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<p>We use cookies to provide a better user experience and analyze traffic. By using our site, you agree to our use of cookies.
<a class="link link--border-underline font-size--12" href="https://www.thereformation.com/privacy-policy.html" target="_blank">Learn more</a> about cookies and how you can refuse them.</p>
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PRIVACY
Last updated: March 8, 2023
This Privacy Policy ("Policy") applies to information collected by LYMI, Inc.,
dba Reformation, and its subsidiaries (“Ref,” “we,” “our” or “us”) in connection
with the products and services that Ref offers both through the website, mobile
applications and in-store (collectively, the "Site"). This includes information
collected online through our websites, branded pages on third party platforms
(i.e, social networking services), mobile applications, Ref’s proprietary Retail
X in-store platform ("Retail X"), and through our direct marketing campaigns or
other online communications, as well as offline through our Customer Love Team,
events, in-store campaigns, purchases, and requests, and mobile messaging
services (collectively, "Ref Services").
This Policy explains what information may be collected through the Ref Services,
how such information may be used and/or shared with others, how we safeguard it
and how you may access and control its use in connection with our marketing
communications and business activities. By using the Ref Services, you agree to
the collection, use, and disclosure of your information as described in this
Policy. If you do not so agree, please do not use the Ref Services.
By visiting our Site, creating an account on our Site, or otherwise providing us
with your (or others’) information, you consent to the information handling
practices described in this Policy and you acknowledge and confirm that you have
permission to provide us such information. If you do not agree with this Policy
or ourTerms of Use, please do not access or use the Site, or register for an
account on the Site.
Table of Contents
1. Categories of Information We Collect
2. How Information Is Collected
3. How We Use Your Information
4. Our Information Sharing and Selling Practices
5. How We Store and Protect Your Information
6. Your Choices Relating To Your Information
7. Additional Information For California Residents
8. Additional Information For Nevada Residents
9. Additional Information For residents of all other states
10. Additional Information For European Union and UK Residents
11. Additional Information For Canadian Residents
12. Cookie and Interest-Based Advertising Policy
13. Children's Privacy
14. Exercising Your Rights Under Other Privacy Laws
15. Changes To This Privacy Policy
16. Privacy Questions and Contact Information
1. CATEGORIES OF INFORMATION WE COLLECT
The categories of information collected are generally described in this section.
We collect specific categories of your information in order to provide you with
our products and services, to communicate with you, and to improve your
experience when visiting and using our Site.
Information that identifies, relates to, describes, is reasonably capable of
being associated with, or could be reasonably linked, directly or indirectly,
with a particular consumer or household is defined as "Personal Information".
Depending on your jurisdiction, personal Information may not include: (a)
publicly available information from government records; (b) de-identified or
aggregated consumer information; and/or (c) information otherwise considered
excluded from Personal Information by law.
In particular, the Site, or third-parties with whom we work, collects the
following categories of information from you, some of which may be considered
Personal Information as defined above. While you may decline to provide this
information as described in more detail below, this may affect or limit the
ability to purchase our products and/or use our Site.
Category Examples
Personal Identifiers
Your name, mailing address, email address, telephone number(s), account or user
name, password, social media profile, or other similar identifiers.
Device Identifiers and Usage Data
Browser type, browser version, and other diagnostic data
Purchase and financial information
Transaction details and other information needed to process and fulfill a
purchase order, including order history, shopping preferences, credit card type,
credit card number, expiration date, security code, billing address, and
delivery address.
Product and Service Feedback and Reviews
Your name, user name, email address, and any other content included in any
communication provided by you to us.
Internet or other similar network activity
Browsing history, search history, information on a consumer’s interaction with a
website, application, or advertisement.
Geolocation data
IP address based on location of device, location data (e.g., city, state,
country, zip code).
Job applicant data
Information contained in a resume, cover letter, or other employment-related
materials; intelligence, abilities and aptitudes.
Marketing
Email addresses or contact details that we use to send marketing communications
and your preferences for receiving communications about our activities, events,
sweepstakes and contests.
Data About Others
Data from when you purchase an item or gift for another person, such as name,
delivery address and phone number.
2. HOW INFORMATION IS COLLECTED
The information listed above is collected in several ways and is described in
this section. In short, information is: (a) provided by you directly; (b)
collected automatically; and (c) provided by third-parties.
2.1. Information You Provide to Us Directly
When you visit the Site without creating an account, you can browse without
submitting information about yourself. In general, we collect information that
you submit to us in the process of creating or editing your account and user
profile on the Site, or that you submit to us voluntarily through your use of
the Site.
We may also collect information that you provide us when purchasing a product,
or communicating with us directly via email or other means.
2.2. Information Collected Automatically
Like many other websites, we may also gather information when you access the
Site through the use of cookies and other similar technologies such as server
logs, pixel tags, web beacons, user website activity and JavaScript
(collectively, "Cookies"). Cookies are small pieces of data – usually text files
– placed on your computer, tablet, phone, or similar device when you use that
device to visit our Site. They enable us to recognize your web browser or
device and tell us how and when you visit and use our Site, to analyze trends,
to learn about our user base, and to operate and improve our Site and services.
We may also supplement the information we collect from you with information
received from third-parties, including third-parties that have placed their own
Cookies on your device(s).
Please visit our Cookie and Interest-Based Advertising Policy for further
information on the types of Cookies used on our Site, and options for disabling
certain Cookies.
Please note: If you restrict, disable, or block certain Cookies from your web
browser or mobile or other device, the Site may not operate properly, and you
may not have access to certain services or parts of the Site. We will not be
liable for any interruption in, or inability to use, the Site or our services or
degraded functioning thereof, where such are caused by your settings and choices
regarding Cookies.
