Privacy Policy

Last updated May 20, 2025

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This Privacy Notice describes how Caroo collects, uses, shares, and otherwise processes personal information. Caroo supports companies to facilitate employee gifting through our website,  https://caroo.com (“Website”), and associated digital platform, https://app.caroo.com (“Digital Platform”),  which enables companies and individuals to administer and manage mass gifting, and associated recipient preference information.

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This Privacy Notice is addressed to brands, and their employees and representatives, whose products are posted and sold on our Website and Digital Platform (“Brands”), employer customers and their representatives and others that utilize our Website and Digital Platform to facilitate purchase and gifting (“Employers”, “Purchasers”, and/or “Senders”), and employees and other gift recipients whose personal data is provided to our Digital Platform (“Employees”, “Clients”, “Contacts”, and/or “Recipients”). This Privacy Notice is also addressed to visitors (“Visitors”) to our Website.

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For individuals who interact with us online, we collect information you choose to give us and other information that may be collected from your use of our Website and through our Digital Platform, including from your device(s). We use that information to operate our business and for purposes set forth below. Below, we also describe choices we offer with respect to your information.

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This Privacy Notice does not apply to information that cannot be identified to any individual, household, or their devices, such as de-identified or anonymized information. This Privacy Notice does not apply to personal information that is not processed by Caroo, including information which may be processed by Brands or Employers. If you have questions about how Brands or Employers collect and process your personal information, please contact them directly and/or see their privacy notice(s).

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Table of Contents

  1. Definitions
  2. Information We Collect
  3. Automatic Information Collection, Logging, and Tracking
  4. Other Ways We Use Information We Collect
  5. How We Secure Information
  6. How We Share Information
  7. What Choices Do I Have?
  8. Updates to Our Privacy Notice
  9. Contact Information

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Definitions

  • Brands: Companies and their employees or representatives whose products are listed, posted, and sold through the Caroo Website and Digital Platform.
  • Cookies: Small data files stored on your device when you access our service. Cookies may persist for varying lengths of time and can be managed or deleted through your browser settings.
  • Device Fingerprinting: The combination of data from your device, such as browser settings, installed fonts, and other identifiers, to create a unique identifier that helps recognize your device.
  • Digital Platform: The Caroo digital platform, located at https://app.caroo.com, which allows users to manage gifting processes and recipient preferences for companies and individuals.
  • Embedded Scripts: Temporary pieces of code that track your interactions with the service while you are connected. These scripts are deactivated once you disconnect.
  • Employees (also referred to as Clients, Contacts, or Recipients): Individuals who receive gifts through the Caroo Digital Platform, often with personal data provided for managing recipient preferences.
  • Employers (also referred to as Purchasers or Senders): Employer customers, their representatives, or other users who utilize the Caroo Website and Digital Platform to facilitate the purchase and gifting of products and collecting and storing recipient preference information.
  • Location-identifying Technologies: Technologies like GPS and geo-filtering that determine your location to deliver relevant content or restrict access based on location.
  • Transactional Emails: Automated emails sent to users that contain information related to their account or transactions, such as order confirmations, shipping notifications, account updates, or password resets. These emails are intended to facilitate user interactions and provide essential information about their activity on the platform.
  • Usage Data: Information automatically collected about your interactions with the Caroo Website or Digital Platform, such as your IP address, device type, browser, language, pages viewed, clicks, session time, and email activity.​
  • Visitors: Individuals who visit or interact with the Caroo Website without engaging in purchasing or gifting activities or creating a user account.
  • Web Beacons (Tracking Pixels): Small graphic images embedded in web pages or emails, used to count visitors and track navigation and content views.
  • Website: The Caroo website, located at https://caroo.com, provides information about our team, policies, features, pricing, and other important updates for visitors, existing and prospective customers, partners, and other stakeholders.

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Information We Collect

We collect personal information about individuals from a variety of sources, including:

  • Directly from Employers, Employees, Brands, and Visitors when provided to us, for instance when contacting us via the Website, signing up for an account on the Digital Platform, “liking” or purchasing products on the Digital Platform, or responding to our inquiries or a survey.
  • Automatically as you utilize the Website or Digital Platform. We may receive information in connection with content, widgets, cookies, components, or other tools deployed on our Website and Digital Platform. Such information may be from your browser or device or from third parties (see Automatic Information Collection).
  • From third parties.  We may collect information from advertisers, marketing service providers, analytics services, affiliates, promotional partners, and application providers. We may collect and process personal data, including collection from third parties, as detailed in the chart below:

Category of individual

Personal Information Collected

Key Information Uses

Employers

  • Name
  • Address
  • Email address
  • Phone number
  • Official titles and job duties
  • Payment information such as bank account and/or credit card number
  • Browsing and purchase history
  • Communications content (such as messages) sent to us as a part of the business relationship
  • Other data communicated to us through the Digital Platform or through submitted questions or surveys
  • Usage Data
  • Provide our Digital Platform and facilitate gifting.
  • Fulfill and track orders.Provide functionality in support of gift selection, customer service, mass gifting, and related messaging.
  • Manage the business relationship.
  • Facilitate, record, and store communications.
  • For marketing and advertising such as to provide information about new or related services we may offer.
  • To collect analytics about the use of the Digital Platform.
  • For other general purposes noted below (e.g., to maintain records, enforce legal terms or comply with law) (see Other Ways We Use Information We Collect).

