Effective Date: July 1, 2023:
Get answers and information about:
What Type of Information Do We Collect and How Do We Use It?
We may collect personal information (“PI” – for example, your full name, email address, mailing address, telephone number, mobile phone number or payment information) from you when you voluntarily submit the information to us, such as when you purchase items from us, sign up for one of our services or programs, or register with our Site. We may also collect PI from you–either directly or via one of our vendors–in other ways, including, without limitation, if you choose to subscribe to our emails; participate in sweepstakes, contests, surveys, and polls; post content or suggestions on this Site; or use any of the Site’s other features that otherwise permit you to provide information or other content.
We also may collect other information about you, including, without limitation, demographic information (such as number of household members, age, and gender) and information about your purchase preferences directly from you (whether online or offline) or from vendors such as public databases, social media platforms, data append services, and others. In addition, we may collect information (such as your interests, hobbies, and lifestyle choices; groups with which you are affiliated; and products you want, like, or own) from you as you use this Site and when you choose to provide this information to us through any interaction with this Site or otherwise.
We may use the information we collect from and about you to: process and fulfill your order, notify you of your order status, prevent fraud, and otherwise provide you with customer service; respond to your inquiries and requests; create an account and register you as a Site user (“Registered User”) and/or Shop Your Way member (“Member”); for marketing purposes and to send you information regarding this Site and other Transformco Sites, as well as about our products, programs or services; provide you with mobile alerts, if you have requested them; customize your experience on this Site and on other Transformco Sites; provide you with relevant offers, products and services; permit you to use this Site’s social networking features; or provide you with other services. Please note that message and data fees may apply if you register for mobile alerts. We may also use the PI we collect from and about you for our business purposes, such as data analysis, audits, developing new products and services, enhancing our Sites, improving our services, personalizing your experiences, identifying usage trends and determining the effectiveness of our promotional campaigns.
Some Site features may make use of your device attributes and settings that will allow our Site to determine your physical location. Such technologies may include IP address mapping, WiFi, GPS signals, cell tower positioning or other technologies. We use this information to enhance and personalize your experience and provide you with offers, products and services that may be of interest to you. For example, this Site may help you find your closest store or send you messages that may be of interest to you based on your current location.
We may engage vendors to provide certain interactive features on our Site. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on the Site to assist you and for other customer service purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf.
Other personal information may be collected from you by means of cookies, pixel tags (also called web beacons or clear gifs), local shared objects and other tracking technologies (collectively “Cookies”). Cookies are small bits of information that this Site places on your computer. We and our vendors use these technologies to identify your IP address, browser type, device characteristics, domain name, referring URLs and specific links and web pages through which you click. This data is collected automatically and utilized for data analytics, site operations, fraud prevention, advertising and marketing, and to help us improve this Site and your overall experience. This technology also allows us to recognize you when you return to this Site and to provide you with a customized experience that we feel will be of value to you.
What Information Do We Share and With Whom?
We may share your PI with selected vendors with which Transformco or its affiliates have a relationship, and which have agreed to appropriate restrictions on the disclosure and use of your information.
We may disclose your PI to identify you to anyone to whom you send messages through this Site. You may disclose your own PI through services to which you are able to post information and materials. Please note that any information you post or disclose through these services may be available to Site visitors and to the general public, depending on the particular service and any privacy settings in place (such as through your profile).
We may share your PI with our vendors that need access to your information to provide operational or other support services, such as payment processors, shipping agents, and product fulfillment vendors. These vendors must agree to appropriate restrictions on the disclosure and use of your information.
We may provide information about you, which may include PI, to regulatory authorities and law enforcement officials in accordance with applicable law, when we believe in good faith that the law requires it or to respond to requests from government authorities. There may be instances when we may use or disclose your PI in order to protect or defend the legal rights, property or operations of Transformco or our employees or agents; to protect the rights, privacy, safety or security of Users, Members or others; to protect against fraud; and to allow us to pursue available remedies or limit the damages that we may sustain.
