PRIVACY POLICY

Last Updated: October 22, 2019

This Privacy Policy describes the privacy practices of www.shoppremiumoutlets.com and any successor thereto (the “Site”) and related services together, the “Platform,” operated by Shop PO, LLC (“Shop PO,” ‘us” or “we”) and its affiliates.  This Privacy Policy explains the information that we gather about you while you use the Platform, and the ways in which we use and share that information.  You agree that your use of the Platform signifies that you have read and consent to the collection, use and sharing of your information in accordance with this Privacy Policy, including the transfer to and storage of your personal information in the United States. If you do not agree with this Privacy Policy, you should not use the Platform.

 

Guide to Contents

  1. What We Collect
  2. How We Use Information
  3. How We Share Information
  4. Your Choices
  5. Your California Privacy Rights
  6. Information Security
  7. Non-US Residents and Cross-Border Transfer
  8. Your Right to Lodge Complaints
  9. Changes to this Privacy Policy
  10. 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. 

1.1 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

We use and disclose the information collected as explained in this Privacy Policy. How we use and disclose that information may be supplemented in the area where you provide the information.

Terminating Your Account. You may terminate your account by e-mailing legal@sspo.com. 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.

1.2 Information We Gather Automatically

When you access the Site through a web browser, we collect technical information that identifies your computer, software, browser settings and Internet Service Provider (ISP), such as your Internet Protocol (IP) address (a unique number that is automatically assigned to your computer when you access the web); browser type and version; operating system and version; domain name; device's preferred language; country information configured in your browser; a randomly assigned, unique user identification number (UID) set by us; and/or other characteristics relating to your device, its software and the mode of communication with us; as well as information regarding your visit to the Site, such as the date, time and duration of a visit, the specific webpages you visit, what products are reviewed and/or selected, order history, other site navigation data and patterns, the links you click throughout the Site, and/or the external websites from which you arrived at the Site or to which you linked from the Site (see our Cookie Policy for more information). You may choose not to accept cookies using your browser. See our Cookie Policy for more information.

On many of our web and app forms, we may utilize the Google reCAPTCHA v3 service to fight spam and abuse on our Platform, which is clearly noted by the presence of a badge image that appears in the bottom right corner of a user’s screen. For clarity, note that the use of these web and app forms that use the reCAPTCHA v3 service is also subject to Google’s Privacy Policy and Terms of Use.

1.3 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.

1.4  Involvement of Others in Data Collection 

We may work with third parties 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

2.1  Platform Operation 

We use the information we collect to operate, maintain and improve the Platform and our products and services, such as to respond to comments and questions and provide customer service; send information including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages; communicate about promotions, upcoming events, and other products and services offered by us and/or by third parties, including through the use of contextual and interest-based advertising; link or combine the information we collect with other information we get from third parties, to help understand your interests and provide you with better service; protect, investigate and deter against fraudulent, unauthorized or illegal activity; provide and deliver the products and services you request; identify you as a user in our system, such as when we feel it is necessary to enforce compliance with our Terms of Use or to protect the Platform, customers, or other individuals; facilitate the creation of and secure any accounts you created on our Platform; develop and improve marketing and advertising for the Platform; and/or for other purposes in operating the Platform.

We may create de-identified information records and "aggregate data" reports about how users use the Platform, such as the number and frequency of visitors to the Site or the App, which may be derived from technical and/or personal information. This information cannot be readily tied back to you, your account, your web browser or your mobile device. We may use this de-identified information for business purposes, such as to enhance the content of and improve the Platform, for example by allowing us and third parties authorized by us to ascertain how often individuals use areas of the Platform so that we may focus on and improve those areas.

We may use technical data we gather to enable us or a third party to provide you with information about products and services while you are using the Platform.

2.2 Location Information 

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 Advertising 

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.

Some retailers may employ their own advertising campaigns with us via the Platform which adhere to differing practices. You may learn about a specific retailer's practices by reviewing that retailer's privacy policy.

Various data collected for advertising purposes may use and be restricted through cookies. See our Cookie Policy for more information.

 

3. How We Share Information

We share your information with others as follows.

3.1 Other Users 

If you create an account, information such as your username, photo, birthday and other information you enter may be displayed to other users of the Platform to facilitate user interaction within the Platform. We will not reveal your contact information to other users without your permission.

3.2 Promotions and Marketing 

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 also share such information with third parties that provide marketing and advertising on our behalf, as well as with our retailers. We may share information regarding your use of the Site and email response information with our retail partners. 

Occasionally, 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 Services 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.

3.3 Your Transactions 

We may share your information to fulfill the purpose for which you provide it, such as to purchase merchandise and have it shipped to you, or for any other purpose disclosed by us when you provide the information, or with your consent, or to third parties designated by you. We may share financial information with our third-party payment processing company, our credit card gateway and fraud detection company, our remote checkout bot company and any applicable retailers.

We may use various third parties that may do one or more of the following activities in regard to credit card transactions: (a) 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.

