Privacy Policy

Effective Date: February 9, 2026

 

Your privacy is important to us and we want you to understand what personal information we gather about you, how we use it, and the safeguards we have in place designed to protect it. This Privacy Policy (“Policy”) applies to any personal information processed through your use of any website, mobile application, services, products, call centers, and other offerings (together, the “Services”) maintained by or on behalf of Transform Holdco LLC (“Transformco”, “we”, “our”, or “us”) entity or licensee and which links to this Policy. We may update this Policy from time to time. Please check this Policy periodically for changes. If we make any changes, the updated Policy will be posted to the Services with a revised Effective Date. We encourage you to periodically review this Policy for the latest information on our privacy practices. By using the Services or otherwise providing personal information to us, you acknowledge that we will process your information in accordance with this Policy.

Get answers and information about:

What Type of Personal Information Do We Collect and How Do We Use It?
What Personal Information Do We Share and With Whom?
Can I Disable Cookies?
Children’s Privacy?
What About Links to Other Sites?
Interest-Based Ads – Online Advertisements
Is My Personal Information Secure?
How Can I Access My Personal Information?
Can I “Opt-Out” of Receiving Promotional Emails?
Your Rights and Choices
Additional Information for Nevada Residents
How May I Contact You?
California Privacy Notice
Additional Information for California and Colorado Residents Regarding Loyalty Programs or Financial Incentives

What Type of Personal Information Do We Collect and How Do We Use It?

We may collect personal information such as identifiers (for example, your full name, email address, mailing address, telephone number, mobile phone number) and commercial information (such as payment information, purchase history and preferences) when you voluntarily submit the information to us directly, such as when you purchase items from us, sign up for one of our services or programs, or register for an account with our Services. We may also collect personal information from you – either directly or via one of our vendors – if you choose to subscribe to our emails, participate in sweepstakes, contests, surveys, and polls, post content or suggestions on the Services, or use any of the Services’ other features that otherwise permit you to provide information or other content.

We may collect other information about you, including, without limitation, demographic information and commercial information from vendors such as public databases, social media platforms, data appends services, and others. We may collect information from third party vendors who allow us to verify your status as a first responder, veteran, military personnel, or otherwise, which will allow you to receive certain discounts, sales and promotions.

We may collect internet or other electronic network activity information (such as browsing history, search history, and information regarding your interaction with an internet website application or advertisement).

We may collect personal information about you automatically through cookies, pixel tags (also called web beacons or clear gifs), and other tracking technologies (collectively “Cookies”). We and our partners use these technologies to identify information about your device and internet activity, such as your IP address, browser type, device characteristics, domain name, referring URLs and specific links and web pages through which you click. We and our partners may also use this information to create inferences about your behavior, such as what types of products you may be interested in, to provide you with more relevant advertising. For more information about these practices, please see the “Interest-Based Ads – Online Advertising” section of this Policy.

We may use the information referenced above to:

  • provide you with requested products and services, such as processing and fulfilling your orders or scheduling appointments;
  • notify you of your order status and otherwise provide you with customer service;
  • prevent security incidents, protect against fraudulent or illegal activty, debug our systems, and fix errors;
  • respond to your inquiries and requests;
  • create and manage an account and register you as a Services user (“Registered User”) and/or Shop Your Way member (“Member”);
  • engage in marketing, including targeted advertising, and to send you information regarding the Services and other Transformco Services, as well as about our products, programs or services;
  • draw inferences to create a profile about you which reflects your preferences, characteristics, or predispositions;
  • provide you with text messages and push notifications, if you have requested them;
  • customize your experience on the Services and on other Transformco Services;
  • provide you with relevant offers, products and services;
  • permit you to access our pages on third party social media platforms;
  • facilitate any sweepstakes, promotions, or other similar contests you’ve signed up for;
  • perform data analysis and audits;
  • develop new products and services;
  • enhance and improve our existing products and services;
  • identify usage trends and determine the effectiveness of our campaigns;
  • provide you with other services; and/or
  • perform any purpose for which you provide consent for us to do so.

