Privacy Policy

Your privacy is very important to us. This privacy policy addresses how TFG Holding, Inc., and its subsidiaries, JustFab, LLC (d/b/a JustFab and ShoeDazzle) and Personal Retailing, Inc. (d/b/a FabKids) (collectively, "Company"), collect and use information you provide. By visiting www.JustFab.com (this "Site"), and providing your information to us, you agree to accept the practices described in this Privacy Policy.

How We Use Your Information

We collect personal information to make our services related to this Site (the "Services") more rewarding for you to use, including billing, shipping and tracking your orders. If we have any questions or concerns regarding your order, we may use this information to contact you. We also use this information for internal purposes, such as studying our customers' preferences and improving customer experience on the Site. We may also use your information to contact you for promotional purposes and provide customer service to you. If you enter into a sweepstakes, contest or similar promotion, we may use the information you provide to administer those activities. We may combine information about you with information from other sources in order to improve the quality of our Services.


We also receive and store certain personally non-identifiable information, which is collected passively using various technologies, and cannot presently be used to specifically identify you. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, the domain names of our visitors' Internet service providers, and how our users use and interact with the Services. Also, in an ongoing effort to better understand and serve you, we often conduct research on customer demographics, interests and behavior based on the personal and other information provided to us. This research may be compiled and analyzed on an aggregate basis. We may share this non-identifiable and aggregate data with affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.

What Information Is Collected

We group the collection of user information into two categories: personal, which is information identifiable to a specific member, and aggregate, which is general demographic information that does not identify any individual member. Personal information may include your name, email address, mailing address, credit card information and phone number. We may also collect certain demographic information such as your Site preferences, sizes, age, gender, geographical location, language, time zone, income and education (some of the information we ask for may be optional). JustFab may use or disclose aggregate information for any purpose.

How Is This Information Shared

There are certain circumstances in which we may share your personal information with certain third parties without further notice to you, as set forth below:



  • We do not sell any of your personal information to third parties for profit. Like most online businesses, we do share some information with contracted third parties in order to provide better services and advertising to you, and do afford you the option to opt-out of sharing this information.
  • We may share information about you with trusted third parties in order to improve your customer experience. These third parties may contact you about products, services or promotions you may be interested in, or to otherwise improve your customer experience with this Site.
  • We may share information about you, such as your name, address, email address, as well as a record of any transactions you conduct on our website or offline with us via our third-party advertising partners and its service providers, in order to deliver to you banner advertisements and other advertising tailored to your interests when you visit certain websites. Our advertising partners will make the data we provide to it anonymous. To learn more about the use of this information or to make choices about receiving personalized advertising provided by third parties, please visit the Network Advertising Initiative by clicking here.
  • We may also use your personal information in connection with automated decision making via our contracted third party service providers to protect our business from fraud during the checkout process. Certain transactions that appear to be fraudulent may be blocked from processing through automated decision making. We process this information given our legitimate interest in protecting our Services, to measure the adequate performance of our contract with you, and to comply with applicable laws.
  • As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, your information may be part of the transferred assets.
  • When we believe in good faith that disclosure is necessary to protect the rights, property and safety of JustFab, its users or the public.
  • As required by law, to comply with a judicial proceeding or court order, to exercise our rights, or to defend against any claims.

Cookies and Web Beacons

This Site uses cookies and web beacons to gather aggregated, non-personally identifiable information in order to help us better understand user behavior, tell us which parts of this Site users have visited, whether any products are left in your shopping cart, and facilitate and measure the effectiveness of advertisements and web searches. Such information may be shared with trusted third parties but the information will not personally identify you. To the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information. As we develop this Site, we may gather additional information from you through the use of other technologies.

