Privacy Policy

WRSTOPIA, Inc. ("WRSTOPIA," "we," "our," or "us") is a Delaware corporation, with its principal place of business at 10 W 46th st 6th floor, New York, New York. We operate a proprietary online marketplace platform (the "Platform") connecting watch service dealers, watchmakers, and service centers with consumers for watch repair, service, and appraisal ("Watch Services").

WRSTOPIA respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and share information when you use our website, Platform, and related services (collectively, the "Services").

By accessing or using the Services, you agree to the practices described in this Privacy Policy and you hereby consent to our collection, use, and sharing of your information as set forth herein. This Policy is incorporated into our Terms of Service, Consumer Service Contract, Dealer-to-Dealer Service Fulfillment Agreement, and Dealer Platform Agreement and should be read in conjunction with those documents.

1. Information We Collect

We collect information to operate our Services and ensure secure, transparent, and efficient luxury Watch Services.

a. Information You Provide Directly

When you create an account, submit a request, register as a dealer or watchmaker, or interact with our Services, we may collect:

• Name, email address, phone number, and mailing address
• Business information (for dealers, service centers, and watchmakers), including business name, address, tax identification number, and proof of credentials and insurance
• Watch details (brand, reference, model, serial number, condition, and service or appraisal needs)
• Payment information (processed securely by third-party providers — we do not store full card numbers)
• Communications sent through the Platform, including service descriptions, dispute submissions, and support requests
• Uploaded photos or documents related to services or appraisals
• Bank account information for dealers receiving disbursements (collected by our payment processor)
• Any other information you voluntarily provide

b. Automatically Collected Information

When you use our Services, we may automatically collect:

• IP address and general location derived from IP (not precise GPS)
• Device and browser information, including operating system and device identifiers
• Pages viewed and actions taken on the Platform
• Log files, usage data, and access timestamps
• Transaction data, including service requests, quotes accepted, payments made, and service history
• Cookies and similar tracking technologies (see Section 6)

c. Third-Party Information

We may receive information from:

• Payment processors (transaction confirmation and fraud detection)
• Shipping providers (delivery confirmation and tracking)
• Identity or verification services
• Public review platforms (e.g., Google Reviews, Trustpilot) when linked by dealers, service centers, and watchmakers through their account settings

2. How We Use Your Information

We use your information to:

• Create and manage accounts
• Facilitate service requests, appraisals, and dealer matching
• Enable secure payments and Stripe Connect-backed transactions
• Coordinate shipping, insured delivery, or drop-off logistics
• Provide service status updates and notifications
• Maintain the Digital Service Passport for each watch (see Section 5)
• Verify dealers, watchmakers, and service centers
• Detect, investigate, and prevent fraud, abuse, and security incidents
• Improve Platform performance and user experience
• Communicate important updates, confirmations, and support messages
• Send marketing and promotional communications only where you have opted in or where permitted by applicable law (see Section 10 for opt-out options)
• Comply with legal obligations, including tax reporting and anti-money laundering requirements
• Enforce our Terms, contracts, and policies

We process your data based on the following legal bases: performance of a contract with you; compliance with legal obligations; our legitimate business interests (fraud prevention, Platform improvement, security); and your consent where required by applicable law.

By using the Services, you consent to our use of your information for these purposes.

3. How Information Is Shared

We do not sell your personal information.

We may share information only as necessary with:

• Verified dealers, watchmakers, or service centers involved in your service request or appraisal — only the information necessary to perform the service (such as watch details, shipping address, and service notes) is shared
• Payment processors to complete and secure transactions
• Shipping providers for insured delivery or drop-off coordination
• Technology providers that support our Platform operations (cloud hosting, analytics, email delivery, customer support tools) — all contractually required to handle your information securely and only as directed by WRSTOPIA
• Legal or regulatory authorities if required by applicable law, court order, or governmental request
• Any successor entity in connection with a merger, acquisition, reorganization, or sale of assets (see Section 3a below)

We may also share aggregated, de-identified, or anonymized data that cannot reasonably identify you with third parties for research, analytics, or business purposes.

a. Business Transfers

If WRSTOPIA is involved in a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change via the Platform or email prior to your information becoming subject to a different privacy policy.

b. Dealer Data Processing Obligations

When consumer personal data is shared with dealers, watchmakers, or service centers to fulfill a service request, those parties receive it as authorized service providers acting for the limited purpose of completing the service. Under our Dealer Platform Agreement, all dealers are contractually required to: (a) use consumer personal data only for the purpose of fulfilling the assigned service; (b) protect the data with reasonable security measures; (c) not use consumer data for independent marketing or any purpose unrelated to the service without the consumer's separate consent; and (d) comply with all applicable data protection and privacy laws. Dealers are prohibited from retaining or using consumer personal data after the service is completed except as required by law.

