ShopRunner Privacy Policy

Updated and effective: October 19th, 2018.

This Privacy Policy applies to the website from which you are accessing this Privacy Policy, and its features, and any applications, interactive features or online services that post a link to or include this Privacy Policy (collectively, the “Services”). Shoprunner, Inc. (“ShopRunner”) owns or operates the Services. This Privacy Policy describes our practices with regard to the information we collect about you through the Services. Except where specifically stated otherwise, this Privacy Policy applies only to information collected when using the Services and does not apply to information collected by ShopRunner offline or otherwise outside of the Services.

By using the Services, you agree to this Privacy Policy. Please also review the Terms of Service, which governs your use of the Services. Please note that certain features or services discussed in this Privacy Policy may not be offered at any particular time or may not be available on every website, application, interactive feature or online service that links to this Privacy Policy.

SUMMARY

THIS SUMMARY PROVIDES AN OVERVIEW OF SOME IMPORTANT INFORMATION REGARDING OUR USE AND SHARING OF INFORMATION AND THIRD PARTIES WHO MAY SERVE ADVERTISEMENTS AND WHO OTHERWISE MAY SET COOKIES OR SIMILAR TRACKING TECHNOLOGIES WHEN YOU INTERACT WITH THE SITE. PLEASE REVIEW OUR FULL PRIVACY POLICY BEFORE USING OUR SITE.
- We may collect Personal Information from you. We use this information primarily in connection with your relationship with ShopRunner, your use of the Services, and for sending you information from us or on behalf of certain third parties, including retailers as described in more detail below. Please review the INFORMATION WE MAY COLLECT ON THE SITE and HOW WE MAY USE THE INFORMATION COLLECTED sections of this Privacy Policy for a full description of the information we collect, including without limitation Personal Information, and how we use that information.
- We have relationships with retailers who offer ShopRunner benefits to consumers who have ShopRunner memberships (“Retailers”). We may share Personal Information with Retailers and we may also receive information about you, including Personal Information from those Retailers. This includes details about the orders you place with Retailers for products eligible for ShopRunner benefits. Retailers may use the information we share with them for their direct marketing purposes. See the HOW AND WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES section of this Privacy Policy for more information. If you are a California resident and have questions about information we have shared with third parties for their marketing purposes, please see the CALIFORNIA RESIDENTS YOUR PRIVACY RIGHTS section of this Privacy Policy for more information.

Contents
- SUMMARY
- INFORMATION WE MAY COLLECT THROUGH THE SITE
- Information You Provide in Connection with your Use of the Services
- Information Third Parties Provide About You
- Social Networking Features
- Community Forums and User Submissions
- Refer to a Friend and Gift or Guest Membership Features
- Information We Collect Automatically As You Access and Use the Services
- Cookies & Local Storage
- Web Beacons
- Embedded Scripts
- HOW WE MAY USE THE INFORMATION COLLECTED
- HOW AND WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES
- Retailers
- Unrelated Third Parties
- Sweepstakes, Contests and Promotions
- Employment; EEOC
- Administrative and Legal Reasons
- Business Transfers
- THIRD-PARTY ADVERTISING COMPANIES AND ANALYTICS SERVICES
- HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
- CHANGING YOUR PREFERENCES AND ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION
- THIRD-PARTY CONTENT, LINKS TO OTHER SITES, AND SHOPRUNNER CONTENT FOUND OUTSIDE OF THE SITE
- SECURITY
- JURISDICTION AND CROSS-BORDER TRANSFER
- SENSITIVE INFORMATION
- REVISIONS TO THIS PRIVACY POLICY
- CALIFORNIA RESIDENTS YOUR CALIFORNIA PRIVACY RIGHTS
- CONTACTING US

INFORMATION WE MAY COLLECT THROUGH THE SITE

Information You Provide in Connection with your use of Services
When you create an account, contact us, or otherwise interact with the Services, you may provide ShopRunner with “Personal Information” (which is information that identifies or can be used to identify you as a specific individual, such as your name or email address) and other information about you, such as demographic information (ZIP code, gender or age, for example) and information about your interests and preferences. If we combine this other information with Personal Information, then we will treat the combined information as Personal Information under this Privacy Policy. In addition, registering for and using certain ShopRunner Services may require you to pay online, and therefore require that you supply us with information associated with your credit card or other accepted form of payment; some of this information may be Personal Information. We also collect payment information when you make a merchandise purchase through our Services.