Cookies

A cookie is a small text file that is stored on a user's computer for record-keeping purposes. We use cookies to collect anonymous information about how you use this Site by setting and accessing cookies on your computer. These cookies track information such as how often you visit our Site, what pages you view, and where you go after you leave our Site. The cookies are not connected to your personal information. We recommend that you leave cookies turned on because they allow you to take advantage of some of this Site's features. You also have the ability to restrict the use of cookies and advertising IDs:


  • You can use your browser’s settings to clear, delete or prevent cookies. We cannot control cookies that you have stored on your browser and recommend deleting all current cookies. Instructions for how to do this on different types of browsers can be found here: https://www.allaboutcookies.org/manage-cookies/
  • We use Google Ads and Google Analytics to serve and measure advertising. Please go here and here to opt-out of any personalized ads and cookies.
  • We also use Facebook to help serve advertising. Please go here to control Facebook’s use of cookies.
  • You may also find more information on our use of cookies and how to manage them in the Sections titled "Cookies and Web Beacons" and "Opting Out," above your Cookie Settings, located in the footer of this Site.

Web Beacons

Web beacons, or clear gifs, are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user's computer hard drive, web beacons are embedded invisibly on web pages. Web beacons help us better manage content on our Site by informing us what content is effective. We do not tie the information gathered by web beacons to your personal information.

Security

The security of your personal information is important to us. When you provide sensitive information (such as a credit card number), we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee the absolute security of such information. If you have any questions about security on our Site, please contact us as indicated below.

Opting Out


We may occasionally send you newsletters and emails regarding special offers, promotions, features and/or product updates. We may also communicate with you on behalf of third parties about special offers, promotions, features and/or product updates we think may be of interest to you, or you may have opted-in to receive newsletters or special promotions from one of our trusted third party providers. If you decide you do not wish to receive these communications, you may opt-out by clicking the unsubscribe link or by following the instructions included in the communication. Note however that as user of the Services you cannot opt-out of some administrative communications that are reasonably necessary to the Services, such as billing or service notifications. You may also opt-out of certain targeted advertising by visiting http://www.networkadvertising.org/choiceshttp://www.networkadvertising.org/mobile-choices or http://www.aboutads.info/choices.Example Text

SMS Messaging


JustFab collects various information from and about you when you sign up to receive automated marketing text messages, including information you directly provide when you enroll in its text message marketing program (the “Messaging Service”). For example, we collect the phone number and email address you provided when signing up for the Messaging Service. When you send messages via the Messaging Service, we will also collect your messaging history and any information included in those messages.

 

We may also collect information about you using cookies or similar technologies. Cookies enable personalization of your experience on the Messaging Service (e.g., sending you personalized text messages such as shopping cart reminders).

If you participate in a contest, sweepstakes, research study, or email survey associated with the Messaging Service, we will collect basic contact information and any other information you choose to provide in connection with these activities. We will also collect your contact information if you contact us with questions about the Messaging Service or for customer service.

 

We may share, transfer, or disclose your information, if you consent to us doing so, as well as in the following circumstances:

From time to time, we may share aggregate or de-identified information about use of the Messaging Service and such aggregated or de-identified information may be shared with any third party, including advertisers, promotional partners, and sponsors.

 

We retain your information for as long as you participate in the Messaging Service or as needed to comply with applicable legal obligations. We will also retain and use your information as necessary to resolve disputes, protect us and our customers, and enforce our agreements.

 

Consent to receive automated marketing text messages is not a condition of any purchase. You can opt-out of receiving further commercial text messages via the Messaging Service by responding to any of our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT. For additional opt-out information, please review our Terms of Service.

 

If you are experiencing any problems with the Messaging Service, you may call us at 1-866-337-0906 or contact us through live chat available 9am - 9pm (EST), 7 days a week.


Security

Links to Other Sites


This Site may contain links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites. This privacy statement applies only to information collected by this Site. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every Web site that collects personally identifiable information. This Privacy Policy does not cover any information that you disclose to such sites or that they may collect. The privacy policies of these other sites may be significantly different from this Privacy Policy. We are not responsible for the privacy practices of these other sites and cannot guarantee the security of any of your personal information collected there. This Site may enable you to post comments, reviews and other information on publicly available areas of this Site. Any information you post in these areas of this Site will be available to all of our users, so please use caution in disclosing any personal information when you post such comments, reviews or other information.

