Privacy Policy

Last Updated: September 20, 2025

This Privacy Policy describes how Be Lenka, Inc. and its affiliates (referred to as “Be Lenka”, “our”, “we”, or “us” in this Policy) collect, use, share, and protect your personal information, what choices you have relating to your personal information, and how you can contact us.

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy (“Policy”) applies to the personal information that Be Lenka collects and processes when you interact with us as a customer, including when you interact with our websites, digital experiences, mobile apps, stores, or one of our other products or services, all of which are part of Be Lenka’s “Platform” and direct to this Privacy Policy. This Policy also applies to the personal information that Be Lenka processes when you subscribe to receive marketing communications from us, communicate with us, or engage with us via our Platform.

2. PERSONAL INFORMATION WE COLLECT

Be Lenka collects personal information directly from you, automatically when you use our Platform or interact with us, and from third parties.

Personal Information Collected Directly from You. We ask you for certain personal information to provide you with the products or services you request. The personal information we collect from you depends on how you interact with us or use our Platform. This personal information includes your:

  • Identifiers. We collect certain personal information from you, such as your name, telephone number, email address, date of birth, password, and other identifiers, as well as any personal and demographic information. When you make a purchase, we collect your payment or credit card information, your shipping and billing address.
  • Commercial Information. We collect information about your purchases, favorites, and items that you view or add to your cart.
  • Communications. When you communicate with us, we collect your contact details and keep a record of the communications, as well as our responses.
  • Physical Characteristics. We collect information on your physical characteristics, including weight, height, and body measurements (such as estimated stride and shoe/foot measurements or apparel size).

Personal Information We Derive or Collect Automatically. We also collect and generate data automatically when you use our Platform, such as device info, online activity, and inferences to personalize your experience. This information includes:

  • Location information. We may collect or derive approximate or precise location information about you. You may turn off precise location information sharing through your device settings.
  • Device information. When you interact with our Platform, we collect technical information about your device, including your IP address, unique identifiers, unique device identifier and device type, domain, browser type, and similar device and usage information.
  • Online Activity and Browsing Information. We use cookies, log files, pixel tags, and other tracking technologies to automatically collect information about your interaction with our websites and apps and communications you receive from us. For more information, see “About Cookies and Similar Technologies” below.
  • Inferences. To personalize your experience on the Platform, we may draw inferences using your personal information to create a profile reflecting your interests, preferences, and characteristics.

Personal Information from Third Parties. We may collect personal information about you from third-party sources, including when you use our Platform with third-party products and sources. This includes:

  • Information from Third-Party Products and Services. If you connect your Be Lenka account or access our Platform through third-party products or services (such as app stores or social media platforms), we may collect information about you from that third-party product or service.
  • Information from Partners. With your consent, where required, we may obtain information about how you participate or engage with marketing campaigns. Third-party products and services may control the information they collect and share about you. For information about how these third parties may use and disclose your information, please consult their respective privacy policies.

3. HOW AND WHY WE USE YOUR INFORMATION

Be Lenka collects, uses, discloses, and otherwise processes the personal information we collect for the following business and commercial purposes:

  • Providing Features of the Platform and the Services You Request. When you use our Platform, we will use your personal information to provide the requested product or service. For example, if you make a purchase on belenka.shop or barebarics.shop, we will use your personal information to fulfill your order and complete the transaction.
  • Marketing and Other Promotional Purposes. If you are an existing customer of, Be Lenka (for example, if you have placed an order with us), we may use the contact details you provide to send you marketing communications about similar Be Lenka products or services, where permitted by applicable law (unless you have opted out). In other cases, we ask for your consent to send you marketing information.
  • For Research, analytics, and improvement. We use information to better understand how consumers engage with the Platform and our products and offerings, including consumer behavior and preferences. We also use information for other research and analytical purposes, such as to evaluate and improve our Platform and business operations, to develop services and features, and for internal quality control and training purposes.
  • To Personalize Your Experience and Our Platform. We use personal information, including inferences drawn from your personal information to tailor and personalize your experience on our Platform.
  • To Protect Our or Others’ Rights, Property, or Safety. We use information to protect the Platform and our business operations; to protect our rights or those of our stakeholders; to prevent, detect, and investigate actual or suspected fraud, abuse, illegal use, or violations of our Terms of Use.
  • To Comply with Legal Obligations. We may also use your personal information as part of legal proceedings, to respond to legal process, and to comply with court orders, governmental requests, or applicable law.
  • Other purposes. We may also use your personal information in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.