Transformco may sell, transfer and/or share PI in connection with a merger, reorganization, joint venture, assignment, spin-off, transfer or sale or disposition of all or any portion of our business, and in the event of a store closing or bankruptcy.
Can I Disable Cookies?
Most web browsers allow you to exercise control over Cookie files on your computer by erasing them, blocking them, or notifying you when a file is stored. Please take a look at your particular browser for instructions on this function. If you do elect to disable Cookies, please note that you may not be able to take full advantage of a personalized experience on this Site and on other Transformco Sites.
This Site is intended for a general audience and not directed to children less than 13 years of age. We do not intend to collect PI in a manner that is not permitted by Children’s Online Privacy Protection Act (“COPPA”). If you are under 13, do not provide any PI to us. If we obtain actual knowledge that we have collected children’s PI in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA. If you believe your child may have provided us with their PI, you can contact us at (888) 823-0650 and we will delete their PI to the extent required by law.
I Am a Minor, How Can I Remove My Posted Content?
If you are under 18 and a Registered User or Member, you may ask us to remove content or information that you have posted to the Site.
To remove posted content or information on shopyourway.com, please write to email@example.com. Please note that your request does not ensure complete or comprehensive removal of the content or information.
What About Links to Other Sites?
This Site may contain links to content from other websites or applications that are not owned and operated by Transformco. Transformco is not responsible for the privacy practices of non-affiliated websites or applications, including, without limitation, those that are linked to or framed on this Site. You should read the privacy statements of each and every website and application that collects PI.
Interest-Based Ads – Online Advertisements
This Site may display ads from other companies. We also partner with vendors to serve ads on our behalf on other non-affiliated sites or apps. Some of the ads on this Site or on other websites or apps may be personalized, meaning that they are intended to be relevant to you based on what we or the online advertising network serving the ad know about you or your device’s browsing activity. For example, information collected by our ad networks or other vendors across multiple sites that you visit may enable the ad network to predict your preferences and show you ads that are most likely to be of interest to you. We may share your information with our vendors to permit them to recognize and serve targeted ads to you across the different devices you use.
We may use certain web analytics services, including Google Analytics, to help us understand and analyze how visitors use the Site and to serve ads on our behalf across the Internet. We’ve implemented Google Analytics Advertising Features such as remarketing with analytics, interest-based advertising, and demographics and interests reporting. For more information on how Google Analytics uses data collected through the Site, visit policies.google.com/technologies/partner-sites. You may also be able to opt out of Google Analytics by visiting tools.google.com/dlpage/gaoptout.
If you do not wish to receive personalized advertising from us on other mobile or desktop sites, please visit the Network Advertising Initiative Opt-Out page. You may also download the AppChoices app at www.aboutads.info/appchoices to opt-out of personalized in-app advertising. The Network Advertising Initiative offers useful information about internet advertising companies, including information about how to opt-out of interest-based advertising by their members. You may also visit www.aboutads.info/consumers/ to learn about how to opt-out from online or in-app behavioral ads served by some or all participating companies. To opt out of Google’s network of interest-based advertising, visit adssettings.google.com.
These opt-out mechanisms rely on Cookies to remember your choices with respect to ad-serving on websites. If you delete your Cookies, use another computer or device, or change browsers, you will need to repeat this process. In addition, opting out of interest-based ads will not opt you out of all ads, but rather only those ads that are personalized to your interests based on activities observed on our Site and/or websites or mobile apps not owned and operated by Transformco.
Some browsers may enable you to turn on or off a “Do Not Track” signal. We do not respond to “Do Not Track” signals.
Is My Information Secure?
We protect your PI using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Although we implement reasonable security measures on our Site, you should be aware that we cannot guarantee the security of your information submitted via the Internet. It is your responsibility to make sure that your passwords and account registration information are secure and not shared with third parties.
How Can I Access My Information?
