CrazyBee Privacy Policy

This Privacy Policy describes how ReFlip LLC and the CrazyBee Platform (collectively, “we,” “us,” or “our”) collect, use, share, and protect the personal information you provide or that we collect when you interact with our Websites, Services, and Products and any other sites or Services (“Services”) under our control where this Privacy Policy is displayed. It also describes your choices regarding the use, access, and correction of your personal information.

At CrazyBee, we respect your ability to know, access, correct, transfer, restrict the processing of, and delete your personal information. We provide these rights to every customer, and if you choose to exercise these privacy rights, you have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from CrazyBee. If you are asked to consent to the processing of your personal information by CrazyBee, you have the right to withdraw your consent at any time.

To exercise your privacy rights and choices, please contact us via email at the Compliance & Policy Department (provided at the end). For the security of your personal information, you will be required to log into your account and verify your identity. Additionally, you have the right to lodge a complaint with the relevant supervisory authority.

In some cases, we may not be able to approve your request, for example, if you request the deletion of your transaction data but CrazyBee is legally obligated to keep a record of that transaction to comply with applicable law. To the extent permitted by law, we may refuse your request for specific reasons. For details, please refer to the section “Your Privacy Rights and How to Exercise Them”.

1. Categories of Personal Information We Collect

Depending on how you interact with CrazyBee, we process different types of personal information.

If you are a direct customer of CrazyBee, we may collect the following personal information to contact you and process transactions:

• When you register for an account, we collect your name, email address, and password.
• When you use our services, we collect your name, email address, postal address, delivery address, rental term (if applicable), and financial information for billing purposes, including your payment method and preferences (such as credit or debit card number) and billing and credit history (if applicable).
• When you visit our website and provide your email address, use the “favorites” tool, or complete a transaction, we may collect information about the products or services you consider and/or purchase.
• When you fill out our online contact form, we collect your name, email address, and phone number.
• We may collect personal information included in your interactions with us, including audio, electronic, or visual information, screen sharing views, and any documents you provide to us via email, chat features, social media, phone, or other means.
• When you ask us a question or make a request via email, text message, or tweet, we collect your email address, phone number, or handle to process your request and respond to your question.
• If you contact us by phone, we may record the call for internal purposes only and will collect your name, email address, phone number, and any information necessary to provide customer service, which may include your payment information.

Data that does not contain any personal data that can be used to identify you or has otherwise been de-identified or aggregated is not considered personal data. To the extent we process de-identified data, we will maintain and use the data in de-identified form and will not attempt to reidentify the data unless permitted by applicable law.

2. How We Collect Personal Information

We collect personal information from the following categories of sources:

• Directly From Users of the Service – We collect personal information that you provide to us as described above.
• From Third Parties – We may collect personal information from third parties including your employer, our business partners, and service providers, advertising networks, analytics providers, and search information providers, who may provide us with personal information about you.
• Through Online Tracking Technologies – We use cookies and similar technologies to collect personal information related to activity on our website. For additional information regarding our use of these technologies, see the section below.

3. Core Automated Processes

CrazyBee relies on automated processes to enable certain parts of our services, including functions essential to our business such as matching (pairing users with preferred products and merchants with target audiences) and fraud prevention and detection. These processes allow CrazyBee to provide a seamless and secure service experience.

This section describes how automated matching and fraud prevention and detection processes work, including how they impact your CrazyBee experience and the personal and non-personal data used to enable these processes.

You may contact us by email at General_Counsel@ReFlip.life if you have questions or concerns regarding these processes.

Matching

CrazyBee uses algorithms to efficiently match users with products and merchants with potential customers. This minimizes user search time and increases product exposure for merchants.

The matching process is triggered when you browse or search on CrazyBee. Our algorithms then evaluate various factors to determine the best match, including your browsing history, search keywords, purchase preferences, geographic location, product inventory status, merchant reputation ratings, product sales volume and reviews, and in some cases, whether the specific users and merchants have previously reported having negative experiences with each other.

