Last Updated: November 15, 2021
Guide to Contents
- What We Collect
- How We Use Information
- How We Share Information
- Your Choices
- Your California Privacy Rights
- Information Security
- Non-US Residents and Cross-Border Transfer
- Your Right to Lodge Complaints
- How to Contact Us
1. What We Collect
We collect information through the Platform, including personal information about you. Some information you may provide to us voluntarily, while other information we gather through various means. We will retain that information for so long as you have an account or we have a permissible legal or business purpose for it, unless otherwise stated herein. Your personal information may be collected, processed and stored on servers in the United States and in other countries. The following explains what we collect and how we collect it.
To provide the Platform and a first-class shopping experience, we collect information from and about you. That information may include the following categories of personal information:
- Contact Information and Other Personal Identifiers: This may include your name, email address(es), postal address(es), and telephone number(s), including your mobile phone number(s).
- Payment Information: If you make purchases via the Platform, we (and our current payment processor Shopify Payments and any future payment processor) may collect your credit card number, expiration date, CVV code, and billing address.
- Commercial Information: We may collect directly or indirectly your order and payment history.
- Browsing and Device Information: We may collect your IP address or other device identifier, the kind of browser you use, browsing information such as the pages and content that you visit, location data, data analytics and other information regarding your interaction with the Platform or our advertisements or location information from your device.
- Demographic Information: We may collect demographic information like your age, birth date, gender and income.
- Other Information: We may collect additional information including information you submit via chat or online forms, completing surveys or participating in contests and sweepstakes.
Please review the rest of this Section 1 for additional context regarding the personal information Shop PO collects. Sections 2 and 3 provide details on the business or commercial purposes for which each of the above categories of personal information are collected and the categories of third parties with which the business shares the information.
1.2 Information You Voluntarily Provide
You may provide us with information in order to use, or participate in, certain features of the Platform, such as registering for an account, participating in our SPO Rewards Program, making a purchase, and you may receive communications relating to those transactions and programs. If you sign up for emails, you will also receive emails from us related to your purchases, current offers, and your participation in the Platform.
Account. If you register for an account, you will need to provide certain information, such as your first and last name, password and e-mail address. You may also have the option to provide additional information for a user profile, such as your photo, demographic information and birthdate. You may log into your account to access and edit certain information associated with your account, such as your contact information. You will also be enrolled in the SPO Rewards Program.
Online purchases. If you make a purchase, you will need to provide the following information:
- Financial information. To pay for your purchase on the Platform you will either be redirected to the retailer's website where you will pay the retailer directly, or you will provide us or our third-party payment processing company certain financial information, such as your credit card number, type and expiration date, along with your name and address. The payment processor will use and share the information as explained below.
- In order to provide information for your receipts and to facilitate future orders you may make, we (through our payment processor, Shopify Payments) or the retailers may collect your credit card information or store a secure token for your credit card, your credit card type and the last four digits of your credit card number. We do not collect any other financial information in connection with the Platform.
- Purchase and shipping information. We and the retailers may collect the information in your shopping cart, such as the specific products that you wish to order, the stores they are sold from and the shipping information for those products, including the recipient's first name, last name, mailing address, e-mail address and telephone number. We provide certain information back to our retail partners.
- Other information. You may have the opportunity to provide information at other areas of the Platform. These include, for example:
- Communications and sign-up with us. If you sign up for certain services and products or provide feedback through a form or contact us via e-mail, we may collect your name and e-mail address, as well as any other content or information you provide and provide that information to our retail partners or others.
- Communications and sign-up with retailers. When you sign up for certain services and products with our retail partners, they may provide us with personal information that you provide to them that Shop PO will use to improve the Platform and tailor our communications to you.
- Rewards Program. We and our rewards program partners may collect information about your purchases and interactions with the SPO Rewards Program, including the points and rewards that you have received and used and other information you choose to provide like birthdate and anniversary date.
- Surveys, promotions, etc. We or our retail partners may collect information you provide by participating in surveys, sweepstakes, contests, promotions or other solicitations by us and our retail partners
- Public postings. We may also collect information you post at other areas of the Platform, such as public areas of the Platform including message boards, blogs and reviews.
Children. The Platform is not directed to children under the age of 18. We do not knowingly collect personal information from children under the age of 18, nor do we knowingly distribute such information to third parties. If you are not 18 or older, you are not authorized to use the Platform. Parents should be aware that there are parental control tools available online that you can use to prevent your children from submitting information online without parental permission or from accessing material that is harmful to minors.