You can personalize your experience on this Site and other Transformco Sites by becoming a Registered User or Member. By registering, you will be able to tell us what products and services interest you, and whether you wish to receive information about special sales, promotions and other events. Once registered, you can submit, review and maintain your account profile information at any time by accessing your profile from within the particular Site. Your account information is accessible by using a password that you select or, if available and you choose to enable this feature, by using social networking login credentials for other non-affiliated sites such as Facebook or Google.
Can I “Opt-Out” of Receiving Promotional E-mails?
From time to time, we may send you emails with promotional offers and messages. If you would no longer like to receive emails with promotional offers and messages from this Site, you can unsubscribe from these emails by following the unsubscribe link located at the bottom of each promotional email. Please note that you may still receive transactional notices in email or other non-promotional emails (e.g., order confirmations, shipping notices, account statements, or important information regarding a product you have purchased) which will not have an unsubscribe link as they are not marketing emails.
This California Consumer Privacy Notice section (“California Notice”) applies to Consumers as defined by the California Consumer Privacy Act (as amended the “CCPA”) and should be read along with our other notices found on Transformco.com, and other websites in our family of brands (including but not limited to Sears, Kmart, and ShopYourWay). In the event of a conflict between any other Transformco policy, statement or notice and this California Notice, this California Notice will prevail as to California Consumers’ rights under the CCPA.
This California Notice applies to California Consumers that visit our Site. If you are a current employee of Transformco, you may view your California Notice by visiting MPI. If you are a job applicant, you may view your California Notice by visiting our Careers page. If you interact with us in other contexts and have questions about your privacy rights or our Information Practices you can contact us at (888) 823-0650.
How and Why We Collect Your Personal Information
We Collect, use, and disclose the categories of Personal Information about California Consumers that are indicated in the chart below. Note that the specific pieces of Personal Information we Collect, use, and disclose about you may vary depending on the nature of your interactions with us, and may not include all of the examples listed.
|Category of Personal Information||Business Purposes for Collection, Use, and Disclosure|
|Identifiers such as a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.|
|Personal Records Any Personal information described in subdivision (e) of Section 1798.80 of the California Civil Code) such as the Identifiers listed above, telephone number, or other financial information|
|Protected Classifications under California or federal law (e.g., age, gender, household information, marital status, veteran or military status).|
|Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a Consumer’s interaction with an internet website application, or advertisement.|
|Sensory information, Audio, electronic, visual, or similar information.|
|Professional or employment-related information, (Ex. education level or employment status).|
|Inferences drawn from any of the information identified in this subdivision to create a profile about a Consumer reflecting the Consumer’s preferences, characteristics, or predispositions|
|Sensitive Personal Information, precise geolocation.|
Sources of Personal Information
We Collect Personal Information directly from you, your devices or browser, vendors that assist us in providing our services and running our internal business operations, data analytics providers, advertising networks, suppliers, public databases, social media platforms, data enrichment services, other companies in the Transformco family of businesses, and other data providers.
Recipients to Which Personal Information is Disclosed
We use Service Providers to help us operate our websites and provide other services on our behalf such as credit and collection agencies, marketing services companies, call center vendors, and field services technicians. Our Service Providers only use Personal Information they Collect or Process on our behalf to provide us services.
Retention of Personal Information
We keep the categories of Personal Information described above for the purposes described in this California Notice or otherwise authorized by law. This generally means holding the Personal Information for as long as one of the following criteria apply:
Where Personal Information is used for more than one purpose, we may retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
Selling and Sharing of Personal Information
We may Sell or Share Identifiers, Internet or other electronic network activity information, and/or geolocation data for advertising and marketing purposes with Third Parties including our advertising and analytics partners.