2.3. Information Received From Third-Party Sources
We also may receive information about you from other, third-party, sources, as
described below.
1. Social Media Sites. We may collect information from your use of, and
interactions with us and others on, social media sites including, but not
limited to, Facebook®, Instagram®, Twitter®, Snapchat®, and YouTube®
(collectively, "Social Media"). In such cases, please be aware that: (a) the
Personal Information that you submit by and through such Social Media can be
read, collected and/or used by us (depending on your Social Media privacy
settings) as described in this Policy, and (b) where we respond to any
interaction with you on Social Media, your account name/handle may be
viewable by any and all members or users of our own Social Media accounts.
We are not responsible for the Personal Information that you choose to
submit or link on any Social Media. Social Media operates independently from
us, and we are not responsible for Social Media interfaces or privacy or
security practices. We encourage you to review the privacy policies and
settings of any Social Media with which you interact to help you understand
their privacy practices. If you have questions about the security and
privacy settings of any Social Media that you use, please refer to the
applicable privacy notices or policies.
2. Member Content (if applicable). We may receive information about you when
you or another member uploads photos or posts other content to our Site.
For further details about the rights over this information available to
individuals, see Section 6 below.
3. Other Third-Parties Analytics Tools. In order to provide you with more
tailored recommendations, we may obtain information about you from publicly
and commercially available sources where we are permitted to under
applicable laws, such as third-party publishers, advertising networks,
product vendors, and service providers that we use to manage our ads on
other sites, and other third parties as permitted by law. For more
information about the data that we obtain from these providers, please
contact us at privacyrequests@thereformation.us. See also Section 11 below
for our Cookie and Interest-Based Advertising Policy.
3. HOW WE USE YOUR INFORMATION
The ways in which we use your information is generally described in this
section.
3.1 General "Business Purpose" Uses
We process Personal Information to operate, improve, understand and personalize
our Site, and provide you with products and services (collectively "Business
Purposes"). Specifically, the Business Purposes for which we use your Personal
Information are as follows:
1. To meet or fulfill the reason you provided the information to us.
2. To communicate with you about the Site, including product announcements,
updates or offers.
3. For marketing and promotions, including to check your eligibility for
giveaways and competitions and to contact you in the event that you win,
and to administer our various promotional programs.
4. To personalize your experience and to deliver content and product and
service offerings, products, and services relevant to your interests,
including offers and advertisements through third-party sites, and via
email including card reminders (with your consent, where required by law).
5. To provide support and assistance for your use of the Site and purchase of
our products.
6. To create and manage your account or other user profiles.
7. To personalize website content and communications based on your
preferences, including targeted offers and ads served through the Site.
8. To process orders or other transactions.
9. To respond to user inquiries and fulfill user requests.
10. To process, evaluate and respond to your application for employment.
11. To improve and develop the Site, including testing, research, analysis and
product development.
12. To protect against or deter fraudulent, illegal or harmful actions and
maintain the safety, security and integrity of our services.
13. To comply with our legal or contractual obligations, resolve disputes, and
enforce our Terms of Use.
14. To respond to law enforcement requests and as required by applicable law,
court order, or governmental regulations.
15. To evaluate or conduct a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of some or all of
our assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which Personal Information held by
us about our users is among the assets transferred or liquidated.
16. For any other Business Purpose stated when collecting your Personal
Information, or as otherwise set forth in applicable data privacy laws,
such as the California Consumer Privacy Act (the "CCPA").
We will not collect additional categories of Personal Information or use the
Personal Information we collected for materially different, unrelated, or
incompatible purposes without providing you notice or obtaining your consent,
where required by law.
3.2 Account-Related Emails
When you create an account with us and provide us with your email we may,
subject to applicable law, use your email address to send you Site-related
notices (including any notices required by law, in lieu of communication by
postal mail), updates, news, and marketing messages. For example, when you
register, you will receive a welcome email. If the Site or our services are
temporarily unavailable, we may also send you an email notice.
Email communications you receive from us will generally provide an unsubscribe
link or instructions allowing you to opt out of receiving future emails or to
change your contact preferences. If you have an account with us, you can also
change your contact preferences by updating your contact information within your
account settings. Please remember that even if you opt-out of receiving
marketing e-mails, we may still send you important transactional messages or
service information related to your account and the Site. If you correspond
with us by email, we may retain the content of your email messages, your email
address, and our responses to assist you in the future.
3.3 Interest-Based Advertising
For information regarding our interest-based advertising practices, please see
our Cookie and Interest-Based Advertising Policy below.
3.4 Customer Testimonials or Reviews
We may display personal testimonials of satisfied customers on our Site in
addition to other endorsements. With your consent, we may post your testimonial
along with your name. If you wish to update or delete your testimonial, you can
contact us at privacyrequests@thereformation.us.
3.5. Non- Identifiable or Aggregated Information
We may use non-identifiable information, such as anonymized and/or aggregated
Site usage data, in any manner that does not identify individual users for the
purpose of improving the operation and management of the Site, including to
develop new features, functionality, and services, to conduct internal research,
to better understand Site usage patterns, to resolve disputes, to troubleshoot
problems, to fulfill user requests, or for security and compliance purposes. Any
data that is combined with Personal Information or could be used to identify an
individual will be treated by us as Personal Information.
4. OUR INFORMATION SHARING AND SELLING PRACTICES
4.1 Sharing of Personal Information
We may share your Personal Information with one or more of the following
entities, and for the following corresponding reasons:
1. With Other Third-Parties at Your Consent or at Your Direction. We may
disclose your Personal Information to third-parties with your consent, which
may be obtained in writing, online, or orally. We may also share your
Personal Information with third-parties when you direct us to do so or when
you use our products or services to intentionally interact with
third-parties (if applicable). Use of the information you agree to share
will be subject to those third-parties’ separate privacy policies.
