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Privacy Policy

Effective Date: January 1, 2023:

This website or mobile application (“Site”) is owned and operated by a Transform Holdco LLC (“Transformco”, “we”, “our”, or “us”) entity or licensee. Your privacy is important to us and we want you to understand what information we gather about you, how we use it, and the safeguards we have in place designed to protect it. This Privacy Policy applies to information collected through this Site, our services, products, call centers, and other offerings. We may update this Privacy Policy from time to time. Please check this Privacy Policy periodically for changes. If we make any changes, the updated Privacy Policy will be posted to this Site with a revised Effective Date. We encourage you to periodically review this page for the latest information on our privacy practices. Your use of this Site, and any disputes arising from it, are subject to this Privacy Policy as well as our Terms of Use and all of its dispute resolution provisions, including arbitration, class action waiver, limitation on damages and choice of law. By using the Site or otherwise providing personal information to us, you agree to our Terms of Use and consent to our personal information collection, use, and disclosure practices. If you do not agree, please discontinue use of the Site.

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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 PII 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.

We may use single sign-on services that allow you to sign into this Site using social networking login credentials for accounts such as Facebook or Google. This allows you to link your existing social network profile to your Site account. Once connected, you may be able to post content on the social networking website from this Site and interact with your friends from the social networking site(s). Any information or content that you post to the social networking website will be subject to that website’s own privacy policy. We may also access and use available information from your social network profile, such as your name, location, and profile picture if you make such information available.

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.

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.

We may disclose your PII to identify you to anyone to whom you send messages through this Site. You may disclose your own PII 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 PII 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 PII, 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 PII 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 PII 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.

To remove posted content or information on shopyourway.com, please write to sywsolutions@syw.com. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another User or Member.

Our vendors, including Facebook and Google, may use Cookies, web beacons, and other storage technologies to collect or receive information about your internet usage, including your use of this Site, and use that information to provide measurement services and target ads. We and our vendors may use first-party Cookies or other first-party identifiers as well as Cookies or other identifiers operated by our vendors to deliver advertisements, create a profile of you, measure your interests, detect your demographics, detect your location, and personalize content.

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.

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.

Capitalized terms that are used herein shall have the meaning given to them in the remainder of the Privacy Policy except capitalized terms defined in the CCPA that are used in this California Notice shall have the same meaning as in the CCPA. Unless otherwise noted, the disclosures contained within this California Notice cover our activities in the prior 12 months from the effective date noted atop this Privacy Policy, as well as our current practices.

Category of Personal InformationBusiness 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.
  • Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity;
  • Debugging the Site to identify and repair errors;
  • Internal research and development;
  • Quality and safety assurance, and improving, upgrading, and enhancing the Site and our products and services; and
  • Processing and managing interactions and transactions on the Site and our products and services
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
  • Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity; and
Protected Classifications under California or federal law (e.g., age, gender, household information, marital status, veteran or military status).
  • Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
  • Internal research and development; and
  • Processing and managing interactions and transactions on the Site and our products and services
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.
  • Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity;
  • Debugging the Site to identify and repair errors;
  • Internal research and development;
  • Quality and safety assurance, and improving, upgrading, and enhancing the Site and our products and services; and
  • Processing and managing interactions and transactions on the Site and our products and services
Geolocation Data
  • Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity; and
  • Processing and managing interactions and transactions on the Site and our products and services
Sensory information, Audio, electronic, visual, or similar information.
  • Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services; and
  • CCTV recordings from inside our facilities for use in fraud investigations and security purposes and call center recordings from when you contact customer service
Professional or employment-related information, (Ex. education level or employment status).
  • Processing and managing interactions and transactions on the Site and our products and services
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
  • Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
  • Internal research and development;
  • Quality and safety assurance, and improving, upgrading, and enhancing the Site and our products and services; and
  • Processing and managing interactions and transactions on the Site and our products and services
Sensitive Personal Information, precise geolocation.
  • Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services
  • to manage our operations, to manage your relationship with us, to provide you with information regarding our products or services, or to satisfy another purpose for which we Collected the information
  • to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was Collected;
  • to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
  • we are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.

