Privacy Policy

“Personal Information” is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, e-mail address, telephone number, home address, or payment information (e.g., account information or credit card number).

We may collect Personal Information when you interact with shopeas or any of our brands, such as when you:

• Purchase, return, reserve or try-on merchandise at one of our stores or through our Platforms;

• Consent to receive our promotional email, SMS/text messages, job postings or other communications;

• Visit or register through our Platforms;

• Information from your emails, texts, chats, video calls and voice calls with our sales associate sand Artificial Intelligence (AI) Chatbots;

• Visit our stores;

• Participate in our contests, sweepstakes or promotions, or participate in one of our surveys or other customer research;

• Submit product ratings and reviews;

• Contact or visit our Customer Service Department, or otherwise contact us or one of our service providers with a comment, question or complaint; or

• Enroll in one or more of our loyalty or other reward programs.

Purchasing, returning, reserving or trying-on merchandise. When you purchase or return merchandise through one of our stores or through our Platforms, we collect and use the Personal Information that you provide, such as your personal identifiers (such as name, address, email address and telephone number), commercial transaction information (such as order details) and financial information (such as payment card information), for the purposes of fulfilling your order, processing your return or exchange, improving our service and merchandise offerings, security and anti-fraud efforts, tailoring our marketing efforts, auditing, updating you on the status of your order/return and reporting internally. When you reserve or try-on merchandise in-store, we may collect Personal Information such as your personal identifiers (contact information), store location and commercial transaction information (the items you wish to reserve or try-on) for the purposes of fulfilling your request.

We receive personal characteristics (such as size information and locale) when you provide the information to us. We use size information to provide you with the products you order and save your preferences.

In certain circumstances, we may also collect Personal Information that you provide to us regarding other people. For example, you may provide us with personal identifiers (such as the name and address) for a gift recipient. When you provide us with this Personal Information, we use it for the purposes of processing the shipment and, in some cases, to communicate with the intended recipient. We rely on you to obtain any necessary consent from the intended recipient to our use of their Personal Information for these purposes.

Promotional email, SMS/text messages, job postings or other communications. When you consent to receive information from us such as promotional emails, SMS/text messages, job postings or other information, we collect and use your personal identifiers (such as contact information) for the purposes of fulfilling your request. You can unsubscribe from promotional communications by following the instructions in the message, or for SMS/text messages, replying with ‘STOP’. If you have any questions about unsubscribing from our messages, please contact us as outlined below.

Visit or register through our Platforms. If you choose to visit and register with one of our Platforms, we will collect the registration information that you provide, such as your personal identifiers (including your name, email address, telephone number, password, shipping addresses), financial information (including payment card information) and combined it commercial transaction information (such as your purchase history with shopeas and shopeas’s branded credit card) and loyalty program information (described below) for the purposes of administering and securing your account on our Platforms. Additionally, when you shop with us through our Platforms, we store your browsing history, what you searched for, including when you use our style personalization tools, what you have saved for later, and when you ask us to notify you about items that go on sale or come back in stock and what you bought (if you make a purchase).

We also collect certain information through our Platforms automatically, such as:

• Usage and Geolocation Information. Whenever you visit or interact with our Platforms, we, as well as our service providers and trusted partners (collectively, “Vendors”), may use a variety of technologies (such as cookies, beacons and pixels) that automatically or passively collect information (“Automated Technologies”) about how the Platforms are navigated, accessed and used (“Usage Activity Information”), and geo-location data. Usage Activity Information may include the pages served, the time/date of your visit, the preceding page views, and your use of and pathway through the Platforms.

• Device Identifiers and Characteristics. We and our Vendors may use Automated Technologies to collect personal identifiers (such as your IP address(es) or other unique device identifiers) and device characteristics (such as browser type, device type, operating system and application version) for the device (e.g., computer, mobile phone, tablet or other device) you use to access the Platforms.

• Automated Technologies. The Automated Technologies used on the Platforms to collect Usage Information include, but are not limited to, cookies (data files placed on a device when it is used to visit the Platforms), mobile analytics software, pixel tags (a transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a Platform to indicate that a page or e-mail has been viewed), and similar technologies. Both session cookies (which expire once you close your web browser) and persistent cookies (which remain on your device, sometimes until you delete them) may be used. Some Automated Technologies may tell your browser to get third party content, such as customer reviews, from Vendors and/or third parties.

