EFFECTIVE DATE: January 1, 2020
1. INTRODUCTION
At SharingWell Inc., we are striving every day to build a pivotal company laser focused on providing change for the disadvantaged through our many events, goods and services. Key to our efforts are the many relationships we have built and look forward to developing in the future. With trust as the cornerstone of every great relationship, we take the privacy rights of our customers seriously. The privacy policy below explains how we collect and use your personal information to serve you.
2. TYPES OF INFORMATION WE COLLECT
We collect information about you such as your contact information, payment information, demographic information, shopping preferences and information about the devices you use to shop online.
We do not knowingly collect personal information directly from children under the age of 13 (16 in the United Kingdom/European Union) without parental consent. Our websites are general audience sites and are not specifically targeted to or intended for use by children.
We need to collect personal information in order to provide the products and services you request. If you do not provide the information requested, we may not be able to provide you with these products and services.
Dependent on the products or services procured, we may collect the following information:
- Contact information, such as name, email address, postal address, phone number, affiliation
- Payment information, such as credit card number, bank card numbers, check and other payment details
- Order and refund history
- Demographic information, such as age, estimated income, household information and occupation
- Information about your interests, preferences and purchase history
- As part of processing a return, you may be asked to provide government issued identification numbers, such as social security number, national identification number, and/or driver’s license number
- Information may be collected from you if you interact with us on our site as well social media sites, such as Facebook, Instagram, and Snapchat including your comments
- An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available at https://automattic.com/privacy After approval of your comment, your profile picture is visible to the public in the context of your comment.
- If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
- Device and browser information including location information, MAC addresses, browser user agent, IP addresses, Cookies, and other online identifiers to help with spam detection
- If you disclose any personal information relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy
3. HOW WE COLLECT YOUR INFORMATION
We collect information about you in a variety of different ways:
- Information you provide to us, such as while making a purchase or signing up for a loyalty or rewards program.
- Information we collect while you interact with our websites, mobile or other apps, social media sites, and other products and services. This often involves information about your device such as IP addresses and MAC addresses, as well as information collected through cookies.
- Information we collect about you from other sources, such as credit card issuers and data analytics firms.
- Information we create ourselves after we analyze the information we collected about you, such as your shopping preferences.
- Detailed information you provide to us:
- Online Order Information
When you make a purchase from our websites or mobile apps, we ask you to provide us with information about your purchase such as your name, email address, shipping address, phone number, and payment information.
- In-Person / Event
When you attend one of our events, we may ask you for certain information, such as at the point of sale or while interacting with one of our team members. This may include payment information, product information (such as clothing size), and other information about your purchase, including your name, email address, shipping address, and phone number.
- Online Accounts
If you sign up for an online account through our websites or mobile applications, we may ask you to provide your username, password, email address, phone number, payment card information, product preferences, past purchases, or gender. You do not have to create an online account to make a purchase.
If you connect your social media account to your online account, you will share certain personal information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be accessible to us when you connect your social media account to your online account.
- Marketing Communications
If you would like to receive marketing communications from us, you may do so by signing up on our websites, mobile applications, or at an event. We will ask you to provide your email address or phone number so we can send you marketing materials.
- Communicating with us
When you contact us about a customer service issue, or to make other inquiries, we collect the content of those communications, and any additional information about the method of communication such as phone, SMS, email, chat, or through social media platforms. For example, if you email us, we will collect your email address, if you send us a text message, we will collect your phone number, and so on.
- Loyalty & Rewards Programs
If you enroll in a loyalty or rewards program that we may offer from time to time, we collect information such as your name, email, telephone number, or mailing address in order to track your rewards and process redemptions.
4. COOKIES AND SIMILAR TECHNOLOGIES
Cookies are little bits of computer code that collect data by tagging along with you while you browse. Most websites, including ours, wouldn’t work very well without certain cookies. They allow us to prevent crashes, display information, fix bugs, and ensure the security of our site (and your account). These types of cookies are often called “strictly necessary” cookies. Because they are needed for our site to work, we don’t provide you with an ability to opt-out of these cookies. But you can remove them by using your browser settings. Keep in mind that certain features on our site may not be available to you.