2. With Service Providers. We share your Personal Information with certain
affiliates and third-party service providers to provide services to us on
our behalf, such as support for the internal operations of our Site, online
stores (including payment processors and third-parties we use for sending
your orders to your home address), services (e.g., technical support
processing), advertising, analytics and marketing services, as well as
related offline product support services, data storage and other services.
Where permitted, Personal Information is shared with third party marketing
partners for commercial purposes.
3. Installment Payment Services. We may offer you the ability to pay for
purchases on our Site using a third-party installment payment service, such
as Afterpay or Klarna. If you choose to use this service, you will be
directed to the third party to create an account and complete your
transaction. We will transfer certain personal information to the third
party to help them create your account and provide you with services, such
as your name, email address, billing address, mobile number and purchase
information. You will be required to provide additional information to the
third party, such as your payment information for the installment payments.
Your information will be treated in accordance with the third party’s
privacy policy, which is provided to you at the time of checkout.
4. In the Event of a Potential Business Sale or Merger. We may share or
transfer your Personal Information in connection with, or during
negotiations of, any merger, sale of our assets, financing, or acquisition
of all or a portion of our business to another company. To the extent
applicable, we will provide notice (and obtain your consent, where required
by law) before your Personal Information is transferred and becomes subject
to a different privacy policy.
5. With Certain Business Partners. With your consent (where required by law),
we may share your Personal Information with our business partners to offer
you certain products, services or promotions.
6. With other users. When you share Personal Information or otherwise interact
in the public areas with other users (e.g., Social Media), such information
may be viewed by all users and may be publicly distributed outside. If you
interact with other users or register through a Social Media service, your
contacts on that Social Media service may see specific Personal Information,
such as your name, profile, pictures and description of your activity.
Similarly, other users will be able to view descriptions of your activity
and view your profile, and further may be able to communicate with you.
7. With Law Enforcement or Other Government Entities. We may also disclose your
Personal Information if we believe we are required to do so by law, or that
doing so is reasonably necessary to comply with legal processes; when we
believe necessary or appropriate to disclose Personal Information to law
enforcement authorities, such as to investigate actual or suspected fraud or
violations of law, breaches of security, or breaches of this Policy, to
respond to any claims against us, and to protect the rights, property, or
personal safety of us, our customers, or the public.
4.2 Sharing of Aggregate / De-Identified Information
Notwithstanding anything else in this Policy, we may share aggregate or
non-identifiable information with third-parties for research, marketing,
analytics and other purposes, provided such information does not identify a
particular individual.
5. HOW WE STORE AND PROTECT YOUR INFORMATION
We use certain physical, managerial, and technical safeguards designed to
preserve the security of your Personal Information that we maintain in
connection with your use of the Site. This, however, does not guarantee that
your Personal Information may not be accessed, disclosed, altered, or destroyed
by any breach of our physical, technical or managerial safeguards. In the event
that any of your Personal Information under our control is compromised as a
result of a breach of security, we will take reasonable steps to investigate the
situation and will notify you, as appropriate, in accordance with pertinent laws
and regulations.
We, or our third-party hosting providers, store Personal Information in
operating environments that are safeguarded against public or unauthorized
access and protected from internal access with physical and technical security
measures. While these measures are helpful to safeguard your Personal
Information after we receive it, no transmission of data over the internet is
100% secure.
6. YOUR CHOICES RELATING TO YOUR INFORMATION
Depending on where you reside and the types of information that we collect from
you, you have various rights and choices surrounding the collecting, processing,
sharing and selling of your Personal Information. Within this section is a list
of general rights that you have, with additional rights listed in this Policy
below for specific locations.
We strive to timely respond to all requests that we receive from individuals who
wish to exercise their data privacy and protection rights in accordance with
applicable law. You can contact us with your request by sending an email to
privacyrequests@thereformation.us or as otherwise described in this Policy.
6.1 Opting Out of Providing Personal Information or Deleting Account.
Please note that while you can always opt not to disclose Personal Information
to us, some Personal Information may be needed to set up an account with us or
to take advantage of some features on our Site. You may be able to add, update,
or delete information within an account you create. When you update information,
however, we may maintain a copy of the unrevised information in our records. You
may also request deletion of your account by emailing
privacyrequests@thereformation.us. However, some information may remain in our
records after your deletion of such information from your account to meet our
legal, business or contractual obligations. We may use any aggregated data
derived from or incorporating your Personal Information after you update or
delete it, but not in a manner that could reasonably be used to identify you
personally, and we may also retain and continue to use your non-personally
identifiable information.
6.2 Online Tracking/Cookie Choices.
Most browsers are initially set up to accept Cookies, but you can reset your
browser to refuse certain Cookies or to indicate when a cookie is being sent.
However, some features and services of the Site (particularly those that require
sign-in) may not function properly if your Cookies are disabled. Similarly, if
you choose to delete session objects from our Site, you may not be able to
access and use all or part of the site or benefit from some or all of the
information or features and services offered. See our Cookie and Interest-Based
Advertising Policy for additional information.
6.3 Opting Out of Interest-Based Advertising.
See our Cookie and Interest-Based Advertising Policy on how to opt-out of
Interest-Based Advertising activities.
6.4 Do Not Track.
Some web browsers incorporate a "Do Not Track" ("DNT") or similar feature that
signals to websites that a user does not want to have the user’s online activity
and behavior tracked. If a website that responds to a particular DNT signal
receives the DNT signal, the browser can block that website from collecting
certain information about that browser’s user. Not all browsers offer a DNT
option and DNT signals are not yet uniform. For this reason, the Site may not
respond to DNT signals.
7. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
If you are a California resident, you have the rights outlined in this section,
and in accordance with the California Consumer Privacy Act ("CCPA") and
California Consumer Privacy Rights Act ("CPRA"). Please see the "Exercising Your
Rights" sub-section below for instructions regarding how to exercise these
rights. If there are any conflicts between this section and any other provision
of this Policy and you are a California resident, the portion that is more
protective of your Personal Information shall control. If you have any questions
about this section or whether any of the following applies to you, please
contact us at privacyrequests@thereformation.us.
7.1 Right to Access
You have the right to request certain information about our collection and use
of your Personal Information over the past 12 months. Assuming verification of
your identity, we will provide you with the following information:
1. The categories of Personal Information that we have collected about you.
2. The categories of sources from which that Personal Information was
collected.
3. The business or commercial purpose for collecting or selling your Personal
Information.
4. The categories of third-parties with whom we have shared your Personal
Information.
5. The specific pieces of Personal Information that we have collected about
you.
6. If we have disclosed your Personal Information for a business purpose over
the past 12 months, we will identify the categories of Personal Information
shared with each category of third party recipient.
If we have sold your Personal Information over the past 12 months, we will
identify the categories of Personal Data purchased by each category of third
party recipient.
7.2 Right to Deletion
You have the right to request that we delete the Personal Information that we
have collected from you (or your household). Note that this deletion right does
not include Personal Information we have collected from third-party sources.
Furthermore, under the CCPA/CPRA, this deletion right is subject to certain
exceptions: for example, we may need to retain your Personal Information to
provide you with services or complete a transaction or other action you have
requested. If your deletion request is subject to one of these exceptions, we
may deny your deletion request.
7.3 Exercising Right To Access and/or Right to Deletion
If you are a California resident, and to exercise the rights described above,
you (or someone acting under your express authorization) must send us a request
that (a) provides sufficient information to allow us to verify that you are the
person about whom we have collected Personal Information, and (b) describes your
request in sufficient detail to allow us to understand, evaluate, and respond to
it. If someone is submitting a request on your behalf, they must further (c)
provide proof that they are authorized to act for you in this regard.
Each request that meets both of these criteria will be considered a "Valid
Request". We may not respond to requests that do not meet these criteria. We
will only use Personal Information provided in a Valid Request to verify you and
complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. If we
are not able to respond to your request within 45 days, we will let you know
that we may need additional time to respond, up to 90 total days. We will not
charge you a fee for making a Valid Request unless your Valid Request(s) is
excessive, repetitive, or manifestly unfounded. If we determine that your Valid
Request warrants a fee, we will notify you of the fee and explain that decision
before completing your request.
You may submit a Valid Request here or by:
Emailing us at: privacyrequests@thereformation.us
By Mail: LYMI Inc. d/b/a Reformation
Attn: Data Privacy Team
2263 E. Vernon Ave.
Vernon, CA 90058
By Phone: +1 (844) 701-0139
7.4 Right to Opt-Out of "Sale" or "Sharing" of Personal Information
The CCPA/CPRA defines "sale" to include sharing or disclosing of personal data
with a third-party for monetary or other valuable consideration. This may
include when we share information about you that is associated with device
identifiers with third-parties for targeted advertising purposes, and as
generally described above. The CPRA further defines "sharing" as disclosing,
making available, transferring, or communicating a consumer’s Personal
Information to a third party for "cross-context behavioral advertising", whether
or not for monetary or other valuable consideration.
There are circumstances where sharing of personal data with third-parties is not
considered to be a sale. For example, we may share personal data with service
providers who work on our behalf if the service provider agrees not to use that
personal data for other purposes. In addition, you may intentionally direct us
to share information with a third-party, which is also not a sale.
The CCPA and CPRA give California residents the right to direct a business that
sells or shares Personal Information about that consumer to third-parties not to
sell or share such information. To this end, we provide the Do Not Sell My
Personal Information link to comply with the CCPA. We give you the option to
opt-out of these sales at any time by following the link below:
Do Not Sell My Personal Information
Once you have submitted an opt-out request, we will not ask you to reauthorize
the sale of your Personal Information for at least twelve (12) months. However,
you may change your mind and opt back in to Personal Information sales at any
time by emailing us at:privacyrequests@thereformation.us.
To the extent your request comes from a third-party, we have the right to
request proof from that third-party that they are authorized to act on your
behalf.
7.5 Right to Correct Inaccurate Personal Information
The CPRA provides California residents with the right to request the correction
of inaccurate Personal Information kept by businesses. Upon submission of a
valid request by a California resident, and verification by us of the same, we
shall use commercially reasonable efforts to correct inaccurate Personal
Information identified by you.
7.6 Right to Limit Use and Disclosure of Sensitive Personal Information
The CPRA provides California residents with the right to direct a business that
collects Sensitive Personal Information (as defined above) about the resident to
limit its use of such information to that use which is necessary to perform the
services or provide the goods reasonably expected by the average consumer who
requests such goods or services. Any uses, or disclosure, of the consumer’s
Sensitive Personal Information beyond this must be disclosed by the business and
the consumer has the right to limit such use and/or disclosure. If you are
interested in limiting such use and/or disclosure please email us
at:privacyrequests@thereformation.us .
7.7 The Sale or Sharing of Personal Information of Children (16 years old and
younger)
We will not knowingly sell the Personal Information of a child 16 years old or
younger without first obtaining the required authorizations. Specifically:
1. Children Between 13 and 16 Years of Age. If you are between 13 and 16 years
of age, you must authorize us to sell your Personal Information, which you
may do by emailing us at: privacyrequests@thereformation.us.