Some Service features may make use of your device attributes and settings that will allow our Services to determine your physical location. Such technologies may include IP address mapping, WiFi, GPS signals, cell tower positioning or other technologies. We use this information to provide you with services you have requested and enhance and personalize your experience, and we may use general information about your location to provide you with offers, products and services that may be of interest to you. For example, the Services may help you find your closest store, send you messages that may be of interest to you based on your current location, or collect location information about your smart appliances when you connect them to our applications.

We may collect audio, video, or other sensory information to provide the Services. For example, we capture CCTV recordings from inside our facilities for use in fraud investigations and for security purposes, as well as call center recordings when you contact customer service.

We and our vendors may use technology to collect information about how you use the Services, like replays of your visit to the Services and to observe your mouse movements, scrolling, and clicks on our Services. We use these tools for support and analytics purposes, and to better understand how people engage with our Services.

We may engage vendors to provide certain interactive features on our Services. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on the Services to assist you and for other customer service purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the personal information obtained through the feature to provide the service on our behalf.

Artificial Intelligence and Generative AI Services

We use artificial intelligence and generative AI services (together, “AI Services”) to provide you with customer service and technician scheduling support, including through phone services and website chatbot functionality. These AI Services collect certain information you provide when you use the AI Services, such as contact information required to book a service appointment or questions you may ask our chatbot or voice AI agents, as well as information about the products and services you use (for example, if you are scheduling an appliance repair) and your visits to and use of our Services. We may also collect the following information: IP address, device ID, or other unique identifiers; and general information about Services traffic data, performance, and related statistics, etc.

All information processed through our AI Services may be used for a variety of purposes, including providing you with the Services or other information that you request; automated processing to improve our products or services; quality improvement; or training, including continuous training of our AI Services. You should not submit confidential or proprietary information to our AI Services as it could be compromised. In addition, please note that we will maintain records of your communications with any chatbot, voice AI agent or similar features.

What Personal Information Do We Disclose and to Whom?

We may disclose your personal information within our family of affiliated companies. We may disclose your personal information to business partners to provide you with services that you participate in or request, such as co-sponsors of a promotion that runs on the Services. We are not responsible for the privacy practices of these entities.

We may disclose your personal information to selected vendors that provide services to Transformco or its affiliates, such as payment processors, shipping agents, and product fulfillment vendors.

You may disclose your own personal information through Services that allow you to post information and materials. Please note that any information you post or disclose through these Services may be available to Service visitors and to the general public, depending on the particular Service and any privacy settings in place (such as through your profile).

We may provide information about you, which may include personal information, to regulatory authorities and law enforcement officials in accordance with applicable law, when we believe in good faith that the law requires or allows it or to respond to requests from government authorities. There may be instances when we may use or disclose your personal information in order to protect or defend the legal rights, property or operations of Transformco or our employees or agents; to protect the rights, privacy, safety or security of Registered Users, Members or others; to protect against fraud; and to allow us to pursue available remedies or limit the damages that we may sustain.

Third parties may collect or receive certain information about you and/or your use of the Services to provide advertising (including targeted advertising), content, or functionality, or to measure and analyze ad performance, on our Services or other websites or platforms. We disclose or allow third parties to collect device information (e.g., browser type, IP address, or device ID), usage information, or click information obtained through Cookies and similar technologies. Some of this information is combined with information collected across different websites, online services, and other linked or associated devices. We may also disclose information, including personal information about you (e.g., email address) in hashed or other obscured format, for advertising purposes, including targeted advertising, either on our Services or for our products on other websites or platforms.

Transformco may sell, transfer and/or disclose personal information in connection with a planned, proposed, or effectuated merger, reorganization, joint venture, assignment, spin-off, transfer or sale or disposition of all or any portion of our business, and in the event of a store closing or bankruptcy.