Facebook



You can log in to your account using your Facebook account, or utilize your Facebook account to access and use the social features on this Site. In doing so, Facebook will ask your permission to share certain information from your Facebook account with this Site. This may include your first name, last name, gender, profile picture, list of friends, a link to your Facebook profile, likes, and other data that is part of your or your friends' Facebook profile(s). This information is collected by Facebook and is provided to us under the terms of Facebook's Privacy Policy. You can control the information that we receive from Facebook using the privacy settings in your Facebook account. If you use your Facebook account to access and use the social features on this Site, your Facebook user name and your Facebook profile picture will be shared with other users of this Site. Further, other users of this Site may be able to view your profile and shopping activity on this Site.


You may choose to share your shopping activity on this Site with your friends on Facebook. A subset of your user activity on this Site, including your likes, purchases, wishlists and friends will automatically be shared to both your friends on Facebook and with your Facebook friends on this Site. Additionally, such activity will be visible to users on this Site who have a Facebook account but who might not be your friend on Facebook. The information you choose to share with your Facebook friends will be attributed to your Facebook account that was used to access this Site. Facebook's use of such information and any information it collects from your use of Facebook is governed by Facebook's Privacy Policy. JustFab has no liability or responsibility for the privacy practices or other actions of Facebook that may be enabled within use of this Site. The use of information on this Site is governed by this Site's Privacy Policy. You understand and acknowledge that you have read and are familiar with this Site's Privacy Policy and Facebook's Privacy Policy. If you do not wish to share your activity on this Site with your friends on Facebook, you may adjust your sharing settings on this Site at any time to disable such sharing. You understand and acknowledge that if you adjust your settings to disable such sharing on Facebook, such activity may continue to be publicly available to other users on this Site, including users with Facebook accounts.

Updating or Deleting Your Online Account Information


You may update or correct your online account information at any time by logging into your account and navigating to the "My Account" page or by contacting us. You can also contact us by phone if you wish to deactivate your account, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Children Under 18


Children under 18 may view this Site, but they cannot make a purchase or provide any personal information. This Site is not designed for children and we do not wish to collect personal information from children under 18. If you register with us and we discover that you are under 18, we will delete your account. You must be 18 or over to purchase any products from this Site. If a child under the age of 18 has provided us with personally identifiable information online, we ask that a parent or guardian contact us.

Exclusion to This Privacy Policy



This Privacy Policy shall not apply to any unsolicited information you provide to JustFab through this Site or through any other means. This includes, but is not limited to, information posted to any public areas of the Site, such as review sections and forums (collectively, "Public Areas"), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, "Unsolicited Information"). All Unsolicited Information shall be deemed to be non-confidential and JustFab shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

 

Important Information for California Residents - California Privacy Rights

 

***This notice went into effect on January 1, 2020 and was last updated on December 15, 2022*** 

 

If you are a California resident, this section applies to you. It describes how we collect, use and share personal information of California residents, and their rights with respect to their personal information, as defined under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”).

 

            Your Privacy Rights

 

As a California resident, you have the following rights in connection with your personal information (collectively, “Privacy Rights”):


    1. Right to Know What Personal Information is Being Collected. You have the right to know the categories of personal information that we have collected about you, the categories of sources from which we have collected your personal information, the business purposes for collecting, selling or sharing your personal information, the categories of third parties that we disclose your personal information to, and the specific pieces of personal information that we have collected about you. You may find all of this information in our Privacy Policy under Personal Information Collected, Sold or Shared in the Preceding 12 Months.


  1. Right to Know What Personal Information is Sold or Shared. You have the right to know the categories of personal information that we have collected about you, which of those categories of personal information have been sold or shared, the categories of third parties that the personal information was sold or shared, and for what business purpose was the personal information sold or shared. You may find all of this information in our Privacy Policy under Personal Information Collected, Sold or Shared in the Preceding 12 Months.


