Last Updated: July 1, 2020
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. During the past twelve months, 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), social media user names, and telephone number(s), including your mobile phone number(s).
- Payment Information: If you make purchases via the Platform, we may collect your credit card number, expiration date, CVV code, and billing address but do not store your credit card number.
- 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 Services 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 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 or making a purchase. Once you register, you have opted in to receive electronic communications from us, unless you were prompted to indicate consent to such communications at the time of registration in accordance with the applicable law in the country where you reside.
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.
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 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 or 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.
- 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 e-mailing firstname.lastname@example.org. 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 App 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.
Do Not Track. Do not track is a voluntary program among Internet advertisers that is intended to give users the ability to opt-out of interest-based advertising. There are a few ways in which your computer may transmit a "do not track" signal to certain websites and online services you visit, and currently no standard has been established. We do not respond to do not track signals, and the settings in your browser will have no effect on the Site.
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
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, 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.
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; and
- 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; and
- 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 for the following purposes.
3.1 Contact Information and Personal Identifiers, Browsing and Device Information; and Demographic Information
- 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 our website and mobile application, 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 such communications by going to My Account. 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
4.4 Accessing, Updating and Deleting Your Information
We respect your right to access and correct your personal information. If you are a registered user, you may access and update your registration information through your MyAccount page. You may also manage your preferences to receive email or other communications from us by sending an email to email@example.com. 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 what 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.
You can make this request by contacting the retailer(s) with whom you made your purchase on the Platform. If you are unable to identify or contact the relevant retailer, you can also contact us and we may be able to assist you with your request. To submit a request to know or a request for deletion to us, you may send an email to firstname.lastname@example.org. 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 member 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 email@example.com 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, ticket agents, 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
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 firstname.lastname@example.org.
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 - 2020 Shop PO, LLC. All Rights Reserved.