Privacy Policy

Effective Date: February 26, 2025

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This Privacy Policy describes how Whaleco Inc., a Delaware company ("Temu", "we", "us" or "our") handles personal information that we collect through our digital properties that link to this Privacy Policy, including our website (www.temu.com) and mobile application (collectively, the "Service") and other activities as described in this Privacy Policy. At Temu, we care deeply about privacy. We strive to be transparent about our privacy practices, including how we treat your personal information. This Privacy Policy explains how we collect, use, share, and otherwise process the personal information of users in connection with our Service. If you are a resident of a U.S. state that has enacted comprehensive privacy legislation, please see our Privacy Policy Addendum for U.S. Residents for additional information.

What Information Do We Collect

In the course of providing and improving our Service, we collect your personal information for the purposes described in this Privacy Policy. The following are the types of personal information that we collect:

Information that you provide

When you create an account, place an order at checkout, contact us directly, or otherwise use the Service, you may provide some or all of the following information:

Account and profile

We collect your mobile phone number or email address as the login credentials for your account and assign a user identification number to your account. If you choose to register or log in via external third-party services, such as Facebook or Google, you agree we may collect your profile photo, username, and email address associated with the relevant third-party service provider. We may also collect information in your profile, account settings and preferences.

Purchases

We collect data related to your orders on the Service (e.g., transaction ID, transaction history), payment information required to complete the transaction (e.g., payment card number or other third-party payment information required for payment, billing address), information provided by you for product sizing purposes, your shipping address (e.g., city, state, country of residence, postal code), and recipient contact information (e.g., name, mobile phone number). We also collect your region on a country/region basis.

Customer support activity

When you communicate with our customer service team through our customer support functions in the app/on the website, either with a customer service agent or with our virtual assistant (via the chatbot or hotline), through social media, or any other means, we will collect your communication history with us which includes any text, images, video, audio, or supporting documents exchanged between us.

Information when you contact us

When you contact us, we collect the information you send us, such as reports, feedback, or inquiries about your use of the Service or information about possible violations of our Terms of Use or other policies.

Chats with merchandise partners

When you chat with merchandise partners on Temu, we collect your chat communications and other related user data.

User-generated content

When you provide product reviews and ratings on the Service, we collect this information, including any accompanying images, videos, or text, as well as associated metadata.

Promotion and event participation

We collect certain information when you participate in a contest, event, promotion, survey, giveaway or sweepstake, as part of the participation process, such as your desired prize selection. Such sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstake and contest that you enter. In addition, we collect information about your preferences for receiving marketing communications from us, as well as your interactions with them.

Other information not explicitly listed here

We will collect other information that you provide for purposes as described in this Privacy Policy or for any other purpose disclosed to you at the time we collect your information.

Information from third-party sources

To the extent permitted by applicable law, we may collect your personal information from other third-party sources, such as:

Data providers

We receive and collect your personal information, such as identity verification information and fraud prevention risk-scoring, from information services to help us detect fraud regarding payments, prevent unauthorized transactions, and safeguard the Service.

Marketing and advertising partners

We receive and collect your personal information from our marketing and advertising partners, such as business partners with whom we collaborate on marketing events and promotion of the Service. Specifically, we receive from these partners information including, for example, the specific advertisements you clicked on, attribution information via cookies and similar technologies to help us determine the origin of traffic to our Service, device data if you clicked on certain advertisements, responses to marketing emails, advertisements and offers, and audience information from marketing partners where they have the authority to share that information with us.

U.S. public authorities, public sources, and rights holders

We obtain your personal information which may include username, address, email, mobile phone number, purchase and/or payment information from third party sources, for example, as necessary to comply with our obligations, prevent, investigate and detect an alleged claim or crime, or for a party to assert their legal rights.

Our payment processors

We obtain your personal information from our third-party payment processors who help us process transactions, provide our Service, and prevent fraudulent or illegal activity. The personal information our payment processors pass to us includes your name, email address, billing address, and phone number.

Merchandise partners and their business partners

We collect publicly available information about you from our merchandise partners and/or their business partners, such as information about your purchases, use of products, ratings and reviews.

Other third-party services

We collect your personal information from other third-party services, such as:

  • Social media services, from whom we may collect your username, profile picture, and email address associated with the relevant third-party service provider, if you choose to register or log in via said third-party service.