  2. Right to Access/Portability. You have the right to request and receive a copy of your personal information we have collected, used, disclosed, sold or shared within the previous 12 months. You can also view and manage most of your personal information by logging into your account.


  3. Right to Deletion. You have the right to request the deletion of your personal information we collect and maintain. Please be aware that deleting your personal information is irreversible and means that you will no longer have an account with us. By submitting a deletion request, you will be deleting your entire account including any member credits, reward points, and order history. If you have any member credits on your account, those credits will be deleted and can no longer be used. If you chose to use our Site at a later time, you will need to sign up again and create a new account. However, if you prefer to keep your account and member credits, and instead would like to cancel your monthly VIP Membership, you may do so by contacting our customer service representatives at 1-866-337-0906 or through live chat , or manage online

  4. Right to Opt-Out of Sale or Sharing of Personal Information. You have the right to opt-out of the sale or sharing of your personal information. Please note, we do not sell any of your personal information to third parties for profit. Like most online businesses, we do share some information with contracted third parties in order to provide better services and advertising to you. California law may classify our limited sharing with these contracted third parties as a “sale” or "sharing" of personal information, and we do afford you the option to opt-out of sharing this information. You can opt-out by submitting a request through our online webform located here or by contacting our customer service representatives via online live chat 24 hours a day, 7 days a week or by calling 1-855-266-9947 at any time. 

     

    You may also opt-out of the sale of sharing your personal information by enabling an Opt-Out Preference Signal, such as the Global Privacy Control (“GPC”), available in certain browsers and extensions. We will treat the GPC browser signal as a valid opt-out request. If you do not have a JustFab account or if you are not logged into your JustFab account, your request to opt-out via the Global Privacy Control will be linked to your browser identifier only and not linked to any account because your connection between your browser and account is not known to us. If you would like us to make the connection between your browser and your account, please sign-in to your account and enable the Global Privacy Control. You may need to take this step to opt-out on additional browsers and devices that you use. If you block or clear cookies from your browser, it may remove the Global Privacy Control settings, requiring you to opt-out again.

    Please be aware that even after submitting an Opt-Out request, you may still continue to see advertisements regarding our company online or through third parties. If you continue to visit or use the Site, you may also come across our ads. You will no longer receive personalized advertisements, but you may still see generic, non-personalized advertisements such as those based on the topic and content of a webpage that you visit.

  5. Right to No Retaliation/Non-Discrimination. You have the right to exercise any of your Privacy Rights free from discriminatory practices prohibited by California law. For example, unless permitted under CPRA, we will not deny you goods or services, charge you a different price or rate for goods or services, provide you with or suggest that you will receive a different level or quality of goods or services if you make an access, deletion, opt-out or limitation of use/disclosure request. Some of our products and Services, however, may require your personal information. If you choose not to provide your personal information that is necessary for any aspect of our products or Services, you may not be able to use those products or Services.

  6. Effective January 1, 2023: Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to request that your sensitive personal information only be used for certain business purposes that are necessary for us to perform our services or provide our products to you. Those business purposes are: (i) to ensure the security and integrity of our systems and networks; (ii) to provide non-personalized advertising as a part of your current interaction with our business; (iii) to perform our Services to you, including, but not limited to, maintaining or servicing your Account, providing customer service, processing or fulfilling orders, verifying customer information, processing payments, providing analytics services, storing customer information, or providing similar business services; and (iv) to verify and maintain the quality and safety of our Services and to improve, upgrade or enhance our Services to you. Please be aware that we do not use any sensitive personal information for any purposes other than those that are permitted under the law and specified under this section.

  7.  Effective January 1, 2023: Right to Correct Inaccurate Personal Information. You have the right to correct inaccurate personal information that we maintain about you. You can also view and manage most of your personal information by logging into your account.


            How To Exercise Your Privacy Rights

 

To submit a privacy related request, you may call us at 855-266-9947, contact us through live chat available 24 hours / 7 days a week, email us at CCPARequest@justfab.com, or fill out our privacy webform available here: Your Privacy Choices.

