Updated: Oct 5, 2020
1. Collection of Information
2. Use of Information We Collect
3. Sharing Information
4. Your Choices
5. Your rights regarding your personal information
6. Other Notices
8. Contact Us
1. Collection of Information.
Sources of CollectionWe collect, process, and use your information about you when you:
• Register for our Services
• Interact with our Services
• Install and/or access our Services through our application(s), including our mobile application
• Connect to our Services using third party accounts, such as social media and email accounts
• Contact us for support
• Enter a sweepstakes, contest, promotion, or respond to a survey or poll
We collect certain information when you submit or provide it to us directly. When you have installed our mobile application or when you interact with our Services online, we also automatically collect information about you and your use of the Services through the use of log processes, cookies, location-identifying technologies, and other tracking technologies. Certain information is collected about you from third parties, such as when you connect through a third-party service.
Types of Information We May Collect
The types of information we collect about you may include personal information of the following types:
• Identifiers that you provide us directly, such as your first and last name, username, email address, postal address, location, tax information (for sweepstakes, contests, and promotion winners in the United States)
• Identifiers, collected through your use of the Services, such as unique online or device identifiers, IP address, device or session IDs and information regarding your system configuration (operating system and version), network, and connected hardware (e.g., computer or mobile device and carrier)
• Customer Record Information, such as payment account number, payment card expiration date, and billing address
• Commercial Information about you, such as records of products or services purchased, obtained, or considered by you, including products, merchants, and deals you searched for, viewed, or clicked, product types, merchant sites visited from our Services, merchant types, transaction history related to our Services, purchase confirmation data, preferred gender category of clothing, favorite stores, brands, products, influencers, and looks, Sale Alerts you set, and Searches you save, and accrued cash back (United States users only)
• Internet and other Network Activity, such as browsing and search history and your interactions with our Services, including:
• Products, coupons, offers, or merchants you search, click, favorite, and/or view, including clicks you make on merchant sites you visit within our mobile app,• Geolocation, to the extent you have configured your device to share such information with us, and locale preferences for your use of the Services.
• URL’s of pages you visit,
• Date and time stamps associated with such browsing, searches, and clicks, and
• Click stream data, meaning the page by page clicks that you make as you navigate through our Services, including the web page visited before you can to our Services.
• Inferences drawn about you and your likely preferences, characteristics, behavior, and attitudes from any information we collect about you.
2. Use of Information We Collect.
We use information we collect about you for the following business and commercial purposes:
To Provide Our Services and Manage Your Account
• Process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our programs
• Manage your account, including managing your favorite stores, products, brands, looks, and influencers
• Track your shopping and identify opportunities for rewards and/or offers
• Facilitate and manage your purchase transactions
• Send you technical notices, updates, security alerts, and administrative messages
• Provide you customer service regarding your account and reply to your questions, comments, and requests
To Personalize and Improve Our Services
We may use information we collect about you to create a profile of your preferences to personalize and tailor Services content so that it is more likely to be of interest to you. For example, we may use your recent search or purchase history to display more relevant offers and stores within the Services. Data collected from a browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected (also known as cross-linking). We may also use information we collect about you to identify usage trends and perform statistical analyses to improve our Services, websites, applications, and marketing efforts to provide a better service to you in the future.
To Provide You Marketing and Advertisement Information
To the extent permitted by applicable law or subject to your consent, we may use your personal information to provide you more personalized offers and/or special offers, discounts and similar information, and to send you newsletters, rewards, discounts, promotion codes, events, and general information about the Service. You can manage these communications in accordance with Section 4 (Your Choices) below. To the extent permitted by applicable law or subject to your consent or right to opt-out, we may also use your information to advertise to you online, including targeting advertising to you on other websites.
To Protect You, Others, and our Business
We may use collected information to assess risk and to investigate and limit fraud, spam, and other malicious online activities in our Services, and to improve our security measures. We may also use collected information to assert our legal rights or to defend our legal rights against third parties.
To Comply with Applicable Laws
We may use information we collect about you to enable us to comply with applicable laws, rules, regulations, and judicial authorities in each geographical region in which we operate.
