Published 05/22/2018 10:33 AM | Updated 02/22/2019 11:38 AM
INFORMATION WE COLLECT
OUR USE OF INFORMATION
SHARING OF INFORMATION
THIRD-PARTY LINKS & CONTENT
ONLINE ADVERTISING AND ANALYTICS
HOW WE RESPOND TO "DO NOT TRACK" SIGNALS
CONSENT TO TRANSFER AND STORAGE IN THE UNITED STATES
ACCESSING AND UPDATING INFORMATION AND CHOICES
YOUR CALIFORNIA PRIVACY RIGHTS
How Does Dressbarn Use the Information it Collects?
When we collect or receive information about our users and customers, we primarily use this information in connection with your relationship with Dressbarn, including making it possible for you to use the features of our Channels and to provide you with special offers and content we think will most interest you.
When you shop with us or interact with us through one of our Channels, we share information with our sister companies. We will use this information to better understand our customers and improve your shopping and browsing experience. Other brands may also contact you with marketing information, such as special offers and promotions. If you would prefer that we not make your Personal Information available to our sister and other companies for their own direct marketing purposes.
Does Dressbarn Share Information with Other Third Parties?
How Does Dressbarn Work with Third-Party Analytics and Advertising Companies?
We work with online advertising and analytics providers to serve our ads online and provide us with information regarding traffic on the Channels. The companies with which we work may use information about your activities on the Channels - and other websites and services you visit across the various devices you use - to recognize you and your devices across the internet and to provide you targeted advertising based upon your interests. Some of these companies participate in self-regulatory programs that allow you to opt-out of having information about you used for targeted advertising purposes, and you may access those opt-outs at optout.networkadvertising.org and optout.aboutads.info . Please note these mechanisms will not stop you from seeing ads while you are online. If you opt-out, you will see generic ads instead of ads targeted to your interests.
What if I am a Resident of California?
If you are a resident of California, please see “Your California Privacy Rights.”
INFORMATION WE COLLECT
Through various features on the Channels, we may collect personal information, which is information that is linked to a specific, identifiable individual ("Personal Information"), such as first and last name, email addresses, postal addresses, and telephone numbers. We may also collect other information about you, such as payment card data or other payment information, information about your purchases and other transactions with us, demographic information (e.g., your gender, ZIP code/postal code, or similar information), information about the device you are using to access the Channels, and information about your preferences and interests. We may also offer features through which you may choose to provide us with information that may be considered to include biometric identifiers (e.g., imaging used to help fit clothing). We may take your Personal Information and make it non-personally identifiable, either by combining it with information about other individuals and/or by hashing the information or otherwise removing characteristics that make the information personally identifiable directly to you.
Our Channels are intended for a general audience and are not intended for use by or targeted to children younger than the age of 13. We do not knowingly collect Personal Information from children younger than the age of 13. If we learn that we have inadvertently collected Personal Information from a user who is younger than age 13, we will delete that information from our active databases. If you are the parent or legal guardian of a child younger than 13 and believe that we have inadvertently collected Personal Information from your child, please contact us using the information in the "Contact Us" section below.
Information You Provide. We may ask you to provide certain information to us (including your Personal Information) when you use the Channels or offline. For example, you may give us your information when making a purchase or completing another transaction, joining our affiliate program, interacting with customer service (including live chat), and through interactive features. When interacting with customer service, you may have the option to allow our representatives to share your screen. If you choose to permit screen sharing, we may be able to view any data and applications present on your device screen at that time. You may choose not to provide certain information; however, choosing to do so may prevent you from being able to take advantage of some of our offered features or from conducting transactions.
Social Networking Features
Information Provided by Third Parties
Send-to-a-Friend Features. We may make available on the Channels a "send-to-a-friend," "refer a friend," "wishlist" or similar function that permits you to send Channel content directly to a third party through the Channels. If you send a friend a communication using such functionality, the information you provide about your friend (e.g., name and e-mail address) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person.
Information the Channels Automatically Collect When You Interact with Us.