We collect this information automatically through our Platforms for security and anti-fraud purposes (including protecting the integrity of the Platforms and our stores), to better understand and enhance user navigation on our Platforms, for marketing and analytics purposes (including allowing the selection of personalized ads or offers believed to appeal to you, based on your interests, preferences, location, or demographic information), and for internal operations and auditing. Additionally, Automated Technologies may be used to associate you with social networking sites (e.g., Facebook, Twitter and Snapchat), and, if you so choose, enable interaction between your activities on the Platforms and your activities on such social networking sites.

To the extent that these Automated Technologies are deemed to be a “sale” / “sharing” (which includes targeted advertising) under applicable U.S. state laws, you can opt-out of these Automated Technologies by submitting a request via the “Your Privacy Choices” link, which is available in the footer of the shopeas website, and Settings of the shopeas. Please note, some features of our websites may not be available to you as a result. For additional information about “sale/sharing”, please see “Section 10” of this notice and the “NOTICE AT COLLECTION” table within.

Visiting our stores. To help protect you and others, we monitor and record video and take photographs of the public areas of stores for security, anti-fraud, loss prevention, incident reporting and other operational purposes. We may also collect personal identifiers (such as IP Address and other unique device identifiers) and geo-location information of visitors’ devices in and around our stores to monitor foot traffic to help us understand how shoppers move around our stores, identify what shoppers seem interested in and improve the shopping experience.

Participating in our contests, sweepstakes, promotions, surveys or customer research. We collect the Personal Information (such as personal identifiers and responses) that you provide if you choose to participate in one of our contests, sweepstakes, promotions, surveys or other customer research, for the purposes of administering them. We will also use the Personal Information you provide to analyze and better understand how customers interact with our brands.

Product ratings and reviews. We collect the Personal Information through purchase and product review forms on the Platforms, such as personal identifiers (including your nickname and email address), your personal characteristics (including your height and weight) and commercial transaction information (including information about the product you purchased and your rating and review information). We use this information to display publicly on the Platforms and other locations (such as in stores, on television, and on social media pages). We also use the information to better understand your needs and preferences, enhance and personalize our product offerings to you and improve the Platforms and our service and merchandise offerings.

Contacting customer service. We use the Personal Information (including personal identifiers, commercial transaction information and financial information) you provide to us when you contact our Customer Service Department for the purposes of reviewing any questions you raise and responding to you. Depending upon the nature of your query, we may request additional Personal Information for the purposes of verifying your identity. We may record the audio information in customer service telephone calls, and may save and store written customer service interactions such as chat and email, for quality and training purposes and to meet our legal obligations.

AI Chatbots. We operate interactive chatbots on our platforms to assist you with inquiries and provide personalized product recommendations. When you interact with our AI Chatbot (including to facilitate returns), we may collect and use your personal information (such as your name and email address), commercial transaction information including order details, carrier information, and the content of your conversations for the purposes of providing customer service, improving our services, and for quality and training purposes. We may also use this information to analyze and better understand how you interact with us. This information is used for the purposes of providing product recommendations, customer service, improving our services, and for quality and training. Your interactions with our AI Chatbots may be saved and stored. By using our AI Chatbots, you consent to the collection, use, and disclosure of such information in accordance with this Notice.

Loyalty program. If you choose to enroll or engage in one of our optional loyalty programs, we will use the Personal Information you provide to us, which includes personal identifiers (zip code), personal characteristics (birth date) and financial information, along with commercial transaction information about the products and services you purchase from shopeas, for the purposes of administering the loyalty program, including any points you earn or redeem through the programs.

Information we receive from others. We may obtain Personal Information from other sources and combine that with information we collect directly from you. For example, we may collect personal identifiers, commercial transaction information, and personal characteristics (such as gender and birth date) from third parties to ensure we have up-to-date contact information for you, to detect fraud or theft, to facilitate your use of a third-party application or feature (such as one of our Facebook, Twitter or Snapchat applications or a similar application or feature on a third-party website), or from third-party analytics and advertising providers as further described below. We may also receive commercial transaction information (including purchase history) when you use the shopeas credit card. We apply the applicable provisions of this Notice to such combined information, so long as it is combined.

