Last updated: September 17, 2022
This Privacy Notice for California Residents supplements the information contained in the general Privacy Policy of Shoptrue, Inc. (“Shoptrue,” “we,” or “us”), which is incorporated in this privacy notice by this reference. This privacy notice applies to California residents from whom we collect personal information (“consumers” or “you”), including visitors to http://www.shoptrue.com (the “Site”). We adopt this privacy notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this privacy notice.
Information We Collect
This Site collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). In particular, within the last 12 months Shoptrue’s Site has collected, or may collect, the following categories of personal information:
| Description of Category | What We Collect | Source | Business/Commercial Purposes for Collection |
| Identifiers (“Identity Data”) | Name, Email address, Phone number, Postal address | Directly from consumers (e.g., when consumers create an account with Shoptrue or make a purchase) Third party partners | Marketing communications, providing customer support, facilitating orders and returns via third parties, and other related purposes |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“Customer Records Data”). | Name, Email address, Phone number, Postal address, Birth month and year, Gender identity | Directly from consumers (e.g., when consumers take a style quiz, create an account with Shoptrue, or make a purchase) Third party partners | Marketing communications, providing personalized shopping experiences, customer support, facilitating orders and returns via third parties, and other related purposes |
| Protected classification characteristics under California or federal law (“Protected Class Data”). | Gender identity, user fit, style, and size preferences, Birth month and year | Directly from consumers (e.g., when consumers take a style quiz, create an account with Shoptrue, or make a purchase) Third party partners | To understand user preferences in order to provide relevant product recommendations and marketing/advertising communications |
| Commercial information (“Commercial Data”). | Records of products or services purchased, or considered, or other purchasing or consuming histories or tendencies | Directly from consumers Third party partners | To understand user preferences in order to provide relevant products recommendations and marketing/advertising communications |
| Internet or other similar network activity (“Internet Use Data”) | Device information (IP address, device type, etc.), dates/times/duration of use and clickstream data, browsing history, or information on a consumer’s interaction with our site | Indirectly from consumers (e.g. when a consumer interacts with our website) Directly from consumers Third party partners | To provide personalized recommendations for users on the site or via marketing communications General site analytics & reporting |
| Geolocation data (“Location Data”). | Device information (IP address, user location, device type, etc.), dates/times/duration of use and clickstream data | Indirectly from consumers (e.g. when a consumer interacts with our website) Third party partners | To provide personalized recommendations for users on the site or via marketing communications General site analytics & reporting |
| Inferences drawn from other personal information (“Inferences”). | User fit, style, size preferences | Directly from consumers Third party partners | To provide personalized recommendations for users on the site or via marketing communications |
Personal information does not include (i) publicly available information from government records; (ii) de identified or aggregated consumer information; and (iii) information excluded from the CCPA’s scope.
Purpose for Collection of Personal Information.
In addition to the business or commercial purposes for collection described above, we have in the preceding 12 months collected, or may collect, all categories of personal information described above for the following purposes:
- To process your requests, transactions and to prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To create, maintain, customize, and secure your account with us.
- For testing, research, analysis, and product development, including to develop and improve this Site and our products and services.
- To provide, support, personalize, and develop this Site and our products and services.
- To help maintain the safety, security, and integrity of this Site and our products, services, databases, other technology assets, and business.
- To deliver content and product and service offerings relevant to your interests, including targeted offers and ads through this Site, third-party sites, and via email or text message (with your consent, where required by law).
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Shoptrue’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Shoptrue about the users of this Site is among the assets transferred.
Disclosures of Personal Information for a Business Purpose
We share your personal information for a business purpose to the following categories of third parties:
- Service providers
- Advertising networks
- Data analytics providers
- Social networks
When we disclose your personal information to a service provider, we enter into a contract with the service provider that describes the business purpose for which your personal information is disclosed and restricts the service provider from using your personal information for any purpose except performing the contract.
In the preceding 12 months, we have disclosed to these third parties the following categories of personal information for a business purpose:
- Identity Data
- Customer Records Data
- Protected Class Data
- Commercial Data
- Internet Use Data
- Location Data
- Inferences
Sale or Sharing of Personal Information
In the preceding 12 months, we have not sold personal information.
Your Rights and Choices
The CCPA provides you as California residents with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
Deletion Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Emailing us at privacy@shoptrue.com
- Visiting https://blog.shoptrue.com/shoptrue-privacy-notice-for-california-residents/
- Submitting the form available at https://blog.shoptrue.com/shoptrue-privacy-notice-for-california-residents/ by email
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the personal information requested.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless the request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 years of age and less than 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized agent) may submit a request to us by visiting our “Do Not Sell My Personal Information” webpage. If your authorized agent submits a request on your behalf, the authorized agent must provide either (1) a copy of your written permission for the authorized agent to submit a request on your behalf and information sufficient to verify the authorized agent’s identity or (2) power of attorney pursuant to California’s Probate Code.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
- Provide you a different level or quality of goods or services, including denial of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, levels, or quality of goods or services. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of this Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information set forth below.
Changes to this Privacy Notice
Shoptrue reserves the right to update or change this privacy notice at any time. When we make changes to this privacy notice, we will post the updated notice on this Site and update the date on which this privacy notice was last updated. The date this privacy notice was last updated is at the top of this page. You are responsible for periodically reviewing this Site and this privacy notice to check for any updates or changes. Your continued use of this Site following the posting of changes constitutes your acceptance of such changes.
Contact Us
If you have any questions or comments about this privacy notice or our privacy practices, your choices and rights regarding use of your personal information, or wish to exercise your rights under California law, please contact us by email at privacy@shoptrue.com
CCPA Consumer Request Form
If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with certain rights to your personal information, including the rights to:
- Information regarding what personal information we collect, use, and disclose about you and access to the specific pieces of personal information we have about you (“Right to Know”)
- Delete your personal information (“Right to Delete”)
When processing your request, we must verify your identity before we delete or provide you with access to the personal information we hold about you or others if you are an Authorized Agent. For more information about these privacy rights and our verification process, please visit our California Privacy Notice.