Note that we may also de-identify Personal Information and make it non-personally identifiable, either by combining it with information about other individuals and/or by hashing the information or otherwise removing characteristics that make the information personally identifiable directly to you. De-identified information does not identify you directly, and we treat it as non-personally identifiable, but it may be used to connect your activity, devices and interests.

The Services are intended for a general audience and are not intended for use by or targeted to children younger than the age of 13. We do not knowingly collect Personal Information from children younger than the age of 13. If we learn that we have inadvertently collected Personal Information from a user who is younger than age 13, we will delete that information from our active databases. If you are the parent or legal guardian of a child younger than 13 and believe that we have inadvertently collected Personal Information from your child, please contact us at privacy@shoprunner.com.

Information Third Parties Provide About You
We may receive information about you from third parties. For example, if you are on another website and you agree to receive information from ShopRunner, that website will forward your information to us so that we may contact you. We also receive information from Retailers when you make purchases utilizing ShopRunner benefits. And we may supplement the information we collect with outside records from third parties, such as public databases, publicly available Social Media pages or joint marketing partners, for various purposes, such as to provide you with information, services or products, to tailor our content and the offers we show you, or to enhance our products and services. We may also collect Personal Information and de-identified or otherwise anonymous data from partners with whom we have a relationship. We may combine the information we receive from third parties with information we collect through the Services. In those cases, we will apply this Privacy Policy to the combined information.

Social Networking Features
The Services may permit or facilitate interactions with an interactive third-party website or service (“Social Media”), such as enabling you to “like” or “share” content from the Services or to “like” or “share” our page or Retailers’ pages on a third-party service. If you choose to share content or otherwise post information from or via the Services to Social Media, that information may be public and the third party may have access to information about you and your use of our Services. You may also choose to participate on Social Media in a way that connects that third-party service with our Services (such as posting to one of our pages on a Social Media site or signing into the Services with your credentials from another website or service). Doing so may allow us to collect (or the third party to share) information about you, including Personal Information. For example, if you choose to connect your Facebook account with the Service, you are authorizing us to access certain information contained in your Facebook profile. You agree that we can access this information even when you are not actively using the Services. We may also receive information about you if other users of Social Media give us access to their profiles and you are one of their “connections.” And, if you post about Shoprunner or the Service on a third party platform, that third party may give us the right to post your content on our websites or in connection with the Services or to otherwise have access to or use your content, subject to the third party’s policies and agreements with you.

The information we collect is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy policies, including without limitation whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third-party website or service. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected.

Community Forums and User Submission
The Services may provide you the opportunity to submit information to us, including messages and reviews of Retailers or products and to post content publicly in forums, through interactive features and through other communication functionality (“Community Forums”). The information you submit through such Community Forums includes any and all content that you submit or post through the Services, including, without limitation, photos, video, messages, text, files, or other content you provide us and as further described in our Terms of Service (collectively, “User Submissions”).

Please note that certain information, such as your name and/or username, may be publicly displayed through the Services along with your User Submissions. Your use of any Community Forum is subject to our Terms of Service, including without limitation the “User Submissions” section. Note that anything you submit through a public-facing Community Forum may be made public; others will have access to your User Submission and may use it or share it with third parties. We are not responsible for the actions of third parties and the use of your information and other User Submissions by such third parties is not subject to the protections of this Privacy Policy.

If you submit User Submissions or engage in Social Media interactions, we may publish that information or content online or offline, including in connection with our advertising, marketing, publicity, and promotional activities, as further described in our Terms of Service.