4. HOW WE DISCLOSE AND SHARE PERSONAL INFORMATION

Be Lenka may disclose and share personal information we collect with the following types of entities and recipients:

  • To our affiliates, subsidiaries, vendors, and service providers. We may disclose personal information to our affiliates and subsidiaries, as well as service providers, vendors, and others for business purposes and to perform functions on our behalf.
  • To other Platform users. Your username and any information that you post to our Platform, including, without limitation, reviews, comments, and other text, will be available to and searchable by other users of the Platform. You can review and make changes to who can view your profile in your account settings.
  • To Third-Party Advertising and Social Platforms and Networks. We may disclose or make available personal information to third-party platforms and providers to obtain personalized and tailored advertising services, to provide or make available certain features or portions of the Platform, or as necessary to respond to your requests. Providing tailored advertising services may be considered a “sale,” “sharing” for cross-context behavioral advertising, or “targeted advertising,” as defined by applicable law. We do not disclose, sell, or share personal information to third parties for money­ or compensation. You may opt out of cross-context behavioral advertising or targeted advertising by using the relevant settings available in our Platform.
  • Business partners and potential buyers (and their agents and advisors). We may disclose your personal information with actual or potential buyers (and their agents and advisors) in connection with any actual or proposed purchase, merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider.
  • Other Parties. We may disclose personal information to other parties, including government entities and regulators, to the extent necessary to: (i) comply with a government request or applicable law and to respond to legal process; (ii) prevent illegal uses of our Platform or violations of our Platform's Terms of Use and our policies; (iii) defend ourselves against third party claims; and (iv) assist in fraud prevention or investigation (e.g., counterfeiting).
  • With your consent. We may disclose your personal information to any other third party where you have provided your consent.

5. CHILDREN’S PRIVACY

We do not knowingly collect personal information online from children under the age of 13. If you’re a parent or guardian and you believe we have collected your child’s information, please contact us at [email protected].

6. PROTECTION OF PERSONAL INFORMATION

We use a variety of technical, administrative, and organizational security measures, including encryption and authentication tools in certain circumstances, that are intended to protect your personal information. Please be aware that despite our efforts, no data security measures can guarantee security. You can help keep your data safe by taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

7. RETENTION OF PERSONAL INFORMATION

We retain your personal information for as long as reasonably necessary to fulfill the purposes described in this Policy or disclosed to you at the time of collection, unless otherwise required or permitted by law. For example, we keep your account profile information for as long as you keep your Be Lenka account, but we may keep your purchase history longer to comply with our legal, tax, accounting and recordkeeping obligations, administer applicable returns and warranty programs, and for research, development and safety purposes, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims or comply with legal obligations.

8. MANAGING YOUR PRIVACY RIGHTS AND CHOICES

Privacy Rights. You may have certain rights identified below under the applicable laws of where you reside with respect to your personal information. We have full discretion in choosing to voluntarily provide you with some or all of those rights, regardless of the state in which you reside. Please refer to “Additional State-Specific Information” to determine the rights you have in the state where you reside.

Depending upon the applicable law, access to your rights may be denied, such as: (a) when denial is required or permitted by law; (b) when granting access would have a negative impact on another's privacy; or (c) to protect our rights and properties.

The privacy rights you may have include the following:

  • Right to know and access your personal information. You may have the right to know what personal information we collect about you, including the categories of personal information, the sources from and purposes for which we collect it, and the types of recipients we disclose it to, and to request a copy of the specific pieces of personal information that we maintain about you.
  • Right to correct your personal information. Right to correct inaccurate personal information that we maintain about you.
  • Right to delete your personal information. You may request the deletion of their personal information that we have collected about you, subject to certain exceptions.
  • Right to opt out of targeted advertising. You may request to opt out of our sale of your personal information and the sharing of your personal information for cross-context behavioral advertising or targeted advertising. We share your personal information with third parties (such as marketing and advertising networks and social platforms) for behavioral advertising or disclose your personal information to other third-party partners in accordance with your privacy settings and/or consent. These types of disclosures of your personal information may be deemed a “sale” or “sharing” of your personal information under applicable privacy laws.
  • Right to non-discrimination. You have the right not to be subject to discriminatory treatment for exercising your rights under certain laws.

