the Runway processes certain personal data about you.

The purpose of this privacy notice (“Notice”) is to provide job candidates and prospects (“you” or “your”) with information about how Rent the Runway collects, uses, stores, transfers and otherwise processes your personal data.

Rent the Runway, Inc. and (if different) the Rent the Runway entity listed in Schedule 1 with whom you are seeking to enter into an employment contract or to which you otherwise seek to provide services (collectively, “Rent the Runway”, “we”, “us” or “our”), are data controllers of your personal data.

This Notice does not cover information collected about you as a Rent the Runway customer or user of our websites, mobile applications or our other products and services. To learn more about our information practices in those situations, please read our online Privacy Policy above.

1. Types of information we collect

We collect personal data you provide directly to us, such as when you apply to work for us. We also obtain personal data from third parties, such as your previous employers, named references, educational institutions, background check providers, recruitment consultants and professional recruitment agencies. This information includes:

● Personal identifiers and contact information: This includes information such as name, home address, telephone number, personal email address, and LinkedIn profile and website (if provided voluntarily).

● Recruitment and application details, education and training information: This includes information contained in letters of application and CVs, previous employment background and references, technical skills, information about your degrees and training, transcripts, educational background, professional qualifications and registrations, training courses attended, language capabilities and other relevant skills, nationality, visas and work authorizations.

● Assessment details: If we ask you to attend an interview (either in person or by telephone or video), we may generate information about you such as assessments or interview notes.

● Results of background or other regulatory screening checks: If we make a conditional offer of employment, we will consider the results of these checks where permitted by local law.

● Other information that you submit: This includes additional information you provide in an application form, cover letter or other work product.

● Sensitive personal data: In some cases, we may collect sensitive personal data, which requires a higher level of protection. Please note that, where permitted by law, we may collect, store, and use sensitive personal data about you, including race, ethnicity, veteran status, disability status, gender, age, marital status, and health and medical conditions. We collect this information for specific purposes, such as to improve our diversity and inclusion efforts and comply with legal obligations. You are entirely free to decide whether to provide such information and your application will not be affected either way. Except as specifically requested, we ask that you avoid submitting information which may qualify as sensitive personal data under applicable law, including race, religion, ethnicity, nationality, age, gender identity, sexual life or sexual orientation, medical or health information, political opinions, political party or trade union membership and judicial data such as criminal records.

In some cases, we collect personal data about you automatically. For example, we use tracking technologies, such as cookies and web beacons, to collect certain information about your interactions with our Careers site. A “cookie” is a small text file stored on your hard drive or in device memory that helps us improve our site and your experience. Web beacons (also known as “pixel tags” or “clear GIFs,”) are electronic images that we use on our site and in our emails to help deliver cookies, count visits, and understand usage. In addition, if you visit our physical premises as part of our interview process, we may capture photos and video recordings through cameras and CCTV for security purposes.

2. How we use this information

We use the above information for the purpose of progressing applications, assessing the suitability of candidates for employment or engagement with Rent the Runway and managing our business. Where you have given us permission, we also keep this information as part of our talent database so that we can contact you about current and future open positions at Rent the Runway.

We may also use the above information for the following purposes: to improve our recruitment and hiring process; to protect the health, safety, and vital interests of you or of another natural person, such as during an emergency where your health or security is in danger; to prevent physical harm or financial loss, or to comply with our legal obligations or public health recommendations; to administer our applications, software and systems, including ensuring the security of our workforce, guests, property, and assets and to monitor and audit network traffic and information in such applications, software, and systems as permitted under applicable law; to comply with legal obligations and internal policies relating to diversity, inclusion, and anti-discrimination; and as necessary and appropriate to provide reasonable workplace accommodations.

By collecting and processing the above categories of personal data, Rent the Runway is pursuing its legitimate business interests in hiring suitable candidates and seeking assurances from previous employers and referees as to candidates’ work performance and reliability. It is also necessary in the legitimate interests of Rent the Runway to maintain a talented workforce and in your legitimate interests of ensuring that you are considered for future roles at Rent the Runway.

We also use the information to fulfil legal or regulatory requirements if necessary. For example, if we make a conditional offer of employment, we may be required to confirm the identity of our personnel and their right to work in a particular country under immigration and employment rules.

We may also be required to carry out pre-employment screening against global exclusion and sanction lists for the purposes of international and US export control regulations. To do this, we ask one of our service providers to search third party databases to ensure you are not on a sanction list.

When collecting your personal data is mandatory, this will be stated at the time of collection of the personal data. If you choose not to provide the mandatorily required personal data, this might affect your application.

3. How we disclose this information

Where necessary, and in accordance with the purposes set out in this Notice, your personal data will be disclosed internally to individuals involved in the hiring and recruitment process and with other Rent the Runway group affiliates and/or third-party providers. These will include, for example, third parties who provide pre-employment screening services to us, recruiters and our applicant tracking system provider.

In certain limited circumstance, we disclose personal data to other recipients, including (a) professional advisors, including accountants, auditors, lawyers, insurers and bankers, (b) to comply with our legal obligations, (c) to protect the rights and property of Rent the Runway, our customers and the public, (d) to cooperate with law enforcement investigations and to detect and respond to suspected illegal activity and threats to the health or safety of any person or of our systems or services, (e) in connection with, or during negotiations of, any merger, joint venture, sale of company assets, financing or acquisition of all or a portion of our business, assets or stock by another company (including in connection with any bankruptcy or similar proceedings) and (f) with your consent or at your direction.