  • Logistics service providers. To effectively complete order fulfillment, we will obtain your logistics information from logistics providers, such as delivery progress and delivery address, and make this information available to you within your account.

Information collected automatically

To enhance your experience with the Services and support the other purposes for which we collect personal information as outlined in this Privacy Policy, we may automatically collect information about you, your computer, or mobile device and your interactions with the Service and our communications over time, such as:

Device data

We collect personal information about the device you use to access the Service, such as device model, operating system information, language settings, unique identifiers (including identifiers used for advertising purposes).

Service usage information

We collect personal information about your interactions with the Service, including the items in your shopping cart, the order pages you view, the duration on a page, the source from which you arrived at the page, your interactions with the page, your searched text and images, your browsing history, whether you opened our emails, and whether you clicked the links within our emails. We also collect service-related, diagnostic, and performance information, including crash reports and performance logs.

General location data

We collect your approximate location data based on your technical information (e.g., IP address).

Cookies and similar technologies

We collect information from cookies and similar technologies stored on your device. These cookies are either necessary and required to provide our Service (for example, the cookies we use to display products relevant to your language and location) or optional (for example, the cookies used to track and measure the advertisements shown to you). To learn how to disable certain cookies, please read our Cookie and Similar Technologies Policy.

Declining to provide information

We need to collect your personal information to provide certain services. If you do not provide the information we require to provide the Service, we cannot provide the Service. Other information is optional, but without it, the quality of your experience of the Service may be affected.

How and Why We Use Your Information

We use the personal information that we collect for various purposes, including to develop, improve, support, and provide the Service, allowing you to use its features while fulfilling and enforcing our Terms of Use. We may use your personal information for the following purposes:

Create and maintain your account

We use your personal information to create and maintain your account on the Service, and enable account security features (e.g., sending security codes via email or SMS).

Orders and delivery of products and services

We use your personal information to receive and process orders, deliver products and services, process payments, communicate with you regarding orders, products, services and promotional offers, and facilitate order disputes, refunds and/or returns of your orders.

Improve and optimize services and troubleshooting

We use your personal information to optimize features, analyze performance metrics, fix errors, and maintain and improve the Service and our business. As part of these activities, we may create aggregated or otherwise deidentified data based on the personal information we collect.

Deidentified information

We deidentify your personal information such that it cannot reasonably be used to infer information about you or otherwise be linked to you, and we may use such deidentified information for any purpose. To the extent we possess or process any deidentified information, we will maintain and use such information in deidentified form and not attempt to re-identify the information, except solely for the purpose of determining whether our deidentification process satisfies legal requirements.

Personalize your experience

We use your personal information to recommend features, products, and services that may be of interest to you. Personal information will also be used to determine your preferences and personalize your experience with the Service.

Communicate with you and provide customer support

We use your personal information to communicate with you (e.g., announcements, updates, security alerts, support, and administrative messages) and provide customer support for your requests, questions, and feedback.

Sweepstakes, contests, and other promotions and events

We use your user profile picture and account information to identify you in promotion activities and events, and facilitate your invitations to friends who you want to invite to join the Service.

Marketing

We and our service providers collect and use your personal information for marketing purposes. We may send you direct marketing communications. You may opt out of our marketing communications as described in the “Your Rights and Choices” section below.

Interest-based advertising

We, our service providers, and our third-party advertising partners may collect and use your personal information for interest-based advertising purposes. In providing interest-based advertising, we follow the Self-Regulatory Principles for Online Behavioral Advertising as set forth by the Digital Advertising Alliance (DAA), which is an advocacy organization for responsible digital marketing and consumer privacy. You can learn more about interest-based advertising and your opt-out choices here.

Fraud prevention and security

We use your personal information to prevent, detect, investigate, and respond to fraud, unauthorized access to or use of the Service, violations of the Terms of Use and other Temu policies, or other misconduct.

Compliance, legal obligations, and protection

We may use your personal information for compliance purposes and to comply with applicable U.S. laws, including lawful requests, and legal processes (e.g., responding to subpoenas or requests from U.S. government or regulatory authorities); to comply with legal requirements of government entities (e.g., U.S. Customs), which may release such information pursuant to rules and regulations governing the public disclosure of government data; to protect our, your, and other users' rights, privacy, safety, or property (including introducing and defending legal claims); to audit internal processes to ensure compliance with U.S. legal and contractual requirements and our internal policies; to enforce the terms and conditions that govern the Service; to prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activities, including cyberattacks and identity theft.