Employees

  • Name
  • Address
  • Email address
  • Phone number
  • Official titles and job duties
  • Communications content (such as messages) sent to us as a part of the business relationship
  • Browsing data and “liked” productsOther data communicated to us through the Digital Platform or through submitted questions or surveys
  • Usage Data
  • Provide our Digital Platform including posting products for purchase, and to facilitate gifting.
  • Facilitate shipping and delivery.
  • Manage the business relationship.
  • Facilitate, record, and store communications.
  • For marketing and advertising such as to provide information about new or related services we may offer.
  • For other general purposes noted below (e.g., to maintain records, enforce legal terms or comply with law) (see Other Ways We Use Information We Collect).

Brands

  • Name
  • Email address
  • Phone number
  • Official titles and job duties
  • Communications content (such as messages) sent to us as a part of the business relationship
  • Other data communicated to us
  • Usage Data
  • Provide our Digital Platform including posting products for purchase, and to facilitate gifting.
  • Facilitate shipping and delivery.
  • Manage the business relationship.
  • Facilitate, record, and store communications.
  • For marketing and advertising such as to provide information about new or related services we may offer.
  • For other general purposes noted below (e.g., to maintain records, enforce legal terms or comply with law) (see Other Ways We Use Information We Collect).

Visitors

  • Data communicated to us while using the Website.
  • Information provided in response to a form or survey.
  • Usage Data
  • Provide Website functionality.
  • Develop analytics to understand our Website audiences, develop business strategies and marketing plans.
  • Provide information about new or related services we may offer.
  • For other general purposes noted below (e.g., to maintain records, enforce legal terms or comply with law) (see Other Ways We Use Information We Collect).

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Automatic Information Collection, Logging and Tracking

If you are a Website Visitor or a Brand, Employer, or Employee interacting with our Website and/or Digital Platform, your browser or device may be subject to our collection of logging and other automatically collected information. This includes the use of third-party analytics and tracking tools to improve your user experience, troubleshoot issues, ensure security, prevent fraud, and optimize functionality. These services may use cookies, scripts, web beacons, embedded scripts, and other tracking technologies.

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The information we automatically collect may include browsing and session information such as IP address, browser type, date and time of access, pages and content viewed, session duration, errors encountered, websites linked to or from, interaction with emails (such as whether they were opened and the links clicked), clicks, scrolls, and other user interactions. We may also collect device details like language preferences, device type, and operating system, including unique device identifiers (collectively, “Usage Data”).

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Please note that third parties may collect personal information about your online activities over time and across third-party websites and online services. These third parties may provide us information in connection with content, widgets, components, cookies, or other tools offered on our Website or Digital Platform. They may use this information to provide you with interest-based advertising or other targeted content, and for other purposes. We may not control personal information once collected by these parties.

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We do not respond to “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an individual consumer’s online activities over time and across third-party websites or online services.

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Let it also be known that Caroo’s Website and Digital Platform use third party services owned and/or operated by Google, including the Google Maps API(s), and therefore by using Caroo you agree to be bound by Google’s Terms of Service.

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In all cases, we may collect and use other information you choose to provide or with your consent.

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Other Ways We Use Information We Collect

In addition to the uses described above, we may use the information we collect in order to:

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  • Enable purchases, fulfillment, and tracking of orders, including gifts.
  • Maintain, analyze, customize and improve your experience on our Website and Digital Platform.
  • Troubleshoot issues, ensure security, and optimize the functionality and performance of our Website and Digital Platform.
  • Support business development, research, marketing and promotional purposes, press inquiries, or aggregate statistical analysis and site customization.
  • Communicate with Brands, Employers, Employees, and Visitors about our products and services, including customer service, technical notices, security alerts, and support and administrative messages.
  • Provide Digital Platform and Website support, including notices about accounts and changes to our service.
  • Send promotional and marketing materials, support contests and other promotions, notify you about incentives and rewards.
  • Provide you information that you request from us or otherwise respond to your communications and questions.
  • Monitor and enforce our contracts, legal terms, acceptable use or other policies or similar terms.
  • Comply with law and satisfy our regulatory and compliance obligations. Additionally, we may use information we collect to support compliance efforts on behalf of others and ourselves.
  • Provide a personalized experience. Automatically collected and device information may also be used to help us estimate our audience size, usage patterns, and analyze trends and administer our Website and Digital
  • Platform, and used for research and marketing purposes.
  • Help detect and prevent fraudulent use of our Website and Digital Platform and other prohibited, illicit or illegal activity.
  • Monitor information security, manage and protect our technical infrastructure (such as servers and networks), and to protect the rights and interests of you, others, and ourselves.
  • Address existing or anticipated disputes and to protect our legal interests.
  • Otherwise operate our business, including support for transactions impacting our company as a whole (such as mergers, acquisitions, reorganizations, underwriting or asset purchases).
  • Fulfill any other purpose for which you provide your information to us and for other purposes disclosed to you in connection with our services.
  • Other purposes permitted by law or to which you consent.

