Privacy Policy and Notice of Personal Information Collection

Last updated: December 22, 2022

  1. Collection of Information
  2. Use of Information We Collect
  3. Disclosure of Information
  4. Your Choices
  5. Your Privacy Rights
  6. Privacy Rights Applicable to UK Users
  7. Data Transfers
  8. Other Notices
  9. Privacy Policy Changes
  10. Contact Us

This Privacy Policy describes how ShopStyle Inc. ("we," "us," "our," "Company") collect, use, disclose, and protect information in connection with the Company websites, mobile websites, mobile applications, and any related services that refer or link to this Privacy Policy ("Services"). ShopStyle is part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company Rakuten Group, Inc., based in Tokyo, Japan.

1. COLLECTION OF INFORMATION

SOURCES OF COLLECTION

We collect 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 or business partner site or when information is shared by merchants and business partners with whom you have also interacted.

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 automatically 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
    • 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 came to our Services
  • Geolocation, (non-precise), to the extent you have configured your device to share such information with us, and locale preferences you indicate for your use of the Services
  • Account credentialssuch as usernames, passwords
  • Inferences drawn about you and your likely preferences, characteristics, behavior, and attitudes from any information we collect about you.

We do not collect any “special category” data per the UK General Data Protection Regulation (UK GDPR), or types of information considered “sensitive” personal information under applicable U.S. state privacy laws.

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, including to:

  • Process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our program
  • Manage your account, including managing your favorite stores, products, brands, looks, and influencers
  • Track your shopping and identify opportunities for rewards and/or offers
  • 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
  • Administer contests, sweepstakes, or promotions you enter, including to determine your eligibility to win a prize.

To Improve Our Services

We use information we collect about your use of our Services to identify site 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. We use the feedback you provide or submit in polls or surveys to provide us aggregated and deidentified insights on business and shopping trends, which we use to improve the product offerings on our services as well as our stores, brands, and collections. Where we deidentify information, we maintain it in that format and do not attempt to reidentify it.

To Personalize Our Services

We use information we collect about your activity in relation to our Services to create a profile of your preferences to personalize and tailor Services content, including offers and discounts, so that it is more likely to be of interest to you, subject to your consent where required. For example, we may use your recent search or purchase history to display more relevant offers and stores within the Services.

To Provide You Direct Marketing and Targeted Advertisement Information

We use your personal information to send you newsletters, rewards, discounts, promotion codes, events, and general promotional information about the Service and we may also use your information to advertise to you online, including targeting advertising to you on other websites, each to the extent permitted by applicable law and/or subject to your consent or right to opt-out. You can manage direct promotional communications in accordance with Section 4 (Your Choices) below, and manage our use of your information for targeted advertising as provided in Sections 5 and 6.

To Detect Fraud and Improve Security

We use collected information to assess risk related to online security and to investigate and limit fraud, spam, and other malicious online activities in our Services, and to improve our security measures.

To Protect and Assert our Legal Rights and Comply with our Legal Obligations

We may use collected information as necessary to assert our legal rights or to defend our legal rights against third parties in the event of a lawsuit or other legal or regulatory action. We also use your location information to ensure we apply the appropriate practices and handling of your information according to the data protection laws of your jurisdiction.

3. DISCLOSURE of INFORMATION

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 disclose all categories of your personal information as necessary to our service providers (which may include third parties and Company affiliates) who perform various business operations 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 customer support services, authentication services, prevent fraud on our Services, administer our promotions, sweepstakes, and surveys, perform analytics, and manage our databases.

Disclosure to Our Affiliate Partners

We work with various affiliate networks to offer our Services. We may disclose the following types of information to such affiliate networks. For UK users, this disclosure and usage will occur only with your consent and you may update your preferences at any time by following the instructions in Section 6 below.

For non-UK users, when you click on a link to a merchant site presented on our Services to start a shopping trip, you evidence your intent to interact with that business through our Services, and thereby are directing us to disclose certain information about you (including the link you clicked in our Services and a unique ID assigned to track that your shopping originated from our Services) to an affiliate network to properly account for your purchases. For a small number of merchants that do not utilize an affiliate network, this information is provided directly to the merchant. The Affiliate Partner will collect Internet and Network Activity information about your use of our Services in relation to the merchant site, products, or offers. Our Affiliate Partners collect this information to track the shopping trip, but some of them may also use this information to contribute it to their own user profiles and/or combine it with information they collect elsewhere, which they may make available for use by their other business clients. In such cases, our disclosure to certain of these Affiliate Partners could be considered a “sale” or “sharing” of your personal information as those terms are defined under applicable U.S. state privacy laws, and the opt-out we offer to consumers in Section 5, below, would signal these Affiliate Partners to not collect or use your information from our Services except as necessary to validate and provide your Cash Back.