Your CCPA Rights

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.

Non-Discrimination
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.

a. The Right to Know

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:

  • The categories of Personal Information we have Collected about you.
  • The categories of sources from which we Collected your Personal Information.
  • The Business or Commercial Purposes for our Collecting and/or Selling/Sharing your Personal Information.
  • The categories of Third Parties to whom we have Sold/Shared your Personal Information.
  • A list of the categories of Personal Information disclosed for a Business Purpose.
  • A list of the categories of Personal Information Sold/Shared about you, or that no Sale/Share occurred. If we Sold/Shared your Personal Information, we will explain:
    – The categories of your Personal Information we have Sold/Shared.
    – The categories of Third Parties to which we Sold/Shared Personal Information, by categories of Personal Information Sold/Shared for each Third Party.

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.

b. The Right to Deletion

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.

c. Right to Correct

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.”

d. Exercise Your Rights

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.

Notice of Financial Incentive

This Financial Incentives disclosure applies to the Shop You Way program (“Shop Your Way” or the “Program”). A separate notice for it follows below. 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. You can opt-out of non-Program marketing emails or delete your Personal Information from our active marketing lists and retain your Program account and benefits.

a. Shop Your Way Financial Incentive Notice

ProgramIncentive OfferedMaterial TermsHow 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.

  • Available at participating merchant brands.
Categories of Personal Information Collected:
  • Identifiers (e.g., name, email address, Internet Protocol address)
  • Personal Records (e.g., signatures, financial account information).
  • Personal Characteristics (e.g., age, gender, household information, marital status, veteran or military status)
  • Commercial Information (e.g., purchase history, service history)
  • Internet or Other Electronic Network Activity Information (e.g., browsing history, search history)
  • Geolocation Data (e.g., your location we infer based on your IP address)
  • Sensory Information (e.g., voice recordings from call centers, profile pictures on accounts)
  • Professional or Employment Information (e.g., education level or employment status)
  • Inferences from Personal Information Collected (e.g., customer profiles including shopping preferences, product preferences, customer characteristics and behaviors)

Register for an account online or on the mobile app.

Participating in Shop Your Way is entirely optional but is subject to additional Shop Your Way Program Terms and Conditions.

We treat the value of Consumer data 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.

California Consumers may make a Personal Information deletion request under the CCPA by calling us at (888) 527-6415 or by submitting a request online here. If this request includes deleting your email address, then it will terminate your Program membership because that information is necessary for us 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.

California Shine the Light Law

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.

If you are a Virginia resident, subject to certain conditions and restrictions set out in the Virginia Consumer Data Protection Act (“VCDPA”) and other applicable laws, you have the following rights with regard to your “personal data” (as defined in the VCDPA):

  1. Right to access. You have the right to request access to and obtain a copy of any personal data that we may hold about you.
  2. Right to correct. You have the right to request that we correct inaccuracies in your personal data.
  3. Right to delete. You have the right to request that we delete personal data that we have collected from or obtained about you.
  4. Right to opt out of sales. You have the right to opt-out of the sale of personal data. However, we do not sell personal data as defined under the VCDPA, and as such do not offer this right.
  5. Right to opt out of targeted advertising. You may request that we stop disclosures of your personal data for targeted advertising.
  6. Right to opt out of profiling. You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not engage in profiling that results in any legal or similarly significant effects and as such do not offer this right.
  7. Right to appeal. If you are unsatisfied with our actions related to our resolution of your privacy request, you may appeal our decision.
  8. Right to non-discrimination. If you choose to exercise any of the privacy rights described above, we will not deny our products or services to you, charge you different prices or provide a different level or quality of products or services to you.

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 under the VCDPA 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 and comply with the VCDPA’s requirements. 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.

Still have questions? Contact Us