We may also disclose information about you to third parties whenever you consent to or direct such disclosures.

Can I Disable Cookies?

Most web browsers allow you to exercise control over Cookie files on your computer by erasing them, blocking them, or notifying you when a file is stored. Please take a look at your particular browser for instructions on this function. If you do elect to disable Cookies, please note that you may not be able to take full advantage of a personalized experience on this Services and on other Transformco Services. For more information about your choices regarding the use of Cookies in certain contexts, such as for targeted advertising purposes, please see the “Your Rights and Choices” section of this Policy.

Children’s Privacy?

The Services are intended for a general audience and not directed to children younger than 18 years of age. If you are under 18, do not provide any personal information to us. If we obtain actual knowledge that we have collected children’s personal information, we will remove such data. If you believe your child may have provided us with their personal information, you can contact us at (888) 823-0650 and we will delete their personal information to the extent required by law.

What About Links to Other Services?

The Services may contain links to content from other websites or applications that are not owned and operated by Transformco. Transformco is not responsible for the privacy practices of non-affiliated websites or applications, including, without limitation, those that are linked to or framed on these Services. You should read the privacy statements of each and every website and application that collects personal information.

Interest-Based Ads – Online Advertisements

The Services may display ads from other companies. We also partner with companies to serve ads on our behalf on other non-affiliated sites or apps. Some of the ads on our Services or on other websites or apps may be personalized, meaning that they are intended to be relevant to you based on what we or the online advertising network serving the ad know about you or your device’s browsing activity. For example, information collected by our ad networks or other vendors across multiple sites that you visit may enable the ad network to predict your preferences and show you ads that are most likely to be of interest to you. As noted in “What Personal Information Do We Disclose and to Whom?,” we may disclose information to our vendors to permit them to recognize and serve targeted ads to you across the different devices you use.

Our partners, including Facebook and Google, may use Cookies, web beacons, and other tracking technologies to collect or receive information about your internet usage, including your use of the Services, and use that information to provide measurement services and targeted ads. We and our partners may use first-party Cookies or other first-party identifiers as well as Cookies or other identifiers operated by our partners to deliver advertisements, create a profile of you, measure your interests, detect your demographics, detect your location, and personalize content.

We may use certain web analytics services, including Google Analytics, to help us understand and analyze how visitors use the Services and to serve ads on our behalf across the Internet. We’ve implemented Google Analytics Advertising Features such as remarketing with analytics, interest-based advertising, and demographics and interests reporting. For more information on how Google Analytics uses data collected through the Services, visit policies.google.com/technologies/partner-sites.  You may also be able to opt out of Google Analytics by visiting tools.google.com/dlpage/gaoptout.

We may integrate the analytics services we use with advertising services that are made available by our analytics providers. For example, we integrate Google Analytics with the following Google advertising features:

  • Remarketing with Google Analytics

  • Google Analytics Demographics and Interest Reporting
  • Google Display Network Impression Reporting

You may also download the AppChoices app at http://www.aboutads.info/appchoices/ to opt-out of personalized in-app advertising. The Network Advertising Initiative offers useful information about internet advertising companies, including information about how to opt-out of interest-based advertising by their members. You may also visit http://www.aboutads.info/consumers/ to learn about how to opt-out from online or in-app behavioral ads served by some or all participating companies. To opt-out of Google’s network of interest-based advertising, visit adssettings.google.com

These opt-out mechanisms rely on Cookies to remember your choices with respect to ad-serving on websites. If you delete your Cookies, use another computer or device, or change browsers, you will need to repeat this process. In addition, opting out of interest-based ads will not opt you out of all ads, but rather only those ads that are personalized to your interests based on activities observed on our Services and/or websites or mobile apps not owned and operated by Transformco.

For more information about your choices regarding targeted advertising, please visit the “Your Rights and Choices” section of this Policy.

Some browsers may enable you to turn on or off a “Do Not Track” signal. We do not respond to “Do Not Track” signals.