Right to Opt Out of Sales and Sharing
You can opt out of Sales and Sharing of your Personal Information in the context of Cookies by clicking on the “Do Not Sell or Share My Personal Information” link in the footer of the Site you are visiting. Opting-out will not affect our ability to personalize your experience on our Site. We may still present contextual advertisements or you may still receive non-personalized advertisements that do not rely on “Sales” or “Sharing” to our advertising partners. Because of the way some Third Parties operate, you may need to also opt-out on your other browsers and devices. Cookie-enabled opt-out signals may no longer be effective if you block or clear Cookies. For more information on how to exercise choices regarding Cookies and interest-based advertising, see the section above titled “Interest-Based Ads – Online Advertisements”.
We use Service Providers to help us operate our Sites and provide other services on our behalf. Our Service Providers only use Personal Information they Collect or Process on our behalf to provide us services. Opting out will not affect Cookies deployed by our Service Providers.
Opt-Out Preference Signals
You may also opt out of the Sale or Sharing of your Personal Information through an opt-out preference signal. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use.
We will not discriminate against you in a manner prohibited by the CCPA because you exercised your CCPA rights.
Rights to Know, Delete, and Correct Personal Information
California Consumers have the right to exercise certain privacy rights under the CCPA. Any request you submit to us is subject to an identification and residency verification process. We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we Collected Personal Information.
If you are unable to provide us with certain information about yourself or, in some cases, about your transaction history with us, we will be unable to verify your identity to fulfill a request to know or delete. As an initial matter, we require you to provide your name, address, email address, and phone number to be submitted via our online request form or toll-free telephone number. In some cases, we may verify identity by confirming that you are the owner of the email address we have on file. For specific pieces of Personal Information, we will apply heightened verification standards, and reserve the right to request further information from you.
If we cannot comply with a request, we will explain the reasons in our response. We will make commercially reasonable efforts to identify Consumer Personal Information that we Collect, Process, store, disclose, and otherwise use to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
You may use an authorized agent to submit a consumer rights request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your Personal Information that we have Collected in the period that is 12 months prior to the request date and are maintaining. Please note that Personal Information is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
You may request that we delete your Personal Information that we have Collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your Personal Information for regulatory reasons, to complete a warranty or other contract with you, or other internal uses of the information that are compatible with the context in which you provided it.
You may request that we correct Personal Information that we maintain about you if you believe such Personal Information is inaccurate. We may request documentation from you in connection with your request where we have reliable documentation showing the accuracy of the information. As with a Right to Know or Right to Delete request, to protect you, we will require you (or your agent) to be verified before honoring your correction requests. Upon receipt of a verifiable request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the information as you direct. You may be able to correct certain Personal Information that we maintain about you by visiting your “My Account.”
To exercise the right to know, correct, or right to delete, you may submit a request by calling us at (888) 527-6415 or online by clicking here. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so.
California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes.
We do not share personal information with third parties for their direct marketing purposes. If you are a California resident, you may request information about our compliance with Shine the Light by contacting us at ShineTheLightCA@transformco.com or by sending a letter to:
Transform SR Holding Management LLC
ATTN: Legal Intake/Privacy Team
5407 Trillium Boulevard, Suite B120
Hoffman Estates, Illinois 60192
Any such request must include “California Shine the Light Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.
This Loyalty Program and Financial Incentive disclosure applies to California and Colorado Consumers who are members of the Shop Your Way program (“Shop Your Way” or the “Program”). We may add or change programs and/or their terms by posting a notice on the program descriptions, so check them regularly. We will not discriminate against you if you exercise any of the rights provided by the CCPA or the CPA. You can unsubscribe from marketing emails and retain your Program account and benefits. References to “personal information” in this section describe our practices with respect to “personal data,” as defined under the Colorado Privacy Act (CPA).
a. Shop Your Way Loyalty Program and Financial Incentive Disclosure
|Program||Incentive Offered||Material Terms||How to Opt-In|
Shop Your Way
Your Shop Your Way account earns points for purchases at eligible stores, special offers, and eligible credit card purchases. Points are accumulated to earn Rewards that may be redeemed for discounts on future purchases or gift cards.