We may also disclose aggregated or de-identified information, which cannot reasonably be used to identify you. Rent the Runway processes, maintains and uses this information only in a de-identified fashion and will not attempt to re-identify such information except as permitted by law.

When you use third-party apps, websites or other products integrated with our systems to apply for a role, they may collect information about you subject to their own terms and privacy policies.

4. How we retain this information

Rent the Runway maintains appropriate technical and organisational measures to protect against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment at Rent the Runway and for an extended period of time. To determine such period of time, we take into account a number of factors, including our legal and regulatory obligations (such as financial reporting obligations and equal opportunity or anti-discrimination reporting obligations) and whether we may need to retain personal data to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes, and/or enforce our agreements.

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for a period of three (3) years so that we can comply with our legal obligations and resolve disputes. With your permission, your information will be retained for a further 2 years so that we can contact you about current and future open positions at Rent the Runway.

5. How we transfer this information

Rent the Runway is a global business and we may process, store and transfer your personal data across international borders, consistent with applicable data protection laws. Some of these countries may not have the same levels of data protection or similar rules regulating government agency access to personal data as are present in your home country. In these cases, we take steps to protect your personal data. Rent the Runway will typically transfer and disclose your information in compliance with the Standard Contractual Clauses approved by the European Commission. You can request a copy of the Standard Contractual Clauses by emailing hr-privacy@renttherunway.com.

6. Your privacy rights and choices

Please make sure that your personal data is accurate and up to date, and please inform us of changes in a timely manner.

If you are a candidate in the EEA, with some limited exceptions, you may inquire about the personal data we maintain about you and exercise your rights to access, correct, export, and delete your personal data, including information contained in your employee file. In addition, when we process your personal data based on our legitimate interests (as set out above), you have a right to object to our processing of your personal data. If you would like to exercise any of these statutory rights, please contact hr-privacy@renttherunway.com. You may also have a right to lodge a complaint with your local data protection authority. You also have a right to obtain a copy of your information in an easily accessible format. In certain circumstances, you may also request us to transfer this information to third parties. You have the right to withdraw your consent to our processing of your information at any time. Please email us at hr-privacy@renttherunway.com should you wish to exercise this right.

If you are a California resident, please refer to our California Candidate Privacy Notice Addendum for more information.

7. Changes to this Notice

We may update this notice from time-to-time. If we make changes, we will notify you by revising the date at the top of this Notice. If we make material changes, we will provide you with additional notice (such as by sending you a notification). We encourage you to review this Notice regularly to stay informed about our information practices and the choices available to you.

8. Contact us

If you have questions or suggestions about our personal data processing practices or if you would like to exercise your statutory rights, you can contact hr-privacy@renttherunway.com, or for Irish candidates contact Sarah Lynch, salynch@renttherunway.com or hr-privacy@renttherunway.com.

California Candidate Privacy Notice Addendum
RENT THE RUNWAY, INC. CALIFORNIA CANDIDATE PRIVACY NOTICE ADDENDUM

Effective Date: November 1, 2023

This Rent the Runway California Candidate Privacy Notice Addendum (“Addendum”) supplements the Rent the Runway Candidate Privacy Notice (“Notice”) above and provides additional information about our privacy practices and your privacy rights, as required by California law. If you are a California resident, this Addendum applies to you.

Additional Disclosures

In the preceding 12 months, we have collected the following categories of personal information: identifiers; characteristics of protected classifications under California or U.S. federal law; audio or visual data; professional or employment-related information; education information, and sensitive personal information, each as further described in Section 1 of the Notice. We collect such categories of personal information from the sources identified in Section 1 of the Notice, such as collecting the information directly from you when you submit information to us, indirectly from parties such as references and emergency contacts, automatically through surveillance equipment or other devices and we also develop data during our interactions with you.

We collect, use and disclose personal information for the following business purposes: recruiting and hiring; human resources purposes; to protect the interests of Rent the Runway and others; legal compliance purposes; to operate third-party relationships to conduct our business and as otherwise explained in Sections 2 and 3 of the Notice. We do not use or disclose your sensitive personal information for purposes other than those expressly permitted under California law.

In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

California Privacy Rights

California residents have certain rights with respect to their personal information, including the following:

● Right to Access: You may ask us to confirm whether we are processing your personal information and, if so, to provide you with a copy of the personal information we hold about you in a portable format (along with certain other details).

● Right to Correction: If the personal information we hold about you is inaccurate or incomplete, you are entitled to ask for correction or completion.

● Right to Deletion: You may ask us to delete or remove your personal information in some circumstances—for example, if we no longer need it.

To request access, correction, or deletion of your personal information, please visit this webpage or call our toll-free number at +1 (888) 914-9661 and enter PIN: 996 984. We may verify your request by asking you to provide information about you, such as your email address or telephone number. You may also designate an authorized agent to exercise privacy rights on your behalf by providing the authorized agent signed permission to submit the request on your behalf. If an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal information. If you are an authorized agent seeking to make a rights request, please contact us at hr-privacy@renttherunway.com.

We will assess any requests to exercise your privacy rights on a case-by-case basis. There may be circumstances in which we are not legally required to comply with your request because of a relevant legal exemption provided for under applicable law. We will not discriminate or retaliate against you for exercising your privacy rights.

We do not “sell” or “share” your personal information as those terms are defined under California law.