Is My Personal Information Secure?

We protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Although we implement reasonable security measures on our Services, you should be aware that we cannot guarantee the security of your information submitted via the Internet. It is your responsibility to make sure that your passwords and account registration information are secure and not shared with third parties.

Can I “Opt-Out” of Receiving Promotional Emails?

From time to time, we may send you emails with promotional offers and messages. If you would no longer like to receive emails with promotional offers and messages from this Site, you can unsubscribe from these emails by following the unsubscribe link located at the bottom of each promotional email. Please note that you may still receive transactional notices in email (e.g., order confirmations, shipping notices, account statements, or important information regarding a product you have purchased) which will not have an unsubscribe link as they are not marketing emails.

Your Rights and Choices

Depending on where you live (such as residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia), you may have additional rights concerning your information. Depending on your jurisdiction, you may request that we:

  • Provide you with access to and/or a copy of certain personal information we hold about you;
  • Correct inaccurate information that we have about you;
  • Delete certain personal information we have collected from you; and/or
  • Provide information about financial incentives that we offer to you, if any.

California and Oregon residents can also request information about the categories of personal information we collect, disclose or sell or share about you.

California residents can request the categories of sources of such information; the business or commercial purpose for collecting or selling or sharing your personal information; and the categories of third parties to whom we disclose personal information. Such information is also set forth in this Privacy Policy.

Minnesota, Oregon, and Rhode Island residents can request a list of the specific third parties, other than natural persons, to which we have disclosed personal information.

To exercise your rights, please use this webform or call us at (888) 527-6415. We may need to ask for additional information to verify your request before fulfilling your request. If we are unable to verify your identity, we may be unable to respond to your requests.

You may be able to designate an authorized agent to make certain requests on your behalf in certain locations. In order for us to verify an agent, you must provide the authorized agent with signed, written permission to make such requests or power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.

Please note that certain information may be exempt from such requests under applicable law. For example, we may retain certain information for legal compliance and to secure the Services. We may need to retain certain information to provide the Services to you. If you ask us to delete it, you may no longer be able to use the Services.

You also have the right not to be discriminated or retaliated against (as provided for in applicable law) for exercising your rights.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request.

California residents may obtain more specific information about how we process their personal information by reviewing the chart below.

Opt Out of Sale, Sharing, Targeted Advertising

As discussed in the “Interest-Based Ads – Online Advertisements” section of this Policy, we use Cookies that process your information for targeted advertising purposes. This may be considered a “sale,” “sharing,” or use of your information for “targeted advertising” as defined under applicable privacy laws. Depending on your jurisdiction, you may have the right to opt out of the use of personal information for this purpose. To opt out of such “sales,” “sharing,” and “targeted advertising,” please click the “Do Not Sell or Share My Personal Information” link in the footer of the Services. We also respond to legally recognized browser-based opt-out signals, such as the Global Privacy Control (if you use a browser or browser extension that supports such a signal). You will need to also opt-out on your other browsers and devices. Cookie-enabled opt-out signals may no longer be effective if you block or clear Cookies.

We may also disclose personal information to third parties to serve you with personalized advertising on our partners’ websites, like social media sites. This activity may also be considered “selling,” “sharing,” or processing your personal information for targeted advertising purposes. To opt out of non-Cookie based Sales and Targeted Advertising please use our webform here.

Additional Information for Nevada Residents

Nevada consumers have the right to instruct website operators to not sell certain personal information to third parties. Transformco does not sell such information as defined under Nevada law. If we consider selling the information in the future, we will update this Privacy Policy to give you notice of this change and provide a formal method for Nevada consumers to exercise their opt-out rights under that law.

How May I Contact You?

