SHOPTRUE PRIVACY POLICY

Effective Date: September 14, 2022

In order for you to use our services to obtain personalized style and fit recommendations or make purchases (the “Shoptrue Service”), Shoptrue, Inc. and its subsidiaries and affiliates (collectively, “Shoptrue”) collects certain personal information about you. We take the privacy of this personal information very seriously, and provide this Privacy Policy to let you know how we collect personal information, what personal information we collect, and how we use the personal information we receive.

We may amend or update this Privacy Policy from time to time. If we believe that the changes are material, we’ll let you know by posting the changes on or through the Shoptrue Service, and/or sending you an email or message about the changes if you have provided us with your email address. We encourage you to check back regularly and review any updates to this Privacy Policy.

This Privacy Policy applies to personal information provided to us about or relating to you, and from which, either alone or when connected with other information to which we may have access, you can be individually identified (“personal information”). That personal information is described in more detail below.

Shoptrue Privacy Principles

Shoptrue follows these principles in order to protect your privacy:

 

• • We do not collect any more personal information about you than is necessary;

• • Unless you agree otherwise, we only use your personal information for the purposes we specify in this Privacy Policy;

• • We do not keep your personal information if it is no longer needed; and

• • Other than as described in this Privacy Policy, we do not share your personal information with third parties.

This Privacy Policy addresses the following questions:

 

1. 1. What personal information do we collect?

1. 1. Why do we collect personal information?

1. 1. How do we use personal information?

1. 1. With whom do we share personal information?

1. 1. How do we secure personal information?

1. 1. How do we respect your choices about your personal information?

1. 1. How do we use third-party advertising and analytics services?

1. 1. Who do I contact if I have questions or concerns about my privacy or this Privacy Policy?

1. 1. What other terms apply to personal information?

1. What personal information do we collect and how is it collected?

(a) Personal information provided by you. We collect personal information by asking you questions about yourself. When you set up a Shoptrue account, we may ask you for personal information such as your age or birthdate; gender; and your size, brand, fit, size and style preferences. We may also request your email address and phone number, so that we can communicate with you. You may also provide us with personal information through any website mobile application provided to you by Shoptrue or controlled by a Shoptrue retail partner or service provider. Shoptrue retail partners are third party retailers whose apparel may be purchased through our Service, directly, or via affiliates, and our service providers are third parties that assist us with providing the Shoptrue Service, such as payment processing and order fulfillment.

(b) Personal information automatically collected. While you use the Shoptrue Service, we automatically record information that your browser sends whenever you visit a website. For example, we may receive: the name of the domain and host from which you access the Internet, the Internet Protocol (IP) address of the computer you are using, the date and time you access our Service, and which apparel items you view and/or purchase. We use this information to measure the usage of the Shoptrue Service, and to understand how we can serve you better.

When you use the Shoptrue Service, we may collect certain information by automated means, such as through the use of cookies and web beacons. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag, or clear GIF, is used to transmit information about actions of the user opening the page or email containing the beacon back to a web server. We may also use third-party analytics tools such as Google Analytics, that collect information about use of the Shoptrue Service and user traffic.

The information we collect automatically may include personal information, such as purchase and return information. This information helps us to improve and better personalize our Service, including by enabling us to identify and authenticate users and by providing a more relevant and seamless user experience.

(c) Personal information from Third Parties. We may collect personal information about you from our retail partners, business partners, contractors, and other third parties. This includes, but is not limited to, instances in which you affirmatively authorize those third parties to provide us with personal information. For example, retail partners may provide us with personal information about items you have purchased or returned from them in the past so that we can provide better style and fit recommendations for you. This personal information is shared with us in accordance with that third party’s privacy policy. If you have any questions or concerns about the information that we may have received about you, please contact us at privacy@shoptrue.com.

Approved third parties may also set cookies when you interact with the Shoptrue Service. Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies. These third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, and to perform services on behalf of Shoptrue.

For more information about our service providers and their activities, please see Section 6, below.

2. Why do we collect personal information?

We collect your personal information to provide you with the Shoptrue Service and to administer our business. This information also allows us to provide you with easy access to products and our services, with a particular focus on the items and programs that may be of most interest to you. Your personal information also allows us to communicate with you about special offers, promotions, and other marketing programs and news that may be of interest to you.