A registered user of the Services has the right to request the removal of certain content that (s)he has publicly posted on a Services platform. A user can request that we remove content (s)he has previously posted by contacting us at privacy@shoprunner.com. When submitting a request, please be sure to include your full name, email address, and information sufficient to permit us to locate the User Submission(s) for which you are requesting removal (e.g., for product reviews, a URL of the product page and the user name under which you posted your review). At our discretion, we may remove only your Personal Information, but maintain the rest of your User Submission or otherwise anonymize your User Submission in lieu of removal. Note that any removal or anonymization of your public postings in accordance with these procedures does not ensure complete or comprehensive removal of the content or information you posted, which may persist in archival records or may have been copied by third parties while publicly accessible.

Refer to a Friend and Gift or Guest Membership Features
If you purchase a ShopRunner membership for a friend through the Services or invite a friend to sign up for ShopRunner Services, or otherwise provide information about a friend, the information you provide (names, email addresses, etc.) will be used to send the friend requested information and to facilitate that friend’s membership or invitation If you disclose any Personal Information relating to other people to us, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

Information We Collect Automatically As You Access and Use our Services
In addition to any Personal Information or other information you choose to submit through the Services, we, and our third-party service providers (including without limitation any third-party advertisers and content or analytics providers), may use a variety of technologies that automatically or passively collect and record certain website usage information whenever you visit or interact with the Services, including e-mails we send you (“Services Usage Information”). This Services Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Services, the search terms you entered into a search engine that led you to our Services (if applicable), which Services you use or otherwise interact with, all of the areas within our websites and other online platforms that you visit, and the time of day, and the products that you searched, viewed, purchased, and shipped, among other information. We may collect this information from Retailer sites, too. We may use this Services Usage Information for a variety of purposes, including without limitation enhancing or otherwise improving the Services. This information also helps us create a better experience for our users and provide you with targeted advertising. Please see the “Third Party Advertising Companies and Analytics Providers” section below for more information about how to control the use of your Personal Information for the purposes of advertising. Services Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.

In addition, we automatically collect your IP address or other unique identifier for your computer, mobile phone, or other device used to access the Services. We may be able to collect or infer your approximate location through information we collect, such as an IP address. A device identifier is a number that is automatically assigned to your mobile or other device used to access the Services, and our servers identify your device by its device identifier.

We may directly collect specific location information from your devices if you have opted-in to such collection through one of our mobile applications. You may be able to turn off the collection of location information through your device’s settings. However, please note that we may still be able to collect or infer your approximate location through other information we collect, such as IP address. In addition, some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the device used to access the Services. We may link any location data that we collect or infer with other information that you provide to us or that may be accessed in connection with your use of the Services.

The methods used to collect Services Usage Information may include, without limitation, the following:

Cookies & Local Storage. A cookie is a data file placed on a device when it is used to visit or use the Services or otherwise access our online content. Certain web browsers and certain browser add-ons may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included with our Services may make use of this local storage.. Cookies and other local storage devices may be used for a variety of purposes (e.g., to identify your device when you revisit or reuse our Services, to recall your authentication information, to store information related to your navigation throughout our Services, or to enable certain features on our Services). Some cookies are essential to the functioning of the Services, and, without them, some features and services you have requested cannot be provided. Other cookies help us to understand and improve how the Services works or allow us to personalize it for you. For example, these technologies are able to store a unique identifier for a device to allow a certain Internet site to recognize the device whenever the device is used to visit the site. These technologies may be used for many purposes by us and our third-party service providers, such as automatically collecting Services Usage Information, enabling features, remembering your preferences, and providing you with targeted advertising elsewhere online. You may be able to refuse or remove some or all of these cookie and local storage technologies, such as through your browser settings. If you choose to do so, some features of the Services may not function properly. You can find more information about cookies and how they work at www.allaboutcookies.org.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs”, “clear GIFs” or “tracking pixels”) may be included in our web pages and email messages. Our web beacons may also be included on our Retailer’s sites to allow us to collect information. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our website or Retailer sites, or other interactions with the Services, to monitor how users navigate the Services and Retailer sites, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed. Our web beacons on Retailer sites may also be used to collect order information on the order confirmation page, including order ID number, product codes, shipping method, and products eligible for ShopRunner benefits.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

