Privacy



Last updated: June 10, 2024
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 our Terms 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

Notice At Collection

 

  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 Categories of
Third Parties
to Whom We Disclose
Personal Information
for Business or
Commercial Purposes		 Categories of
Third Parties
to Whom Personal
Information Is Shared		 Processing Purposes
(See Section 3
for a detailed
description of each
Processing Purpose)
Personal Identifiers Your name, mailing address, email address, telephone number(s), account or user name, password, social media profile, or other similar identifiers. Affiliates; business partners; service providers and suppliers; marketing partners; digital advertising and analytics providers; payment services providers; government entities; and others where required by law or directed or authorized by you. Affiliates; marketing partners; third party ad companies and other marketing and advertising partners; and analytics providers.
  • Provide our services and customer support.
  • Operations and general business purposes.
  • Marketing, promotions, and personalization.
  • Cross-context behavioral advertising.
  • Improve and develop our products and services.
  • Fraud prevention and security.
  • Legal and compliance.
Device Identifiers and Usage Data Browser type, browser version, and other diagnostic data. Affiliates; business partners; service providers and suppliers; marketing partners; digital advertising and analytics providers; payment services providers; government entities; and others where required by law or directed or authorized by you. Affiliates; marketing partners; third party ad companies and other marketing and advertising partners; and analytics providers.
  • Provide our services and customer support.
  • Operations and general business purposes.
  • Marketing, promotions, and personalization.
  • Cross-context behavioral advertising.
  • Improve and develop our products and services.
  • Fraud prevention and security.
  • Legal and compliance.
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. Affiliates; business partners; service providers and suppliers; marketing partners; digital advertising and analytics providers; payment services providers; government entities; and others where required by law or directed or authorized by you. Affiliates; marketing partners; third party ad companies and other marketing and advertising partners; and analytics providers.
  • Provide our services and customer support.
  • Operations and general business purposes.
  • Marketing, promotions, and personalization.
  • Cross-context behavioral advertising.
  • Improve and develop our products and services.
  • Fraud prevention and security.
  • Legal and compliance.
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. Service providers and suppliers; analytics providers; and others where required by law or directed or authorized by you. Affiliates; marketing partners; third party ad companies and other marketing and advertising partners; and analytics providers.
  • Provide our services and customer support.
  • Operations and general business purposes.
  • Marketing, promotions, and personalization.
  • Cross-context behavioral advertising.
  • Improve and develop our products and services.
  • Legal and compliance.
Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Affiliates; business partners; service providers and suppliers; marketing partners; digital advertising and analytics providers; payment services providers; government entities; and others where required by law or directed or authorized by you. Affiliates; marketing partners; third party ad companies and other marketing and advertising partners; and analytics providers.
  • Provide our services and customer support.
  • Operations and general business purposes.
  • Marketing, promotions, and personalization.
  • Cross-context behavioral advertising.
  • Improve and develop our products and services.
  • Fraud prevention and security.
  • Legal and compliance.
Geolocation data IP address based on location of device, location data (e.g., city, state, country, zip code). Affiliates; business partners; service providers and suppliers; marketing partners; digital advertising and analytics providers; government entities; and others where required by law or directed or authorized by you. Affiliates; marketing partners; third party ad companies and other marketing and advertising partners; and analytics providers.
  • Provide our services and customer support.
  • Operations and general business purposes.
  • Marketing, promotions, and personalization.
  • Cross-context behavioral advertising.
  • Improve and develop our products and services.
  • Fraud prevention and security.
  • Legal and compliance.
Job applicant data Information contained in a resume, cover letter, or other employment-related materials; intelligence, abilities and aptitudes. Affiliates; business partners; service providers and suppliers; government entities; and others where required by law or directed or authorized by you. N/A
  • Provide our services and customer support.
  • Operations and general business purposes.
  • Improve and develop our products and services.
  • Fraud prevention and security.
  • Legal and compliance.
Marketing Email addresses, phone numbers or contact details that we use to send marketing communications and your preferences for receiving communications about our activities, events, sweepstakes and contests. Affiliates; business partners; service providers and suppliers; marketing partners; digital advertising and analytics providers; payment services providers; government entities; and others where required by law or directed or authorized by you. Affiliates; marketing partners; third party ad companies and other marketing and advertising partners; and analytics providers.
  • Provide our services and customer support.
  • Operations and general business purposes.
  • Marketing, promotions, and personalization.
  • Cross-context behavioral advertising.
  • Improve and develop our products and services.
  • Fraud prevention and security.
  • Legal and compliance.
Data About Others Data from when you purchase an item or gift for another person, such as name, delivery address and phone number. Affiliates; business partners; service providers and suppliers; payment services providers; government entities; and others where required by law or directed or authorized by you. Affiliates; marketing partners; third party ad companies and other marketing and advertising partners; and analytics providers.
  • Provide our services and customer support.
  • Operations and general business purposes.
  • Marketing, promotions, and personalization.
  • Fraud prevention and security.
  • Legal and compliance.