Terminating Your Account. You may terminate your account by submitting a request via the online request form. If you terminate your account, any association between your account and information we store will no longer be accessible through your account. We may retain the information collected prior to termination for legally permitted purposes and this will be explained to you if necessary.
1.3 Information We Gather Automatically
1.4 Location Information
General Location. When you use the Site, we may collect location data that is provided by your ISP or a third party data provider, such as your ZIP code, city and state. When you access the Apps using your mobile device, we collect the location data (such as your current latitude/longitude coordinates) that is provided by your mobile device (if you enable that feature on your device and choose to share your location with us).
You may adjust the settings on most devices to allow the Site or App to gather, or to disable it from gathering, location positioning data. Certain features, such as a mall locator, may not work as effectively if you disable location positioning data.
1.5 Involvement of Others in Data Collection
We may work with third parties, including the retailers whose products are offered on the Platform, to collect and analyze the information as described above and for other purposes described below.
Further, we may obtain information from others (including social media networks, advertising service providers and networks) that does not identify you personally or, if you have given that service or us permission to do so, information that identifies you personally. This information may be combined with information you have provided to us or that we or others have collected about you, so that we may maximize the benefit you receive from the Platform and deliver advertising targeted to your specific interests on our Site and App and when you use other websites or mobile applications. Information about you also may be aggregated with other subscriber information for the purposes identified above.
1.6 Cookie Use
- Strictly Necessary Cookies:These cookies are essential to enable you to browse and use the functionality of a website and without them, the Platform cannot be provided. We use these cookies, among other things, to recognize and maintain your logged-in status throughout your visit and manage your shopping cart.
- Performance Cookies: These cookies collect information about how visitors use the Platform, for example, pages that they visit and if they receive error messages. This information does not identify you individually and is used in the aggregate to improve our Platform.
- Functionality Cookies: These cookies allow us to remember certain choices you make about how you like to use the Platform and provide you a more personalized experience, for example, your shipping country and currency preferences.
- Targeting Cookies:These cookies are used to deliver online advertisements that are relevant to you and your interests and to measure the effectiveness of advertising campaigns. They may be placed on the Platform by us or by our advertising partners with our permission. For more on targeting cookies and your ability to control their use, please see below.
To understand your choices for receiving more relevant advertising or to manage your settings, please review the information below:
To learn more about managing your privacy and storage settings and opting out from receiving third party advertiser cookies, you may visit the Network Advertising Initiative's opt-out page at http://www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices and follow the instructions on how to opt-out.
If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout/.
We or our service providers may also use Flash cookies (also known as Local Stored Objects) or other similar technologies. A Flash cookie is a small data file placed on a computer using Adobe Flash or similar technology that may be built into your computer or downloaded or installed by you on your computer. We use these technologies to personalize and enhance your online experience, facilitate processes, and personalize and store your settings. Flash cookies may help our website visitors to, for example, set volume preference associated with a video experience, play games, and perform surveys. They help us improve our websites by measuring which areas are of greatest interest to customers. They may be recognized by other websites or by our marketing or business partners. Flash cookies are different from browser cookies and the cookie management tools provided by your browser may not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain features and services that make your online experience more efficient and enjoyable.
2. How We Use Information
We use the information we collect in several ways:
2.1 Contact Information and Personal Identifiers, Payment Information, and Commercial Information
- To facilitate provision of the Platform, including the purchase of goods or services, enable your participation in the SPO Rewards Program, send communications about the Platform and respond to questions or requests.
- To support and enhance your use of the Platform and their features, including without limitation: facilitating your purchase of goods; providing customer service; and otherwise supporting your use of the Platform and its features.
- To identify you as a user in our system, such as when we feel it is necessary to enforce compliance with our Terms of Service or to protect the Platform, retailers, customers, or other individuals; or to facilitate the creation of and secure any accounts you created on our Platform.
2.2 Browsing and Device Information, Location Data, and Demographic Information
- To give you a more enjoyable, convenient shopping experience, learn about your habits, personalize your user experience, and help us identify and/or provide information, products or services that may be of interest to you.
- To serve you ads tailored to your interests or to tailor ads that may be served to you when you visit other websites, mobile applications or social media networks.
- To conduct market research, improve the Platform and help us identify others who may be interested in the Platform.