Exercising Your Rights and Choices. You may submit privacy rights requests and manage your privacy choices in several ways.

You may request to access your personal information (both the categories of data we collect, which is laid out in this policy, and specific pieces of information), obtain an electronic copy of your personal information, correct your personal information if it is incomplete or inaccurate, or delete or restrict sharing of your personal information in certain circumstances, as provided by applicable law. If we deny your request, you can appeal by contacting us at [insert email].

  • Opting Out of Direct Marketing. If you have a Be Lenka account, you can opt out or unsubscribe by contacting us at [email protected].
  • Opt-out of Targeted Advertising. We share your personal information with third parties (such as marketing and advertising networks and social platforms) for targeted advertising. These types of disclosures of your personal information may be deemed a “sale” or “sharing” of your personal information under applicable privacy laws.  However, Be Lenka does not disclose, sell, share, or rent your personal information for money or compensation. You may opt out of targeted advertising by emailing us at [email protected].
  • Update Your Profile Information. You can update certain personal information, like your email, address, and phone number, by logging in and updating it through your Be Lenka account settings.
  • Managing the content you post. You can request the removal of content you have posted on the Platform, but please note that removal may not encompass all possible locations, for example, back-ups or sharing by other users initiated prior to removal.

Additional tools to manage what data we collect. When using our Platform, we also provide in timely notice or obtain consent for certain practices. Your web browser or mobile device platform provides additional tools to allow you to control when your device collects or shares certain categories of personal information. For example, your mobile device or web browser may offer tools to allow you to manage cookie usage or location sharing. We encourage you to familiarize yourself with and use the tools available on your device.

9. ABOUT COOKIES AND SIMILAR TECHNOLOGIES

Be Lenka, our service providers, and third parties collect information, which may include personal information, from your browser, devices, or apps when you use our Platform using a variety of methods, such as cookies, pixel tags, identifiers for mobile devices, and other similar technologies. The information collected by these cookies and similar technologies may include your: IP address; unique cookie identifier and information obtained through cookies; unique device identifier and device type; domain, browser type and language, operating system, and system settings; country and time zone; previously visited websites; information about your interaction with our Platform such as click behavior, purchases and indicated preferences; and access times and referring URLs.

We use cookies and similar technologies to analyze and understand how you access, use, and interact with our Platform and our consumers’ preferences (such as country and language choices), as well as to assess, secure, protect, optimize, and improve the performance of our Platform. This enables us to provide services to our consumers and improve their online experience. We also use cookies and pixel tags to obtain aggregate data about Platform traffic and interaction, to conduct analytics, identify trends, and obtain statistics so that we can improve our Platform. We also use cookies and similar technologies to target advertising and content across our Platform and third-party sites and services.

Third-Party Technologies and Services. Some of the cookies and similar technologies we use are operated by third-party companies. We use third-party services, such as Google Analytics and its advertising products, such as Google Signals and Google Ads, that may collect usage data (using cookies, pixel tags and similar tools) about our Platform to provide us with reports and metrics that help us to evaluate usage of our Platform, improve performance and user experiences, and serve relevant advertising to you. We also use third-party technologies and services to support the security of our Platform and protect against fraud and abuse.  In some cases, the processing of this data is subject to these third parties’ privacy policies (for example, for Google Analytics, see Google’s Privacy & Terms, Google’s Privacy Policy).

Managing Your Cookie Preferences. We make available several ways for you to manage your cookies within our Platform. Many of these are browser and device specific, which means that you need to set the preference for each browser and device you use to access our Platform; in addition, if you delete or block cookies, you may need to reapply these preferences. Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or contextual ads from us.