Inferences from the information listed above. We will use the information listed above to draw inferences about your preferences (such as your preferred brands and styles) to help us provide you with personalized content and offers and help us develop and provide better merchandise and services.

De-identified or aggregated information. We de-identify and/or aggregate data we receive and may use and disclose it for any business purpose.

Except as described in this Notice, we will not provide your Personal Information to third parties without your consent. We may, however, share aggregated, non-personal or de-identified information, which cannot reasonably be used to identify you, with third parties. We may also share any of your Personal Information (listed above) for our business and commercial purposes and as more specifically described below:

Service Providers Providing Services on Behalf. We may share your Personal Information with service providers that perform functions on our behalf or assist with our business operations, such as those that host or operate our Platforms, analyze data, fulfill, ship, and deliver orders, and provide customer service (including our AI Chatbot); advertisers; or other service providers that participate in or administer our promotions, contests, sweepstakes, surveys or provide marketing or promotional assistance; and “powered by” partners who power product reviews on our products or services. These service providers may use the Personal Information only for the purposes of providing the services to you and us.

Marketing Partners. For marketing and other commercial purposes, we may share your Personal Information with third party marketing partners, such as Data Cooperatives, for commercial purposes, to create a lookalike audience of prospective customers of our service. This allows us to target advertisements to potential customers who are similar to our current customers. For these purposes, we may provide such partners with and receive from such partners your name, physical address, and email address. Please note such partners may keep and use your personal information for its own commercial purposes. To opt-out of this sharing, please submit a request via the “Your Privacy Choices” link, which is available in the footer of the shopeas website, and Settings of the shopeas.

Our Banking Partner. If you apply for an shopeas credit card in the United States, we will share your Personal Information with Synchrony Bank, the issuer of the shopeas credit card. To create a more convenient application process, we may provide information from your customer account to Synchrony Bank in order to generate a pre-approved credit offer and/or pre-populate your online credit card application with information from your customer account.

Similarly, if you qualify for a credit account and are not offered a credit account we may share your personal information with our partner, Synchrony Bank, so that they may extend the offer of credit as required by law. Synchrony Bank is independent of shopeas and has its own privacy notice that applies to your application for and use of the shopeas credit card.

Publicly. If you choose to participate in a product review or rating or rate a review as helpful or not helpful, the submissions may be published on the Platforms, in emails, on television, and on social media platforms. Published ratings and reviews may identify the author’s personal identifiers (such as nickname), personal characteristics, locale and the content of the submissions. You consent to making this information available to the public.

Your Consent to Have Your Personal Information Shared. While utilizing our Platforms, you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the disclosure of your information with other Vendors. If you agree to have your Personal Information disclosed, your Personal Information will be disclosed to such Vendors and the Personal Information you disclose may be subject to the privacy notice and business practices of such Vendors.

Social Media Platforms and Networks. Some of our Platforms have features such as, plugins, widgets, and/or other tools made available by social media platforms and networks that may result in information being collected or disclosed between us and such parties. Their use of your information is not governed by this Notice.

Business Transfers. We may share your Personal Information with other entities and their advisors in connection with an actual or potential bankruptcy, merger, acquisition, financing, reorganization or sale of company assets, or negotiation thereof.

Legal and Additional Disclosure. We may transfer and disclose your information to law enforcement, the courts, our advisors, attorneys, and others who participate in the legal process to comply with a legal obligation; when we believe in good faith that the law or a governmental authority requires it; to verify or enforce applicable policies; to detect and address fraud, security or technical issues; to respond to an emergency; otherwise to protect the rights, property or security of shopeas or third parties, or as otherwise required or permitted by law.

Accessing/Updating/Deleting Your Personal Information. If you wish to access, modify, correct or delete any of your Personal Information collected through the Platforms, you may contact us through our Data Request or call us at 701-677-0759. Alternatively, you may access, modify, verify, correct or delete your registered user information through our Platforms. We may refuse requests that are unreasonably repetitive, require disproportionate technical efforts, risk the privacy of others, or are impractical.