HOW WE MAY USE THE INFORMATION COLLECTED
ShopRunner may use information collected through the Services, including without limitation your Personal Information, de-identified information, and Services Usage Information, in order to: (1) allow you to participate in the Services and features offered through the Services and to provide customer service, including without limitation to resolve any billing or payment processing inquiries; (2) tailor content, recommendations, and offers we or our Retailers display to you, both on the Services and elsewhere online; (3) process your registration with the Services, including without limitation verifying that your email address or other information is active and valid; (4) provide you with services or information, or fulfill transactions that you have requested or otherwise agreed to receive, including without limitation facilitating orders you place through our Services, enrollment in the ShopRunner Services, and authorizing and processing your membership and any membership payments, and to process benefits like free shipping and returns; (5) contact you with special offers from us, our advertisers, or third-party business partners, including promotion emails as described in this Privacy Policy and with consent where required by law; (6) communicate with Retailers about your purchases and use of the ShopRunner Services; (7) allocate costs for providing the Services between ShopRunner and its Retailers; (8) protect each party from errors, misuse of the Services, fraud, or any criminal activity; (9) facilitate your job search via the Services and prepare related governmental and internal statistics reports; (10) contact you with regard to your use of the Services or similar administrative communications, including, without limitation and in our discretion, security, support and maintenance advisories and changes to the Services’ policies; (11) use for internal business purposes such as to improve the Services or our products and services and to comply with regulatory and legal obligations; and (12) use for purposes as disclosed at the time you provide your information or otherwise with your consent, and as further described in this Privacy Policy.

We may use, for any purpose, information that does not identify you or relate to an identifiable individual, except where we are required to do otherwise under applicable law.

HOW AND WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES
ShopRunner may freely share non-Personal Information, such as Services Usage Information, aggregated user statistics and de-identified information, with third parties in our discretion. ShopRunner may share the information we have collected about you, including without limitation Personal Information, as disclosed at the time you provide your information or otherwise with your consent, as described in this Privacy Policy, and in the circumstances set forth below. Residents of California should see “CALIFORNIA RESIDENTS - YOUR CALIFORNIA PRIVACY RIGHTS” for more information.

Retailers. We may share your Personal Information with Retailers if you use the ShopRunner Services to make a purchase or otherwise engage in a transaction with a Retailer or on a Retailer’s site. For example, if you use our 2-Day Shipping program, we may provide your email address to help connect your ShopRunner account to your account with the Retailer. If you use our ShopRunner Express Checkout Services, we may disclose Personal Information to Retailers to initiate the checkout process and to allow the Retailer to process your purchase. If we disclose your Personal Information to a Retailer, the privacy policies of each Retailer shall govern the applicable Retailer’s use and disclosure of your Personal Information. We are not responsible for any Retailer’s use of any Personal Information.

Other Unrelated Third Parties. You may be presented with an opportunity to receive information or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. You also may request, sometimes through your use of an interactive feature or third-party application, that we share information about you with a third party, and we will typically do so under those circumstances. We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

Third Parties Providing Services on Our Behalf. We sometimes use other businesses to perform services for us, such as website hosting, conducting website usage analysis, sending email or other communications, administering our Services, providing marketing assistance and data analysis, processing payments (including without limitation clearing and processing credit card payments), or performing other services. We may provide access to your Personal Information to such service providers in order for them to complete a requested transaction or otherwise to perform these services.

Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests or other promotions (any, a “Promotion”), that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern that Promotion, which may contain specific requirements of you (including, without limitation and except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, as required by law or permitted by the Promotion’s terms or official rules (such as on a winners list).

