Gilt Privacy Notice

Last updated December 30, 2022

CONSUMER DATA PRIVACY

If you are a California resident, please refer to your California Consumer Privacy Rights in Section 11. Residents of other states may also have rights regarding the use of their personal information, as addressed under Consumer Privacy Law in Section 11 below.

GLOBAL DATA PRIVACY

Thank you for visiting Gilt, which is operated by Gilt Groupe, LP ("Gilt"). We are committed to providing an exciting and safe online shopping experience and an elevated level of personal service synonymous with Gilt. This commitment includes respecting and protecting the privacy of your personal information.

This privacy policy describes the types of information we collect from and about you when you visit our website (each a "Site") or use our mobile applications (each an "App”). The Sites and Apps are collectively referred to as the "Services." This privacy policy also explains how Gilt may use and share your personal information, as well as your ability to control certain uses of it. If you have difficulty accessing or reading this Privacy Policy, you may access a PDF version here.

You agree that your use of the Services signifies that you have read and consent to the collection, use, and disclosure of your information as described in this privacy policy, including the transfer to and storage of your personal information in the United States, and agree to the Terms of Use which are incorporated by reference. If you do not agree, please do not access or use the Services.

1. WHAT INFORMATION DOES GILT COLLECT?

To provide the Services and first-class shopping experience, we collect information from and about you. During the past twelve months, that information may include the following categories of information:

Contact Information and Other Personal Identifiers:	This may include your name, email address(es), postal address(es), social media usernames, and telephone number(s), including your mobile phone number(s).
Payment Information:	If you make purchases via the Services, 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 collect your order and payment history.
Browsing and Device Information:	We may collect your IP address or another device identifier, the kind of browser you use, browsing information such as the pages and content that you visit, 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 about your lifestyle and retail interests.
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 Gilt 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. Please read Sections 5 and 6 for additional information regarding data collected via cookies and your options relating to cookie use.

Information From Gilt's Interactions With You: Registration with us is mandatory to place orders and fully use the Services. During the registration process (whether on our website or through downloading the mobile application), we collect personal information such as your name, email address, or social media username. 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.

We also collect personal information when you choose to use certain other aspects of the Services, such as making purchases; electing to receive text messages about upcoming boutiques; promotions or events; or if you provide it in response to surveys, contests, sweepstakes or other requests. When you choose to use these additional features, we may require you to provide additional personal information such as your phone number, billing and shipping addresses, and credit card information, and we may request additional personal information such as your shopping preferences and demographics.

We may collect other information that you submit to us or that you have consented to permit us to collect or third parties to share with us from time to time.

Automatically on the Site or App: In addition, we use technologies such as pixels and JavaScript to automatically gather certain information about your use of the Services, such as your IP address, operating system, browser type, and date/stamp time for your visit. If you use our mobile applications, this may include information such as geo-location data (e.g., through GPS, Bluetooth, Wi-Fi, or other means) and device information, such as your MAC address, for the handheld mobile device on which the mobile application is installed. We may collect other information that you have consented to permit your mobile phone or application to share with us from time to time.  If you sign up for our text messaging program, cookies may be used to personalize your experience (e.g., send you personalized text messages such as shopping cart reminders).

From Third-Party Sources: We may work with third parties to collect and analyze the information as described above and for other purposes described below.

If you access our Services through other websites on which we have "stores" (e.g., eBay), we will collect and analyze the information described above that is obtained through your interaction with those websites. We may add this information to the information we have already collected from you via other aspects of the Services. You are also subject to such "store's" terms of use and privacy policy in connection with these Services.

If you access our Services with your login credentials from a social networking site (e.g., Facebook or Twitter) or if you otherwise agree to associate your Gilt account with a social networking account, we may receive personal information about you from such social networking site, in accordance with the terms of use and privacy policy of the social networking site. For example, Facebook may share with us your friend list, birthday, information about the interests of you or your friends, or other personal information, to help us establish your account, tailor the Services to you and find other current or potential Services users that you know. We may add this information to the information we have already collected from you via other aspects of the Service. You are also subject to the social networking site's terms of use and privacy policy. We use the OAuth (open authorization) protocol to enable us to access this information without collecting your password when you agree to allow another application to access your account information.

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 Services and deliver advertising or other promotions targeted to your specific interests on our websites and mobile applications 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 DOES GILT USES YOUR INFORMATION?

Gilt may use the information we collect from and about you for any of the following purposes:

Contact Information and Personal Identifiers, Payment Information, and Commercial Information:	To facilitate the provision of the Services, including the purchase of goods or services, send communications about the Services and respond to questions or requests;
	To support and enhance your use of the Services and their features, including without limitation: fulfilling your order; providing customer service; tracking email invitations you send; and otherwise supporting your use of the Services and its features.
Browsing and Device Information 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 Services and help us identify others who may be interested in the Services.
Contact Information and Commercial Information, in combination with Demographic and Other Data:	To protect the security and integrity of the Services and our business, including preventing fraud, hacking, and other criminal activity, or to meet legal obligations; and
	We may use the information we collect from you in other ways for which we provide specific notice at the time of collection.