  • Mobile settings. Some of our apps may include third-party advertising. You can adjust your advertising preferences on your mobile device at the device level.
  • Industry ad choice programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our sites and your use of our mobile applications, and those of third parties, to display more relevant targeted advertising to you.
  • Browser settings. For a comprehensive and up-to-date summary of every third-party accessing your web browser (through the Be Lenka Platform or otherwise), we recommend installing a web browser plugin built for this purpose. Your browser may offer choices to manage your cookies, including blocking all or third-party cookies. You do this through your browser settings on each browser and device that you use. If you turn cookies off, you may not have access to many features that make our Platform more efficient, and some of our services will not function properly.

Do Not Track. Please note that we do not recognize or respond to any signal which your browser might transmit through the “Do Not Track” feature your browser might have. If you wish to disable cookies on our Platform, you should not rely on any “Do Not Track” feature your browser might have.

10. USING THE BE LENKA PLATFORM WITH THIRD-PARTY PRODUCTS AND SERVICES

Our Platform allows you to interact with a wide variety of other digital products and services. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.

11. CHANGES TO OUR PRIVACY POLICY

If we decide to update our Privacy Policy, we will post the changes on our Platform and, if material, provide notice or obtain consent where required by law. We strongly encourage you to read our Privacy Policy and keep yourself informed of our practices.

12. QUESTIONS, FEEDBACK

We welcome questions, comments, and concerns about our privacy policy and privacy practices. You may contact us via email at [email protected].

13. ADDITIONAL STATE-SPECIFIC INFORMATION

CALIFORNIA RESIDENTS

This section provides California residents with additional information regarding our collection, use, and disclosure of their personal information that supplements the disclosures in our Privacy Policy above. This section uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations.

Categories of Personal Information Collected. We collect the personal information detailed in the “Personal Information We Collect” section above. This information includes the following categories of personal information as defined under California law:

  • Identifiers
  • Personal Information described in California Section 1798.80(e)
  • Characteristics of protected classifications under California or federal law
  • Commercial Information
  • Internet or other electronic activity information
  • Inferences
  • Sensitive personal information, specifically: (a) log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, (b) precise geolocation information; and (c) personal information collected and analyzed concerning a consumer’s health.

Categories of Personal Information Disclosed for Business Purposes. The personal information we process varies based on our relationship and interactions with you. We may disclose the categories of personal information described above for the business purposes outlined in “How and Why We Use Personal Information.” The recipients to whom we may disclose your personal information (and that may have received such information during the last 12-months) for business purposes include: our affiliates and subsidiaries; order processing, fulfillment, shipping, and logistics vendors; payment processors and financial institutions; analytics and research vendors; information technology vendors; fraud prevention and security vendors; vendors supporting legal, compliance, accounting, audits and other internal functions; and certain marketing and advertising vendors.

Categories of Personal Information Shared with Third Parties. We share your personal information with third parties (such as marketing and advertising networks and social platforms) for behavioral advertising or with other third-party partners in accordance with your privacy settings and/or consent. These types of disclosures of your personal information may be deemed a “sale” or “sharing” of your personal information under California privacy laws.

California privacy laws define a “sale” as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising or with affiliates and business partners. Be Lenka does not disclose, sell, share, or rent your personal information to third parties in exchange for money or compensation. Further, we do not “sell” or “share” sensitive personal information, nor do we “sell” or “share” any personal information about individuals who we know are under the age of 16.

Below is an overview of categories of third parties with whom we share your information and the categories of personal information they receive:

Advertising and Social Platforms and Networks

  • Identifiers
  • Device information
  • Online Activity and Browsing Information
  • Inferences

Privacy Rights. California residents have the following rights with respect to their personal information:

To know what personal information is collected

  • To access personal information
  • To correct personal information
  • To delete personal information
  • To opt out of the “sale” of personal information
  • To opt out of “sharing” of personal information for cross-context behavioral advertising
  • To limit the use of sensitive personal information
  • To non-discrimination

These rights are further detailed in “Managing Your Privacy Rights and Choices” above. California residents may exercise their privacy rights by following the instructions included in “Exercising your Rights and Choices.”

Shine the Light. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request via email us at [email protected] and include in your request a current California address and your attestation that you are a California resident.