Rakuten Group Companies

We work closely with our affiliated businesses and companies within the Rakuten Group and disclose your personal information to them for our internal business administration.

If you are accessing the Services from the United States, we work with our sister company, Ebates Performance Marketing, Inc. dba Rakuten Rewards (“Rakuten Rewards”) to make those cash back offers available to you. When you elect to join cash back or sign up for a ShopStyle account via www.shopstyle.com, ShopStyle will disclose your email address to Rakuten Rewards in order to facilitate the connection or creation of your cash back account on www.rakuten.com. By electing to join cash back, you are also agreeing to the Rakuten Rewards terms and conditions and privacy policy. Information relating to shopping trips that you start on our Services (such as retailer, offer type, date and time of the click) may be used to administer your cash back and to personalize offers and content for you in accordance with this privacy policy and the Rakuten Rewards privacy policy.

Disclosure to Digital Advertising Providers

To provide us with targeted advertising and marketing services, we partner with certain third parties that automatically collect Internet and Network Activity information about your use of the Services, such as your browsing history, IP address, pages viewed, and links clicked, so that they can use this information to serve you ads for our Services on other sites you visit. Some of these third parties may also further use this collected information for their own purposes. For UK users, this sharing is subject to your consent to third-party marketing cookies in our Cookie Banner or Consent Preference Center. For non-UK users, you have the right to opt out of our sharing of your information with certain third parties for the purposes of cross-context behavioral or targeted advertising. To exercise this right, you can opt-out via the instructions in Section 5, below. Note that this Privacy Policy covers only our use and sharing of your data. If you wish to opt out of interest-based advertising in general, please visit http://www.aboutads.info/choices/

Disclosure for Legal Purposes

We may disclose the information we collect, including personal information, to the extent permitted by the data protection laws applicable in your jurisdiction, (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

We may disclose the information we collect, including personal information, to any third party in connection with, or during confidential negotiations of, any proposed or actual merger, purchase, sale (including a liquidation, realization, foreclosure or repossession) or any other type of acquisition of all or any portion of Company assets, conveyance or transfer of all or a portion of our business to another company. In such event, the acquiring company would be contractually required to use your collected information in accordance with this Privacy Policy and applicable law or to provide prior notice to you of any new or materially changed practices.

For UK visitors, Legal basis for using your Personal Information

If you are a visitor from the United Kingdom (“UK”), 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, and may include the following:

  • Performance of a contract. The use of your personal information may be necessary to provide you our Services and meet our obligations as set forth in our Services terms and conditions and other policies under which we provide our Services.
  • Consent. We will rely on your consent to use (i) technical information such as cookie data and geolocation data; and (ii) your personal information for direct marketing, personalization, and targeted advertising purposes. You may withdraw your consent at any time by adjusting your cookie preferences in our Privacy Preference Center (for cookie data) or following an unsubscribe link in any marketing communication you receive from us (for direct marketing). If you have any issues with these methods, please contact us using the information at the end of this Privacy Policy.
  • Legitimate interests. We may use your personal information to serve our legitimate interests in operating our platform, managing your account, improving our Services, communicating with you and responding to customer service queries, providing security and preventing fraud other illegal acts on our site and Services, protecting our legal rights and complying with our legal obligations, and sharing information with our affiliates for internal administration. In such circumstances it is for us to ensure that these interests do not override your data protection interests or fundamental privacy rights and freedoms.

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.

Communications Preferences

Email Messaging

We may send you periodic electronic communications and direct mailings for administrative purposes when you sign up for an account and/or, subject to your consent or opt-out, for promotional purposes. You can opt out of receiving promotional communications from us at any time by following the instructions provided in those communications to unsubscribe or 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 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 PRIVACY RIGHTS

You have certain rights regarding your personal information based on applicable local laws, which may include the following rights:

To Know and Access your personal information/data portability

You have the right to know the categories and elements of personal information about you that we collected, used, disclosed for a business purpose, sold and shared for the purposes of cross-context or targeted advertising, including the categories of sources from which we acquired your information and the categories of third parties to whom we disclosed your information. You have the right to request that we send you (or another organization, under certain conditions) a copy of your personal data we process, in a readily usable and portable format.