 

Prior to processing, we will authenticate your request through our standard verification procedures, such as by requesting you to log in to your account or by verifying the information you provided in your request with your account information we have on file. This information may include first name, last name, email and phone number. Please be aware that this information will only be used to verify and help process your request. However, we are required by law to keep information related to your request for record keeping purposes.

 

Please allow up to 15-45 days for us to complete your request. Please note, these Privacy Rights are subject to exceptions, and in certain cases we may decline your request as permitted by law. For example, if you have placed an order or initiated a return or exchange within the last 90 days prior to submitting a deletion request, we will hold on your deletion request until the 90 days has passed so that we may fulfill your order and uphold our return and exchange obligations to you.

 

You may also allow an authorized agent to submit privacy related requests on your behalf. If you would like to do so, please submit a signed Power of Attorney naming the person who will be your authorized agent. This person may then submit privacy related requests on your behalf using any of the available methods we offer. Please mail the signed Power of Attorney to Attn: General Counsel-Privacy Request, JustFab, 800 Apollo Street, El Segundo, CA 90245.

 

Notice of Financial Incentives

 

From time to time, we may offer special discounts, rewards, offers or other perks to you related to the collection of your personal information. You may be presented a financial incentive to register for an account, sign up for our mailing list or text message program, or participate in our friend referral program. We offer these financial incentives to enhance our relationship with you and your customer experience on the Site. There is no obligation to sign up for any of these incentives and you may withdraw your consent at any time.

 

  • When you register for an account or sign up for our marketing emails or text messages you may receive an exclusive VIP offer on your first VIP purchase. You can opt-in to receive this offer by providing the personal information requested in the sign-up form (e.g., name, email address, phone number, zip code, birthday or size preferences). You have the right to opt-out from our marketing communications at any time by clicking on the “Unsubscribe” link at the bottom of our emails or by texting STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any of our text messages.
  • If you are a VIP Member, you will also have the opportunity to invite friends to join the JustFab VIP Membership in exchange for a referral credit and/or reward points. You may invite your friend by providing their email address or by sharing your personalized referral link in your Account. The referral credit and/or reward points are automatically added to your Account once your friend enrolls in the VIP Membership and makes their first purchase. There is no obligation to join and the VIP Membership can be cancelled at any time by contacting our customer service representatives at (866) 337-0906, through live chat or visiting us online to cancel. For more information on our referral program, please visit https://www.justfab.com/account/friends.

 

Generally, we do not assign monetary or other value to the personal information that we collect and consider the value to be in the form of customer loyalty and increased purchase engagement. However, in the event we are required by law to assign such value in the context of financial incentives or price differences that we offer, we have valued the personal information as being equal to the value of the offer, less the expense related to providing that offer to our customers. The value will vary by customer depending on the amount and frequency of purchases, the value of the discount offered and the expense associated with acquiring the personal information. Any value that may be assigned to your personal information cannot be redeemed for cash. This notice of value is not intended to waive, nor should be interpreted as a waiver to, our proprietary or confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

Personal Information Collected, Sold or Shared in the Preceding 12 Months

 

The chart below summarizes the categories of personal information we collect and share, as well as where we collect it from, how we use it, and who we share it with. For more information on: the categories of information we collect, please see the Section titled “Information We Collect”; the business and commercial purposes for which we collect your personal information, please see the Section titled “How We Use Your Information”; or the categories of third parties with whom personal information is shared or sold, please see the Section titled “How Is This Information Shared”.

Categories of Personal

Information Collected

and Sold/Shared

Sources of Personal Information

Purposes for Collection and Selling/Sharing of Personal Information

Categories of Service Providers and Third Parties with Whom We Sell or Share the Personal Information

Profile information, such as name, email address, customer ID, mailing address, phone number, photos and/or Facebook username and profile picture.

This information has either been provided to us by you directly, or, with your permission, service providers or contracted third-party providers, such as customer review platforms, and marketing and advertising partners.