Employment; EEOC. If you apply for a job with us via the Services, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity) in connection with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information to the EEOC, the OFCCP and similar state and local regulatory agencies for business-related purposes, including, but not limited to responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.

Administrative and Legal Reasons. ShopRunner may transfer and disclose information, including without limitation your Personal Information, Services Usage Information and device identifiers (e.g., IP address), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Service or other applicable Services policies; to respond to an emergency; or otherwise to protect our rights, property, safety, or security or that of other Services users/visitors or the public. We may also use device identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion. Such disclosures may be carried out without notice to you.

Business Transfers. In the event that ShopRunner goes through a transition such as being sold, has all or a portion of its assets acquired or transferred, whether voluntary or involuntary (such as through bankruptcy), or merges or becomes affiliated with any other division, individual or entity; the current policy only covers acquisition(including, without limitation, during the course of any due diligence process), any customer information owned or under the control of ShopRunner (including without limitation your Personal Information) will likely be one of the transferred assets. We reserve the right, as part of this type of transaction, to assign or otherwise transfer your information (including without limitation Personal Information) and other information we have collected from users of the Services. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.

THIRD-PARTY ADVERTISING COMPANIES AND ANALYTICS SERVICES
ShopRunner may work with network advertisers, ad agencies, analytics service providers, and other vendors to serve third-party advertisements on our websites and in connection with the Services; to serve our advertisements elsewhere online; and to provide us with information regarding use of and traffic on our websites and in connection with the Services (including without limitation the pages viewed and the actions users take when visiting our websites or using the Services) and the effectiveness of our advertisements. For example, if you click on an advertisement for ShopRunner, our service provider(s) may be able to tell us the advertisement you clicked on and where you were viewing the advertisement; likewise, if you click on an advertisement you see when using our Services, our service provider(s) may be able to tell which page you were visiting on our websites or when you were using the Services and pass that information to the advertiser. The advertisements you see may be served by one or more third parties, who may use information about your activities in connection with the Services, and other websites and services you visit, across the various devices you use, to provide you targeted advertising based upon your interests. Our service providers may collect certain information about your visits to and activity on our websites and in connection with the Services and other websites and services and may use this information to target advertising to you.

These service providers may set and access their own tracking technologies on your devices (including without limitation cookies and web beacons) and may otherwise collect or have access to information about you (such as your Services Usage Information and device identifiers). They may collect information about you over time and across different websites and other online platforms. Cookies and web beacons, including without limitation those set by third-party network advertisers, may be used to (among other things): target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share certain information such as device identifiers, Services Usage Information and de-identified information with third-party advertising companies, analytics providers and other vendors for advertising and analytics purposes.

We use a variety of service providers to perform advertising and analytics services, and some of these companies may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”). You may wish to visit optout.networkadvertising.org, which provides information regarding targeted advertising and the opt-out procedures of NAI members. You may also want to visit optout.aboutads.info, which provides information regarding targeted advertising and offers an opt-out for participating companies.

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to google.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout.

For mobile apps, you may be able to limit certain advertising practices using the settings on your phone, tablet or other mobile device. You may download the AppChoices app at youradchoices.com/appchoices to opt out of the delivery of interest-based advertisements in mobile apps.
Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive non-targeted advertisements while online or on your device.

HOW WE RESPOND TO DO NOT TRACK SIGNALS
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, our websites and other Services do not alter their practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

CHANGING YOUR PREFERENCES AND ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION
You can correct or update some of the Personal Information you have provided to us through registration with the Services by editing your Account profile. In addition, if you would like to request deletion of Personal Information that you have provided to us, you may contact us at privacy@shoprunner.com. Your request must be sent with the subject line “Account Deletion Request” and be sent from the email address associated with your ShopRunner account. When we delete any information, it will be deleted from the active database, however, such information may continue to be retained on our backup and archival systems. Accordingly, when you request that we remove your information from our systems, copies may remain on our systems for a certain time unless prohibited by law. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or within our other records. Also, please note that we may need to retain certain information for our administrative purposes. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information, either through any online account feature offered or by contacting us as set forth under “Contacting Us,” below.