To Rectify or Correct the information we hold about you

You have the right to request that we correct any personal information about you that is factually inaccurate or complete any personal information that is incomplete.

To Erase or Delete your personal information

You have the right to request that we erase or delete your personal information we collected from or maintain about you. We will delete your personal information upon such request, except to the extent we determine that we need the information for a business purpose and have a legal right to maintain it, or if an exception applies, in which case we will inform you of that legal exception.

To Opt-out of Sale or Sharing of Your Personal Information or Use for Targeted Advertising

You have the right to opt out of certain disclosures of your personal information that may be considered “selling”, “sharing”, or processing for the purpose of “targeted advertising” under applicable U.S. State privacy laws. If you would like to opt-out of having your personal information disclosed or processed in this way, please click the link below to visit the Privacy Preferences Center:

DO NOT SELL OR SHARE MY PERSONAL INFORMATION / PERSONAL DATA OPT-OUT

To Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights.

Unless otherwise permitted by applicable law, we will not do any of the following because you request to know, access, correct, or delete your information or opt out of its sale, sharing, or processing for the purposes of targeted advertising:

  • deny you goods or services
  • charge you different prices or rates for goods or services, including through granting others or denying you 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.

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 the functionality 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.

How To Exercise Your Rights to Know, Access, Correct, and Request Deletion:

To assert your privacy rights please visit the Privacy Preferences Center. To verify your identity, we will ask you to login to your account. If you do not have an account or 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 laws of certain jurisdictions, 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 prove that you authorized this agent to submit a request on your behalf, and we may require you to independently verify your identity.

Right to Appeal

You may have the right to appeal our decision regarding your privacy rights request, depending on your state of residence. You may submit an appeal request by contacting us through the details provided in the Contact Us section, below. We will respond according to the law applicable in your location.

6. PRIVACY RIGHTS APPLICABLE TO UK USERS

If your personal information is subject to the protections offered by UK privacy law, you may:

  • Request to access, correct, update, delete or receive in a portable format your personal information that we hold, at any time by contacting us using the information provided in the Contact Us section below, or by updating your account profile at https://www.shopstyle.co.uk/my/profile and your privacy preferences at https://www.shopstyle.co.uk/privacy/preferences
  • Object to processing of your personal information or ask us to restrict processing of your personal information You have the right to request that we limit or restrict our processing of your personal information, under certain circumstances.
  • Withdraw your consent at any time if we have collected and process your personal information based on 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 UK at https://ico.org.uk/global/privacy-notice/how-you-can-contact-us/)

To exercise any of these rights please contact us in accordance with the contact details set forth in the Contact Us section, below, or by updating your preferences at https://www.shopstyle.co.uk/privacy/preferences.

7. DATA TRANSFERS

If you are visiting our site from the UK or other regions with laws governing cross-border transfer of personal data, please note that your personal information may be transferred for the purposes described under this Privacy Policy for processing in the United States and in other countries with less rigorous data protection laws than your jurisdiction. We take great care in protecting your personal information and have put in place adequate mechanisms to protect it when it is transferred internationally, including Standard Contractual Clauses. As part of the Rakuten Group, we rely on the Rakuten Binding Corporate Rules,found at https://corp.rakuten.co.jp/privacy/en/bcr.html, to legitimize international data transfers of UK data within the Rakuten Group.

8. 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.

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 or share 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 if an exception applies, or 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 your expectations 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.

9. CHANGES TO PRIVACY POLICY

This Privacy Policy is current as of the date set forth above. We reserve the right to change this Privacy Policy from time to time consistent with applicable privacy laws and principles and our practices in relation to personal information. If we make changes to this Privacy Policy we will notify you by revising the date at the top of this Privacy Policy. In the event of a material change, and where such changes will impact you as a data subject, we will provide you with additional notice (such as adding a statement to the homepages of our Services or sending you an email notification).

10. CONTACT US

If you have any questions regarding this Privacy Policy, please feel free to contact us by email at [email protected] or by mail at ShopStyle Inc., 800 Concar Drive, Suite 175, San Mateo, CA 94402, ATTN: ShopStyle Legal.