Revolve Group Personnel and Applicant Privacy Policy
Last Updated: January 27, 2023
This Privacy Policy describes how Revolve Group, Inc. and its subsidiaries and affiliates including Eminent, Inc., FWRD, LLC., and Alliance Apparel Group, Inc. (collectively, “Revolve” or “we”) handle personal information we collect about employees and independent contractors who currently work or previously have worked for Revolve, as well as individuals who have applied, or are being evaluated, for positions with Revolve. This Policy explains the types of personal information we collect, how we may use and disclose the information, and how to contact us with questions.
Information We Collect
We collect information you provide directly to us as well as information about you that we generate internally or obtain from third parties.
The types of personal information we may collect include:
- Internet or electronic network activity information in connection with your use of our websites and online services, including pages you visited, completed job applications and other usage information;
- Identifiers and contact information, such as your name, email address, mailing address, device identifiers, and phone number and similar information regarding your dependents or references;
- Visual information, such as photographs or video obtained through CCTV cameras during on-site visits;
- Professional and education information, such as your resume, education history, and employment application; and
- Racial or ethnic origin, requested on a voluntarily basis only for us to comply with legal obligations and internal policies relating to diversity and anti-discrimination;
- Demographic information, such as age information from your date of birth and gender; and
- Other information used to perform appropriate background checks (such as criminal record information).
In addition, if you become an employee or independent contractor of Revolve, we may also collect:
- Payroll information, such as your banking and direct deposit forms, salary and sales commission information, tax forms, expense reports, and leave and PTO records;
- Government identification information, such as your social security number, driver’s license and passport information, and visas and work authorizations;
- Performance information, such as performance reviews, disciplinary reports, employee ID number, and start and end dates of your employment;
- Benefits information, such as your benefits elections, beneficiaries, spousal or partner information, and dependent information;
- Medical information, including disability information, medical accommodations and leaves taken for medical reasons;
- Information about your designated emergency contacts;
- Inferences drawn related to job performance, including abilities and aptitudes;
- Internet or electronic network activity information in connection with your use of company technology and resources, including email, instant messaging, file share and employee collaboration platforms;
- Biometric information, such as a scan of your finger to identify you on our biometric timekeeping devices; and
- Other information that supports our human resources or our business operations, including information about your participation in voluntary testing or screening and information received in the course of investigations or complaints.
How We Use Your Information
We use the information we collect to support Revolve’s human resources and other business purposes as follows:
- As necessary for compliance with a legal obligation, such as complying with applicable laws and regulations (e.g., minimum wage, working time, tax, health and safety, antidiscrimination laws, global migration and, processing a data subject request under applicable privacy laws), and investigating potential non-compliance with or violations of laws and regulations;
- As necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, such as to arrange for payment to personnel that have contracts with Revolve;
- As necessary in order to protect the vital interests of the personnel or of another natural person, such as an emergency where the health or security of personnel is in danger, or to prevent imminent physical harm or financial loss;
- In limited circumstances, if we ask for your consent and you provide it; and
- For the following legitimate interests:
- Recruitment, such as evaluating applications for employment, conducting interviews and background checks, and deciding terms of employment offers;
- Personnel management, such as monitoring assignments, evaluating performance, training employees, communicating with you, and responding to your requests and inquiries;
- Operational purposes, such as operating and improving our recruitment site and services, distributing payroll and company benefits, updating personnel files, conducting audits, and providing IT support;
- Protecting the health and security of our employees, customers, personal information, intellectual property and other business assets;
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will let you know whether the provision of your personal information is mandatory and the possible consequences of your refusal to provide it.
How We Disclose Your Information
We disclose your personal information in the limited circumstances described below:
- With Revolve personnel and affiliates to carry out human resources and other business operations;
- With vendors and service providers that perform services for us or for you (e.g., insurance and other benefits providers and technology providers);
- With legal or regulatory authorities to comply with our obligations, to protect the rights and property of Revolve, our customers, and the public, and to detect and respond to suspected illegal activity or threats to the safety of any person or of our systems or services;
- In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company; and
- With your consent or at your direction.