2. Children Under 13 Years of Age. If you are under 13 years of age, your
parent or guardian must authorize us to sell your Personal Information,
which your parent or guardian may do by emailing us at:
privacyrequests@thereformation.us.
7.8 No Discrimination For Exercising Your Rights
We will not discriminate against you for exercising your rights under the CCPA.
We will not deny you our goods or services, charge you different prices or
rates, or provide you a lower quality of goods and services if you exercise your
rights under the CCPA. However, we may offer different tiers of our services as
allowed by applicable data privacy laws (including the CCPA) with varying
prices, rates, or levels of quality of the goods or services you receive related
to the value of Personal Information that we receive from you.
7.9 California Shine The Light Law
Under California Civil Code Sections 1798.83-1798.84, California residents are
entitled to obtain from us once a year, free of charge, a list of third-parties
to whom we have disclosed Personal Information (if any) for direct marketing
purposes in the preceding calendar year. If you are a California resident and
you wish to make such a request, please send an e-mail with "California Privacy
Rights" in the subject line to privacyrequests@thereformation.us.
8. ADDITIONAL INFORMATION FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of
certain Personal Information to third-parties who intend to license or sell that
Personal Information. You can exercise this right by contacting us
atprivacyrequests@thereformation.us with the subject line "Nevada Do Not Sell
Request" and providing us with your name and the email address associated with
your account.
Please note we will take reasonable steps to verify your identity and the
authenticity of the request. Once verified, we will maintain your request in
the event our practices change.
We will respond to verified requests within 60 days after we receive the request
and may need to extend our response by up to 30 days.
9. ADDITIONAL INFORMATION FOR RESIDENTS OF ALL OTHER STATES
If you are a resident of a state in the United States not otherwise mentioned in
this Policy, we shall use our best efforts to honor your request to either
delete, restrict the use of your Personal information and opt-out of the sharing
of your Personal Information with third parties. Please see the "Exercising Your
Rights" sub-section below for instructions regarding how to exercise these
rights. If there are any conflicts between this section and any other provision
of this Policy and you are a California resident, the portion that is more
protective of your Personal Information shall control. If you have any questions
about this section or whether any of the following applies to you, please
contact us at privacyrequests@thereformation.us.
10. ADDITIONAL INFORMATION FOR CERTAIN EUROPEAN AND UK RESIDENTS
If you are a resident of the European Union ("EU"), United Kingdom,
Lichtenstein, Norway, or Iceland, you may have additional rights under the EU
General Data Protection Regulation and the UK General Data Protection Regulation
(together, the "GDPR") with respect to your Personal Data, as outlined below.
For this section, we use the term "processing" as it is defined in the GDPR, but
"processing" generally covers actions that can be performed in connection with
data such as collection, use, storage and disclosure. We will be the controller
of your Personal Information processed in connection with your access and
visiting of the Site. If you have any questions about this section or whether
any of the following applies to you, please contact us at
privacyrequests@thereformation.us.
If there are any conflicts between this section and any other provision of this
Policy, the policy or portion that is more protective of Personal Information
shall control to the extent of such conflict.
10.1 Personal Information We Collect
The "Categories of Information We Collect" section above details the Personal
Information that we collect from you.
10.2 Personal Information Use and Processing Grounds
The "How We Use Your Personal Data" section above explains the purposes for
which and how we use your Personal Data. Where we intend to further process your
personal data for a purpose other than that for which your personal data was
collected, we shall provide you prior to that further processing with
information on that other purpose.
We will only process your Personal Data if we have a lawful basis for doing so.
Lawful bases for processing include consent, contractual necessity and our
"legitimate interests" or the legitimate interest of others, as further
described below.
1. Contractual Necessity. We process the following categories of Personal Data
as a matter of "contractual necessity", meaning that we need to process the
data to perform under our Terms of Use with you, which enables us to provide
you with the Services. When we process data due to contractual necessity,
failure to provide such Personal Data will result in your inability to use
some or all portions of the Services that require such data.
* Personal identifiers
* Customer records identified by state law
* Commercial information
* Special categories of data under the GDPR
* Personal Data about children under the age of 16
2. Legitimate Interest. We process the following categories of Personal Data
when we believe it furthers the legitimate interest of us or third parties.
* Personal identifiers
* Customer records identified by state law
* Protected classification characteristics under state or federal law
* Commercial information
* Internet or other similar network activity information
* Geolocation data
* Inferences drawn from other personal information
* Age or date of birth
* Special categories of data under the GDPR
* Personal Data about children under the age of 16
Examples of these legitimate interests include:
* Operation and improvement of our business, products and Services
* Marketing of our products and Services
* Provision of customer support
* Protection from fraud or security threats
* Compliance with legal obligations
* Completion of corporate transactions
3. Consent. In some cases, we process Personal Data based on the consent you
expressly grant to us at the time we collect such data. When we process
Personal Data based on your consent, it will be expressly indicated to you
at the point and time of collection.
4. Other Processing Grounds. From time to time we may also need to process
Personal Data to comply with a legal obligation, if it is necessary to
protect the vital interests of you or other data subjects, or if it is
necessary for a task carried out in the public interest.
5. Special categories of data. Where we process special category data under
GDPR (which includes data relating to health, ethnicity or biometrics) we
will ensure we satisfy one of the conditions for processing such data under
applicable law in addition to ensuring we have a lawful basis for processing
as described above.
10.3 Sharing and/or Selling of Personal Information
The section above titled "Our Information Sharing and Selling Practices" details
how we share and/or sell your Personal Information with third-parties.
