EFFECTIVE: January 1, 2020
We hope this information increases your confidence in Walkpop and enhances your experience with us.
- Personal information we collect
- Purpose and legal basis for processing your information
- Sharing your personal information
- Choice/opt-out of/unsubscribe from communication
- Data retention
- Security of your personal information
- Privacy Rights
- Contact us
- PERSONAL INFORMATION WE COLLECT
When you use the Services, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card number and expiration date), email address, and phone number. We refer to this information as “Order Information.”
We also collect information when you voluntarily submit information to us (“User-Submitted Information”). Our primary purpose in collecting User-Submitted Information is to provide you with a smooth, efficient, and customized experience. We only collect information about you that we consider necessary for achieving this purpose. We may collect the following User-Submitted Information:
- In order to better tailor our services to you, we may ask for certain personal characteristics, such as your cup size, band size, and dress size. This information is not mandatory and you may choose not to provide such information.
- We might collect your email address if you sign-up to receive our newsletter. You can control your email preferences or unsubscribe on your account page.
- If you order a gift card, we may require that you provide the recipient’s name, shipping address and email address. We use this information for billing purposes and to fill your orders.
- We may provide you the opportunity to participate in surveys or contests on our Site. If you choose to participate in a survey or contest, we will collect certain Personal Information from you, which typically includes contact information (such as name, email address and shipping address) and demographic information.
- Refer a Friend. If you choose to use our referral service to tell a friend about our Services, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Site. Walkpop collects your friend’s name and email address for the sole purpose of sending this one-time email and tracking the success of our referral program. We will make clear that our email to your friend was sent at your request. You should check that your friends consent to your sharing of their personal information before submitting it to us. If your friend does not wish to receive future invitations or emails from us, your friend may unsubscribe by following the link included on our email or contact our help team at firstname.lastname@example.org to request that we remove her/his email address from our mailing list.
- When you reach out to our Help Team, including by email at email@example.com, you may provide Personal Information. This information is collected and used solely for purposes of handling your claim or request and manage our customer service efficiently.
- PURPOSE AND LEGAL BASIS FOR PROCESSING
a. Purpose of Processing
We collect, use, disclose or otherwise process your Personal Information for one or more of the following purposes:
- To fulfill the purpose for which you provided the information.
- To communicate with you, including via email, text message, push notification and/or telephone calls.
- To operate, maintain, and provide to you the features and functionality of the Service.
- To screen our orders for potential risk or fraud; and we use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
- When in line with the preferences you have shared with us, to provide you with information or advertising relating to our products or services
- To market to you, including through email, direct mail, phone or text message.
- To personalize your experience and to deliver custom content and product and service offerings relevant to your interests, including targeted offers and ads through our Site or third-party websites.
- To recognize you and remember your information when you return to our Site or Services.
- To help maintain the safety, security, and integrity of our Services, technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To protect Walkpop’s rights.
- To evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Walkpop or Walkpop’s parent company Adore Me’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Walkpop or Adore Me about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.
- We also use this information to contact you about the products and Services on our Site in which you have expressed interest and otherwise to communicate with you about Walkpop and our marketing partners, including special offers and updates, messages about the Services and Your Account
b. Legal basis for processing
- Walkpop may process your Personal Information on the following legal grounds:
- Performance of a contract to which you are a party
- Walkpop’s legitimate interest
- Compliance with legal obligations
- Your consent
- SHARING YOUR PERSONAL INFORMATION
Walkpop may share Personal Information with third parties for business purposes or as required by law.
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
We may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
We may disclose your Personal Information to the following categories of third parties:
- Walkpop Partners: Walkpop engages in marketing and promotional activities with carefully screened brands, or “Partners,” which we think will appeal to our user base. Partners may be provided with non-identifying or aggregate information indicating the demographic information of users on our Site, buying behavior, and opportunities to market to select segments of our customer base indirectly. When we share aggregate user data, we do so in a way that it cannot be linked with a user’s Personal Information.
- Third Party Advertisers: Walkpop uses third party advertising companies to help us further enhance our users’ experience and to better tailor our content to our individual customers. Third party advertising companies may collect Personal Information during your visits to this Site and other websites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or third-party web beacon to collect this information.
- Law enforcement and third parties pursuant to legal request: Walkpop may from time to time disclose Personal Information as it deems reasonably necessary to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations, in the United States and in other jurisdictions.
- Others: We may also disclose Personal Information to third parties in the context of a corporate transaction, as reasonably necessary to evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Adore Me's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Walkpop or Adore Me about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.
b. International Transfer of Personal Information
Your Personal Information may be processed directly by us in the United States or in Europe, or by third parties as described above. As such, the Personal Information we collect from you may be transferred to, accessed in or stored outside the European Economic Area (EEA). Wherever your Personal Information is stored, we will work to ensure that it is held securely and in line with applicable data protection regulation.
c. “Do Not Track” or “Opt-out” options
California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. Our Site is not at this time configured to read or respond to “do not track” settings or signals in your browser headings, which vary by browser provider, because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
In lieu of a browser-based opt-out solution, you can utilize the Network Advertising Initiative approved methods for placement of “opt-out” cookies and learn more about how targeted advertising works, by visiting the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
Our Site and those of our third-party advertisers or other vendors are configured to read and honor these opt-out cookies, so long as they are present on your computer. Note that if you delete all cookies, you will need to reset your opt-out cookies for them to be read and honored.