Dressbarn and our third-party service providers, including analytics providers, advertisers, and third-party content providers, may automatically or passively receive and record certain information about your use of the Channels whenever you visit or interact with the Channels, such as: your IP address, mobile device identifier, or similar device identifier; browser type; type of device you use to access the Channels; the domain name from which you arrived at the Channels; the time of day you visit our Channels; Location Data (defined below); and specific pages or areas of the Channel through which you navigate and how you interact with those pages or areas ("Usage Information"). This information helps us create a better experience for our users and provide you with targeted advertising. Please see the "Online Advertising and Analytics Providers" section below for more information about how to control the use of your Personal Information for the purposes of advertising.
We may capture and record or infer certain location data regarding your use of the Channels and your travels ("Location Data"). We may link that Location Data to other information that you provide to us or that may be accessed in connection with your use of the Channels. We may directly collect precise Location Data from the device you use to access the Channels if you have opted-in to such collection through our mobile application or your browser. You may be able to turn off the collection of precise Location Data through your device settings. However, please note that we may still be able to infer your approximate location through other information we collect, such as IP address.
The methods used to collect Usage Information may include:
Cookies and Local Storage. "Cookies" and local storage are pieces of information (data files) transferred to an individual's browser on their device when the device is used to visit a Channel. These technologies are able to store a unique identifier for a device to allow a certain Internet site to recognize the device whenever the device is used to visit the site. These technologies may be used for many purposes by us and our third-party service providers, such as automatically collecting Usage Information, enabling features, remembering your preferences, and providing you with targeted advertising elsewhere online. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. You can find more information about cookies and how they work at www.allaboutcookies.org.
Certain browsers or browser add-ons, such as Adobe Flash, may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Channels may make use of this local storage. For example, a Flash cookie is a data file placed on a device via the Adobe Flash plug-in that may be built into or downloaded by you onto your device. Flash cookies may be used for various purposes, including, without limitation, enabling a Flash feature and remembering your preferences. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you choose to disable cookies, to adjust your Flash privacy settings on your device, or to otherwise restrict local storage, some features of the Channels may not function properly, including the shopping cart and ordering processes.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as "pixel tags," "1x1 GIFs," or "clear GIFs") may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to a Channel, to monitor how users navigate the Channel, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Channels, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected to a Channel, and is deactivated or deleted thereafter.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
OUR USE OF INFORMATION
We may use information collected from or about you, including your Personal Information and Usage Information, to:
· allow you to participate in the Channels, or features or activities we offer, including sweepstakes, contests, or other prize promotions;
· process a transaction (through our Channels or in our stores) or your account registration, verify your identity or eligibility, and send you confirmations and receipts;
· send you information and special offers from us, our advertisers, or third-party business partners; to contact you regarding any problems with your merchandise order or account; and to respond to your inquiries and provide customer service related to your use of the Channels;
· administer and manage our affiliate program, through which third parties make money by referring customers to our Channels;
· protect each party from errors, misuse of the Channels, fraud, or any criminal activity;
· help us serve you better, including personalizing your shopping experience and tailoring content, recommendations, and offers we display to you, including advertisements, both on the Channels and elsewhere online;
· improve the Channels or our products and services and for legal, regulatory and internal business purposes;
· detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Channels; and
SHARING OF INFORMATION
Affiliated and Unaffiliated Third Parties for Direct Marketing
Dressbarn may share your information, including Personal Information, with its and our affiliates and subsidiaries, for business, analytical, and operational purposes. We also share Personal Information with these affiliated companies so that they may contact you with their own direct marketing. We may share Personal Information with unaffiliated third parties as well (which may include advertising member networks and other data cooperatives) for their own direct marketing purposes and those of such unaffiliated third parties' own clients. You may opt out of our sharing Personal Information we have collected about you with third parties for their direct marketing purposes.
Please note that if you have separately signed up to receive marketing communications from another brand, you will need to follow the opt-out procedures offered by that brand in order to stop receiving marketing messages from that brand. Using the affiliate opt-out feature described below will not affect your receipt of marketing messages from other brands that you have interacted with directly. And, if we have shared your information prior to you exercising your right to opt-out, you will need to opt-out directly with any third party who contacts you with marketing communications.
Third Parties Providing Services on Our Behalf
We may use third-party service providers to perform certain services on our behalf, such as hosting the Channels or Channel features, delivering packages, processing credit card payments, processing transactions and fulfilling orders, removing repetitive information from customer lists, providing customer service, providing website usage analytics, providing search results and links (including paid listings and links), providing targeted advertising, sending email, direct mail or other communications, providing marketing assistance and data analysis or enhancement, or performing other administrative services. One of these third-party service providers is Shopify. We may give these service providers access to your information (including Personal Information) so that they can carry out the services they are performing for you or for Dressbarn.
