Privacy Policy

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

This Privacy Policy describes the privacy practices of www.shoppremiumoutlets.com and any successor thereto (the “Site”) and related iOS and Android apps (“Apps”) 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.

1. What Information 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 Summary

To provide the Platform and a first-class shopping experience, we collect information from and about you. That information may include the following categories of personal 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 Platform, we (and our current payment processor Shopify Payments and any future payment processor) may collect your credit card number, expiration date, CVV code, and billing address but do not store your credit card number.
Commercial Information:	We may directly or indirectly 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 Shop PO 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.

1.2 Information You Voluntarily Provide

You may provide us with information to use or participate in certain features of the Platform, such as registering for an account, participating in our SPO Rewards Program or SPO Ambassador Program, or making a purchase, and you may receive communications relating to those transactions and programs. If you sign up for emails or texts, you may also receive communications from us related to your purchases, current offers, and your participation in the Platform.

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 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. You will also be enrolled in the SPO Rewards Program.

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.

· To provide information for your receipts and to facilitate future orders you may make, we (through our payment processor, Shopify Payments) 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 and 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.

· Rewards Program. We and our rewards program partners may collect information about your purchases and interactions with the SPO Rewards Program, including the points and rewards that you have received and used and other information you choose to provide like birthdate and anniversary date.

· 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.

1.3 Additional Uses.

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

1.4 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. If you sign up for our text messaging program, cookies may be used to personalize your experience (e.g., sending you personalized text messages such as shopping cart reminders). You may choose not to accept cookies using your browser or opt out of certain cookies. See Sections 4 and 5 below regarding our use of cookies 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.

1.5 Location Information

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 Apps 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.

1.6 Involvement of Others in Data Collection

We may work with third parties, including the retailers whose products are offered on the Platform, 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

We use the information we collect in several ways:

Contact Information and Personal Identifiers, Payment Information, and Commercial Information

To facilitate provision of the Platform, including the purchase of goods or services, enable your participation in the SPO Rewards Program and SPO Ambassador Program, send communications about the Platform and respond to questions or requests.

To support and enhance your use of the Platform and their features, including without limitation: facilitating your purchase of goods; providing customer service; and otherwise supporting your use of the Platform and its features.

To identify you as a user in our system, such as when we feel it is necessary to enforce compliance with our Terms of Service or to protect the Platform, retailers, customers, or other individuals; or to facilitate the creation of and secure any accounts you created on our Platform.

Browsing and Device Information, Location Data, 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.

To conduct market research, improve the Platform and help us identify others who may be interested in the Platform.

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.

Contact Information and Commercial Information, in Combination with Demographic and Other Data

To protect the security and integrity of the Platform and our business, including preventing fraud, hacking and other criminal activity, or to meet legal obligations.

We may use information we collect from you in other ways for which we provide specific notice at the time of collection.

3. How We Share Information

3.1 To Provide the Platform and Related Services

We share your information with others, including our retail partners, for the following purposes:

Contact Information and Personal Identifiers, Browsing and Device Information; and Demographic Information

We may share certain Contact Information for you with retailers from whom you make a purchase on the Platform, which will be used to process your order and, in some cases, so that the retailer may provide you with marketing. By using the Platform to purchase from retailers, you are directing that Shop PO intentionally disclose certain personal information to retailers from whom you purchase on the Platform.

We may store your contact information and commercial information with service providers who help us provide the Platform, for example, hosting the website and operating various features of the Platform and our retail partners.

We may share personal identifiers, browsing information or demographic information to serve you ads tailored to your interests or to tailor ads that may be served to you on the Site and Apps, 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.

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 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, to provide more targeted advertisements about goods and services from us or retailers that may be of interest to you.

We will not share text messaging originator opt-in data and consent with third parties except as described above. We will never share that information with third parties for their own marketing purposes.

Payment Information and Commercial Information

Your payment and commercial information with retail partners, shipping services and trusted payment processors and other financial vendors who 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.

3.2 Promotions and Marketing

Occasionally, where permitted by applicable law, 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 Platform or other products or services that may be of interest to you. 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. We may also share your data for advertising purposes as further described in Section 4.

3.3 Your Transactions

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 which we provide to the retailer to fulfill your purchases or after you are redirected to the retailer’s 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 regarding your information that we provide to the retailer or 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.

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.

3.4 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.

3.5 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.

3.6 Strategic Partners

From time to time, where permitted by applicable law, 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.

3.7 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 Service, 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 Service ); 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).

3.8 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. Advertising and Cookies

4.1 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 targeted advertising. These companies may use data about your visits to the Platform and other websites or mobile applications 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 online advertising industry guidelines, such as the Digital Advertising Alliance's principles for online behavioral advertising and the National Advertising Initiative’s Code of Conduct. 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 targeted advertising generally. If you would like more information about advertising industry practices and how to opt-out of receiving communications from these third-party advertising companies, please visit this link.

For retailers from whom you purchase on the Platform, we may share your email and other Contact Information so that the retailer may market to you directly. By using the Platform to purchase from retailers, you are directing that Shop PO intentionally disclose your personal information to retailers. In addition, 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.

See Section 5, Your Choices and Opting Out, about how to opt out of Shop PO’s targeted advertisements and sharing of your data for marketing purposes, as well as what rights you may have to do so in Section 11, Your Data Privacy Rights.

4.2 Cookies

Certain parts of the Platform and App require cookies. By registering for and using the Platform, you are consenting to the use of cookies. 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 5 provides more information on how to opt out or restrict cookies.

The following is a description of the four categories of cookies and examples of how we use them to provide you the Platform:

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 5 regarding Your Choices and Opting Out below.

4.3 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 5, Your Choices and Opting Out, about how to opt out of these online advertisements and what rights you may have to do so in Section 11, Your Data Privacy Rights.

5. Your Choices and Opting Out

We offer you certain choices about the collection, use and sharing of your information either through the Platform or through third-party tools:

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 by sending an email to onlinesupport@sspo.com or submitting a request via our online request form. 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. 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.
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 Platform while you are on our websites, please see the Targeted Advertising section 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	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. Opt-out mechanisms provided by third-parties or depending on your browser are not controlled by us, and we cannot guarantee their effectiveness.
Account information and deletion	If you are a registered user, you may update your account information, including changing your password, by sending an email to onlinesupport@sspo.com or submitting a request via our online request form. You may terminate your account by submitting a request via the online request form. 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.
Sale of Personal Information	Shop PO 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 settings menu of our mobile apps.

6. Data 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, credit card processing companies, fraud detection service providers, issuing banks, card network issuers, shipping/fulfillment companies, and other parties i 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 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.

7. 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.

8. 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.

9. 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.

10. Children’s Privacy and Parental Control

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.

11. Your Data Privacy Rights

11.1 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 account. 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 herein.

11.2 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 online request form or send an email to onlinesupport@sspo.com. 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 settings section of our mobile apps.

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 the email address attached to your 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.

11.3 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 1-855-776-2743 or onlinesupport@sspo.com. 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 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 Street
Boston, MA 02210
Attn: Legal Department

11.4 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 Service, 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. 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.

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.

12. 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.

13. 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