Your Privacy Rights:
If you are in California or the UK, you have the following rights with respect to the personal information we process about you:
- Request a copy of the personal information Revolve holds about you (including as necessary to support your right of data portability),
- Request to know information about the categories of personal information we process about you,
- Request that Revolve correct your data,
- Request that your data be deleted,
- Withdraw consent for any processing where we have requested your consent, and
- If you are in the UK only:
- Request that our data processing be restricted, and
- Object to the processing of your personal information.
- Right to Opt Out of “Sales” or “Sharing” of Personal Information. Please note however that Revolve does not “sell” or “share” (as those terms are defined by the CCPA) your personal information.
- Right to Limit Use of Sensitive Personal Information. However, Revolve does not use or disclose sensitive personal information for any purpose other than as permitted by the law without right to limit.
To exercise your privacy rights, please call our toll-free number at 1-877-284-5652 or contact us at hr@revolve.com. We will verify your request by asking you to provide information we collect during your application or onboarding. You may 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 using the same channels mentioned above.
We will not discriminate against you for exercising any privacy rights afforded to you under law. If you are in the UK and have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO)data protection authority where you reside. Please refer to their website for details: ico.org.uk.
Transfers of Personal information Outside the UK
Revolve processes information in the United States and other countries. Accordingly, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. Revolve generally transfers information to service providers in the United States, although in some cases those service providers may transfer information to their own service providers, or we may transfer information directly to our service providers, including in other countries. We have implemented safeguards designed to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it. Data transferred from the UK to Revolve entities in the United States will be processed pursuant to appropriate safeguards, including the approved Standard Contractual Clauses to ensure an adequate level of protection. Copies of the Standard Contractual Clauses we use to facilitate the transfer of data outside the UK are available upon request.
Additional Disclosure for Individuals in California
The California Consumer Privacy Act or “CCPA”, as amended by the California Privacy Rights Act, affords individuals residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you. In the preceding 12 months, we have collected the following categories of personal information and used and disclosed them to the following categories of recipients:
Categories of Personal Information
Categories of Recipients with whom Information may be Disclosed
- Identifiers, such as device identifiers or name, address, phone number, email address, or other contact information
- Professional or employment-related information, such as your resume or CV, work history, certifications, professional licenses, and contact details of your former/current employer
- Education information, such as your degrees, training, transcripts, and academic achievements
- Inferences to create a profile that may reflect your employment preferences, characteristics, behavior, intelligence, abilities, and aptitudes
- Sensitive personal information, which may include government-issued identification numbers, racial or ethnic origin, contents of communications and personal information collected and analyzed concerning your health (e.g., information about disability status) or sexual orientation.
- Vendors, consultants and service providers, including data analytics service providers, background check service providers, and recruitment agencies, in connection with the services they perform for us or on our behalf;
- Third parties when compelled by law, such as law enforcement or other governmental authorities;
- Third parties in connection with, or during the negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; and
- Third parties for purposes of protecting Revolve, including to establish, exercise, or defend against potential, threatened or actual legal claims; enforcing any contract with you or if we believe that your actions are inconsistent with our policies, and responding to any claims, protecting our rights or the rights of a third party, protecting the safety of any person or preventing any illegal activity.
In addition to the rights mentioned in the Your Privacy Rights section above, California residents also have the following rights:
Data Retention
The length of time we retain your personal information depends on the status of our relationship with you and the requirements of applicable law. To determine that period, 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 information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes, and/or enforce our agreements. In no event will we retain your personal information for longer than reasonably necessary to accomplish the purposes described in this policy.
Changes to this Privacy Policy
We may change this privacy policy from time to time. If we make changes, we will revise the date at the top of this policy.
Contacting Revolve
If you have questions or concerns, please contact us using the information provided below.
Revolve Group, Inc.
12889 Moore St.
Cerritos, CA 90703
privacy@revolve.comIf you are in the UK, your primary data controller is the below Revolve entity in the UK:
RVLV UK Limited
Curo House
GREENBOX, Office
17-25 Westonhall Rd.
Stoke Prior
Bromsgrove B60 4AL
United Kingdom
privacy@revolve.com