Some cookies provide important services but are not strictly necessary for our website to work. These cookies use information about your interactions with us so we can suggest merchandise, services or events as well special offers for you. If your shopping is interrupted, they remember where you left off and send you reminders, providing continuity during your shopping experience. These reminders might be sent to you in an email, on social media or while you’re browsing another website or on another device. We think these cookies are useful and will make it easier for you to shop with us. But you might disagree. If so, you can tell us not to use certain cookies by using the opt-out tools we have placed on our ecommerce website.
We also use cookies and similar technologies to gather information about the success of our ad campaigns and use of our products, services and events. These technologies include Google Analytics, Adobe Analytic and others. You can opt-out by visiting Google Analytics Opt-out Browser Add-on and Adobe Your Privacy Choices.
5. HOW WE USE YOUR INFORMATION
We use your personal information to provide you with our products and services and to operate our business. We often use the information we collect for multiple purposes. For example, if you make a purchase on our website, we collect several types of data from you and use it in multiple ways: First, we use your shipping address to make sure that our products arrive at your door. We may also use your contact information to send you a receipt of purchase. We may look at your experience on our website to make improvements to it and try to tailor it to your needs. We will also analyze the data you provide us and your behavior on our website to ensure that the activity is not fraudulent. Finally, we use your purchase information for other business-related purposes like accounting and financial reporting.
We may also combine information we collect from you with information we obtain from other sources. This may include your online and in-store purchase transactions and other interactions you have with us and our partners.
We often obtain your consent to use your information. But sometimes, obtaining your consent is not needed because we may use your information for our own legitimate interests, to fulfill a contract with you, or to comply with legal obligations imposed on us. For example, when you make purchases online, we process your information to fulfill our contractual obligations. When you visit our websites, we have a legitimate interest in using your browsing data to improve our site’s usability, and when you engage with us online, we have a legal obligation to ensure that you are not attempting to defraud, us or our customers.
Below are details regarding specific use cases related to your information:
5.1 Providing you with Products and Services
We use your information to process, fulfill and communicate with you about your orders, respond to your customer service inquiries, allow you to use at-event and online technologies, enroll you in rewards and loyalty programs and to inform you of policy or product changes that may impact you. When we use information in this way, we do so for the purpose of fulfilling a contract with you, or to comply with a legal obligation.
5.2 For Marketing Communications and Promotions
We use your personal information to send you marketing communications about our products and services, contests, and promotions. We may send you emails, postal mail, text messages, phone calls, or social media messages that we believe you would be interested in. We will do this either with your consent or because we have a legitimate interest to do so.
5.3 For Business Reporting and Providing Personalized Services and Ads
We use your personal information to analyze or predict our customer preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our products and services. We also use personal information to better understand you and your preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests. We use information in this way with your consent or because we have a legitimate interest to do so.
5.4 Allowing you to participate in promotions and events
We may use your personal information to allow you to participate in local community events, promotions, and at-event experiences. Some of these may have additional rules containing information about how we will use and disclose your personal information. We use this information for the purpose of fulfilling a contract with you or because we have a legitimate interest to do so.
5.5 For other business purposes
We may use your personal information to learn more about our customer base, perform data analyses, address problems with our technology, improve our products and services or develop new ones, to investigate and prevent fraud or other illegal activity, to enforce our Terms of Sale and Use, and to provide a more consistent experience across our brands and channels. We may also use your information where we believe it is required to protect the rights, property, safety and security of SharingWell, Inc., our employees, customers, and others. Finally, we may be required to use your personal information to comply with applicable law, for auditing purposes, or to respond to requests from government authorities.
We will engage in these activities to fulfill a contract with you, to comply with a legal obligation, and/or because we have a legitimate interest in doing so.