To create and manage your account and VIP Membership; to provide, administer, deliver, support, maintain and improve our products, events, promotions and the Services, such as fulfilling and tracking your orders, processing payments through third-party vendors, and performing our contractual obligations within the context of our ongoing business relationship with you; to improve customer experience on the Site; to send and respond to communications from you related to your account, purchases, exchanges, returns and participation in JustFab’s VIP Membership program, including to provide customer service; to conduct research and development of our products and Services; to prevent and detect fraudulent activities and ensure the security of your account and our Services; and to provide and improve advertisements, including sending marketing communications about products, services, offers, promotions, rewards and events that may be of interest to you to better understand your interests and behaviors; to respond to law enforcement requests as required by applicable law, court order or government regulations.

Service providers, such as customer service partners, shipping partners, payment processors, analytics and data warehousing partners; and contracted third-party providers, such as marketing and advertising partners.

Demographic information such as age, gender, birthday and other personal identifiers.

This information has either been provided to us by you directly, or with your permission, service providers or contracted third-party providers, such as marketing partners.

To provide, administer, deliver, customize, support, maintain and improve our products, events, promotions and the Services; to improve customer experience on the Site; to conduct research and development of our products and Services; and to provide and improve advertisements, including sending marketing communications about products, services, offers, promotions, rewards and events that may be of interest to you to better understand your interests and behaviors; to respond to law enforcement requests as required by applicable law, court order or government regulations.


Service providers, such analytics and data warehousing partners; and contracted third-party providers, such as marketing partners.

Commercial information such as order history, delivery information, payment method, credit or debit card information, billing and shipping information, order ID, items purchased, items returned or exchanged, size, style and product preferences, other unique identifiers, and inferences drawn therefrom related to your purchases or the use of our Services

This information has either been provided to us by you directly, or with your permission, your browser, computer or mobile device, service providers, and contracted third-party providers, such as marketing and advertising partners.

To provide, administer, deliver, customize, support, maintain and improve our products, events, promotions and the Services, such as fulfilling and tracking your orders, processing payments through third-party vendors, and performing our contractual obligations within the context of our ongoing business relationship with you; to improve customer experience on the Site; to send and respond to communications from you related to your account, purchases, exchanges, returns and participation in JustFab’s VIP Membership program, including to provide customer service; to conduct research and development of our products and Services; to prevent and detect fraudulent activities and ensure the security of your account and our Services; and to provide and improve advertisements, including sending marketing communications about products, services, offers, promotions, rewards and events that may be of interest to you to better understand your interests and behaviors; to respond to law enforcement requests as required by applicable law, court order or government regulations.

Service providers, such analytics and data warehousing partners; and contracted third-party providers, such as marketing and advertising partners.

Location information, such as your precise or approximate geolocation information in accordance with your device permissions. You may use our Services without enabling location information through your device, however, with may affect some functionality available in the Services.

This information is either provided to us by you directly or with your permission, your browser, computer or mobile device.

To provide, administer, deliver, customize, support, maintain and improve the Services; to improve customer experience on the Site; to prevent and detect fraudulent activities and ensure the security of your account and our Services; and to provide and improve advertisements, including sending marketing communications about products, services, offers, promotions, rewards and events that may be of interest to you to better understand your interests and behaviors.

Service providers, such analytics and data warehousing partners; and contracted third-party providers, such as marketing and advertising partners.

IP address, cookies, advertising IDs, tracking pixels, and other unique identifiers

This information has either been provided to us by you directly, or with your permission, your browser, computer or mobile device, service providers, or contracted third-party providers, such as marketing and advertising partners.

To provide, administer, deliver, customize, support, maintain and improve our products, events, promotions, and the Services; to improve customer experience on the Site; to conduct research and development of our products and Services; to prevent and detect fraudulent activities and ensure the security of your account and our Services; and to provide and improve advertisements, including sending marketing communications about products, services, offers, promotions, rewards and events that may be of interest to you to better understand your interests and behaviors.

Service providers, such as customer service partners, and analytics and data warehousing partners; and contracted third-party providers, such as marketing and advertising partners.