- We may use the location and Wi-Fi information gathered by our partners to provide specific services, such as offering you a tailored display on the Site and locating a nearby mall when you make such a request. We may also use this information to send you news about the mall, such as promotions from mall retailers, and to provide advertisements about goods and services that may be of interest to you.
2.3 Contact Information and Commercial Information, in Combination with Demographic and Other Data
- To protect the security and integrity of the Platform and our business, including preventing fraud, hacking and other criminal activity, or to meet legal obligations.
- We may use information we collect from you in other ways for which we provide specific notice at the time of collection.
3. How We Share Information
We share your information with others, including our retail partners, for the following purposes:
3.1 Contact Information and Personal Identifiers, Browsing and Device Information; and Demographic Information
- We may share certain Contact Information for you with retailers from whom you make a purchase on the Platform, which will be used to process your order and, in some cases, so that the retailer may provide you with marketing. By using the Platform to purchase from retailers, you are directing that Shop PO intentionally disclose certain personal information to retailers from whom you purchase on the Platform.
- We may store your contact information and commercial information with service providers who help us provide the Platform, for example, hosting the website and operating various features of the Platform and our retail partners.
- We may share personal identifiers, browsing information or demographic information to serve you ads tailored to your interests or to tailor ads that may be served to you on the Site and Apps, as well as other websites and mobile applications, and on social media networks.
- We provide email addresses and browsing information to email and marketing providers as well as analytics services to send email messages and analyze data; provide search results and links and assist in fulfilling your orders.
- If we sponsor surveys, sweepstakes, contests, promotions or other solicitations for third parties, including our retail partners, we may share the information you provide with those third parties.
- We may share certain data, such as your mobile telephone or e-mail contact information, with social media outlets, like Facebook and Instagram, in connection with our agreement to share such information with them, in order to provide more targeted advertisements about goods and services from us or retailers that may be of interest to you.
3.2 Payment Information and Commercial Information
- Your payment and commercial information with retail partners, shipping services and trusted payment processors and other financial vendors who validate, screen for fraud, facilitate, and process credit card transactions, (b) charge and settle credit card transactions, and/or (c) tokenize, vault and store credit card data. We require those third parties to use your information only to process the credit card transactions for us.
3.3 Promotions and Marketing
Occasionally, where permitted by applicable law, we provide our postal mailing list (consisting of customer names and postal mailing addresses, but not email addresses) to retailers and other companies for purposes of marketing the Platform or other products or services that may be of interest to you. In order to determine the information that may be of interest to you, the information that you give us and information about your order may be combined with other personally identifiable information (such as demographic information and past purchase history) available from our records and other sources.
3.4 Your Transactions
We may also share with our retailer partners de-identified segment information, which is information that does not identify you personally, but allows the retailers to know more generally the products being purchased through, and the consumers who are using, the Platform.
3.5 Location Data
We may share location data collected from your ISP or Site via your mobile device with third parties that provide marketing and advertising on our behalf, as well as for our retailers, and who provide analytics services. We may also share aggregate location data with our retail and shopping center partners.
We use analytics services, advertising companies, advertising networks and advertising exchanges to help analyze how users use and navigate the Platform and to engage in advertising on our behalf, on behalf of the retailers for which products and services are available within Shop PO, including contextual advertising and interest-based advertising. These companies may use data about your visits to the Platform and other websites or mobile applications in order to provide advertisements about goods and services that may be of interest to you which are offered by us or by our retailers. Those companies are instructed to follow industry guidelines with regard to interest-based advertising, such as the Digital Advertising Alliance's principles for online behavioral advertising. Among other things, the ads that are displayed to you should have the AdChoices icon or a similar mechanism which you may click to direct you to a website where you may opt-out of interest-based advertising. If you would like more information about this practice and how to opt-out of receiving communications from these third party advertising companies, please visit this link.
3.7 Our Affiliates
We may share personally identifiable or other information with our parent, subsidiaries, divisions, and affiliates and across our various websites, apps and social media pages. This includes Rue Gilt Groupe and Simon Property Group.
3.8 Strategic Partners
3.9 Required By Law or To Protect Interests
3.10 Corporate activity
We may transfer personal information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control.
4. Your Choices
We offer you certain choices about the collection, use and sharing of your information:
4.1 Marketing Communications
You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in the marketing emails. You may change your email address for receipt of by sending an email to email@example.com or submitting a request via our online request form. You may choose to opt out of receiving marketing communications through text notifications in the manner identified when you opt in to receive those notifications.