OREGON RESIDENTS

This section provides Oregon residents with additional information regarding our collection, use, and disclosure of their personal information that supplements the disclosures in our Privacy Policy above. This section uses certain terms that have the meaning given to them in the Oregon Consumer Privacy Act.

Controller of Personal Information. Be Lenka is the controller of your personal information, depends on how you interact with Be Lenka’s Platform.

  • Be Lenka is responsible for operating our digital platforms and experiences, marketing, hosting certain events and contests, and for all other processing in the context of our websites and apps.
  • Be Lenka is responsible for your orders, purchases, and returns at Be Lenka-owned brick and mortar retail stores, if applicable (each a “Retail Store”), and through belenka.shop or barebarics.shop, and the Be Lenka app (each a “Digital Store”).

Personal Information Processed. We collect and process the following categories of personal information as further detailed in “Personal Information We Collect” above: identifiers; commercial information; communications; physical characteristics; fitness and activity information; registration information related to sweepstakes, contests and promotions; events information; location information; device information; online activity and browsing information; audio, visual and other electronic data; sensor and movement data; photos, contacts, and calendar information; and inferences.

As described above, we may collect precise geolocation information from your device or browser for the purposes described in “How and Why We Use Your Information” above. Precise geolocation data is considered “sensitive data” under Oregon law.

Purposes of Processing Personal Information. The purposes for processing personal information are described in “How and Why We Use Your Information” above.

Disclosure of Personal Information. We may disclose and share all of the categories of personal information described above with the following categories of third parties:

  • Other Platform users, such as when you post to our Platform;
  • Actual or potential buyers in connection with a proposed or actual corporate transaction; or
  • Other third parties, as needed for legal purposes, typically courts, law enforcement, other government agencies, or parties to a legal proceeding.

We also share your personal information (including identifiers, device information, online activity and browsing information, and inferences) with marketing and advertising networks and social platforms for targeted advertising. These types of disclosures of your personal information may be deemed a “sale” under applicable law, but we do not otherwise sell personal information to third parties for money or other compensation.

These categories of third parties and their typical purposes for processing your personal information are further described under “How We Disclose and Share Personal Information.”

Privacy Rights. Oregon residents have the following rights with respect to their personal information, subject to certain exceptions and limitations:

  • To opt out of sales and processing for targeted advertising;
  • To confirm whether we are processing or have processed your personal information and the categories of personal information we are processing or have processed;
  • To obtain a copy of your personal information that we process or have processed;
  • To correct inaccuracies in personal information about you;
  • To delete personal information about you; and
  • To obtain a list of the specific third parties to which we have disclosed any personal information.

If you wish to exercise your rights related to your personal information, contact us at [email protected].

Additionally, if you have submitted a request that we have not fulfilled to your satisfaction, you may contact us to appeal our decision by sending an email with the subject line “Appeal” to [email protected].

If you have questions about this policy or our practices, you can send us an email at [email protected].

VIRGINIA RESIDENTS

This section provides Virginia residents with additional information regarding our collection, use, and disclosure of their personal information that supplements the disclosures in our Privacy Policy above. This section uses certain terms that have the meaning given to them in the Virginia Consumer Data Protection Act.

Personal Information Collected. We collect the personal information detailed in the “Personal Information We Collect” section above.

Purposes of Processing Personal Information.  The purposes for processing personal information are described under “How and Why We Use Personal Information.”

Disclosure of Personal Information. We disclose and share your personal information as described under “How We Disclose and Share Personal Information.”

Personal Information Processed for Targeted Advertising. We process and disclose the following categories of personal information for targeted advertising:  identifiers, device information, online activity and browsing information, and inferences.  We share each of these categories of personal information with Advertising and Social Platforms and Networks.

Privacy Rights. Virginia residents have the following rights with respect to their personal information:

  • To access personal information
  • To correct personal information
  • To delete personal information
  • To opt out of targeted advertising
  • To non-discrimination
  • To appeal

These rights are further detailed in “Managing Your Privacy Rights and Choices” above. Virginia residents may exercise their privacy rights by following the instructions included in “Exercising your Rights and Choices.”