We may collect your financial information. If you make a purchase through the Platform and are redirected to the retailer’s website to complete the process, any financial information you provide is submitted directly to the retailer itself. If you remain on the Platform during the purchase process, you will provide your financial information to us or our payment processor and your information is then passed to a third party e-commerce enabler, which will provide the information to the retailer from which your purchase is made. The retailer(s) will fulfill your purchase in each case. We are not responsible for, and this Privacy Policy does not govern, the retailer's privacy practices with regard to your information after you are redirected to their website. You may check the applicable retailer's privacy policy if you have questions regarding their use of information.  

To fulfill a purchase on the Platform, we will either share your information with the retailer, itself, in which case you will be redirected to the retailer's website to process and fulfill your order, or we will share your purchase and shipping information with our third party e-commerce enabler which will provide the information to the retailer(s) from which your purchase is made. Generally, they will use the information for customer service, fulfillment, shipping and returns. The retailer may pass your information to third parties, such as the shipping carrier (USPS, UPS, FedEx, etc.). We are not responsible for, and this Privacy Policy does not govern, the retailer's privacy practices with regard to your information after you are redirected to their website. You may check the applicable retailer's privacy policy if you have questions regarding their use of information. We may also share your purchase and contact information with third parties that provide marketing and advertising services on our behalf, as well as with our retailers.

3.4 Social Media 

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.

3.5 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.

3.6 Third Party Service Providers 

We may share your information with other third party service providers that assist us in operating the Platform, for and on our behalf, such as a hosting company or e-mail provider. They are instructed to use the information only to assist us in operating the Platform. We may also share your information with third parties, such as sharing your feedback with our vendors to improve the Platform. We may also share your information with third parties that provide marketing and advertising on our behalf, as well as with our retailers.

We may share de-identified data concerning retail consumer behavior with third parties, including entities with whom we have entered into an agreement to provide such de-identified data for analytics or marketing purposes.

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.

3.7 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

From time to time, we may share your personal information in connection with strategic relationships. Some of these strategic relationships may include operating a co-branded website or web pages with our retail partners or another 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 this Privacy Policy does not apply to these third party websites. Please consult the privacy policy of the website you are visiting.

3.9 Required By Law or To Protect Interests

We may disclose your information to (i) comply with laws, rules, regulations, legal processes and governmental requests; (ii) enforce this Privacy Policy and our Terms of Use, including investigation of potential violations hereof and thereof; (iii) detect, prevent or otherwise address fraud, security or technical issues (such as for fraud protection, credit risk reduction and spam/malware prevention); (iv) respond to user support requests; (v) avoid liability, or to protect our rights or property or the rights or property of anyone else (such as when user is believed to be in violation of our Terms of Use); and/or (vi) protect the rights, property and safety of our companies, partners, contractors, customers, users and the public (such as to report suspected illegal activity to law enforcement).

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

As disclosed above, we use automated devices and applications to evaluate usage of our websites. These third parties (and third-party devices and applications) may use cookies, web beacons, or other tracking technologies 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 the Interest-Based Advertising section below to learn how you can restrict the use of cookies in your browser and other tracking technologies.

4.3 Interest-Based Advertising

As noted above, we may use the information you provide to us, and information we collect about your use of our products and services, to assist us and our partners in our effort to deliver you online advertising that is relevant to your interests. In connection with these activities, we may work with social media networks and advertising service providers who help deliver these ads to you. For more information, including how you can opt-out, please review our Cookie Policy. For more information on how Google Analytics collects and processes data, please visit https://www.google.com/policies/privacy/partners/. 

4.4 Accessing, Updating and Deleting Your Information

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 onlinesupport@sspo.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, 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 legal@sspo.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

The Platform may have links to third party websites, services and applications, such as websites hosted by third party retailers (collectively, “Third Party Sites”). When you click on such a link, you will leave the Platform and be directed to the Third Party Site and when you leave the Platform, you and are no longer subject to the terms of this Privacy Policy. This Privacy Policy does not apply to Third Party Sites, and we do not review or endorse, and are not responsible for, any Third Party Sites, the content therein, or their privacy practices. This Privacy Policy also does not extend to anything that is inherent in the operation of the Internet, and therefore beyond our control, and is not to be applied in any manner contrary to applicable law or governmental regulation.

 

7. Non-U.S. Residents and Transfer of Your Information

Residents of other countries outside the U.S., such as the European Union, may have other rights. As stated in our Terms of Use, while you may be able to setup an account as a user outside the U.S., we make no assurances or representations of any kind that the Platform is suitable for use in the country in which you reside. Your personal information may be transferred to the United States or another country which may not have the same data protection laws as the country where you reside and such information may be available to government authorities under lawful orders and as applicable in such foreign jurisdictions.  You consent to any such cross-border transfer of your personal information.  

By accessing the Platform, establishing an account or making a purchase, you consent to the processing of your personal information as provided in this Privacy Policy. You may withdraw that consent by contacting us at onlinesupport@sspo.com

 

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 legal@sspo.com.

To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.

 

9. Changes to this Privacy Policy

If we decide to change this Privacy Policy, we will post the revised Privacy Policy on the Shop PO website 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 Platform indicates your consent to the Privacy Policy as posted.

 

10. How to Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Shop PO, LLC
20 Channel Center
Boston, MA 02210
1-855-776-2743
onlinesupport@sspo.com

© 2018 - 2019 Shop PO, LLC. All Rights Reserved.

 

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