When You Agree to Receive Information from Third Parties or Request That We Share Your Information.
Cobranded Credit Card
Dressbarn may share Personal Information and other information with the issuing bank for our Dressbarn Credit Card, and its affiliates, for purposes related to the Dressbarn Credit Card. For example, we may share information in order to send joint offerings, including information on how to apply for the Dressbarn Credit Card, and in connection with your use of a Dressbarn Credit Card, such as to maintain or service accounts and to effectuate transactions. We may also share information with these parties for analytics purposes.
Other Cobranded Partners
Cobranded partners are entities with whom we work to offer a service or feature. You can typically tell when you are accessing a service offered by a cobranded partner because the cobranded partner's name will be featured prominently. You may be asked to provide information about yourself to utilize a feature offered by a cobranded partner. In doing so, you may be providing your information to both us and to the cobranded partner, or we may share your information directly with the cobranded partner. Please note that the cobranded partner's policies will apply its collection and use of your information, not this policy.
Business Transfers and Transitions
In the event Dressbarn goes through a transition (such as a merger, acquisition, bankruptcy or sale of all or a portion of its assets, including, without limitation, during the course of any due diligence process), your information (including your Personal Information) will likely be among the assets transferred. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.
Sweepstakes, Contests, & Promotions
We may offer sweepstakes, contests, and other promotions (any, a "Promotion") that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern that Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, Personal Information may be disclosed to third parties (including, without limitation, a co-sponsor) or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's terms or official rules (such as on a winners list).
Administrative and Legal Reasons
Dressbarn reserves the right to use or disclose any information (including Personal Information) as needed to satisfy any law, regulation or legal request; to protect the integrity of the Channels; to fulfill your requests; to cooperate in any law enforcement investigation, an investigation on a public safety matter, or an investigation into claims of intellectual-property infringement; to protect and defend the legal rights or property of Dressbarn, our parent company, affiliates and shareholders, any Channel or its users, or any other party; or, in an emergency, to protect the health and safety of our users or the general public. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
If you apply for a job through the Channels, we or our service provider(s) may ask you to provide self-identifying information (such as veteran status, gender, and ethnicity) in conjunction with laws and regulations enforced by, as applicable, the Equal Employment Opportunity Commission and other federal, state, provincial/territorial, and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, we and/or our service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints.
THIRD-PARTY LINKS & CONTENT
The Channels may link to or incorporate websites, advertising or content hosted and served by third parties over which we have no control and which are governed by the privacy policies and business practices of those third parties.
Third parties may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads, and other commercial purposes. For more information about the collection, use and sale of your personal information by third parties, and your rights, please refer to the non-exhaustive list below. Dressbarn is not responsible for the privacy practices or business practices of any third party.
ONLINE ADVERTISING AND ANALYTICS PROVIDERS
We may work with network advertisers, ad agencies, analytics service providers, and other vendors to serve our advertisements on third-party websites, apps, and elsewhere online and to provide us with information regarding use of and traffic on the Channels (including without limitation the pages viewed and the actions users take when visiting the Channels) and the effectiveness of our advertisements. For example, if you click on an advertisement for Dressbarn, our service provider(s) may be able to tell us the advertisement you clicked on and where you were viewing the advertisement. The advertisements you see may be served by one or more third parties, who may use information about your activities on the Channels, and other websites and services you visit across the various devices you use, to provide you targeted advertising based upon your interests. Our service providers may collect certain information about your visits to and activity on the Channels and other websites and services and may use this information to target advertising to you.
These service providers may set and access their own tracking technologies on your device (including without limitation cookies and web beacons) and may otherwise collect or have access to information about you (such as Usage Information and device identifier). Some of these parties may collect Personal Information over time when you visit the Channels or other online websites and services. Cookies and web beacons, including without limitation those set by third-party network advertisers, may be used to (among other things): target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share certain information such as device identifiers, Usage Information, records of transactions you conduct on our Channels or offline, and de-identified information with third-party advertising companies, analytics providers, and other vendors for advertising and analytics purposes. In addition, we and our third-party service providers may use this information to perform matching with third-party cookies in order to provide targeted online marketing.