If you have any questions about this Privacy Policy, please contact us at (888) 823-0650. Because voicemail communications are not always secure, please do not include credit card or other financial information, health or prescription-related information, or other sensitive information in your voicemail to us. If you prefer to contact us via US Mail, please address your inquiry to:

Transform SR Holding Management LLC
ATTN: Legal Intake/Privacy Team
5407 Trillium Boulevard, Suite B120
Hoffman Estates, Illinois 60192

California Privacy Notice

This California Privacy Notice (“California Notice”) applies to Consumers as defined by the California Consumer Privacy Act (as amended, the “CCPA”) and should be read along with our other notices found on the Services, and other websites in our family of brands (including but not limited to Sears, Kmart, and Shop Your Way). In the event of a conflict between any other Transformco policy, statement or notice and this California Notice, this California Notice will prevail as to California Consumers’ rights under the CCPA.

This California Notice applies to California Consumers that visit our Services.

Capitalized terms that are used herein shall have the meaning given to them in the remainder of the Privacy Policy, except capitalized terms defined in the CCPA that are used in this California Notice shall have the same meaning as in the CCPA. Unless otherwise noted, the disclosures contained within this California Notice cover our activities within the 12 months prior to the Effective Date noted atop this Policy.

How and Why We Collect Your Personal Information

We Collect, use, and disclose the categories of Personal Information about California Consumers that are indicated in the chart below. Note that the specific pieces of Personal Information we Collect, use, and disclose about you may vary depending on the nature of your interactions with us, and may not include all of the examples listed.

Category of Personal Information

Business Purposes for Collection, Use, and Disclosure

Categories of Recipients to Which We Disclose Personal Information

Identifiers such as a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

  • Providing the Services and our products, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity;
  • Debugging the Services to identify and repair errors;
  • Internal research and development;
  • Quality and safety assurance, and improving, upgrading, and enhancing the Services and our products; and
  • Processing and managing interactions and transactions on the Services and our products
  • Affiliates
  • Business Partners
  • Advertising Vendors
  • Analytics Providers
  • Service Providers

Personal Records, any personal information described in subdivision (e) of Section 1798.80 of the California Civil Code) such as the Identifiers listed above, telephone number, or other financial information.

  • Providing the Services and our products, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services; and
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity
  • Affiliates
  • Business Partners
  • Advertising Vendors
  • Analytics Providers
  • Service Providers

Protected Classifications under California or federal law  (e.g., veteran or military status).

  • Providing the Services and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services
  • Affiliates
  • Analytics Providers
  • Service Providers

Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • Providing the Services and our products, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
  • Internal research and development; and
  • Processing and managing interactions and transactions on the Services and our products
  • Affiliates
  • Business Partners
  • Advertising Vendors
  • Analytics Providers
  • Service Providers

 

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a Consumer’s interaction with an internet website application, or advertisement.

  • Providing the Services and our products, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity;
  • Debugging the Services to identify and repair errors;
  • Internal research and development;
  • Quality and safety assurance, and improving, upgrading, and enhancing the Services and our products and services; and
  • Processing and managing interactions and transactions on the Services and our products
  • Affiliates
  • Business Partners
  • Advertising Vendors
  • Analytics Providers
  • Service Providers

Geolocation Data (such as location information inferred from IP address).

  • Providing the Services and our products, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity; and
  • Processing and managing interactions and transactions on the Services and our products
  • Affiliates
  • Business Partners
  • Advertising Vendors
  • Analytics Providers
  • Service Providers

Sensory information, Audio, video, or similar information

  • Providing the Services and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, and similar functions and services; and
  • CCTV recordings from inside our facilities for use in fraud investigations and security purposes and call center recordings from when you contact customer service
  • Affiliates
  • Business Partners
  • Service Providers

Inferences drawn from any of the information identified in this subdivision to create a profile about a Consumer reflecting the Consumer’s preferences, characteristics, or predispositions.

  • Providing the Services and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
  • Internal research and development;
  • Quality and safety assurance, and improving, upgrading, and enhancing the Services and our products; and
  • Processing and managing interactions and transactions on the Servuces and our products
  • Affiliates
  • Business Partners
  • Advertising Vendors
  • Service Providers

Sensitive Personal Information, precise geolocation.