EU AND UK DATA SUBJECT RIGHTS REGARDING PERSONAL DATA
You have certain rights with respect to your Personal Information, including
those set forth below. For more information about these rights, or to submit a
request, please emailprivacyrequests@thereformation.us . Please note that in
some circumstances, we may not be able to fully comply with your request, such
as if it is manifestly unfounded or excessive, if it jeopardizes the rights of
others, or if it is not required by law, but in those circumstances, we will
still respond to notify you of such a decision. In some cases, we may also need
you to provide us with additional information, which may include Personal
Information, if necessary to verify your identity and the nature of your
request.
1. Access. You can request more information about the Personal Information we
hold about you and request a copy of such Personal Information. You can
also access certain of your Personal Information by logging into your
account.
2. Rectification. If you believe that any Personal Information we are holding
about you is incorrect or incomplete, you can request that we correct or
supplement such information. You can also correct some of this information
directly by logging into your account.
3. Erasure. You can request that we erase some or all of your Personal
Information from our systems.
4. Withdrawal of Consent. If we are processing your Personal Information based
on your consent (as indicated at the time of collection of such
information), you have the right to withdraw your consent at any time.
Please note, however, that if you exercise this right, you may have to then
provide express consent on a case-by-case basis for the use or disclosure of
certain of your Personal Information, if such use or disclosure is necessary
to enable you to utilize some or all of our Site. Any withdrawal of consent
will not affect the lawfulness of any processing based on your consent
before its withdrawal.
5. Portability. You can ask for a copy of your Personal Information in a
machine-readable format. You can also request that we transmit the
information to another controller where technically feasible.
6. Objection. You can contact us to let us know that you object to the further
use or disclosure of your Personal Information for certain purposes, such as
for direct marketing purposes.
7. Restriction of Processing. You can ask us to restrict further processing of
your Personal Information.
8. Right to File Complaint. You have the right to lodge a complaint about our
practices with respect to your Personal Information with the supervisory
authority of your country or EU Member State. You have the same right in the
UK; the relevant data protection authority is the Information Commissioner’s
Office.
By accessing and using the Site, you acknowledge that any Personal Information
about you, regardless of whether provided by you or obtained from a third-party,
is being provided to us in the U.S. and will be hosted on U.S. servers, and you
authorize us to transfer, store and process your information to and in the U.S.,
and possibly other countries. The transfer of your data to the U.S. shall be
subject to appropriate safeguards the details of which are further set forth
below.
10.4 Transfer of Personal Information
The Site is hosted and operated in the United States (“U.S.”) through us and our
service providers, and if you do not reside in the U.S., laws in the U.S. may
differ from the laws where you reside. By accessing and using the Site, you
acknowledge that any Personal Information about you, regardless of whether
provided by you or obtained from a third-party, is being provided to us in the
U.S. and will be hosted on U.S. servers, and that we will transfer, store and
process your information to and in the U.S., and possibly other countries. If we
transfer your Personal Information from the UK or EU to the U.S. or another
country (other than where you provide your Personal Information to us directly
via the Site, which is not considered a transfer by us), we are required to
justify the transfer under GDPR. In some cases, it may be necessary for us to
transfer your Personal Information in order to perform our contractual
obligations to you (e.g. supplying you with goods or services) or to enter into
a contract with you. However, in most cases the relevant safeguard in place for
transfers will be the EU Standard Contractual Clauses which may be found here.
For personal data transfers from the UK to the UK Addendum to the EU SCCs which
may be found here are used. The completed documents may be requested from us at
privacyrequests@thereformation.us. Once the EU-US Data Privacy Framework is
finalized, we may also utilize this mechanism to support our data transfers to
the U.S.
10.5 Data Retention
We will only retain your personal information for as long as necessary to
fulfill the purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements. Details of
retention periods for different aspects of your personal information are
available in our retention policy which is available by contacting the Data
Privacy Team.
10.6 Questions About This Policy for EU Residents Under GDPR
If you have any questions about this section or our data practices generally,
please contact us by email at privacyrequests@thereformation.us or by mail at:
By Postal Address: LYMI Inc. d/b/a Reformation
Attn: Data Privacy Team
2263 E. Vernon Ave.
Vernon, CA 90058
11. ADDITIONAL INFORMATION FOR CANADIAN RESIDENTS
In Canada, Reformation Brand Canada Inc. is responsible for your personal
information. Our Privacy Officer can be reached using the contact information
set out in Section 15.
11.1 Marketing Communications
If you have signed up to receive email or text updates or other marketing
communications, you can unsubscribe at any time by clicking the “unsubscribe”
link included at the bottom of each email, replying “STOP” to any of our text
messages. You may also withdraw your consent by contacting us as set out in the
“Privacy Questions and Contact Information” section below. Please note that you
may continue to receive transactional or account-related communications from us.
11.2 Custom Audience
We may also use services provided by third-party platforms (such as social
networking and other websites) to serve targeted advertisements on such
platforms to you or others. If you have signed-up for our marketing list, we may
provide a hashed version of your email address or other information to the
platform provider for such purposes. To opt-out of the use of your information
for such purposes, please contact us at as set out below under “Privacy
Questions and Contact Information”.
11.3 Transfer of Personal Information
We and our service providers (including affiliates) may access, store and
otherwise process Personal information outside of Canada, including in the
United States and other foreign jurisdictions. We and our service providers may
disclose your Personal Information if we are required or permitted by applicable
law or legal process, which may include lawful access by foreign courts, law
enforcement or other government authorities in the jurisdictions in which we or
our service providers operate. For information about the manner in which we or
our service providers treat Personal Information, please contact us as set out
in Section 15 “Privacy Questions and Contact Information” section below.