To administer Contests, Sweepstakes, Surveys, Polls, and Promotions
From time to time, we may invite you to enter sweepstakes, contests, promotions, surveys, or polls. If you choose to participate in a contest or promotion, your personal information may be used to administer the contest, such as to determine your eligibility for the contest or to award a prize. If you choose to participate in a survey or poll, the feedback you submit will be aggregated and deidentified to provide us insight on business and shopping trends.
3. Sharing Information.
Disclosure for Business and Commercial Purposes.We may disclose the below-specified categories of information for our business or commercial purposes, including the following:
Disclosure to our Service Providers
We may share all categories of your collected personal information as necessary with our third-party service providers (which may include Company affiliates) who perform various business operations, solely for our benefit or on our behalf, under our instructions and in compliance with appropriate contractual, technical and organizational security measures to protect your data from unauthorized use, retention, or disclosure. For example, we may partner with other companies to provide you support services, authentication services, prevent fraud on our Services, administer our promotions, sweepstakes, and surveys, perform analytics, and maintain the accuracy of our databases.
Rakuten Group Companies
We work closely with our affiliated businesses and companies within the Rakuten Group and share your Personal Information for our internal business administration. We may also share your account credentials (username, email address, encrypted password) and related personal identification (first and last name and address) and other personal information with the Rakuten Group for internal business administration and to improve their websites, applications, marketing efforts, and products and services.
Disclosure to Digital Advertising Providers
Disclosure for Legal Purposes
We may share the information we collect, including personal information, to the extent permitted by applicable law, (i) in response to subpoenas or other legal processes or if, in our good faith opinion such disclosure is required or permitted by law without a specific disclosure; (ii) at the request of governmental authorities conducting an investigation; (iii) to enforce our terms and conditions or other policies applicable to our Services; and (iv) to protect the rights, property, life, health, security and safety of Company or any third party.
In Relation to Business Asset Transfers
For EU/EEA visitors, Legal basis for using your Personal Information
If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. For the European Economic Area, there are different legal bases that we rely on to use your Personal Information:
• Performance of a contract. The use of your Personal Information may be necessary to perform the terms and conditions or other policies under which we provide our Services.
• Legitimate interests. We may use your Personal Information for our legitimate interests to improve our Services, security purposes, and fraud prevention, and to share information with our affiliates for internal administration. In such circumstances it is for us to ensure that these interests are not overridden by your data protection interests or fundamental rights and freedoms. If we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), this interest will normally be for to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
4. Your Choices.
Updating Account Information
We encourage you to maintain the accuracy of the information you submit to us. You may provide account updates by logging into your Service account and updating your information in the Settings.
By signing up for an account or if you consent, you may receive periodic electronic communications and direct mailings from Company. You can opt out of receiving promotional communications from us at any time by following the instructions provided in those communications to stop them, modifying the settings of your account, or contacting us through the Services. Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails and other types of communications, as permitted by law, such as service emails relating to our ongoing business relationship. Service emails contain service-related announcements that affect your account, such as product order confirmations, reward or payment updates, and responses to your comments and feedback submitted to us.
Mobile Application Notifications
When using our mobile application, your preferences for receiving push notifications and other mobile alerts can be configured in the settings of your mobile device.
5. Your rights regarding your personal information.
Your privacy rights
You have certain rights regarding your personal information based on applicable local laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act of 2018 (CCPA) where applicable, which may include the following rights:
• To Access your personal information/data portability – You have the right to request that we send you (or another organization, under certain conditions) a copy of your personal data in our possession, in a readily usable and portable format.
• To Rectify the information we hold about you – You have the right to request that we correct any information you believe is inaccurate or complete any information you believe is incomplete.
• To Erase or Delete your personal information – You have the right to request that we erase or delete your personal information under certain conditions or subject to certain legal exceptions.
• To Restrict our processing of your personal information – You have the right to request that we restrict our processing (collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, making available, alignment or combination, restriction, erasure or destruction) of your personal information, under certain circumstances.
• To Object to our processing of your personal information – You have the right to object to our processing of your personal data, under certain circumstances.
• To Opt out of certain sharing of your personal information that California law defines as a “sale,” including our selling, renting , releasing, disclosing, disseminating, making available, transferring, or otherwise communicating your personal information to another business for monetary or other valuable consideration.
• To Lodge a Complaint with your local data protection authority, as set forth below. • To Non-Discrimination – We will not discriminate against you for exercising any of your privacy rights by denying you goods or services, charging you different prices or rates for goods or services, including through granting others or denying you discounts or other benefits or imposing penalties, providing you a different level or quality of goods or services, or suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services if you exercise your rights to access or delete your personal information or opt-out out of its sale.
