PERSONAL DATA PROTECTION POLICY

Reps XI LLC | Effective Date: March 25, 2026 | Version 1.0

1. Company Overview

Reps XI LLC (the Company, we, us, or our) is a liquidation and resale business operating in the United States. We purchase and resell customer returns and overstock merchandise through multiple e-commerce platforms. This Personal Data Protection Policy describes how we collect, use, store, protect, and share personal data in connection with our business operations, including our use of third-party platform APIs such as the Temu Marketplace API.

2. Scope of This Policy

This policy applies to:

All personal data collected through our business operations and third-party platform integrations
Data received from API partners, including Temu, eBay, and other marketplace platforms
Personal data of customers, suppliers, business partners, and employees
All staff, contractors, and systems operated by or on behalf of Reps XI LLC

3. What Personal Data We Collect

3.1 Customer Data

Full name and contact information (email, phone number, mailing address)
Order details, transaction history, and purchase records
Shipping and delivery information
Return and refund records
Customer service communications

3.2 Data Received via Third-Party APIs (including Temu API)

Order and transaction data passed through platform APIs
Shipping recipient information required to fulfill orders
Platform-assigned identifiers and account references
Product listing and inventory data

3.3 Business Partner and Supplier Data

Names and business contact information of suppliers and partners
Transaction and payment records

4. How We Use Personal Data

We use personal data only for the following legitimate business purposes:

Processing and fulfilling customer orders placed through our sales channels
Communicating with customers regarding orders, returns, and inquiries
Managing inventory and product listings across marketplace platforms
Accessing and using third-party marketplace APIs, including the Temu API, to manage listings and process orders
Complying with legal and regulatory obligations
Preventing fraud and ensuring transaction security
Improving our internal operations and customer service

We do not sell, rent, or trade personal data to any third party for marketing or advertising purposes.

5. Legal Basis for Processing

We process personal data under the following legal grounds:

Contract performance - to fulfill orders and deliver services requested by customers
Legal obligation - to comply with applicable federal, state, and local laws
Legitimate business interests - to operate, improve, and secure our business
Consent - where required by law, we obtain explicit consent before processing data

6. Data Sharing and Disclosure

We only share personal data with third parties in the following circumstances:

Marketplace platforms (e.g., Temu, eBay) - to list products, process orders, and manage returns as required by API agreements
Shipping and logistics providers - to fulfill and deliver orders
Payment processors - to securely handle transactions
Legal authorities - when required by law, court order, or regulatory requirement
Service providers - third-party vendors under strict data processing agreements

All third-party service providers are required to handle personal data in a manner consistent with this policy and applicable law.

7. Data Security

Reps XI LLC takes the security of personal data seriously. We implement the following safeguards:

Access controls - personal data is accessible only to employees who need it for their job duties
Secure systems - we use password-protected systems and encrypted storage where applicable
API security - all API credentials and tokens are stored securely and never shared publicly
Employee training - staff are trained to handle personal data responsibly and confidentially
Incident response - in the event of a data breach, we will notify affected individuals and relevant authorities as required by law

8. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes in this policy, or as required by law:

Customer order data is retained for a minimum of 3 years to comply with business and tax record requirements
API transaction data is retained in accordance with the terms of the applicable platform agreement
Data that is no longer needed is securely deleted or anonymized

9. Individual Rights

Depending on applicable law, individuals whose personal data we hold may have the right to:

Access - request a copy of the personal data we hold about them
Correction - request that inaccurate or incomplete data be corrected
Deletion - request that their personal data be deleted, subject to legal retention requirements
Objection - object to certain types of data processing
Portability - request their data in a portable format

To exercise any of these rights, please contact us using the information in Section 12.

10. Third-Party API Compliance (Temu and Other Platforms)

When using third-party marketplace APIs, including the Temu Marketplace API, Reps XI LLC agrees to:

Use data obtained through API access solely for the purposes permitted by the API agreement
Not store, share, or use customer data beyond what is required to fulfill orders and manage our seller account
Comply with all data handling requirements in the platform's API terms of service and data policies
Promptly delete any personal data received via API upon termination of the API agreement or upon request
Not use API data for re-targeting, advertising, or any purpose unrelated to order fulfillment and account management

11. Cookies and Online Tracking

Our internal business systems may use cookies or similar technologies for authentication and system functionality only. We do not use cookies or tracking technologies to collect personal data from third-party consumers beyond what is necessary for platform-integrated operations.

12. Contact Information

For questions, concerns, or requests related to this policy or personal data we hold, please contact:

Reps XI LLC Attn: Data Privacy
Las Vegas, NV, United States

13. Policy Updates

We may update this policy from time to time to reflect changes in our operations, legal requirements, or platform agreements. Any material changes will be communicated through our internal channels. The effective date at the top of this document reflects the most recent revision.