6. HOW WE SHARE PERSONAL INFORMATION
We may share your personal information with our affiliated companies and brands, with third parties who provide services to you or us, with promotional partners, with social media companies, or with other third parties as needed to carry out our business, or comply with a legal obligation.
Below are details regarding specific use cases related to your information:
6.1 Sharing between brands and affiliates
When you provide information to one of our brands, we may share it with our other brands.
6.2 Public posting and social sharing
When you post public comments on our websites, through at-event technologies, on public forums like our social media sites, blogs, and online reviews, your comments are accessible by other members of the public.
6.3 Social media logins and other integrations
When you log into your customer account using your social media account credentials, or use other social media services with us, your personal information will be disclosed to the social media account provider in connection with your login. By doing so, you authorize us to facilitate this sharing of information, and you understand that this sharing is governed by the social media site’s privacy policy that you used to log into your account.
6.4 SharingWell, Inc.’s service providers
SharingWell, Inc. uses third parties to provide services to you or us. This includes managing customer information; fulfilling promotions; sending marketing communications; conducting surveys; hosting websites; analyzing data; processing payments; fulfilling and shipping orders; or providing network security, accounting, auditing, and other services. We do not authorize these service providers to use or disclose your information for purposes other than why we have retained them.
6.5 Third party partners
You may share information with other companies when we work with them to promote our products, services, offers, contests, or other promotions to our customers.
6.6 Script or Loyalty Programs
If you participate in third party scrip, loyalty, or similar programs that a SharingWell, Inc. brand also participates in, we will share your information with them to facilitate the program. This may include sending your purchase information to credit card processors, so part of your purchase may be donated to participating schools or other non-profit organizations. If you participate in loyalty programs, we may send your information to the vendor administering the program. This information may include your name, email, credit card number, your purchase history, and other information you have provided to us through the program.
Once your information is provided to the third party it will be handled in accordance with their privacy policy. You should review the privacy policy before entering into a rewards, loyalty, or scrip program, so that you have a complete understanding of how your information is being used.
6.7 Direct Mail
Through the purchase of our products or services, we use your name, postal address, and shopping history to provide you with relevant catalogs and information communication. If you would prefer not to receive this form of communication, please let us know by contacting SharingWell, Inc. Customer Service as described in the section entitled, “Contact Information”.
6.8 Payment card issuers
In certain countries, we may provide you with the opportunity to apply for an offer of credit from a payment card issuer. To create a more convenient application process, we may provide information from your customer account to a payment card issuer in order to generate a pre-approved credit offer or pre-populate your online credit card application with information from your customer account. By submitting a credit card application either at-event or online, you acknowledge and agree that SharingWell, Inc. may provide your information to the payment card issuer in accordance with the terms and conditions of the application. For information about the privacy practices associated with your credit application, please contact the payment card issuer.
6.9 To fulfill legal obligations and with government agencies
We may share information about you if necessary or appropriate, in our good faith judgment, to comply with laws or regulations, or in response to a valid subpoena, order, or government request, or to protect the operations, privacy, safety, property or rights of SharingWell, Inc. or others.
6.10 During a sale or business transaction
In the event of any potential or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), your personal information may be shared with third parties such as the acquiring entity and its advisors.
7. HOW WE STORE AND SECURE YOUR INFORMATION
7.1 Where We Store Information
SharingWell, Inc. is a United States company with the Personal Information we collect stored in the United States and globally. Your personal information may be subject to the laws of the countries in which it is stored or used. By providing us with any personal information, you understand that your information may be transferred, processed, or stored outside of your country of residence, including the United States, which may have a different data protection regime from the country in which you reside. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.
7.2. Information Retention
We will retain your personal information for as long as needed to provide the service to you (for example, as long as you have an online account with us) or as needed to fulfill our own obligations, such as preventing fraud, meeting regulatory requirements, resolving disputes, improving our services or maintaining security, and in each case, as consistent with applicable law. We may retain non-personal information that has been sufficiently aggregated or anonymized for a longer period.