4.2 Data Analytics
4.3 Interest-Based Advertising
As noted above, we may use the information you provide to us, and information we collect about your use of our products and services, to assist us and our partners in our effort to deliver you online advertising that is relevant to your interests. In connection with these activities, we may work with social media networks and advertising service providers who help deliver these ads to you. For more information, including how you can opt-out, please review Section 1.6 above, Cookie Use. For more information on how Google Analytics collects and processes data, please visit https://www.google.com/policies/privacy/partners/.
4.4 Accessing, Updating and Deleting Your Information
If you are a registered user, you may update your account information, including changing your password, by sending an email to firstname.lastname@example.org or submitting a request via our online request form. We will take commercially reasonable steps to implement your opt-out requests promptly, but you may still receive communications from us for up to ten business days as we process your request.
You may also exercise your rights, where permitted by applicable laws, to request that we delete or restrict access to your personal data. We may need to retain data for legally permitted purposes and this will be explained to you if necessary.
4.5 Data Retention
Personal information that we collect, access or process will be retained only so long as necessary for the fulfillment of the purposes for which it was collected, as necessary for our legitimate business purposes, or as required or authorized by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made de-identified or anonymous.
5. Your California Privacy Rights
If you are a California resident, effective January 1, 2020, California law provides you with the following rights with respect to your personal information:
- The right to know the categories or specific personal information we have collected, used, disclosed and sold about you.
- The right to request that we delete any personal information we have collected about you in accordance with applicable law.
- The right to opt out of the sale of any personal information we have collected about you, where applicable.
To submit a request to know or a request for deletion to us, you may submit an online request via the online request form or by sending an email to email@example.com. You also may designate an authorized agent in writing to make a request on your behalf.
When you exercise these rights and submit a request to us, and depending on the nature of your request, we will verify your identity by asking you for the email address attached to your account, your billing address and the last four digits of a credit or debit card on file. We also may use a third-party verification provider to verify your identity.
We will not discriminate against you because you exercised any of these rights.
We do not sell personal information as we understand that term is defined under the California Consumer Privacy Act.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for their direct marketing purposes. To request a list of the names and addresses of third parties to whom we disclosed such information during the preceding calendar year along with a list of the categories of information disclosed, please send an email to firstname.lastname@example.org or write to us at the following address:
Shop PO, LLC
20 Channel Center
Boston, MA 02210
Attn: Legal Department
6. Information Security
We endeavor to protect the security of the information collected through the Platform and implement generally accepted standards of information technology security designed to protect information from loss, misuse and unauthorized access, disclosure, alteration or destruction. It is not possible, however, to guarantee the security or integrity of information disclosed online due to, among other things, technological limitations and the fact that no data accessible through or transmitted via the Internet is completely secure. Platform orders involve processing of data by third parties, such as retailers, online gift card providers, credit card processing companies, fraud detection service providers, issuing banks, card network issuers, shipping/fulfillment companies, and other parties in order to complete an order. Those parties with which we contract are required to maintain reasonable measures designed to safeguard the security of the data they process; however, we do not otherwise have control over and are not responsible for their handling of such data.
Your credit card and other personal information is protected using secure socket layer (SSL) or similarly secure technology to provide for the secure transmission of the information from your PC or device. In addition, only those employees and third parties who need access to your information in order to perform their duties are allowed such access.
We also require you to enter a password to access your account. We recommend that you not disclose your password to unauthorized people.
Links to Other Sites
7. Non-U.S. Residents and Transfer of Your Information
Residents of other countries outside the U.S., such as the European Union, may have other rights. As stated in our Terms of Service, while you may be able to setup an account as a user outside the U.S., we make no assurances or representations of any kind that the Platform is suitable for use in the country in which you reside. Your personal information may be transferred to the United States or another country which may not have the same data protection laws as the country where you reside and such information may be available to government authorities under lawful orders and as applicable in such foreign jurisdictions. You consent to any such cross-border transfer of your personal information.
8. Your Right to Lodge Complaints
We are transparent about the ways in which we collect and use personal information and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us at email@example.com.
To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.
10. How to Contact Us
Shop PO, LLC
20 Channel Center
Boston, MA 02210
© 2018 - 2021 Shop PO, LLC. All Rights Reserved.