3. HOW DOES GILT SHARES YOUR INFORMATION WITH OTHER

Gilt may permit certain trusted service providers to access your information in connection with their performance of services to maintain and operate our websites and mobile applications.

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 deliver the Services, for example, hosting the websites and mobile applications and operating various features of the Services.
	We may share personal identifiers, browsing information, or demographic information to advertising providers 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.
Payment Information and Commercial Information:	Your payment and commercial information with trusted payment processors, merchandise vendors, and shipping services who help process and fulfill orders.

Certain areas of the Services may be provided to you in association with service providers and third parties, such as companies that provide products and services, rewards programs, conduct joint sales programs, sweepstakes, promotional campaigns, and other jointly sponsored events. Such Services will identify the third party. If you elect to register for any products and/or services provided during the Services, you either will be providing your information to both Gilt and such third party, or Gilt might share your information directly with such third party for that third party to fulfill their products and our products and services directly with you.

We may share collected information within Gilt Groupe LP’s affiliated companies and any future additions to Gilt Groupe, LP’s family of affiliated companies.

Other Third Parties: Where permitted by applicable law, Gilt may share your information with select partners, affiliates, and other third parties that we believe may have offers or be of interest to you. Some of these strategic relationships may include operating a co-branded website or web pages with a strategic partner. You should be aware that these co-branded sites may collect different or additional information. Additionally, we may provide links to websites controlled by third parties. We have no control over these websites and our privacy policy does not apply to these third-party websites. Please consult the privacy policy of the website you are visiting. Also, as part of providing the Services, we may share personal information or other information with our parent, subsidiaries, divisions, and affiliates and across our various websites, apps, and social media pages. Occasionally, where permitted by applicable law, we provide our postal mailing list (consisting of member names and postal mailing addresses, but not email addresses) to other companies for purposes of marketing the Services or other products or services that may be of interest to you. If you post, use any bulletin board, chat room, or any other publicly accessible area of our websites or mobile applications that we may make available, you should be aware that any personal information you submit there can be read, collected, or used by any person for any purpose. We are not responsible for the personal information or other information you choose to submit in these forums.

Legal Disclosures; Safety: Gilt may transfer and/or disclose the information we receive from and about you to comply with a legal obligation; to provide information to law enforcement and other governmental authorities in accordance with applicable law, and when we believe in good faith that the law requires it. We also reserve the right to share information with legal authorities and other companies for fraud protection and credit risk reduction, to detect any technical or security vulnerabilities, to enforce our Terms of Use or other applicable policies, or to otherwise protect the rights, property, safety, or security of third parties, users of the Services, Gilt, or the public.

Sale of Business: During the normal course of our business, we may sell or purchase assets. If another entity acquires all or a part of Gilt Groupe, LP or its family of affiliated companies, all or a portion of the information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against Gilt Groupe, LP or its family of affiliated companies, such information may be considered an asset of such company and may be sold or transferred to third parties. Should a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personally identifiable information provided through the Services in a manner that is consistent with this Privacy Policy.

Aggregate or Anonymous Non-Personal Information: We may also share or sell non-identifiable aggregate or anonymous information with our affiliates, agents, service providers, business partners, or other third parties for their marketing or analytics uses or for other lawful purposes. This type of non-identifiable and aggregate information cannot be used to identify you personally.

4. WHAT ABOUT CROSS-BORDER TRANSFERS OF YOUR INFORMATION?

Except as expressly provided herein, this is a U.S. website subject to U.S. laws, including those governing privacy and data security, and we will protect your information as described in this Privacy Policy. When we obtain information about you, we and our service providers and partners may process the information outside of the country where you are located, including in the U.S. These countries may not have the same data protection laws as the country in which you are located, and such information may be available to government authorities under lawful orders and as applicable in such foreign jurisdictions. However, we and our vendors have implemented reasonable measures to protect your information, as described in this Privacy Policy. You consent to any such cross-border transfer of your personal information.

5. HOW DOES GILT USE COOKIES AND TARGETED OR BEHAVIORAL ADVERTISING?

Cookies

We and our vendors may use technology such as cookies and web beacons in connection with the Services to identify you when you are online and to collect information about your online activities, such as the type of browser you use, the websites you visit and the content and advertising that you find interesting.

Cookies are small text files that may remain on your computer's hard drive for a period of time that may be used to maintain data relevant to your navigation of the Internet, save personal settings and information, and track web browsing habits. Web beacons are clear picture files that you cannot see that we use to monitor traffic and track your activities on the Internet.