Subsequently, the system will recommend matched products to your homepage, search results page, or relevant recommendation sections, while also pushing potential customer groups to corresponding merchants. Once you select and purchase a product, we will send transaction confirmation notifications to both you and the merchant.

We are constantly refining our matching process to provide the best experience to all users and merchants on our platform and may consider different factors depending on the location and the characteristics of product categories on the platform.

Fraud Prevention and Detection

CrazyBee uses algorithms and machine learning models to prevent and detect fraud against CrazyBee or our users and merchants. This includes efforts to monitor for account takeovers, suspicious transaction behaviors, fake orders, malicious reviews, and unauthorized access attempts, including those through third-party platforms.

These tools look for patterns that may indicate fraudulent behavior, such as those that vary significantly from typical user or merchant behavior. To do this, CrazyBee performs real-time monitoring of information collected from or generated by users and merchants, including account login information, browsing trajectories transaction data, payment information, and various operational activities on the platform. We also examine historical data and compare it against real-time data to help detect suspicious behavior.

CrazyBee may limit your access to its services, or require that you undertake a particular action such as verifying your identity before allowing such access.

You may contact us by email at General_Counsel@ReFlip.life if you have questions or concerns regarding these processes.

Targeting (Audience)

Using our Visits, along with inferences about your interests, location and other demographics that we derive from the data we have about you, we create “Audiences.” Audiences may be used to send you advertisements tailored to your inferred interests.

Attribution

We also help brands measure the effectiveness of their advertisement campaigns by attributing purchases or other actions, such as a store visit, to their ads by matching ad impressions to such actions. As part of Attribution, we may also associate devices that we believe are related to each other.

Aggregated Products and Services

We may also use your data in an aggregated manner to power products and services that offer movement- and location-based insights and trends. In addition, your data may be used to power geospatial data analytics platforms that enable visualization of aggregated data.

4. Cookies and Tracking Technologies

We use cookies and similar technologies (such as web beacons) to optimize website functionality, enhance user experience, and provide personalized services. Cookies are small text files stored on your browser or device. Cookies allow us to recognize your preferences in order to record your preferences and website usage information.

We may use the following types of cookies under this Policy:

• Strictly necessary cookies, to ensure our pages or services function properly, such as authenticating logins and maintaining account security. If you wish to continue accessing our pages or services, it will not be possible to refuse these types of cookies.
• Analytics cookies, to help us understand how users interact with the website (e.g., visit frequency and browsed pages) in order to improve content and services.
• Functionality cookies, to store your previously set preferences, such as your language preferences, in order to enhance your browsing experience.
• Marketing cookies, to allow us to display advertisements that are more relevant to your interests, avoid showing you the same ads repeatedly, and optimize the delivery of our promotional content.

Cookie expiration periods: Some cookies (e.g., session cookies) are automatically deleted when you close your browser; others (e.g., persistent cookies) may remain on your device for a longer period until manually deleted.

How to manage cookies: You can refuse or remove non-essential cookies through your browser settings. For guidance on configuring cookie usage in your browser, please refer to the official instructions of common browsers:

• Firefox
• Google Chrome
• Safari
• Microsoft Edge

It is important to clarify that we are not responsible for the use of cookies by third parties. Cookies placed by third parties may continue to track your online activities, so we recommend regularly managing the cookies installed in your browser.