When visiting our site, if you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website, we also store personal information provided in your user profile. All users can see, edit, or delete their personal information at any time, with the exception of their username which is system generated. Website administrators can also see and edit that information.
Regarding accounts created on our site for the purpose of purchasing goods or services, the following retentions are currently established:
- Retain Inactive Accounts – 3 months
- Retain Pending Orders – 30 days
- Retain Failed Orders – 2 days
- Retain Cancelled Orders – 1 yr
- Retain Completed Orders – 1 yr
- Retain Credit Card Processing Information – 1 yr
7.3. Information Security
We do our best to provide you with a safe and convenient shopping experience. We have put in place a wide variety of technical and organizational security measures to help protect you and the personal information we collect about you. Please note that we will never email you asking for account information like your user name, date of birth, credit card information, or other personal information. If you received a suspicious email that appears to be from us please contact us.
7.4 Third Party Services
We are not responsible for, and this policy does not address, the privacy practices of other third parties, such as Facebook, Apple, Google, Microsoft, or any other app developers, social media platforms, operating system providers, wireless or telecommunications service providers, or device manufacturers. The inclusion of a link on our services does not imply an endorsement of the linked sites or services by us or our affiliates.
7.5 Sensitive Information
Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through our services or otherwise to us.
7.6 Third Party Payment Service
We make certain third-party payment service processors available to you such as PayPal or Apple Pay. If you wish to use one of these services, your personal information will be collected by such third party and will be subject to the third party’s privacy policy. We have no control over, and are not responsible for this third party’s collection, use, and disclosure of your personal information.
7.7 Changes to this Policy
We will post updates to our privacy policy on our websites. If we change the policy in a manner that materially impacts your privacy rights, we will provide additional notice to you.
8. YOUR RIGHT TO CONTROL HOW YOUR PERSONAL INFORMATION IS USED
You have the right to make requests regarding your personal information. You can:
- Review the personal information we have about you or request a copy of it
- Ask us to update or correct personal information if it is inaccurate
- Request that we delete your personal information
- Opt-out of sharing your personal information with third parties for some purposes
- Object to certain types of uses of your personal information
- Make choices about receiving email marketing
These rights vary depending on where you reside. But we will make reasonable efforts to honor your request, even if your country or state does not require us to do so. If you ask us to delete or stop using your personal information, we may not be able to honor that request if the information is required to process your payments or returns; fulfill your order; or comply with tax, audit or regulatory requirements.
To submit a request to access, modify or delete your personal information, please contact us at Customer Support. See the Contact Information section in this policy.
Residents of California have additional rights as outlined below:
California Privacy Rights
Shine the Light
California Civil Code Section 1798.83 permits customers of SharingWell, Inc. who are California residents to request certain information regarding and/or opt-out of our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write to us at the following address:
SharingWell, Inc. – California Privacy Rights
Legal Department
980 Wheeler Way, Unite 393
Langhorne, PA 19047
California Consumer Privacy Act
California residents may request copies of the data collected about them in the past 12 months through the process described in section 2 above. Sections 3 through 8 of this policy describe the categories of personal information we collect, our methods of collection, the business or commercial purpose for collection, and categories of third parties we disclose information to. You can download a copy of this policy any time by clicking the “Downloadable PDF” link at the bottom of this page.
SharingWell, Inc. does not currently sell personal information about its customers who reside in California.
California Minor Content Removal
If you are a resident of California, under 18 and a registered user of our services, you may ask us to remove content or information that you have posted to these services by contacting us. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
California Do Not Track Disclosure
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals. For information about Do Not Track, please visit: www.allaboutdnt.org.
CONTACT INFORMATION
Have questions or want more information?
SharingWell, Inc.
980 Wheeler Way, Unit 393
Langhorne, PA 19047
877.388.9355