3. How do we use personal information?

Shoptrue uses your personal information to provide you with the Shoptrue Service, to provide you with a superior customer experience, and to administer our business. We may use your personal information to:

 

• • Create and provide personalized recommendations on style, fit and size of apparel items;

• • Analyze the style, fit and fashion of apparel items;

• • Create a Shoptrue Profile (personal account) you can log into from any device;

• • Provide you with special offers, promotions, and other marketing programs and news that may be of interest to you;

• • Provide customer support and facilitate orders and returns through our third party partners;

• • Answer questions you ask of us regarding the Service or recommendations;

• • Communicate with you regarding security, privacy, and administrative issues;

• • Validate you are of legal age to use our services;

• • Test and improve our systems and services; and

• • Manage our business.

We may combine the information we collect with information we receive from our parent, affiliates, or subsidiary companies, business partners, and other third parties. We may use that combined information to enhance and personalize your experience with the Shoptrue Service, to communicate with you about goods, services, and events that may be of interest to you, for promotional purposes, and for other purposes described in this Privacy Policy.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We will only keep your personal information for as long as necessary to provide the Shoptrue Service or as long as we are required to by law. After this, your personal information will be deleted. We may not remove your data when there is a legal storage requirement such as bookkeeping rules, or when there is a legal ground to keep the data, such as an on-going contractual relationship.

Non-personal data is used as described above and in other ways as permitted by applicable laws, including combining non-personal data with personal data.

4. With whom do we share personal information?

Protecting the privacy and security of your personal information is a priority at Shoptrue. Except as otherwise described in this Privacy Policy, Shoptrue does not sell or rent your personal information to third parties.

Shoptrue may share your personal information with: (i) our retail partners, so they can better personalize apparel offerings to you; (ii) service providers, subcontractors, and agents who perform services on our behalf; (iii) manufacturers of products sold on our partner’s sites to provide insights relating to the fit, style, and purchase preferences relating to their products; and (iv) third parties in certain business relationships, such as, but not limited to, co-branded offerings where we may offer a service or feature that is co-branded by Shoptrue and the third party. If you provide personal information in connection with a co-branded service or feature, that personal information may be shared between Shoptrue and the third party. Shoptrue’s treatment of that personal information is governed by this Privacy Policy, but the third party’s treatment of your personal information will be subject to the third party’s privacy policy.

In addition, Shoptrue may share any of your personal information with third parties as follows:

 

• • Law Enforcement Officials and as Required by Law. Shoptrue may release any or all of your personal information to third parties when we determine, in our reasonable judgment, that it is necessary to (a) comply with the law, regulation, legal process, or enforceable governmental request; (b) enforce or apply the terms of any of our policies or user agreements; or (c) protect the rights, property, or safety of Shoptrue, our employees, our customers, users, or others.

• • Sales, Mergers, and Acquisitions. If Shoptrue becomes involved in a merger, acquisition, or any form of sale of some or all of its business or assets, your personal information may be provided to the entities and advisors involved, and your personal information may be transferred to a third party in connection with consummation of any such transaction. We will provide notice if your personal information becomes subject to a different privacy policy as a result of any such transaction.

Finally, Shoptrue may share aggregated or de-identified information for our business purposes.

5. How do we secure your personal information?

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received, for example encryption is used to help prevent unauthorized access to personal information. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Shoptrue Service. If you have any questions about the security of your personal information, you can contact us at privacy@shoptrue.com.

6. How do we use third-party advertising and analytics services?

From time to time, we may work with third-party service providers to help us better understand how you use our Service. These service providers may place cookies on your computer or use other technologies, such as pixel tags and clear gifs, to collect personal information. The personal information that is collected will tell us things like how you navigated around our Service, and what actions were taken. This personal information will help us to better serve you and provide you with more personalized offerings. Additionally, some of our service providers use these technologies on our Service to provide certain behavioral advertising services as well as marketing services via email and display advertising.

We will not grant permission to any of these third-party service providers to collect your credit card information, e-mail address, or password information through this technology. Any third-party service provider will be restricted to use your personal information to perform services for us, securely and in confidence. Any such third-party service provider will be restricted from using your personal information for any other purpose, except on an aggregate, anonymous basis. With your privacy in mind, we will work toward engaging third-party service providers who enable you to opt-out of their personal information collection processes.