We use a variety of service providers to perform advertising and analytics services, and some of these companies may be members of the Network Advertising Initiative ("NAI") or Digital Advertising Alliance ("DAA"). You may wish to visit optout.networkadvertising.org, which provides information regarding targeted advertising and the opt-out procedures of NAI members. You may also want to visit optout.aboutads.info, which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies.
For mobile apps, you may be able to limit certain advertising practices using the settings on your phone, tablet or other mobile device. You may also download the AppChoices app at youradchoices.com/appchoices to opt out of the delivery of interest-based advertisements in participating mobile apps.
Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive non-targeted advertisements while online.
HOW WE RESPOND TO "DO NOT TRACK" SIGNALS
Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. other than that a response to a “Do Not Track” signal is voluntary. Like many websites and online services, our Channels do not alter their practices when they receive a "Do Not Track" signal from a visitor's browser. To find out more about "Do Not Track," please visit www.allaboutdnt.com.
We employ commercially reasonable security methods and technologies to help secure your Personal Information, including physical, technological, and organizational protections. However, no system can be guaranteed 100% secure. We therefore cannot ensure or warrant the security of any information that you transmit to us, or that we transmit to you, or guarantee that it will be free from unauthorized access by third parties. You use the Channels and provide us with information at your own initiative and risk.
CONSENT TO TRANSFER AND STORAGE IN THE UNITED STATES
Dressbarn is a United States company. Please be aware that information we collect will be transferred to and processed in the United States and other countries. By using the Channels, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States and other jurisdictions, for which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to laws in those jurisdictions.
ACCESSING AND UPDATING YOUR PERSONAL INFORMATION AND YOUR CHOICES
The Channels may contain webpages or applications through which you can correct or update some of the Personal Information you have provided (such as an online account) or through which you may be able to unsubscribe or modify the email newsletters or similar communications we send to you. If you have an online account, you are responsible for maintaining and updating, as applicable, your account registration data with current, accurate, and complete information. You may view, update, and/or edit the registration data you have provided to Dressbarn by logging in to your account and following the appropriate instructions.
A registered user of a Channel has the right to request the removal of certain content that (s)he has publicly posted on the Channel. A user can request that we remove content (s)he has previously posted by contacting us using the information listed in the "Contact Us" section below. When submitting a request, please be sure to include your full name, email address, and information sufficient to permit us to locate the User Submission(s) for which you are requesting removal (e.g., for product reviews, a URL of the product page and the user name under which you posted your review). In some cases, we may remove only your Personal Information, but maintain the rest of your User Submission. Note that any removal of your public postings in accordance with these procedures does not ensure complete or comprehensive removal of the content or information you posted, which may persist in archival records or may have been copied by third parties while publicly accessible.
Dressbarn will make requested changes in our active databases as soon as reasonably practicable. Note, however, that we may retain information that you have updated or changed for internal or administrative purposes. Public postings that you have made (if any) will generally not be removed as a result of updating or deleting your registered account (unless you also follow the procedure for removing such posts as described above).
You have a right to request access to your Personal Information and to request a correction to it if you believe it is inaccurate. If you have submitted Personal Information to Dressbarn and would like to have access to it, or if you would like to have it corrected, please contact us using the contact information provided below. In some cases, we may not be able to allow you to access certain Personal Information, for example if it contains Personal Information of other persons, or for legal reasons. We may require you to verify your identity before allowing you to access your Personal Information.
You can unsubscribe from marketing emails through the opt-out mechanism included in each marketing email we send to you. You may opt-out of (a) our commercial email or direct-mail marketing messages, (b) having your Personal Information made available to affiliated companies within the family of brands for their direct marketing purposes, and/or (c) sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes. If you sign up to receive SMS or MMS messages that may be offered on the Channels, you may unsubscribe by replying "STOP."
YOUR CALIFORNIA PRIVACY RIGHTS
Right to Request Information about Your Personal Information
Free of charge, you have the right to request for the last 12 months, and receive within 45 days (and in any event no more than 90 days:
1) The categories of personal information we have collected about you;
(2) The categories of sources from which the personal information is collected;
(3) The business or commercial purpose for collecting or selling your personal information.
(4) The categories of third parties with whom we share your personal information.