Categories of Personal Information Collected:
Register for an account online or on the mobile app.
We treat the value of Consumer Personal Information Collected through the Program as the equivalent of relevant expenses related to the Collection and retention of Consumers’ Personal Information as part of the Program. We value the benefits of the Shop Your Way Program as the value of rewards given to Members, which are outlined in the Shop Your Way Program Terms and Conditions. We pay these expenses and provide the Program benefits, which vary depending upon Program participation, to foster a positive relationship with our Members that is invaluable.
Categories of Third Parties that Receive Consumer Personal Information/Data:
|Bona Fide Loyalty Program Partners||Loyalty Program Benefit|
|Citi (powers the Shop Your Way credit card rewards)||Provides card points for purchases using the Citi ShopYourWay Mastercard.|
|Raise (allows Shop Your Way Members to exchange points for gift cards)||Provides gift cards to consumers to a variety of retailers.|
|Mastercard (powers the Shop Your Way CardLink Program offers)||Provides points redeemable through offers sourced by Mastercard and its partners.|
|Wildfire (powers the Shop Your Way rewards available via the Shop Your Way browser extension and offer wall)||Provides points redeemable through offers sourced by Wildfire and its partners.|
|Button (powers the Shop Your Way rewards available via the Shop Your Way offer wall)||Provides points redeemable through offers sourced by Button and its partners.|
Consumers may make a request under the CCPA or CPA by calling us at (888) 527-6415 or by submitting a request online here. If you submit a deletion request, it will terminate your Program membership because we must maintain your Personal Information to provide the Program. Upon a termination request, some Program data associated with the terminated account may be retained for record keeping, tax reporting, and other legally permissible purposes.
This section applies to Colorado, Connecticut, and Virginia (“Regulated State[s]”) residents that visit our stores, access or use our Sites or services. You can learn more about: the categories of Personal Data we process here, disclose to Third Parties here, and the purpose for Processing your Personal Data here. References to “personal information” in our general privacy notice describe our practices with respect to “Personal Data,” as defined under the Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA). Capitalized terms defined in Regulated State privacy laws that are used in this section shall have the same meaning as in the Regulated State privacy laws.
If you are a resident of a Regulated State, subject to certain conditions and restrictions set out in the VCDPA, CPA, CTDPA, and other applicable laws, you have the following rights with regard to your “Personal Data” (as defined in the VCDPA, CPA, and CTDPA):
We Process Personal Data, including personal identifiers, internet or other electronic network activity information, and geolocation data for Targeted Advertising purposes. You have the right to opt out of our use of your Personal Data for Targeted Advertising. Information on how to exercise your opt-out rights as well as other rights you may have are described below.
We may Sell or share the categories of Personal Data listed below to the following categories of Third Parties: advertising and analytics partners.
You may opt out of Targeted Advertising by clicking the “Do Not Sell or Share My Personal Information” link in the footer of the Site you are visiting. You may exercise your other privacy rights here. You may also call us at (888) 527-6415. When you submit a request to us, we will authenticate your request to protect your privacy and security. We will use the Personal Data provided in a privacy rights request only to verify your identity or authority to make the request and to track and document request responses unless you also gave it to us for another purpose. Residents of Regulated States may also contact us here.
Additional Disclosures for Colorado Residents
Below is a description of our online and offline information practices and other disclosures required by the Colorado Privacy Act.
You can learn more about the categories of Personal Data and Sensitive Data that we have collected about consumers and the purpose for processing your Personal Data by visiting the What Type of Information Do We Collect and How Do We Use It?
Information about our Bona Fide Loyalty Program
Please see our Shop Your Way Loyalty Program and Financial Incentive Disclosure, which describes our Personal Data collection practices for our Bona Fide Loyalty Program.
Transform SR Holding Management LLC
ATTN: Legal Intake/Privacy Team
5407 Trillium Boulevard, Suite B120
Hoffman Estates, Illinois 60192