5. How We Use Personal Information

To the extent permitted by applicable law, we use personal information:

• To provide and personalize our Services, such as processing or fulfilling orders and transactions, providing our Services, processing payments, providing customer service, maintaining or servicing accounts, providing financing, verifying customer information, creating and maintaining business records, verifying eligibility, and undertaking or providing similar services.
• For internal research and development, such as testing and verifying the quality of our Services, improving the quality of our Services, and creating new Services.
• For marketing, such as sending information about our Services, including using your information to send you messages, notices, newsletters, surveys, promotions, or news about events.
• For communicating with you, such as responding to your questions and comments.
• For legal, security, or safety reasons, such as protecting our and our users’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
• As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business’ assets, or another corporate transaction, including bankruptcy.
• Affiliates and Subsidiaries – we may share your information with our affiliates or subsidiaries for purposes such as service optimization, internal operations, and ensuring consistent user experience across our platforms.
• In actual or anticipated specific scenarios, data will be used by us for specific business purposes, such as business analysis or data migration.

6. How We Disclose Your Personal Information

We may share your personal and business information in the following circumstances:

• Service Providers: We may share your information with third-party service providers who assist us in delivering and improving our services. For example, we may use tools such as Google Forms to collect business inquiries or customer feedback. These providers are obligated to protect your information and use it solely for the specified purposes.
• Affiliates and Subsidiaries: We may share your information with our affiliates or subsidiaries to optimize services, support internal operations, and ensure a consistent user experience across our platforms.
• Business Transactions: In the event of an actual or proposed merger, acquisition, asset sale, financing, corporate restructuring, or similar transaction, we may disclose or transfer your information. We will take steps to ensure your information continues to be handled in accordance with this Privacy Policy and applicable data protection laws.
• Legal and Regulatory Requirements: When we believe it is necessary or appropriate to comply with applicable laws, regulations, lawful government requests, judicial orders, legal processes, or commercial arrangements, we may disclose your information to law enforcement agencies, regulatory authorities, government entities, courts, or other third parties.

7. Marketing Email Communications

If you wish to stop receiving marketing emails from CrazyBee, you can click the “unsubscribe” button in the email to stop receiving marketing communications. You can also contact us at:

Email: General_Counsel@ReFlip.life

Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.

8. Security

We maintain technical and organizational measures, including, but not limited to, reasonably designed administrative, physical, and technical safeguards, designed to protect the personal information obtained as discussed in this Privacy Policy from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, and access. However, no system of safeguards can guarantee the security of your personal information.

We implement multiple layers of security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, including:

• Data Encryption, using industry-standard encryption technologies during data transmission and storage.
• Access Control, restricting access to personal data to authorized personnel only, with strict identity verification processes.
• Administrative Measures, providing regular privacy and security training to employees and contractors to ensure compliance with our privacy policies.
• Internal Audits, conducting periodic security assessments and compliance reviews to continuously improve our safeguards.

While we have established robust security systems, internet transmission and data storage cannot be entirely risk-free. If you suspect your personal information may have been compromised, please notify us immediately, and we will take appropriate steps to minimize any impact.

9. Retention

We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

To determine the appropriate retention period for your personal data, we will consider the amount, nature, and sensitivity of the personal data, the potential risk from unauthorized use or disclosure, the purposes for which we process personal data and whether we can achieve those purposes through other means, and applicable legal requirements.

When your information no longer meets the above retention conditions, we will securely delete or anonymize it to ensure it cannot be traced back to an individual.

10. Children’s Data

We fully understand the importance of protecting the privacy of children, especially in the online environment. The services provided by the CrazyBee platform are not designed for or intentionally directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16.

If we become aware that we have received personal information from an individual under the age of 16, we will take reasonable steps to remove the individual’s personal information from our records, so as to strictly safeguard the privacy rights and interests of minors.

11. Notice to California Residents

If you are a California resident, this section applies to our collection and use of personal information as required by the California Consumer Privacy Act of 2018 (“CCPA”).

CrazyBee makes the following disclosures regarding personal information collected in the 12 months preceding the effective date of this Privacy Policy:

• Sources of Personal Information – see “How We Collect Personal Information.”
• Use of Personal Information – see “How We Use Personal Information.”