  • Providing the Services and our products, including maintaining and servicing your accounts and appliances, verifying your information, processing payments, analytics services, and similar functions and services
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity; and
  • Processing and managing interactions and transactions on the Services and our products
  • Affiliates
  • Service Providers

Sources of Personal Information

We Collect Personal Information directly from you, your devices or browser, from vendors that assist us in providing our Services and running our internal business operations, data analytics providers, advertising networks, suppliers, public databases, social media platforms, data enrichment services, other companies in the Transformco family of businesses, and other data providers. For more information about how we Collect your Personal Information, see the “What Type of Personal Information Do We Collect and How Do We Use It?” section of this Policy.

Retention of Personal Information

We keep the categories of Personal Information described above for the purposes described in this California Notice or otherwise authorized by law. This generally means holding the Personal Information for as long as one of the following criteria apply:

  • to manage our operations, to manage your relationship with us, to provide you with information regarding our Services, or to satisfy another purpose for which we Collected the Personal Information;
  • to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was Collected;
  • 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.

Selling and Sharing of Personal Information

We engage in targeted (or Cross-Context Behavioral) advertising on the Services or on other sites and when we advertise our Services elsewhere. In connection with such advertising, we may Sell or Share Identifiers, Internet or other electronic network activity information, and/or geolocation data (for example, when inferred from IP address) for advertising and marketing purposes with Third Parties including our advertising and analytics partners and social media networks. We do not Sell or Share Personal Information obtained for text messaging purposes – including Personal Information obtained for opt-in consent purposes – with any Third Parties for those Third Parties’ own marketing purposes.

Your CCPA Rights

a. Right to Opt Out of Sales and Sharing

As discussed in the “Interest-Based Ads – Online Advertisements” of this Policy, some of our uses of Cookies are considered “Sales” or “Sharing” under state privacy laws, including the CCPA. You can opt out of these Sales and Sharing of your Personal Information in the context of Cookies by clicking on the “Do Not Sell or Share My Personal Information” link in the footer of the Services you are visiting. We may still present contextual advertisements or you may still receive non-personalized advertisements that do not rely on Sales or Sharing to our advertising partners. You will need to also opt-out on your other browsers and devices. Cookie-enabled opt-out signals may no longer be effective if you block or clear Cookies.

To opt out of non-Cookie based Sales and Sharing, please use our webform here.

b. Opt-Out Preference Signals

You may also opt out of the Sale or Sharing of your Personal Information through a legally recognized browser-based opt-out preference signal, such as Global Privacy Control. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. 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.

c. Non-Discrimination

We will not discriminate or retaliate against you in a manner prohibited by the CCPA because you exercised your CCPA rights.

d. Rights to Know, Delete, and Correct Personal Information

California Consumers have the right to exercise certain privacy rights under the CCPA, as described further below.

        i. The Right to Know

You have the right to send us a request, no more than twice in a twelve-month period, for access to and/or a copy of certain Personal Information we hold about you, including the following:

  • The categories of Personal Information we have Collected, disclosed, Sold, or Shared about you.
  • The categories of sources from which we Collected your Personal Information.
  • The Business or Commercial Purposes for our Collecting and/or Selling/Sharing your Personal Information.
  • The categories of Third Parties to whom we have disclosed for a Business Purpose and/or Sold/Shared your Personal Information.

Such information is also set forth in this Privacy Policy.

        ii. The Right to Delete

You may request that we delete your Personal Information that we have Collected directly from you. Exceptions do apply, including, without limitation, where we need to retain your Personal Information for legal reasons, to complete a warranty or other contract with you, or for other internal uses of the information that are compatible with the context in which you provided it.

        iii. Right to Correct

You may request that we correct Personal Information that we maintain about you if you believe such Personal Information is inaccurate. We may request documentation from you in connection with your request where we have reliable documentation showing the accuracy of the information. You may be able to correct certain Personal Information that we maintain about you by signing in to your account on certain of our websites. Alternatively, you can submit a request that we correct Personal Information via the webform reference in the next paragraph under “Exercise Your Rights”.

e. Exercise Your Rights

To exercise the right to know, correct, or delete, you may submit a request by filling out this webform or calling us at (888) 527-6415. You may need to verify your identity before we fulfill your request. We may use information you have provided to us through your account or information about your recent transactions to verify your request, depending on the type of request you make.