You may have the opportunity to login to your ShopRunner account by linking it to your account with a third party. If you later remove access to ShopRunner through that third party account, we will honor that request within a reasonable time period.

Users who receive a newsletter or other marketing emails from us and who wish to remove themselves from the mailing list (i.e., opt out) can do so by following the link provided in each such email received. If you sign up to receive SMS or MMS messages that may be offered through the Services, you may unsubscribe from any text messages received by replying “STOP”. You may also be able to adjust your account settings on shoprunner.com. However, please note that we reserve the right to send you certain communications relating to your use of our Services, service announcements, notices of changes to this Privacy Policy or our Terms of Service or similar administrative or transactional messages, and these messages may be unaffected if you choose to opt out from marketing communications.

If you access the Services through one of our mobile apps, we may, with your permission, send push notifications to your personal device. You may opt-out of receiving these at any time by turning push notifications off in your device settings.

RETAILER AND OTHER THIRD-PARTY CONTENT, LINKS TO OTHER SITES, AND SHOPRUNNER CONTENT FOUND OUTSIDE OF THE SITE

Certain content on the Services may be hosted and served by third parties, and the Services may contain links to Retailers and other third-party websites that ShopRunner does not control. For example, our Services may provide links to Retailer and third-party sites through which you can purchase merchandise, products or services or which link to a product or service offered by a third party. In addition, Retailer sites that support ShopRunner benefits may link to our Services. These third parties may collect Services Usage Information through the use of their own cookies and web beacons, independently collect data or solicit Personal Information, and may have the ability to track your use of their sites and services. ShopRunner is not responsible for the privacy or other practices employed by any third party.

SECURITY

While ShopRunner takes commercially reasonable steps designed to secure your Personal Information, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. ShopRunner cannot ensure or warrant the security of any information we collect. Further, ShopRunner is not responsible for your Personal Information after it is provided to a Retailer. You use our Services and provide us information at your own risk.

JURISDICTION AND CROSS-BORDER TRANSFER

ShopRunner is a United States company. Please be aware that information we collect will be transferred to and processed in the United States and other jurisdictions. By using the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States and other jurisdictions, for which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

REVISIONS TO THIS PRIVACY POLICY

We reserve the right to change or modify this Privacy Policy in our discretion at any time and will notify you of material changes by posting the changed or modified Privacy Policy in connection with our Services. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Changes to this Privacy Policy may affect our use of Personal Information that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Information, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. This Privacy Policy is updated frequently and you should check the Services regularly for any new notices of changes. Continued use of our Services following any changes, regardless of whether a notification of such change was sent to you directly, shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

CALIFORNIA RESIDENTS - YOUR CALIFORNIA PRIVACY RIGHTS

Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California certain information relating to third parties to which the company has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes. As stated above in this privacy policy, ShopRunner does not share personal information with non-Retailer third parties for their direct marketing purposes (as defined by California Civil Code Section 1798.83) unless we give you choice (an opt-out) before sharing with those third parties.

If you are a California resident and you would like to request information about the sharing of your personal information with third party Retailers for their direct marketing purposes, please send your request to the following email address: privacy@shoprunner.com or write to us at the following mailing address: Attn: General Counsel, ShopRunner, 350 N. LaSalle, 6th Floor, Chicago, IL 60654. California residents may make this inquiry once per calendar year. If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, you may also contact us at privacy@shoprunner.com or write to us at the following mailing address: Attn: General Counsel, ShopRunner, 350 N. LaSalle, 6th Floor, Chicago, IL 60654. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us using the contact information in the preceding section or the following contact information:

Address:
Attn: Legal Services
ShopRunner, Inc.
350 N. LaSalle, 6th Floor
Chicago, IL 60654