You can opt out of targeted advertising by:
FACEBOOK - https://www.facebook.com/settings/?tab=ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
However, please be aware that we do not control these opt-out processes.
d. No sale of Personal Information
Neither Walkpop nor Adore Me sells your Personal Information and will not sell personal information unless we provide you proper notice and, if appropriate, we obtain explicit consent.
- CHOICE/OPT-OUT OF/UNSUBSCRIBE FROM COMMUNICATION
We may contact you directly by email using the email you provide us. We may also occasionally send you information about your account or our Services via text message. Please note that your carrier’s standard charges, data rates and other fees may apply. If you do not wish to receive SMS text messages from us, please adjust your preferences on our Site your account page or contact our help team at firstname.lastname@example.org.
- DATA RETENTION
We will retain both passively-collected and user-submitted Personal Information only as necessary to achieve the purpose for which it was collected, to the extent required by law (e.g. accounting, litigation hold) or to protect our business interests (e.g. bring or defend legal claims).
Please feel free to contact our Legal Team at email@example.com if you have any questions about our retention policy.
- SECURITY OF YOUR PERSONAL INFORMATION
The security of your Personal Information is important to us. Walkpop uses reasonable security measures to protect against the loss, unauthorized access, misuse, alteration and destruction of Personal Information under our control, both during the transmission and once we receive it. This includes, but is not limited to, the use of firewalls and encryption.
Our Site incorporates physical, electronic, and administrative procedures to safeguard the confidentiality of your Personal Information, including Secure Sockets Layer (“SSL”) protection for all financial transactions conducted through our Site, our App and our Mobile Site. We also take several steps to protect the physical storage of your personal information in our facilities, including the storage of servers in a secure physical environment, behind a locked cage and an electronic firewall.
It is your responsibility to make sure that your Personal Information is accurate and that your password(s) and account registration information are secure and not shared with third-parties.
Although we make good faith efforts to maintain the security of Personal Information, no method of transmission over the Internet or method of electronic storage is 100% secure and we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining this information. To minimize the risk to you, we keep Personal Information no longer than necessary for legitimate business purposes or as required by law.
As part of securing Personal Information stored on our servers, we restrict access to Personal Information to Walkpop and Adore Me employees, contractors and agents who need to know that information in order to operate, develop or improve the Services. These individuals are bound by strict confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
If a security systems breach occurs and Personal Information is compromised, we may post a notice on our homepage (www.walkpop.com) or elsewhere on the Site and take any other appropriate step. If your Personal Information is impacted, we may contact you individually, in compliance with applicable laws.
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. Walkpop and the Site are not directed toward individuals under the age of thirteen (13) We do not knowingly collect or maintain Personal Information from anyone under the age of 13, unless or except as permitted by law. If we learn that Personal Information has been collected from a user under 13 years of age on or through the Site, we will take the appropriate steps to cause this information to be deleted.
If you are the parent or legal guardian of a child under 13 who has registered on the Site or you believe has otherwise provided Personal Information to Walkpop, please contact Walkpop at firstname.lastname@example.org to have that child’s account terminated and information deleted.
- PRIVACY RIGHTS
As a California resident or a resident of the European Economic Area, you have the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations pursuant to applicable law):
Right to Know
In addition, you have the right, in certain circumstances, to request certain information relating to the Personal Information about you that we have collected, processed or disclosed, including:
- Categories of Personal Information we have collected about you
- Categories of sources of the Personal Information
- Categories of Personal Information we have disclosed to third parties and categories of recipients to whom this information was disclosed
- Categories of Personal Information we have sold to third parties and categories of third parties to whom the information was sold, if relevant
- Business or commercial purposes for collecting or sharing your Personal Information
Right to Accurate and Complete Personal Information
- You have a right to request that we rectify or complete inaccurate Personal Information we have about you.
- You may edit or update certain Personal Information directly on our Site in your “My Account” page under “Personal Information”.
Right to Access
- You have the right, in certain circumstances, to request access to the specific pieces of Personal Information we have collected about you. To the extent possible, this data should be provided in a portable and machine-readable format.
Right to Request Deletion
- You have the right, in certain circumstances, to request the deletion of your Personal Information.
Right to Opt Out
- Adore Me does not currently sell your Personal Information. If this changes, you will have the right to direct us not to sell Personal Information we collect about you to third parties.
- In limited circumstances, you may also have a right to opt-out of, limit or object to the processing of your Personal Information.
“Shine the Light”
- In addition to the rights described above, California’s “Shine the Light” law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of Personal Information to third parties for their direct marketing purposes during the immediately preceding calendar year.
You may not be discriminated against for exercising any of the rights listed above.
To exercise any of these rights, you may:
- Write to us at:
Adore Me, Inc.
Attn: Legal Team
16 East 34th Street, 14th Floor,
New York, NY 10016
- Send us an email to Privacy@AdoreMe.com indicating in the subject line which of the rights listed above you are exercising (for example: “Right to know”).
- Use our Toll-free number +1 (800) 433 2367 (Monday-Sunday 8:30am-8:30pm EST).
Note that we will need to verify your identity before processing any request, which may require us to request additional Personal Information from you. We will only use this newly collected Personal Information in connection with the processing of your request.
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
If you are a resident of the EEA and you believe your rights are being infringed upon by Adore Me, you may also lodge a complaint with the competent supervisory authority.
- CONTACT US
Please make sure to check the Site frequently for updates.