Internet activity information such as how a user browses and interacts with our Services, Site and advertisements, and device, browser and/or computer properties

This information has either been provided to us by you directly, or with your permission, your browser, computer or mobile device, service providers, or contracted third-party providers, such as marketing and advertising partners.

To provide, administer, deliver, customize, support, maintain and improve our products ,events, promotions and the Services and the Site; to improve customer experience on the Site; to conduct research and development of our products and Services; to identify, and resolve errors that impair existing functionality; to prevent and detect fraudulent activities and ensure the security of your account and our Services; and to provide and improve advertisements, including sending marketing communications about products, services, offers, promotions, rewards and events that may be of interest to you to better understand your interests and behaviors.

Service providers, such as customer service partners, and analytics and data warehousing partners; and contracted third-party providers, such as marketing and advertising partners.

For users who require access to this Policy in an alternative format, please visit our Accessibility page for more information.

 

If you have any questions or concerns about this Privacy Policy or our privacy practices, you may contact us at 855-266-9947.

 

Data Retention

 

We will retain your personal information only for as long as necessary for the legitimate business purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. For example, to comply with our legal and financial obligations, to prevent fraud and abuse, or to enforce our agreements. In general, we will retain your personal information for so long as you have an account with us, and for as long as is required by law after you delete your account. Following that period, we will delete or anonymize your personal information so that you can no longer be identified from it.

 

California Shine the Light Law

 

Under California Civil Code sections 1798.83-1798.84, 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 JustFab, LLC (JustFab), Attn: Legal Department, California Shine the Light Inquiry, 800 Apollo Drive, El Segundo, CA 90245.

 

Nevada Privacy Rights

 

If you are a Nevada resident and have provided us with any personal identifying information, you may opt-out of sharing your information with third parties if you submit an opt-out request to the following email address: nevadaprivacy@techstyle.com. Please note we do not sell any of your personal information for profit, we do share some information with contracted third parties in order to provide better services and advertising to you. Please allow 60 days for completion of such request.

 

Virginia Privacy Rights

 

***Effective January 1, 2023***

 

If you are a Virginia resident, the information below applies to you in addition to the rest of our privacy policy. Certain terms used in this section have the meanings given to them in the Virginia Consumer Data Protection Act (“VCDPA”).

 

Collection of Personal Data

 

In this section, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable nature person, but does not include de-identified data or publicly available information. The types of personal data we collect about you depend on your interactions with us. For example, we may collect the following categories of personal data:

 

  • Profile information, such as name, email address, customer ID, mailing address, phone number, and/or Facebook username and profile picture;
  • Demographic information, such as age, gender, birthday and other personal identifiers;
  • Commercial information, such as order history, delivery information, payment method, credit or debit card information, billing and shipping information, order ID, items purchased, items returned or exchanged, size, style and product preferences, other unique identifiers related to the use of our Services or your purchases;
  • Location information, such as your precise or approximate geolocation information in accordance with your device permissions. You may use our Services without enabling location information through your device, however, this may affect some functionality available in the Services;
  • IP address, cookies, advertising IDs, tracking pixels, and other unique identifiers
  • Internet activity information such as how a consumer browses and interacts with our Services, Site and advertisements, and device, browser and/or computer properties; and
  • Inferences drawn from any of the above that reflect a consumer’s preferences, characteristics and trends.

 

Use of Personal Data

 

We may use or share the personal data collected above for the following business purposes:

 

  • To create and manage your JustFab account and VIP membership;
  • To provide, administer, deliver, support, maintain and improve our products, events, promotions, and Services, such as fulfilling and tracking your orders, processing payments through third-party vendors, and performing our contractual obligations within the context of our ongoing business relationship with you;
  • To improve customer experience on the Site;
  • To send and respond to communications from you related to your account, purchases, exchanges, returns and participation in JustFab’s VIP Membership program, including to provide customer service;
  • To conduct research and development of our products and Services;
  • To prevent and detect fraudulent activities and ensure the security of your account and our Services;
  • To provide and improve advertisements, including sending marketing communications about products, services, offers, promotions, rewards and events that may be of interest to you to better understand your interests;
  • To respond to law enforcement requests as required by applicable law, court order or government regulations; or
  • In accordance with your consent, specific direction or instructions.