In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Platforms or we have otherwise received. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. It may not always be possible to completely remove or delete all of your information from our databases without some residual data remaining due to backups and other reasons. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and obligations.

Promotional Communications. You may opt out of receiving promotional communications from us at any time by: (i) logging into your online account and updating your preferences; (ii) contacting us by phone, email or postal mail, or (iii) following the removal instructions in the communication that you receive. When you provide your address to us in your account profile, we may send you promotional mailers or advertisements. In addition, you can opt-out of receiving text messages from us at any time by responding to our text messages in the following manner:

• For shopeas, reply “STOP” to EAGLE (32453); and

• For Aerie, reply “STOP” to AERIE (23743)

Location Information. When you first launch any of our mobile applications that collect device geo-location information, you will be asked to consent to the application’s collection of geo-location information. If you initially consent to our collection of this location information, you can subsequently stop the collection of this information at any time by changing the preferences on your device. You may also stop our collection of device geo-location information by following the standard uninstall process to remove all of our mobile applications from your device.

For Our Users With Disabilities. shopeas seeks to provide an environment in which every individual has an opportunity to be a part of our community and where full inclusion and respect for all people encourages creativity and authenticity. When our Platforms are not accessible, we recognize the significance of the impact it can have on people with disabilities. If you use assistive technology (such as a Braille reader, a screen reader, or TTY) and the format of any material on this site interferes with your ability to access information or perform any functions, please contact Beth Henke, Chief Compliance Officer, at dkfcbxcjeu@iubridge.com or contact our customer service team at 701-677-0759. To enable us to respond in a way most helpful to you, please describe the nature of your accessibility problem, the preferred format in which to receive the material, the specific Web address of the requested material, and your contact information.

Selling under Nevada Privacy Law. We do not currently and will not sell your Personal Information (as selling is defined under Nevada Privacy Law) for monetary payments without your consent. If we ever do, we will let you know in this Notice and you will have the right to opt out of selling of certain Personal Information for monetary payments by contacting us at dkfcbxcjeu@iubridge.com to make this request (include your state of residence when making such request).

We use analytic tools (such as Google Analytics) and ad network providers to help analyze the usage of and present ads on the Platforms, third-party mobile applications, or other sites, as well as other service providers to provide analytics services. You can find out how Google Analytics uses data here and how to opt out of Google Analytics here. For more information on how Google uses data when you use our websites, click here.

For the purposes of conducting personalized advertising campaigns, shopeas processes certain data regarding users’ online activity on this website. This data includes online identifiers (e.g. cookie ID / mobile advertising ID), information regarding specific pages entered, products viewed or added to shopping cart and purchased along with timestamps as well as technical device and browser details. shopeas engages RTB House, an ad tech company, as a third-party subcontractor, to conduct advertising campaigns and display personalized ads to users, based on this data.

These entities may use cookies, web beacons and other technologies to collect information about your use of our Platforms, such as personal identifiers (your IP address), device characteristics (web browser, mobile network information) and usage activity (such as pages viewed, time spent on pages, links clicked and conversion information). This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content personalized to your interests and better understand your online or offline activity. For example, you may see advertisements for shopeas on third party sites after you have visited shopeas’s website.

Many advertising and analytics providers are members of associations, which provide a simple way to opt out of analytics and ad targeting, which you can access at:

• United States: Network Advertising Initiative and Digital Advertising Alliance

Do Not Track. Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites may not respond to all browser DNT signals.

We implement and maintain reasonable security practices and procedures appropriate to the nature of the information we maintain, including appropriate technical, administrative, and physical procedures to prevent loss, misuse, or alteration of your information on and offline. It is your responsibility to select a strong password, not reuse or share your password, and alert us if you have any concerns about unauthorized use of your account. We encourage you to use complex passwords and to change them regularly.

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Platforms is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at dkfcbxcjeu@iubridge.com. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

Where required, we do not knowingly sell or share information of our customers under the age of 18 or use the data for targeted advertising. If you are a parent or guardian and believe we may have collected information about your child, please contact us via a method described in the “Contact Us” section of this Notice.

We keep the categories of Personal Information described above for as long as is necessary for the

purposes described in this Notice or otherwise authorized by law. This generally means holding each

category of Personal Information for as long as one of the following criteria apply:

• your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;

• your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was Collected;

• the Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or

• we are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.