We may also retain and use your information in an anonymized or de-identified format where your identity is not recognizable. Such information is not subject to the same usage restrictions as personal information. We may use de-identified information to improve our products and services, conduct research, or for our other business purposes.

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As permitted by law, we may combine the information we gather about you in identifiable form, including information from third parties. We may use this information, for example, to improve and personalize our services, content and advertising.

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How We Secure Information

We are committed to maintaining measures to protect the security of your personal information maintained in our systems. However, no network or system is ever entirely secure, and we cannot guarantee the security of networks and systems that we operate or that are operated on our behalf. If we face a security breach, we may notify you as required by law via email or conspicuous posting on our Website or Digital Platform.

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The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our services, you are responsible for keeping this password confidential. You should not share your password with anyone.

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How We Share Information

We may share your personal information with third parties as reasonable to operate our business (including for the purposes described above), to provide the Website and Digital Platform to you and others, as permitted or required by law, or as directed or authorized by you. For example:

  • Brands. We may share Employer and Employee personal information we collect with Brands in order to facilitate and provide our Website and Digital Platform, including to facilitate gifting, fulfillment, delivery, related communications, and support for transactions on our Website and Digital Platform
  • Affiliated Organizations.  We may share some or all of your information with our parent organizations, subsidiaries, affiliates, joint ventures, or other organizations or entities under common control with us.
  • Third Party Sharing. We work with third parties to help us provide our Website and Digital Platform and to support internal operations. In some cases, they may use your information subject to their own privacy policies and to comply with their own legal and regulatory obligations. We work with different types of third parties, presently including:
    • Data hosting, storage and cloud service providers;
    • Call center providers;
    • Shippers;
    • Companies that support warehousing and order fulfillment;
    • Payment processors;
    • Platform and/or application security service providers;
    • Technical and customer support providers;
    • Marketing and analytics providers; and
    • Other third parties.
  • Professional Advisors, Law Enforcement and Regulators. We share information with our professional advisors who provide legal, compliance, auditing, accounting, banking, consulting, or other professional services, and with regulators, law enforcement, or government agencies, including to:
    • Comply with our legal and regulatory obligations, including those compliance obligations of federal, state or local regulators;  
    • Protect our interests, property or legal rights, or those of our customers or third parties;
    • Respond to a subpoena, court order, or similar law enforcement request, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of this Privacy Notice or other applicable terms; and
    • For other legal purposes, such as to enforce our terms and conditions, or to exercise or defend legal claims.
  • Transaction Impacting the Organization as a Whole. In the event of a transaction or reorganization impacting us as an entity or organization, we may share your personal information. We may share your information in connection with, or during the diligence or negotiation of, any merger, sale of company stock or assets, financing, acquisition, restructuring, divestiture or dissolution of all or a portion of our business, or other similar event.
  • Other Disclosures. In addition to the above disclosures, we may disclose personal information in the event that we believe such disclosure is (i) necessary to provide our products and services or operate our business; (ii) in accordance with purposes we describe when you share it with us; (iii) permitted by law; or (iv) with your consent or at your direction. We may disclose aggregated or de-identified information that does not identify any individual without restriction.

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What Choices Do I Have?

  • Update personal information. If you are a Brand, Employer, or Employee with whom we have an ongoing business relationship, you may request changes to information we maintain concerning you by emailing us at care@caroo.com or by completing our Personal Information Removal Request form. As permitted by law, we may deny a request to change information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, or prevent the provision of our products or services.  
  • Marketing communications. You may receive marketing communications from Caroo, including if you sign up for marketing or other communications. You may opt out of receiving marketing emails by following the unsubscribe link in each email, or by contacting us at care@caroo.com. Please note that you may continue to receive non-marketing emails, including “Transactional Emails”, from us after you opt out. Please note that we do not control communications from others, including Brands. If you have received marketing communications from third parties, you should contact them directly to understand communication choices they may provide you.
  • Cookies. You have choices regarding certain cookies. Most web browsers automatically accept cookies, but you may modify your browser’s setting to notify you of cookie placement or decline cookies. If you choose to decline cookies, certain features of our Website or Digital Platform may not function properly or at all as a result.

Caroo is not responsible for any practices employed by websites linked to or from our Website or Digital Platform, nor their information or content. Please remember that when you use a link to go from our Website or Digital Platform to another website, this Privacy Notice is no longer in effect.

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Updates to Our Privacy Notice

We may update this Privacy Notice from time to time in order to provide clarification or notice of changes to our practices. If we make changes, we will revise the Effective Date at the top of this Privacy Notice. Changes to this Privacy Notice will be effective once they are posted unless otherwise indicated. We may choose to notify you by email to the email address in our records.  We encourage you to periodically review our Privacy Notice to be sure you are familiar with the most current version.

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Contact Information

If you have any questions or concerns about this Privacy Notice or the privacy practices at Caroo, please contact us at care@caroo.com.