Legal claims based on your consent

In some cases, we may specifically ask for your consent to collect, use, or share your personal information, where required by U.S. law.

Cookies and similar technologies for technical operations, performance enhancement, advertising, analytics, etc.

For more information about cookies and how we use them, please read our Cookie and Similar Technologies Policy.

How and Why We Share Your Information

At Temu, we care deeply about privacy. While Temu shares your personal information for the purposes of targeted advertising, which may be considered a “sale” under applicable U.S. state privacy laws (as described further in the Privacy Policy Addendum for U.S. Residents), Temu does not “sell” personal information in the traditional sense. We may share your personal information with the following parties for the purposes outlined below:

Affiliates

As a global company, our Service is supported by other entities within our corporate group in addition to Whaleco Inc. We share some of your personal information with Temu subsidiaries and affiliates as necessary to provide certain functions of the Service, including for the purposes of order fulfilment. Such personal information includes shipping address, and contact information. These subsidiaries and affiliates either follow the same practices described in this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.

Service providers

We share your personal information with third parties who provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, order fulfillment and delivery, marketing, fraud detection, security, consumer research and website analytics). These third-party service providers only have access to personal information needed to perform their functions and services, and we generally require these service providers to use personal information only as necessary to perform their services or comply with applicable legal obligations.

Payment processors

We share your personal information with our payment processors to complete payments, process disputes, and/or process refunds.

Advertising and analytics partners

We may share your personal information with third-party advertising, marketing, and analytics companies for the interest-based advertising and analytics purposes described in our Cookie and Similar Technologies Policy. Certain of these disclosures to third parties are known as “sharing” or processing your personal information for targeted advertising, but “sharing” may be considered “selling” your personal information under applicable law. For additional information and to learn about your right to opt out of such practices, see the Your Rights and Choices section, the Privacy Policy Addendum for U.S. Residents, and the Cookie and Similar Technologies Policy.

Third parties designated by you

We may share your personal information with third parties where you have instructed us or provided your consent to do so. We may share the personal information required for the services you request with third parties designated by you. For example, where you choose to share a link to a Temu product listing via a third-party social media service. Please be aware that when you use third-party sites or services, their own terms and privacy policies will govern your use of those sites or services.

Business and marketing partners

We may share your personal information with third parties with whom we collaborate in order to offer or promote the Service. For example, depending on your communication preferences, we may share your personal information with third-party service providers with whom we have partnered in order to send you marketing SMS and email messages.

Professional advisors, U.S. authorities, institutions, and regulators

We may share your personal information with our professional advisors (e.g., lawyers, auditors, bankers and insurers), and U.S. authorities, such as law enforcement authorities in response to legal processes (e.g., responding to subpoenas or requests from U.S. law enforcement requests); and with other parties (including financial institutions) in order to enforce our agreements or policies, protect the rights, property and safety of Temu, users and others, and to detect, prevent and address actual or suspected fraud, violations of Temu's Terms of Use, other illegal activities, security issues or when it is required by law.

Business transferees

In the rare event of a business transaction such as a merger, acquisition, or reorganization, we may share some of your personal information with relevant parties (such as a buyer or successor) in order to facilitate such a transaction. If we intend to transfer information about you, we will inform you either by email or by posting a notice on the Temu app and on Temu.com.

Merchandise partners

We may share your personal information with the merchandise partners related to the product reviews you leave, the return or refund reasons you request a return or refund, and customization information for customized / personalized items. To fulfill your order, we may share with the merchandise partner your name, shipping address, contact information, communications with our customer support functions, and your order information. For example, to address a query or complaint, or when the merchandise partner connects directly with logistics service providers. The merchandise partner will not receive your payment information or device data.

Other users

Please note that, in using our Services, your personal information may be visible to other users. In accordance with your settings and preferences, we may display your profile photo and username to other users, including when you participate in a promotion or marketing program (including referring friends to our Service and accepting invitations from other users), or when you review or rate a product with 5-stars. To opt out of this profile photo and username sharing, please visit the “Notifications” menu and disable “Avatar and username sharing” and/or edit your reviews.