Where Personal Information is used for more than one purpose, we may retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below

The Platforms may contain links to third party websites and online services. This Notice does not apply to the practices of other websites and online services, and we are not responsible for the actions and privacy policies of the third parties that operate or interact with those other websites.

We may update this Notice from time to time. If we make changes, we will notify you by revising the date at the top of the Notice. We encourage you to review this Notice whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Montana, Nebraska, New Hampshire, New Jersey, Minnesota, Montana, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures. The following provisions address these state- specific requirements and supersede the prior general statements made above. Unless otherwise noted, the disclosures contained within this section cover our activities in the prior 12 months from the effective date, as well as our current practices.

We limit the collection of your personal data to only what is reasonably necessary and proportionate to provide or maintain the specific product or service requested by you, the consumer. We will not collect data beyond this necessary scope without your consent for a new, compatible, and disclosed purpose

NOTICE AT COLLECTION

HOW AND WHY WE COLLECT PERSONAL INFORMATION

CATEGORIES OF SOURCES FROM WHICH shopeas HAS COLLECTED PERSONAL INFORMATION

• Directly from you

• Your browser or device

• shopeas subsidiaries

• Our business partners and affiliates

• Third parties you direct to us share information with us

• Information generated or derived from your online browsing and usage activity

• Social networks

CATEGORIES OF RECIPIENTS TO WHOM PERSONAL INFORMATION IS DISCLOSED FOR BUSINESS PURPOSES

shopeas shares personal information with service providers and governmental authorities and permits our service providers to collect personal information directly from visitors and customers when providing services to shopeas. We do not disclose personal information to service providers that do not agree to acceptable data protection agreement terms.

We provide the categories of personal information listed above to service providers for the following purposes: payment processing, gift card processing, customer service, advertising and marketing, email services, mobile messaging services, mail services, data analytics, shipping, warehousing, anti-fraud services, loyalty program, legal and advisory, computer and data infrastructure, telecommunications, auditing, and building products and services for us.

Categories of Personal Information Sold or Shared

• Internet or other electronic network activity (e.g., “cookies” or other tracking tags, etc.
• Identifiers (e.g., name, mailing address, email address, phone number, etc.
• Commercial Information (e.g., products or services purchased, purchase history, etc.)

Categories of Third Parties to Whom Personal Information was Sold or Shared

• Advertising Networks

• Merchant Partners

• Marketing Partners

The purpose of selling or sharing this Personal Information (as defined under applicable US state laws) is for providers of advertising partners to help us tailor and target our marketing and advertising efforts.

In order to opt-out of selling and sharing, please click on the “Your Privacy Choices” link, which is available in the footer of the shopeas website, and Settings of the shopeas.

COLLECTION, PROCESSING, AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

shopeas does not use or disclose Sensitive Personal Information of consumers for purposes other than those identified in the CCPA.

CALIFORNIA CONSUMER RIGHTS

Under the California Consumer Privacy Act found at California Civil Code § 1798.100 et seq. and its implementing regulations (the “CCPA”), California Consumers have the right to request:

• The deletion of the Personal Information (as defined in the CCPA) we have about them;
• The correction of inaccurate Personal Information we have about them;
• To Know and Access your Personal Information, including information about (1) the categories of Personal Information collected, sold, shared with third parties, or disclosed by us; (2) purposes for which categories of Personal Information are collected, sold or shared with third parties by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed Personal Information; and (5) specific pieces of Personal Information we have collected about them;
• The opt-out of the “sale” or “sharing” of Personal Information: California consumers have the right to opt out of the “selling” and “sharing” of their Personal Information, and can do so by clicking the “Your Privacy Choices” link, which is available in the footer of our the shopeas website, and Settings of the shopeas.
  • Certain Marketing Partners, such as Data Cooperatives, help us identify lookalike audiences of prospective consumers of our service to send our catalog to potential consumers who are similar to our current customers. If you wish to opt-out of such sale or share, you will need to provide your physical address in order to identify you and honor your request.
  • Because sharing and selling also occurs via cookies and tracking technologies (“Cookies”), the link will also direct you to the Cookie Preferences Center in the footer of our website or mobile app Settings to opt-out of such Cookies. Opting-out of “sales” and “sharing” will not stop marketing and advertising, but it may be less tailored and useful for you. Even after you opt-out, we will continue to disclose your Personal Information with our service providers.