4. Payment Information

WRSTOPIA does not store full payment card details. All payments are processed through secure, PCI-compliant third-party payment providers. Bank account information collected for dealer disbursements is held by our payment processor and is subject to their security standards. We receive only transaction confirmation data necessary to operate the Platform.

5. Digital Service Passport

The Digital Service Passport is WRSTOPIA's digital service record associated with each watch serviced or appraised through the Platform. It contains service history, parts information, technician records, appraisal data, and service dates.

Digital Service Passport records are owned by WRSTOPIA and stored on the Platform. By using the Platform for Watch Services, you consent to the creation and maintenance of a Digital Service Passport for your watch. Digital Service Passport data is retained indefinitely as a permanent record tied to the watch.

If you sell your watch, you may choose to share or transfer the Digital Service Passport to the new owner through the Platform. The new owner may access the record using the watch's unique identifier to support transparency and resale value.

Important: Deletion of your WRSTOPIA account does not remove the Digital Service Passport associated with watches you had serviced or appraised. Digital Service Passport data is tied to the watch, not the account. You may request a copy of your watch's Digital Service Passport at any time through your account settings or by contacting us at legal@wrstopia.com.

6. Cookies & Tracking Technologies

We use cookies and similar technologies (such as web beacons and local storage) to operate and improve the Platform. We use the following categories of cookies:

Essential / Strictly Necessary Cookies

These cookies are required for the Platform to function. They enable core features such as account login, session management, payment security, and fraud detection. You cannot disable essential cookies without affecting Platform functionality. These cookies do not require your consent.

Functional / Preference Cookies

These cookies remember your preferences and settings (such as language, saved searches, and notification preferences) to improve your experience. You can disable these through your browser settings or our cookie preference center.

Analytics Cookies

These cookies help us understand how users interact with the Platform. This data is used in aggregate to improve Platform performance and usability. We use third-party analytics services for this purpose. You can opt out of analytics cookies through your browser settings or our cookie preference center.

Marketing / Advertising Cookies

We may use marketing cookies to deliver relevant promotional content to users who have opted in to marketing communications. If you have not opted in, marketing cookies are not active for your session. You can opt out at any time through our cookie preference center or by contacting us.

Cookie Consent: When you first visit the Platform, a cookie consent banner will allow you to accept, decline, or customize non-essential cookies. Your preferences will be saved and can be updated at any time through the cookie settings accessible in the Platform footer. Essential cookies are always active.

Do Not Track

Some browsers offer a "Do Not Track" (DNT) signal requesting that websites not track your activity. We do not currently alter our data collection practices in response to DNT signals, as there is no uniform industry or legal standard for how such signals should be interpreted. California Business & Professions Code Section 22575 requires us to make this disclosure. If a uniform standard is adopted, we will revisit this practice.

7. Account Security

We take reasonable measures to protect your information, including:

• TLS encryption for data in transit
• Encryption of sensitive data at rest
• Secure authentication and access controls
• Role-based permissions limiting internal access to personal data
• Regular security assessments and incident response procedures

However, no system is completely secure. You are responsible for safeguarding your login credentials and notifying us immediately if you suspect unauthorized access to your account.

In the event of a data breach that affects your rights or that we are otherwise required to report under applicable law, we will notify affected users and relevant authorities within the timeframes required by law.

8. Automated Decision-Making

WRSTOPIA uses automated systems and algorithms to facilitate certain Platform operations, including:

• Matching service requests with available dealers and watchmakers based on location, specialty, availability, and ratings
• Detecting potentially fraudulent activity or Platform policy violations
• Generating service recommendations and surfacing relevant dealers to consumers

These automated processes are used to improve efficiency and Platform performance. They do not produce legal effects or other similarly significant effects on users without human review. No user is denied Platform access, suspended, or subject to any adverse action based solely on automated processing without a human review step.