11.4 Data Retention
We will only retain your personal information for as long as necessary to
fulfill the purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements.
11.5 Your Rights
Subject to limited exceptions under applicable law, you have the right to
access, update and correct inaccuracies in your Personal Information in our
custody and control or withdraw your consent to our collection, use and
disclosure of your Personal Information. You may request access, updating and
corrections of inaccuracies in your Personal Information in our custody or
control or withdraw your consent by emailing or writing to us at the contact
information set out below or by making a request here. We may require certain
Personal Information for the purpose of verifying the identity of the individual
making the request.
12. COOKIE AND INTEREST-BASED ADVERTISING POLICY
This Cookie and Interest-Based Advertising Policy explains how Reformation uses
cookies and similar technologies in connection with the www.thereformation.com
website and any other website that we own or control and which posts or links to
this Cookie and Interest-Based Advertising Policy (collectively, the “Sites”),
along with the Reformation mobile application and any other mobile applications
that we own or control and which posts or links to this Cookie and
Interest-Based Advertising Policy (collectively, the “Apps”).
12.1 Cookies and Other Technologies
Cookies are small data files that are placed on your computer or mobile device
when you visit a website. Cookies serve different purposes, like helping us
understand how a site is being used, letting you navigate between pages
efficiently, remembering your preferences and items placed in your cart and
generally improving your browsing experience. In addition to cookies, our Sites
may use other technologies, such as Flash technology and pixel tags to collect
information automatically.
We use two broad categories of cookies or other technologies: (1) first party
cookies, served directly by us to your computer or mobile device, which we use
to recognize your computer or mobile device when it revisits our Sites; and (2)
third party cookies, which are served by service providers or business partners
on our Sites, and can be used by these parties to recognize your computer or
mobile device when it visits other websites. We use cookies for a variety of
purposes, including site analytics, advertising (on and off our Site) and
personalizing content and social media features.
12.2 Web Beacons
We may also use web beacons (which are also known as pixel tags and clear GIFs)
on our Sites and in our HTML formatted emails to track the actions of users on
our Sites and interactions with our emails. Unlike cookies, which are stored on
the hard drive of your computer or mobile device by a website, pixel tags are
embedded invisibly on webpages or within HTML formatted emails. Pixel tags are
used to demonstrate that a webpage was accessed or that certain content was
viewed, typically to measure the success of our marketing campaigns or
engagement with our emails and to compile statistics about usage of the Sites,
so that we can manage our content more effectively.
12.3 Mobile Application Software Development Kits (SDKs)
We may use third-party software development kits (“SDKs”) in our Apps. A SDK is
third-party computer code that may be used for a variety of purposes, including
to provide us with analytics regarding the use of our mobile applications, to
integrate with social media, add features or functionality to our Apps, or to
facilitate online advertising. SDKs may enable third parties to collect
information directly via our Apps.
12.4 Analytics
We may use a third-party such as Google Analytics to help us gather and analyze
information about the areas visited on the Site (such as the pages most read,
time spent, search terms and other engagement data) in order to evaluate and
improve the user experience and the Site. These third parties may use cookies
and other tracking technologies. For more information about Google Analytics or
to prevent the storage and processing of this data (including your IP address)
by Google, you can download and install the browser plug-in available at the
following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also
obtain additional information on Google Analytics’ data privacy and security at
the following links:
https://policies.google.com/technologies/partner-sites and
https://support.google.com/analytics/topic/2919631
12.5 Interest-Based Advertising
As further described in this Policy, we use third-party service providers such
as ad networks and advertising companies to serve advertisements or collect data
on our behalf across the internet and on this Site (“Advertisers”). Some of
these Advertisers may collect your Personal Information about your Site visits
and your interactions with our products and services as well as your visits to
other websites (such as web pages you visit and your interaction with our
advertising) and use this information to make predictions about your preferences
and to tailor advertising or marketing messages on other sites, trigger
real-time interactions, customize the Site, or enhance your profile.
Advertisers may use Cookies, pixel tags and other technologies to collect your
Personal Information, measure the effectiveness of their advertisements, and
personalize the advertisements on other sites. Some of these Advertisers may
collect your Personal Information that you share on the Site via a web form
automatically and prior to your submission of the Personal Information (i.e.,
before you click, “Submit”). Advertisers may be able to use information from
your Site visits to send marketing messages to you in a way that could
personally identify you. The information collected by Advertisers may include
your IP address, email addresses and other user and device level information.
For example, when Advertisers send advertisements and links that appear on the
Site directly to your browser, they automatically receive your IP address.
Please keep in mind that your browser settings may not permit you to control
Advertisers’ technologies, and this Policy does not apply to, and we cannot
control the activities of, Advertisers.
To opt out of third-party interest-based advertising technologies, please see
Section 11.7 “Opting Out of Interest-Based Advertising” below. And if you would
like more information about Advertisers’ practices, please visit the Digital
Advertising Alliance at https://digitaladvertisingalliance.org or
http://optout.aboutads.info/#!/ or, the Digital Advertising Alliance of Canada
at https://youradchoices.ca/ or https://optout.aboutads.info/?c=3&lang=en.
12.6 Opting Out of Interest-Based Advertising
You can opt-out of certain Interest-Based Advertising activities by doing one or
more of the following. Please note that you will need to opt-out of each browser
and device for which you desire to apply these opt-out features. Please note
that even if you opt-out of interest-based advertising by Advertisers, these
tracking technologies may still collect data for other purposes including
analytics and you will still see ads from us, but the ads may be less relevant
to you and your interests.