California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed above. When you make a request, we may require that you provide information and follow procedures to verify the request before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request (including your email and physical address) to information we already have on file to verify your identity. If we are able to verify your identity, we will begin to process it. If we cannot verify your identity, we may ask you for additional information to help us verify your request. If we still cannot verify your identity, we will notify you with further explanation.

We will respond to your request within the 45-day time period required by applicable law. We reserve the right to extend that time to 90 days in order to complete your request. However, we may not always be able to fully comply with your request, and we will notify you in that event. To make requests, California consumers may contact us through our Data Request or call us at 701-677-0759. Consumers will be required to submit their name, email address, and request-related information. We may also ask you to confirm information such as your order history or account settings so that we may verify the request. Please provide as much of the requested information as possible to help us verify your identity. We will use information received in a request only for the purposes of responding to your request.

The CCPA permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a signed document addressing this topic or a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agency must follow the process described above to make a request, and we will additionally require you and your authorized agent to verify his/her own identity. Additionally, we may confirm the agent’s authority with the California consumer about whom the request was made.

GLOBAL PRIVACY CONTROL

You may opt out of the sharing of your Personal Information through an opt-out preference signal setting in your browser. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. Please note that the GPC signal will only apply to the device and browser you are currently using, and any other devices or browsers where you have logged in. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use.

Your GPC opt-out preference signal status will be displayed within “Your Privacy Choices”.

DE-IDENTIFIED INFORMATION

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.

INFORMATION RETENTION

Please refer to Section 7. “Information Retention” of the Notice, above.

GO TO TOP OF PRIVACY NOTICE

CALIFORNIA PRIVACY RIGHTS – CALIFORNIA MINORS

As stated in our Privacy Policy, our websites, mobile/tablet sites, web pages, social media presence, marketing campaigns, applications, our stores and other shopeas controlled digital properties that link to this Policy (collectively, our “Platforms”) are “general audience” websites and not directed toward children.

Certain areas of our Platforms may contain interactive features that allow registered users to post content or information (the “Interactive Services”). If any of our Interactive Services are either: (1) directed toward California residents under the age of eighteen (18); or (2) if shopeas has actual knowledge that a registered user of the Interactive Services is a California resident under the age of eighteen (18), shopeas will permit such registered user to remove (if applicable) or request that shopeas remove or anonymize such content or information as posted by the registered user, to the extent required by California Business and Professions Code § 22581.

If you are under the age of eighteen (18) and would like to request the removal or anonymization of content or information you have posted on or to our Interactive Services, please send your request to dkfcbxcjeu@iubridge.com.

NOTICE OF FINANCIAL INCENTIVE

We may offer new customers with discounts, special offers, and promotions like discounts in connection with you opting in to receive marketing emails. Because this may involve the collection of Personal Information and offering of certain benefits, they might be interpreted as a “financial incentive” program under California law or a “bona fide loyalty program” under Colorado law. Under the California law, the value of your Personal Information to us is related to the discounted products, or other benefits that you obtain or that are provided, less the expense related to offering those products to these new customers.

Participation in a financial incentive program is completely at your own discretion and you can opt-in by providing your email address and clicking “subscribe,” which you may revoke at any time by following the instructions in the removal instructions in the marketing emails that you receive.

NOTICE OF REAL REWARDS FINANCIAL INCENTIVE

The following Notice of Financial Incentive applies to our rewards programs and may include certain promotions such as sweepstakes. Currently, we offer the Real Rewards by shopeas; Aerie program (“Real Rewards”). For financial incentive disclosures specific to any other promotion, please see that promotion’s terms. We reserve the right to terminate Real Rewards or any other offers at any time at our sole discretion.

Value of Consumer Data

The financial incentives that we offer, including Real Rewards, are reasonably related to the value of the consumer’s data. We have made a good faith estimate of the value of consumers’ data based on relevant expenses related to the collection and retention of consumers’ Personal Information as part of Real Rewards.