If you believe an automated process has produced an error or unfair outcome affecting your account or a service transaction, you may contact us at legal@wrstopia.com to request a human review of the decision. We will respond within thirty (30) days.

9. Data Retention

We retain personal information only as long as necessary to provide Services, maintain service and transaction records, comply with legal and regulatory obligations, and enforce our agreements. Specifically:

• Account information is retained for the duration of your account and for five (5) years after account closure
• Transaction records are retained for seven (7) years to comply with tax and financial record-keeping requirements
• Digital Service Passport records are retained indefinitely as part of each watch's permanent record
• Marketing preferences and communications are retained until you opt out or request deletion
• Security and fraud logs are retained for two (2) years

When retention periods expire, we securely delete or anonymize your data. Legal retention obligations (such as seven-year tax records) may prevent us from fulfilling deletion requests for those specific categories of data even after account closure.

10. Your Rights & Choices

Depending on your location, you may have the right to:

• Access your personal information
• Correct inaccurate information
• Request deletion of your data (subject to our legal retention obligations)
• Withdraw consent for certain processing
• Opt out of marketing communications
• Request a copy of your data in a portable format

Requests can be made by contacting us at legal@wrstopia.com. We aim to respond to all privacy rights requests within thirty (30) days.

Opting Out of Marketing Communications

You may opt out of marketing and promotional emails at any time by:

• Clicking the "Unsubscribe" link included at the bottom of every marketing email we send
• Updating your notification preferences in your Platform account settings
• Contacting us directly at legal@wrstopia.com with a written request to be removed from marketing communications

Please allow up to ten (10) business days for your opt-out to take effect. Opting out of marketing does not affect transactional and service-related messages — such as order confirmations, service status updates, payment receipts, warranty notices, and account security notifications — which are necessary to operate the service and cannot be opted out of.

California Residents — CCPA Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including: the right to know what personal information we collect, use, and disclose; the right to delete your personal information; the right to opt out of the sale of personal information (we do not sell personal information); and the right to non-discrimination for exercising your rights. To exercise your CCPA rights, contact us at legal@wrstopia.com. We will respond within forty-five (45) days.

Other State Privacy Rights

Residents of Virginia, Colorado, Connecticut, Texas, and other states with comprehensive privacy laws may have similar rights, including rights to access, correct, delete, and receive a portable copy of their data. We honor requests made pursuant to applicable state privacy laws. Contact us at legal@wrstopia.com to submit a request.

11. Dealer, Watchmaker & Service Center Information

Dealer, Watchmaker and Service Center profiles on the Platform may display:

• Business name
• Location
• Services offered
• Publicly available reviews (when linked by the dealer or watchmaker through their account settings)

Dealers and watchmakers control which external review platforms (such as Google Reviews or Trustpilot) are connected through their account settings. WRSTOPIA does not control or verify the content of reviews hosted on third-party platforms.

Business information collected from dealers and watchmakers during onboarding — including tax identification numbers, proof of credentials, insurance certificates, and bank account information — is used solely to verify qualifications and process payments. This information is not shared publicly and is handled in accordance with the same security standards applied to all user data.

12. Children's Privacy

WRSTOPIA is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a child under 18 without parental consent, we will take steps to delete that information promptly. If you believe we have collected information from a minor, please contact us immediately at legal@wrstopia.com.

13. Third-Party Links

Our Services may contain links to third-party websites or platforms. WRSTOPIA is not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access through or in connection with the Platform.

14. International Data Transfers

WRSTOPIA operates in the United States. If you access the Platform from outside the United States, your information may be transferred to, stored, and processed in the United States, where privacy laws may differ from those in your country. By using the Platform, you consent to the transfer of your information to the United States.

15. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by updating the "Last Updated" date at the top of this policy, posting a notice on the Platform, or sending you an email or in-app notification. Your continued use of the Platform after the effective date of any update constitutes acceptance of the revised policy.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact our designated Privacy and Legal team:

WRSTOPIA, Inc. — Privacy & Legal
10 W 46th st 6th floor, New York, New York
Privacy Requests & Legal Notices: legal@wrstopia.com
General Inquiries: info@wrstopia.com
Phone: 929-552-0336

We aim to respond to all privacy-related inquiries within thirty (30) days. For formal privacy rights requests, data breach notices, and legal correspondence, please use legal@wrstopia.com to ensure proper routing to our legal team.