Categories of Personal Information and Disclosure

The table below summarizes the categories of personal information and the categories of recipients (third parties) to whom we disclose, sell, or share personal information for business purposes. We do not intentionally collect, process, or share personal information of minors under 16 years of age.

* While we do not sell personal information for profit, we share personal information for other benefits that may be deemed a “sale” or “sharing” under various data protection laws, including activities such as serving interest-based advertising on our website or allowing third parties to receive certain information (e.g., cookies, IP addresses, and/or browsing behavior).

Use and Disclosure of Sensitive Personal Information

We only use or disclose sensitive Personal Information as necessary to provide the services, resist malicious, deceptive, fraudulent, or illegal actions directed at our business, ensure the physical safety of natural persons; and verify, maintain, and improve the quality of our services.

Other California Privacy Rights

Under California Civil Code Section 1798.83, California residents who have an existing business relationship with us may request information about whether we have disclosed certain categories of personal information to third parties for their direct marketing purposes (if any). To make such a request, please contact us using the information in the “Contact Us” section below.

Please note that not all information sharing is covered by California privacy rights requirements, and only information on covered sharing will be included in our response. Such requests may be made no more than once per calendar year.

12. Your Privacy Rights and How to Exercise Them

Depending on your place of residence and subject to certain exceptions, you may have the following rights regarding your personal information:

• Access — You have the right to know what personal information we have collected about you and to access that data.
• Data Portability — You have the right to receive a copy of your personal information in a portable and readily usable format.
• Deletion — You have the right to delete your personal information that we process.
• Correction — You have the right to correct inaccuracies in your personal information.
• Opt-Out of Certain Processing — You may have the right to: (a) opt out of the processing of your personal information for targeted advertising purposes; (b) opt out of the sale or sharing of your personal information; (c) limit the use of your sensitive personal information (if applicable); and (d) opt out of the processing of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Object/Restrict Processing — In certain circumstances, you have the right to object to or restrict our processing of your personal information.
• Withdraw Consent — Where we rely on your consent to process your personal information, you may have the right to withdraw your consent.
• Lodge a Complaint — If you believe we have infringed upon any of your rights under applicable data protection laws, you have the right to lodge a complaint with a supervisory authority or other regulatory body. We encourage you to contact us first so that we may have the opportunity to address your concerns directly before you lodge a complaint.
• Opt-Out of Sharing Your Personal Information — You have the right to opt out of the sale or sharing of your personal information by using the opt-out mechanisms we provide (for example, an opt-out link on our homepage where applicable).

If you withdraw your consent or object to the processing of your personal information, or if you choose not to provide certain personal information, we may not be able to provide you with some or all of our Services.

How to Exercise Your Rights

To exercise any of the privacy rights afforded to you under applicable data protection laws, please submit a request to us by one of the following methods:

• Email us at General_Counsel@ReFlip.life.
• Use any opt-out or preference links that may be available on our website.

You will not be discriminated against in any way for exercising the rights listed in this Privacy Policy, meaning we will not deny you goods or Services, charge you different prices or rates for goods or Services, or provide you with a different level or quality of goods or Services.

Only you or an authorized agent authorized to act on your behalf may make a request related to your personal information. You may also make a request on behalf of your minor child.

Before fulfilling your request, we must verify your identity. If we cannot verify your identity, we may request additional information from you. If you are an authorized agent making a request on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or a power of attorney.

We will endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you in writing of the reason and extension period.

We do not charge a fee to process or respond to your request unless it is excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you have the right to appeal that decision, we will inform you of our appeal process when we respond to your request.

13. Updates to the Privacy Policy

We may update this Privacy Policy at any time and amendments will be effective when posted. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective.

You should therefore periodically visit this page to review the current Privacy Policy, so that you are aware of any such revisions.

14. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, you may contact us at:

ReFlip, LLC
ATTN: Compliance and Policy Department
Email: General_Counsel@ReFlip.life
Address: 440 N Wolfe Rd, Sunnyvale, CA 94085