(5) The specific pieces of personal information we have collected about you.
We must provide this information to you in a readily useable format that allows you to easily send the information to and between other entities, thus allowing you to “port” or move your personal information from us to another company offering similar services.
Under the CCPA, “Personal Information” includes, but is not limited to, identifiers such as a real name, alias, postal address, unique personal identifier (including cookies), online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
In the last 12 months, we have collected these categories of personal information from consumers:
Real name, alias, postal address, unique personal identifier (including cookies), online identifier Internet Protocol address, email address, account names and other similar identifiers.
In the last 12 months, we have sold these categories of personal information about consumers:
In the last 12 months, we have disclosed these categories of personal information about consumers for a business purpose:
Real name, alias, postal address, unique personal identifier (including cookies), online identifier Internet Protocol address, email address, account name and other similar identifiers.
Right to Request Deletion of Your Personal Data
Free of charge, you have the right to request deletion of your personal information that we have collected from you. We shall comply with that request by deleting all of your personal information from our records and directing any service providers to delete your personal information from their records.
Some exceptions do exist to our duty to delete your personal information at your request. These are when your personal information may be needed to:
(1) Complete a transaction for which your personal information was collected, provide a good or service that you requested, or that we could reasonably anticipate within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you;
(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
(3) Debug to identify and repair errors that impair existing intended functionality;
(4) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that follows applicable ethics and privacy laws, when our deletion of your information is likely to prevent or seriously impair the achievement of such research, if you have provided informed consent;
(7) To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
(8) Comply with a legal obligation;
(9) Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Disclosure of Categories of Personal Information Sold
Free of charge, you have the right to request for the last 12 months, and receive within 45 days later, the following information about the sale of your personal information:
(1) The categories of personal information that we have collected about you;
(2) The categories of personal information that we sold about you, the categories of third parties that we sold your personal information to, and the category or categories of your personal information that each third party purchased from us;
(3) The categories of your personal information that we disclosed about you for a business purpose;
(4) If we have not sold your personal information, disclosure of that fact.
Right to Request that Personal Data Not be Sold
Free of charge, you have the right to opt out of the sale of your personal information. “Sale” means “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating” your personal information by us to another business or a third party “for monetary or other valuable consideration.”
To make it easy for you to exercise your opt out rights, pursuant to the CCPA, we provide a link on the homepage of www.Dressbarn.com, titled “Do Not Sell My Personal Information,” to enable you to opt out of the sale of your personal information.
If and after you have directed that we not sell your personal information, we are prohibited from selling it until and unless you later expressly authorize us to sell your personal information.
The CCPA prohibits the sale of personal information of consumers under 16 years of age without express approval from the minor (between ages 13 and 16) or the minor’s parent or guardian (if under 13 years of age). Dressbarn does not knowingly collect or sale personal information of minors.
Right to Receive Equal Service and Pricing, Even if Exercising Your Privacy Rights
Pursuant to the CCPA, we cannot and will not discriminate against or penalize you for exercising your privacy rights. We will not:
(1) Charge different prices for our service;
(2) Provide a different level or quality of service to you;
(3) Suggest that you receive a different price for, or a different level or quality of, our service;
Provided, however, the CCPA does not prohibit differences in prices, levels or quality of service offered to users if the difference is reasonably related to the value provided to the consumer by the consumer’s data.
How to Make Requests Regarding Your Personal Information
To request information about your personal information, to delete your personal information, to direct us not to sell your personal information, or for disclosure of the types of your personal information that we may sell, contact us by:
2. 1-800-DRESSBARN (373-7722)
If you have questions about your rights under the CCPA, please send your request by email to email@example.com or write us at Dressbarn Customer Service, 12 Greenway Plaza 11th Floor, Houston, TX 77046. You must put the statement "Your California Privacy Rights" in the subject field of your email or in the address line of your envelope. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
By mail: Dressbarn Customer Service, 12 Greenway Plaza 11th Floor, Houston, TX 77046
By email: firstname.lastname@example.org
By phone: 1-800-DRESSBARN (373-7722)
You may also contact our Chief Counsel - IP & Regulatory at 12 Greenway Plaza 11th Floor, Houston, TX 77046. In any such mailing, please indicate that your questions or comments relate to Dressbarn's privacy practices.