Withdrawal from the Program

You have the right to withdraw from Real Rewards or any other financial incentive at any time. You may withdraw from Real Rewards by calling Customer Service at 701-677-0759.

NOTICE OF ROKT PROMOTIONAL FINANCIAL INCENTIVE

We’ve partnered with Rokt to show you a variety of promotions with exclusive offers. No sensitive data is shared to facilitate these promotions. Promotions are selected using identifying details, transaction details or conversion data. You may receive a discount or other benefit from an advertiser in exchange for this personal information sharing.

Value of Consumer Data

We offer you these benefits and promotions because your personal information allows us to select and display targeted offers from our advertisers that we believe are most relevant to you. This process helps us generate revenue, which in turn allows us to provide our services and the offers you receive. The value of the incentive you receive is reasonably related to the value of the personal information you provide to us and our advertisers.

Withdrawal from the Program

These ads are provided by Rokt. To opt out you can use this site  or contact them via email dkfcbxcjeu@iubridge.com with the subject ‘Opt Out’. You’ll receive an automated response, and your request should be honored within the next 48 hours. You can learn more about Rokt’s privacy policy on their website.

CALIFORNIA SHINE THE LIGHT

California Shine the Light Under California Civil Code §1798.83, if you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes during the preceding calendar year. To request a notice, please submit your request to dkfcbxcjeu@iubridge.com. Please allow 30 days for a response.

ADDITIONAL RIGHTS AND PROVISIONS FOR COLORADO, CONNECTICUT, DELAWARE, INDIANA, IOWA, KENTUCKY, MARYLAND, MINNESOTA, MONTANA, NEBRASKA, NEW HAMPSHIRE, NEW JERSEY, OREGON, RHODE ISLAND, TENNESSEE, TEXAS, UTAH, VIRGINIA RESIDENTS 

This section applies to the “Applicable Privacy Laws” of Consumers as defined by the Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), Delaware Personal Data Privacy Act (“DPDPA”), Indiana Consumer Data Protection Act (“INCDPA”), Iowa Consumer Data Protection Act (“ICDPA”), Kentucky Consumer Data Protection Act (“KCDPA”), Maryland Online Data Privacy Act (“MODPA”), Minnesota Consumer Data Privacy Act (“MCDPA”), Montana Consumer Data Privacy Act (“MTCDPA”), Nebraska Data Privacy Act (“NDPA”), New Hampshire Privacy Act (“NHPA”), New Jersey Data Privacy Act (“NJDPA”), Oregon Consumer Data Privacy Act (“OCPA”), Rhode Island Data Transparency and Privacy Protection Act (“RIDTPPA“), Tennessee Information Protection Act (“TIPA”), Texas Data Privacy and Security Act (“TDPSA”), Utah Consumer Privacy Act (“UCPA”) and Virginia Consumer Data Protection Act (“VCDPA”) that use our Platforms. Capitalized terms defined in the Applicable Privacy Laws that are used in this section shall have the same meaning as in the Applicable Privacy Laws.

This section describes our collection, use, and disclosure of Personal Data. You can learn more about the Personal Data we process and the purpose for processing such Personal Data in Section 1. Collection and Use of Personal Information, above. You can also learn more about our disclosure of Personal Data and the categories of third parties we disclose Personal Data to in Section 2. Sharing of Information, above. To view the categories and the purposes of how shopeas processes Personal Data please see Section 10, Additional Rights and Provisions.

COLLECTION, PROCESSING, AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

shopeas does not use or disclose sensitive personal data of consumers for purposes other than those identified in the Applicable Privacy Laws. We may Process your Personal Data for a Sale or Targeted Advertising. You have the right to opt-out of the Processing of your Personal Data for a Sale or Targeted Advertising, as described below.

Our Use of Your Personal Data for Sale and Targeted Advertising

We may Process your Personal Data for a Sale or Targeted Advertising. 

• Data Sale: We may share your data with partners in exchange for something of value.

• Targeted Ads: We may use your personal data to show you ads based on your interests.

You have the right to opt out of these activities. In order to opt-out, click the “Your Privacy Choices” link, which is available in the footer of the shopeas website, and Settings of the shopeas. You may also opt-out via a GPC browser signal. Please review the next section for further details about your consumer rights. You have the right to opt-out of the Processing of your Personal Data for a Sale or Targeted Advertising, as described below. 