The following is a description of the four general categories of cookies that we may use to provide you the Services:

Strictly Necessary Cookies:	These cookies are essential to enable you to browse and use the functionality of a website and without them, the Services 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 bag.
Performance Cookies:	These cookies may be used to collect information about how visitors use the Services, for example, pages that they visit and if they receive error messages. This information would not identify individual customers and is used in the aggregate to improve our Services.
Functional Cookies:	These cookies may be used to remember certain choices customers make about how they like to use the Services and provide a more personalized experience, for example, shipping country and currency preferences.
Targeted Cookies:	These cookies may be 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 Services by us or by our advertising partners with our permission. For more on targeting cookies and your ability to opt out of control their use, please see Section 6 regarding Choice and Opt-Out below.

By registering for and using the Services, you are consenting to the use of cookies. Because of the members-only nature of our Services, cookies are essential to the function of our websites and the provision of the Services. If you do not agree to the use of cookies, you may not be able to use the Services. Depending on where you reside, you may have the right to opt out of the use of targeted cookies. Section 6 provides more information on how to opt out or restrict cookies.

Targeted/Behavioral Advertising

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.

Our advertising service providers may also use cookies, web beacons, and similar technologies to collect and track information such as demographic information, aggregated information, and Internet activity to assist them in delivering advertising that is more relevant to your interests. See Section 6 about how to opt out of these online advertisements and what rights you may have to do so in Section 11.

6. HOW CAN YOU MAKECHOICES ABOUT OR OPT-OUT OF DATA COLLECTION?

You can make choices about the collection, use, and sharing of your information, either through our website and apps or third-party tools:

Marketing Communications	You may change your email address for receipt of marketing communications by going to My Account. You can opt out of receiving marketing emails from us by clicking on the unsubscribe link provided at the bottom of those emails. You may also manage your preferences to receive email or other communications from us by selecting the “Manage Email Preferences” link in your “My Account” section or by sending an email to [email protected]. 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. Please note that your friends and contacts may still choose to send email invitations to you. You may choose to opt-out of receiving marketing communications through our mobile app notifications and text notifications in the manner identified when you opt-in to receive those notifications or as may be specified in those marketing communications.
Location Data	When you use our mobile applications, you may be able to choose not to share your location data by adjusting the applicable settings on your mobile device (the manufacturer or your service provider should be able to provide assistance). For additional information regarding location data and tracking, including how it may be used and how you may be able to opt-out of or otherwise avoid tracking by many third-party mobile analytics firms, visit https://smart-places.org/ and https://www.networkadvertising.org/mobile-choices.
Data Analytics	As disclosed above, we use automated devices and applications, such as Google Analytics, to evaluate usage of our websites. These third parties (and third-party devices and applications) may use cookies, web beacons, or other tracking technologies, as described above, in performing these services. If you do not wish to have technology used to gather information about how you interact with the Services while you are on our websites, please see Targeted Advertising in this Section 6 below to learn how you can restrict the use of cookies in your browser and other tracking technologies. For more information on how Google Analytics collects and processes data, please visit https://www.google.com/policies/privacy/partners/.
Cookies	You can restrict cookies generally through your browser’s cookie control settings. Each browser is a little different, but the most common browsers (Internet Explorer, Chrome, Firefox, and Safari) have a preference or option you can select so that the browser notifies you if a site wants to set a cookie and typically provides an option to accept or reject the cookie before the cookie is set. If you choose to remove or reject cookies, it will affect many features on our website and you may not be able to access certain aspects of the Services. For additional information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org.
Targeted Advertising	To opt out of targeted cookies on our website that share your personal information with our advertising partners, please click on the Do Not Sell or Share My Personal Information link included at the bottom of each page on our website and in the Account tab of our mobile apps.
	You may also be able to opt out of certain targeted ads through advertising industry organizations or individual advertising providers. For example, you can visit www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices and follow the instructions on how to opt-out. For instructions on how to specifically opt-out of Criteo advertising services, please view the Criteo Privacy Policy at https://www.criteo.com/privacy/. Please also note that most opt-out mechanisms are cookie-based, so you must have cookies enabled in your web browser, and they will only affect the specific computer and browser that is used to submit an opt-out request. If you have multiple computers or change computers, or use multiple browsers, you will need to submit opt-out requests for each such computer or browser. Once you opt-out, if you delete your browser’s saved cookies, you will need to opt-out again. Mobile devices may involve unique advertising choice mechanisms as described in the. For more information, please see the Location Data section above in this Section 6. Opt-out mechanisms provided by third-parties or depending on your browser are not controlled by us, and we cannot guarantee their effectiveness.
Sale of Personal Information	Gilt does not sell our customers’ personal information for money. However, in providing the Services, we may disclose personal information to third parties in ways that may be deemed a sale under California law. You can opt out of these activities by clicking on the Do Not Sell or Share My Personal Information link at the bottom of every page of our website and in the Account tab of our mobile apps.