Your Rights and Choices

We provide you with the ability to exercise certain rights and choices regarding our collection, use and sharing of your personal information. In accordance with applicable law, your rights and choices may include:

Rights to access, delete and correct your personal information

You may have the right to access, delete or correct your personal information, in addition to other rights under applicable U.S. privacy laws. Please see the Privacy Policy Addendum for U.S. Residents for more information.

Opt-out from marketing communications

To manage your preferences or opt-out of marketing communications, you can take any of the following actions:

  • Email promotional offers: If you do not want to receive emails from us regarding special promotions or offers, you may follow the unsubscribe options at the bottom of each email to stop receiving such emails. You can also opt-out of receiving promotional messages via email in “Notifications” menu.

  • Mobile promotional offers: When you provide us with your mobile phone number for marketing purposes, we may send you certain marketing alerts via text message and standard data and messaging rates will apply. If you no longer wish to receive mobile marketing alerts from us, you can follow the instructions provided in these messages or reply "stop" to any alerts we send. Rest assured that you can continue to use Temu even if you stop authorizing Mobile promotional offers.

  • Push notifications: You may receive push notifications when you use the Temu mobile application. If you wish to adjust push notification settings, including turning them off, you may do so in your mobile device’s notification settings. You can also opt-out of receiving promotional messages via push notification in the “Notifications” menu.

Change settings for cookies and similar technologies

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies and similar technologies, including how to see what cookies and similar technologies have been set on your browser and how to manage and delete them, visit https://www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Links to third-party platforms

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. If you choose to connect to the Service through your social media account or another third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. However, please note that these links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. Moreover, we do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. Therefore, we encourage you to read the policies and terms of use/service of the other websites, mobile applications and online services you use. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Other choices

Please see the Privacy Policy Addendum for U.S. Residents and the Cookie and Similar Technologies Policy for additional rights and choices you may have, and how to exercise such rights and choices.

Children

The Service is neither intended for, nor aimed at, children. Temu does not sell products for purchase by children under 13 years of age. We may sell children's products for purchase by adults or teens under adult supervision. If you are between 13 and 17, you may use our Service only with the permission and under the direct supervision of a parent or guardian. You may request deletion of your account through our privacy options. If you would like to report a concern you may reach out to our Customer Service or email us at privacy@temu.com.

We do not knowingly collect personal information from users who are under the age of 13 through the Service. If we become aware that we have unintentionally collected personal information from a child under the age of 13 through the Service, we will delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information or that a child under the age of 18 may have provided us with personal information without the involvement of a parent or guardian, please contact us as specified in the “Contact Us” section of this Privacy Policy or through our online reporting form.

Data Security and Retention

The security of your personal information is important to us. We use technical and organizational measures to help protect your personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and/or destruction. We also follow the Payment Card Industry Data Security Standard (“PCI-DSS”) in handling your credit card information. However, security risk is inherent in all internet and information technologies.

We generally retain personal information to fulfill the purposes for which we collected it, as well as for the purposes of satisfying any U.S. legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable U.S. legal requirements. When we no longer require the personal information we have collected about you, we may delete it, anonymize it, or isolate it from further processing.

Data of Temu’s U.S. users will be stored by default in a cloud service provider in the U.S. As a global one-stop shopping destination, Temu may need to engage service providers in other countries and share your personal information with them for certain purposes, such as order fulfillment. We will ensure that all transfers of personal information comply with applicable U.S. legal requirements.

Privacy Policy Addendum for U.S. Residents

Residents of certain U.S, states may have additional privacy rights under applicable state privacy laws. U.S. users can learn more about which rights may be available to them, and how to exercise those rights, by reviewing our Privacy Policy Addendum for U.S. Residents.

Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy, posting it on the Service, or providing any notice required by applicable U.S. laws. Any modifications to this Privacy Policy will be effective from the time of posting the modified version (or as otherwise indicated at the time of posting). We recommend that you review the Privacy Policy each time you visit our Service to stay informed of our privacy practices.

Contact Us

If you have any questions or comments about our Privacy Policy or the terms mentioned, you may contact us at any time at the following addresses:

  • Temu's Data Protection Office - privacy@temu.com

  • Whaleco Inc., Suite 355, 31 St. James Avenue, Boston, Massachusetts 02116, USA

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