CONSUMER RIGHTS

If you are a Consumer, subject to certain conditions and restrictions set out in the Applicable Privacy Laws and other applicable laws, you have the following rights with regard to your Personal Data:

1. Right to Access. You have the right to know the Personal Data that we may hold about you and access such Personal Data. If you live in Oregon, you also have a right to request a list of specific third parties to which shopeas has disclosed your Personal Data.
2. Right to Correct. You have the right to request that we correct inaccuracies in your Personal Data.
3. Right to Delete. You have the right to request that we delete Personal Data that we have collected from or obtained about you.
4. Right to Opt-Out of Sales. You have the right to opt-out of the Sale of Personal Data. You can opt-out of the Sale of your Personal Data by submitting a request to us as set forth below.
5. Right to Opt-Out of Targeted Advertising. You have the right to opt-out of Targeted Advertising. You can opt-out of Targeted Advertising by submitting a request to us as set forth below.
6. Right to Opt-Out of Profiling. You have the right to opt-out of our processing of Personal Data for the purposes of profiling. Our profiling does not result in decisions that produce legal or similarly significant effects and therefore, we do not offer a way for you to submit such a request.
7. Right to Appeal. If you are unsatisfied with our actions related to the exercise of one of your privacy rights above, you may appeal our decision.
8. Right to Portability/Transfer. If you live in Maryland, you have the right to obtain a copy of the Personal Data done by automatic means in a portable and readily usable format.

Consumers may submit their Data Subject Access Requests via our Data Request. Consumers may also opt-out of Sales and Targeted Advertising by submitting a request via the “Your Privacy Choices” link which is available in the footer of the shopeas website and Settings of the shopeas. You may also opt-out via a GPC browser signal. Your GPC opt-out preference signal status will be displayed within “Your Privacy Choices”. Please note that, depending on the nature of your request, you may be asked to provide information to verify your identity before your request can be processed. We will confirm receipt of your request and respond to your request as soon as we reasonably can and no later than legally required.

You may exercise your privacy rights under the Applicable Privacy Laws. If you choose to exercise any of the privacy rights described above, you will not receive discriminatory treatment from us.

If you make a privacy rights request, we will retain the Personal Data provided to us to fulfill your request for our record keeping purposes.

DE-IDENTIFIED INFORMATION

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.

This Bona Fide Loyalty Program Disclosure applies to our rewards programs and may include certain promotions such as sweepstakes. Currently, we offer the Real Rewards by shopeas.

Categories of personal data collected through the Real Rewards program that will be sold or processed for targeted advertising

• Internet or other electronic network activity (e.g., “cookies” or other tracking tags, etc.)

• Identifiers (e.g., name, mailing address, email address, phone number, etc.)

• Commercial Information (e.g., products or services purchased, purchase history, etc.)

Categories of third parties that will receive personal data through the Real Rewards program

• Advertising Networks

• Merchant Partners

• Your personal data will not be provided to Data Brokers, as defined under law.

Additional Information
If your personal data is deleted from our systems, we will be unable to continue to offer you membership in our Real Rewards program as your Real Reward account information will no longer be available. shopeas does not use or disclose sensitive personal data of consumers for purposes other than those identified in the CPA.

As it relates to questions you might have about this Notice or if you have a concern that shopeas may have failed to adhere to this Notice, please contact us as follows:

Please note, the role and department responsible for compliance with the obligations under this Notice is: Assistant General Counsel, Privacy: Legal Department, dkfcbxcjeu@iubridge.com

shopeas c/o Legal Department
77 Hot Metal Street
Pittsburgh, PA 15203
Attention: Assistant General Counsel, Privacy
Tel: 701-677-0759
E-mail: dkfcbxcjeu@iubridge.com

If you have specific questions regarding your shopeas Credit Card, you can call shopeas Credit Card Customer Service at 701-677-0759 during the Eastern U.S. time zone hours of 8 a.m. – 12 midnight, Monday – Saturday or 9 a.m. – 10 p.m. on Sunday. You can also write to:

shopeas Credit Card
P.O. Box 530993
Atlanta GA, 30353-0993