7. WHAT ABOUT DATA SECURITY?

   We are committed to protecting the information we receive from you. We follow reasonable technical and management practices to help protect the confidentiality, security, and integrity of data stored on our system. While no computer system is completely secure, we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved.

Your credit card and other personal information are protected using reasonable encryption measures 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 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.

8. FOR HOW LONG IS YOUR DATA STORED?

   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 de-identified.

9. WHAT ABOUT CHILDREN'S PRIVACY AND PARENTAL CONTROLS?

   Protecting children's privacy is important to us, and the Site and App are not intended for children under the age of thirteen. We do not direct the Site or App to, nor do we knowingly collect any personal information from, such children. If you are not 18 or older, you are not authorized to use the Services. If Gilt learns that a child under the age of thirteen has provided personally identifiable information to the Site or App, it will use reasonable efforts to remove such information from its files.  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.

10. WHO DO I CONTACT IF I HAVE QUESTIONS ABOUT THIS POLICY OR WANT TO LODGE A COMPLAINT?

    We welcome you to reach out if you have any questions or concerns regarding our privacy practices. Please feel free to contact Customer Service via email at [email protected]. We are transparent about the ways in which we collect and use personal information and welcome your questions and concerns. If you have any concerns or complaints about the way we handle your personal information, please contact us at [email protected]. Please use the words “Privacy Appeal” or similar in the subject line. 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. 

11. WHAT ARE YOUR DATA PRIVACY RIGHTS?

Accessing, Updating, And Deleting Your Personal information

We respect your right to delete, access, and correct your personal information. If you are a registered user, you may access and update your registration information (including your name, email address, phone number, billing and shipping addresses, and payment information) through your MyAccount page.  You can submit personal information related requests by following the directions in the Consumer Privacy Law section below.

We may need to retain data for legally permitted purposes, and this will be explained to you if necessary. You may have additional rights regarding the processing and storage of your personal information under applicable law as discussed in the Consumer Privacy Law and California Consumer Privacy Rights sections.

Consumer Privacy Law

The consumer privacy laws of the state or other jurisdiction where you live in may grant you certain rights in your personal information, including the right to request to know what types of and actual personal information we have collected about you, access your personal information, delete your personal information, correct your personal information, as well as appeal any denial of a request relating to these rights. You also have the right to opt out of the sale of your personal information and to opt out of targeted or behavioral advertising. To submit a request to know, access, delete or correct your personal information, please fill out our Data Rights Request form here. If you are using our mobile apps, you can find the Data Rights Request form link under the Account tab.  You can also reach out to our customer service team for assistance at 1-800-789-2233 or [email protected]. You can opt out of the sale of your personal information or use for targeted advertising, by clicking on the Do Not Sell or Share My Personal Information link at the bottom of each page on our website and in the Account tab of our mobile app.

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 information such as 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.

California Consumer Privacy Rights

If you are a California resident, California law provides you with the rights above with respect to your personal information as well as the right to designate an authorized agent in writing to make a request on your behalf.

No Discrimination. We will not discriminate against you because you exercised any of these rights. We do not knowingly collect personal information from any California consumer under the age of 16.

Notice of Financial Incentive. From time to time, we may offer our customers certain promotions, such as sweepstakes, discounts or free shipping (each a “Promotion”) that may ask you to provide additional personal information, such as your contact information (e.g., email or phone number). The details of any such Promotion will be disclosed at the time of enrollment or participation. Participation in such Promotions is voluntary, and customers may opt out of participating at any time by contacting customer service at 1-800-789-2233 or  [email protected].  The value of the personal information collected from you for a Promotion is reasonably related to the benefit you obtain from the Promotion. 

Shine the Light Requests.  If you are a California resident, California Civil Code Section 1798.83 also 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 protected] or write to us at the following address:

Gilt Groupe, LP

20 Channel Center Street

Boston, MA 02210

Attn:  Legal Department

12. HOW DOES GILT COMMUNICATE CHANGES TO THIS POLICY?

    Any changes to our Privacy Policy will be posted here so that you will always know what information we gather, how we might use that information, and whether we may disclose it to anyone. Your continued use of the Site or App following the posting of changes to these terms will mean you accept these changes.

13. HOW CAN YOU CONTACT GILT?

Please contact us at:

Gilt Groupe, LP

20 Channel Center Street

Boston, MA 02210

1-800-789-2233

[email protected]

For all questions about unsubscribing from marketing communications, contact [email protected]. For questions about this Privacy Policy or other privacy-related questions, contact [email protected].

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