 

In order to opt-out of the “sale” or “sharing” of your Personal Information (as defined under the California Consumer Privacy Act (the “CCPA”)), please do so through the following link: Do Not Sell or Share My Personal Information link to comply with the CCPA. We will not knowingly sell or share the Personal Information of a child 16 years old or younger without first obtaining the required authorizations.

SENSITIVE PERSONAL INFORMATION

We do not collect or process Sensitive Personal Information, as defined under the CCPA.

  1. 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®,TikTok®, 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.
  1. 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 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.

3.6. Non- Identifiable or Aggregated Information

We will retain your Personal Information as long as reasonably necessary for purposes for which the Personal Information was collected and is used by us, as stated in this Policy, and for an additional period of time as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the services to you; (ii) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and (iii) whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations).

GO TO TOP OF PRIVACY POLICY

  1. OUR INFORMATION DISCLOSURE PRACTICES

4.1 Disclosure of Personal Information

We may disclose 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 Affiliates and Service Providers. We disclose your Personal Information to 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 disclosed to 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.
  1. In the Event of a Potential Business Sale or Merger. We may disclose 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.
  2. With Certain Business Partners. With your consent (where required by law), we may disclose your Personal Information to our business partners to offer you certain products, services or promotions.
  3. With other Social Media users. When you disclose 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.
  4. 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 Disclosing Aggregate / De-Identified Information

Notwithstanding anything else in this Policy, we may disclose aggregate or non-identifiable information to third-parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual. Where we use, disclose or process de-identified data (i.e., data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal device), we will maintain and use the information in de-identified form and not to attempt to reidentify the information, except as permitted by applicable privacy laws (such as to confirm whether our de-identification processes are reasonable and adequate).

  1. 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.

  1. 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.

  1. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, you have the rights outlined in this section, and in accordance with the CCPA, as amended. 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, selling, or sharing 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 Information 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, 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. In some cases, we may request additional information (such as your phone number or email address) in order to verify your request. If we cannot verify your identity, we will be unable to process your request to know/access, correct or delete.

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 defines "sale" to include sharing or disclosing of Personal Information 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 disclosure of Personal Information with third-parties is not considered to be a sale. For example, we may disclose Personal Information with service providers who work on our behalf if the service provider agrees not to use that Personal Information for other purposes. In addition, you may intentionally direct us to disclose information to a third-party, which is also not a sale.

The CCPA gives 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 or Share My Personal Information link to comply with the CCPA. We give you the option to opt-out of these sales and shares at any time by following the link below:

Do Not Sell or Share My Personal Information

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale or sharing 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.

In addition, our website responds to global privacy control—or "GPC"—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on that Site. Note that if you come back to the Site from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. More information about GPC is available at https://globalprivacycontrols.org⁠.

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 CCPA 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 The Sale or Sharing of Personal Information of Children (16 years old and younger)

We will not knowingly sell or share 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 or share 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 or share your Personal Information, which your parent or guardian may do by emailing us at: privacyrequests@thereformation.us.

7.7 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.

7.8 No Discrimination For Exercising Your Rights

Authorized agents may also submit requests to us in the same way that individuals can submit requests. We may request that any authorized agents verify their identity, including by providing information about themselves, such as their name, email, phone number, and address. We may also contact consumers directly to confirm the authority of the authorized agent.

7.9 California Invasion of Privacy Act

By using the Ref Services, you consent to our collection, use, and disclosure of your information consistent with this Policy, to the extent such information falls under any provision of the California Invasion of Privacy Act.

7.10 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.

  1. 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 at privacyrequests@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.

  1. 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

  1. 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
  1. 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
  1. 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.
  2. 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.
  3. 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 Disclosure of Personal Information

The section above titled "Our Information Disclosure Practices" details how we disclose 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 email privacyrequests@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.
  1. 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.
  1. Erasure. You can request that we erase some or all of your Personal Information from our systems.
  1. 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.
  1. 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.
  1. 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.
  1. Restriction of Processing. You can ask us to restrict further processing of your Personal Information.
  1. 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.

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

  1. 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 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.

  1. 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

  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. 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.

  1. 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

  1. 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.

  1. 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.

  1. 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