1. Preference Center.
Depending on your jurisdiction, you may be able to adjust your cookies and
interest-based advertising preferences here (Privacy Settings).
2. Third Party Opt-Out.
You can opt-out directly from some third-party ad networks, including
third-party ad servers, ad agencies, ad technology vendors and research
firms by using their opt-out tools.
3. Industry Opt-Out Tools.
Some Advertising Service Providers or providers of Tracking Tools may
participate in the Network Advertising Initiative’s (NAI) Opt-Out Tool
(http://www.networkadvertising.org/choices/) and/or the Digital Advertising
Alliance (DAA) Consumer Choice Page (http://www.aboutads.info/choices/), and
you can opt-out of certain services and learn more about your choices by
visiting the links included here.
Users in the EU can visit http://www.youronlinechoices.eu/ for more
information about your choices and to opt out of participating service
providers.
Users in Canada can visit the Digital Advertising Alliance of Canada (DAAC)
website at http://youradchoices.ca/choices to learn more about
interest-based advertising and visit https://optout.aboutads.info to opt-out
of receiving ads from third-party advertising companies participating in the
DAAC Self-Regulatory Program for Online Interest-Based Advertising.
4. Web Browser Controls.
You can prevent the use of certain Cookies on a device-by-device basis using
the controls in your web browser. These controls can be found in the Tools >
Internet Options (or similar) menu for your browser, or as otherwise
directed by your browser’s support feature. Through your web browser, you
may be able to:
* Delete existing Cookies
* Disable future Cookies
* Set your browser to provide you with a warning each time a cookie or
certain other Tracking Tools are being set
5. Mobile Opt-Out.
In addition to the above, your mobile devices may offer settings that enable
you to make choices about the collection, use, or transfer of mobile app
information for Interest-Based Advertising.
Please note: If you restrict, disable, or block certain Cookies from your
web browser or mobile or other device, the Site may not operate properly,
and you may not have access to certain services or parts of the Site. We
will not be liable for any interruption in, or inability to use, the Site or
our services or degraded functioning thereof, where such are caused by your
settings and choices regarding Cookies.
12.7 Changes
Information about the cookies we use may be updated from time to time, so please
check back on a regular basis for any changes.
13. CHILDREN’S PRIVACY
We greatly respect the privacy of children and their information, and do not
knowingly collect the Personal Information of children under the age of 16 (a
“Child”) without the prior consent of their parent or legal guardian. This
section outlines our policies and practices of the collection of a Child’s
Personal Information.
13.1 Parental Consent Prior to Collection
Information about the cookies we use may be updated from time to time, so please
check back on a regular basis for any changes.
When we knowingly collect a Child’s Personal Information, we will ask that
Child's parent or legal guardian for consent before we collect it, unless the
request falls within an exception.
When prior parental consent is required, we will ask for it in ways allowed by
Children’s Online Privacy Protection Act (“COPPA”) or other applicable law. For
example, if the Child’s Personal Information will be used only by us, we may ask
for the parent's (or legal guardian’s) consent by email. While we do not
currently, and do not expect to, use Child’s Personal Information in this
manner, if we are aware that a Child’s Personal Information is disclosed on our
Site or shared with a third-party besides a service provider, we obtain a higher
level of consent from the parent (or legal guardian), such as by a form to be
returned via U.S. mail or electronic scan, or consent obtained in connection
with a credit card purchase.
13.2 Parental Choices and Controls Under COPPA
If you are a parent (or legal guardian) who has given consent as described
above, you can ask us to:
Allow you to review your Child’s Personal Information; Deactivate your Child's
Site account; Revoke any consent you have given for your Child; Delete the
Child’s Personal Information we have collected; and Stop collecting your Child’s
Personal Information.
To make these requests, or if you have any other questions about our policies or
practices regarding the collection, use, sharing or disclosure of a Child’s
Personal Information, you may contact us at:
By Phone: +1 (844) 701-0139
By Email: privacyrequests@thereformation.us
By Postal Address: LYMI Inc. d/b/a Reformation
Attn: Data Privacy Team
2263 E. Vernon Ave.
Vernon, CA 90058
14. EXERCISING YOUR RIGHTS UNDER OTHER PRIVACY LAWS
Please be aware that we are headquartered in the United States. The Site is
governed by United States law. If you are using any of our products or services
from outside of the United States, your information may be transferred to,
stored, and processed in the United States where our servers may be located. The
United States might not offer the same level of privacy protection as the
country where you reside or are a citizen. By using the Site, communicating with
us via mail, email or telephone, or otherwise providing information to us, you
consent, to the extent required by applicable law, to the transfer to, and
processing of, your information in the United States.
If you would like to exercise a right under a different privacy law, please
contact us at privacyrequests@thereformation.us.
15. CHANGES TO THIS PRIVACY POLICY
Because our privacy practices and privacy law necessarily evolve over time, we
reserve the right to revise this Policy from time to time in our sole
discretion, upon notice to you such as by posting updated Policy on the Site,
sending you an email to your account email, or by any other reasonable means.
You should periodically review this Policy to ensure that you are familiar with
the most current version. Your continued use of the Site after the date posted
above will constitute your acceptance of the updated Policy.
16. PRIVACY QUESTIONS AND CONTACT INFORMATION
If you have any questions or comments about this Policy, including the ways we
collect and use your information as described in this Policy, your choices and
rights regarding such use, or wish to exercise your rights under laws that apply
to you, please contact us in any of the following ways:
By Phone: +1 (844) 701-0139
By Email: privacyrequests@thereformation.us
By Postal Address: LYMI Inc. d/b/a Reformation
Attn: Director, Information Security and Privacy
2263 E. Vernon Ave.
Vernon, CA 90058
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