The third-party services we may use include, but are not limited to, Google and YouTube ads, Facebook/Meta ads, Instagram ads, Pinterest ads, TikTok ads, Twitter ads, and TowerData. To learn more about Google’s advertising policies, see: policies.google.com/technologies/ads; your ad settings with Google, see: adssettings.google.com; and Google’s ad personalization, see: policies.google.com/technologies/partner-sites. To learn more about Facebook’s privacy practices, see: facebook.com/policy.php. To learn more about Instagram’s privacy practices, see: https://help.instagram.com/519522125107875/?maybe_redirect_pol=0. To learn more about TikTok’s privacy practices, see: https://www.tiktok.com/legal/privacy-policy-us?lang=en. To learn more about Twitter’s privacy policy, see: https://twitter.com/en/privacy. To learn more about Pinterest’s privacy practices, see: https://policy.pinterest.com/en/privacy-policy. Additionally, you may choose to opt out of certain behavioral advertising at http://www.aboutads.info/choices. To learn more about TowerData privacy practices, see: https://www.towerdata.com/privacy-policy, and to opt out of their services, see: https://instantdata.towerdata.com/optout.

7. How do we respect your choices about your personal information?

We offer you the following choices about the information we collect from you and how we communicate with you:

Cookies: Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of the features of the Shoptrue Service.

Promotional Communications: When you interact with the Shoptrue Service in certain ways, you may be eligible to receive certain marketing-related and promotional communications as well as special offers (collectively “Promotional Communications”) from Shoptrue or third parties with whom Shoptrue has a business relationship and those communications may include advertisements. If, at any time, you wish to no longer receive Promotional Communications from Shoptrue, you will be able to follow instructions provided with the Promotional Communication or within the Shoptrue Service in connection with Promotional Communications.

Web Analytics: You may opt out of the aggregation and analysis of data collected about you on our website by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

Third-Party Tracking: Although we do not control third parties’ collection or use of your information to serve interest-based advertising or other targeted content, a number of these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted advertisements from members of the Network Advertising Initiative by visiting http://www.networkadvertising.org/choices.

Account Information: You may also be able to access and update your preferences and account information in your account settings.

Please be advised that Shoptrue may periodically archive personal information it has collected and there may be times that such archived information cannot be permanently removed from our systems.

8. Who do I contact if I have questions or concerns?

If you have any questions about this Privacy Policy, please contact us at privacy@shoptrue.com. To request to have all your personal information deleted, or to request a copy of your personal information, please contact us at privacy@shoptrue.com.

If you would like to report a security concern about our website or the Shoptrue Service, please contact us at privacy@shoptrue.com.

9. Additional Terms

Location of Shoptrue. Shoptrue is located in, and the Shoptrue Service is provided from, the United States. If you are interacting with Shoptrue from outside the United States and provide us with any personal information, please note that you do so at your own risk and you are responsible for compliance with applicable local laws. If you access the Shoptrue Services from outside the United States, in order for us to provide the Shoptrue Service or otherwise communicate with you as set forth in this Privacy Policy, it will be necessary for your personal information to be transferred, stored, and processed within the United States. The data protection laws in the United States may not be as comprehensive as those in your country. By doing business or interacting with Shoptrue, you are consenting to the transfer of your personal information to facilities located in the United States and other facility locations selected by Shoptrue.

Children’s Privacy. The Shoptrue Service is not directed to, and we do not knowingly collect or solicit personal information from, children under the age of 13. If we learn we have collected or received personal information from a child under the age of 13, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us at privacy@shoptrue.com..

Do Not Track Signals. Your web browser may let you choose your preference as to whether you want to allow the collection of information about your online activities over time and across different websites or online services. At this time, the Shoptrue Service does not respond to the preferences you may have set in your web browser regarding such collection of your information, although we do provide other opportunities for you to control your information, including, for example, honoring your cookie preferences.

Third-Party Websites. Please be advised that whenever you click on links and banners that take you to a third-party website, you will be subject to the third party’s privacy policies, not Shoptrue’s. This Privacy Policy applies solely to personal information collected by Shoptrue.

Contact Us. If you have any questions about this Privacy Policy or our information practices, please email us at privacy@shoptrue.com.

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