If we cannot comply with a request, we will explain the reasons in our response. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

You may use an authorized agent to submit certain requests. If you use an authorized agent to submit a request, we may require proof that you have authorized the agent to do so, and take other steps permissible under the CCPA to verify the request.

You may have the right to appeal our denial of your request. We will provide you with additional information about your right to appeal as required under applicable law if we deny your request.

We will not discriminate or retaliate against you if you exercise any of the rights provided by the CCPA.

f. Right to Limit the Use of Sensitive Personal Information

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note, in the limited circumstances that we process sensitive personal information as defined by the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.

California Shine the Light Law

California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of “personal data” to third parties for their own direct marketing purposes. “Direct marketing purposes” means “the use of personal data to solicit or induce a purchase, rental, lease, or exchange of products, goods, property, or services directly to individuals by means of the mail, telephone, or electronic mail for their personal, family, or household purposes.” However, a business is not required to provide this information where it adopts and discloses, in its privacy policy, a policy of not disclosing “personal data” to third parties for their “direct marketing purposes” 1) unless the resident first affirmatively agrees or 2) if the resident has exercised an option that prevents that information from being disclosed. Transformco maintains such a policy and thus is not required to provide this information.

To exercise your right to opt out from this activity, to the extent we engage in it, follow the instructions at the “Right to Opt Out of Sales and Sharing” section of this California Notice.

Californial residents may request information about Shine the Light by contacting us at 
ShineTheLightCA@transformco.com or by sending a letter to:

Transform SR Holding Management LLC
ATTN: Legal Intake/Privacy Team
5407 Trillium Boulevard, Suite B120
Hoffman Estates, Illinois 60192

Any such request must include “California Shine the Light Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

Additional Information for California and Colorado Residents Regarding Loyalty Programs or Financial Incentives

The Services may offer opportunities to receive certain services or benefits such as, the Shop Your Way program, which may require the provision of personal information. Such opportunities could be considered a financial incentive under California law (each, an “Incentive”) or “bona fide loyalty program” under Colorado law (each, a “Loyalty Program”).

When you sign up for an Incentive or Loyalty Program, we collect your name, phone number, mailing address, and email address. We also collect data about your transactions in the Loyalty Program (such as your purchases), your reward activities (such as redemption), and we may derive inferences from your Loyalty Program activity to provide you with personalized recommendations. You may have the option for us to save your method of payment to your account for future purchases, in which case we will collect credit card information solely for such purpose. We also collect certain information for fraud prevention purposes, such as device information, session data, and approximate location derived from IP address. We may disclose this and other personal information as described in the section of the Policy entitled “What Personal Information Do We Disclose and To Whom?”

We also may Sell or process data provided in connection with your Incentive or your Loyalty Program data for targeted advertising, including when we disclose it to Loyalty Program partners, advertising partners, ad networks, business partners, advertisers, marketplaces, and commercial data resellers as described in “What Personal Information Do We Share and With Whom?” and “Interest-Based Ads – Online Advertising.”

When you participate in an Incentive or Loyalty Program, you agree to the terms of that Incentive or Loyalty Program and may revoke your participation or opt-out depending on the Incentive or Loyalty Program (by contacting us as described in the Loyalty Program terms). To the extent that you request the deletion of your personal data, you may not be able to continue to participate in certain Incentives or Loyalty Programs, because we require certain personal information to provide you access or manage your account and keep track of your rewards.

You can unsubscribe from marketing emails and retain your Program account and benefits.