• To Modify Your Data Collection Preferences - You may in some cases have the option to decline to provide us with certain information; however, your choice may impact your use of certain features or services for which that information is a necessary component.
• You can prospectively stop all collection of information by our mobile application by uninstalling our mobile application. Because installation of the mobile application permits our data collection about your online behavior on that device, even without your interaction with the application, it must be uninstalled to completely withdraw your consent to this data collection. In some instances, you can opt out of certain data collection by updating your Settings within your mobile device settings.
Rights Applicable to California Residents
This section applies only to California Residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), if you are a California resident, you have certain rights in relation to your personal information, subject to certain exceptions.
Right to Request Deletion: You have the right to request that the Company delete any personal information we have collected from you or maintain about you, subject to certain exceptions. If you request that we delete your personal information, we will do so except to the extent we determine that we need the information for a business purpose and have a legal right to maintain it, in which case we will inform you of that legal exception.
How To Exercise Your CCPA Rights to Know, Access, and Request Deletion: To assert your CCPA privacy rights please visit the Privacy Preferences Center. To verify your identity, we will ask you to login to your account. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. Please note that under the CCPA, we are not required to respond to requests to know and access your information more than twice within a 12-month period.
Agents. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. For any agent making a request on your behalf, we may require you to provide proof that you authorized this agent to submit a request on your behalf or that he or she has power of attorney in connection with your request to know, access or delete your personal information, and we may require you to independently verify your identity or log in to your account to provide the access code.
Right to Opt-out of Sale of Your Personal Information: To the extent that we receive monetary or other valuable consideration for sharing or providing access to information about you with our merchant partners, third parties or affiliates in order to provide you rewards and benefits and for our targeted marketing purposes, the CCPA may deem this a “sale” of your personal information. You have a right under California law to opt-out of our “sale” of your information in this way. If you would like to exercise your right to opt-out of having your personal information shared in this way, please click DO NOT SELL MY PERSONAL INFORMATION to visit the Privacy Preferences Center. Please note that to the extent you opt-out we may be unable to offer you some of our services which require such sharing of your Personal Information.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless otherwise permitted by the CCPA, we will not do any of the following because you request to know, access, or delete your information or opt out of its sale:
• 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, or
• suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
Rights Applicable to EU Users
Choices under EU law
If your Personal Information is subject to the protections offered by EU law, you may:
• Access, correct, update or request deletion of your Personal Information, at any time by contacting us via the Contact information provided in Section 9, below or by updating your account profile here and your privacy preferences here;
• Object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information; and
• Withdraw your consent at any time if we have collected and process your Personal Information with your consent.
• Complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including US and Canada) are available here.)
To exercise any of these rights please contact us in accordance with the contact details set forth below in Section 9, below or by updating your preferences here. Please note that if you are not subject to EU law, these rights do not apply to you.
For all persons except EU visitors and California Residents: To exercise any privacy rights you may have, please contact us via the contact information listed in Section 9, below.
6. Other Notices.
Shine the Light. California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. We do not share your information with third parties for their direct marketing purposes.
Do Not Track. Company does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to monitor and review new technologies and will modify this policy accordingly in the event of a change.
Notice regarding information of minors. This site and any related services are intended for adults 18 years of age or over, and we do not knowingly collect or sell personal information of consumer under 18 years of age without affirmative authorization or without verifiable opt-in consent from a parent for those under age 13.
Retention of Data. We may retain information about you for as long as it is necessary to fulfill the purposes described Section 2. Some of your information may be retained in our systems even after you request your information to be deleted in order to comply with our obligations under applicable law, collect fees owed, resolve disputes, enforce our legal rights, otherwise use internally in a lawful manner that is reasonably aligned with the expectations of the consumer or compatible with the context in which the information was provided, and to undertake any investigations necessitated by the foregoing.
Information Security. We have implemented technical and organizational measures to provide a level of security appropriate to the risk to the Personal Information that we process. These measures are aimed at preserving the ongoing integrity and protecting the confidentiality of users’ Personal Information. We evaluate these measures on a regular basis to confirm that they continue to maintain and apply an appropriate level of security.
8. Contact Us.