 

Disclosure of Personal Data

 

We share the personal data to the following third parties:

 

  • With our affiliates, including our parent company and sister brands;
  • With our service providers, such as customer service providers, shipping partners, payment processors, analytics and data warehousing partners; and
  • Without our contracted third-party providers, such as marketing and advertising partners.

 

Privacy Rights of Virginia Residents

 

  • Right to Access/Portability. You have the right to request and receive a copy of the personal data about you we have collected, used, disclosed or otherwise processed. You can also view and manage most of your personal data by logging into your account.

 

  • Right to Correct Inaccuracies. You have the right to request that we correct inaccurate personal data that we maintain about you. You can also view and manage most of your personal information by logging into your account.

 

  • Right to Delete. You have the right to request the deletion of your personal data we collect and maintain. Please be aware that deleting your personal data is irreversible and means that you will no longer have an account with us. By submitting a deletion request, you will be deleting your entire account including any member credits, reward points, and order history. If you have any member credits on your account, those credits will be deleted and can no longer be used. If you chose to use our Site at a later time, you will need to sign up again and create a new account. However, if you prefer to keep your account and member credits, and instead would like to cancel your monthly VIP Membership, you may do so by contacting our customer service representatives at 1-866-337-0906 or through live chat, or manage online.
  • Right to Opt-Out. You have the right to opt-out of targeted advertising, the sale of your personal information and profiling that would produce legal or similarly significant effects. PLEASE NOTE, WE DO NOT SELL ANY OF YOUR PERSONAL INFORMATION TO THIRD PARTIES FOR PROFIT. LIKE MOST ONLINE BUSINESSES, WE DO SHARE SOME INFORMATION WITH CONTRACTED THIRD PARTIES IN ORDER TO PROVIDE BETTER SERVICES AND ADVERTISING TO YOU. Virginia law may classify our limited sharing with these contracted third parties as “targeted advertising,” and we do afford you the option to opt-out of sharing this information. Please be aware that even after submitting an Opt-Out request, you may still continue to see advertisements regarding our company online or through third parties. If you continue to visit or use the Site, you may also come across our ads. You will no longer receive personalized advertisements, but you may still see generic, non-personalized advertisements such as those based on the topic and content of the webpage that you visit.

 

  • Right to Non-Discrimination. You have the right to exercise any of your Privacy Rights free from discriminatory practices prohibited by Virginia law. For example, unless permitted under VCDPA, we will not deny you goods or services, charge you a different price or rate for goods or services, provide you with a different level or quality of goods or services if you make an access, correction, deletion, or opt-out request. Some of our products and Services, however, may require your personal data. If you choose not to provide your personal data that is necessary for any aspect of our products or Services, you may not be able to use those products or Services.  


How to Exercise Your Privacy Rights

 

To submit a privacy related request, you may call us at 855-266-9947 or contact us through live chat available 24 hours a day, 7 days a week.

 

Prior to processing, we will authenticate your request through our standard verification procedures, such as by requesting you to log in to your account or by verifying the information you provided in your request with your account information we have on file. This information may include first name, last name, email and phone number. Please be aware that this information will only be used to verify and help process your request. However, we are required by law to keep information related to your request for record keeping purposes.

 

Please allow up to 45 days for us to complete your request. Please note, these Privacy Rights are subject to exceptions, and in certain cases we may decline your request as permitted by law. For example, if you have placed an order or initiated a return or exchange within the last 90 days prior to submitting a deletion request, we will hold on your deletion request until the 90 days has passed so that we may fulfill your order and uphold our return and exchange obligations to you.

 

If you wish to appeal a decision denying your request, please submit your appeal to the above contact information and please clearly indicate that it is an appeal to your privacy request.

 

You may also allow an authorized agent to submit privacy related requests on your behalf. If you would like to do so, please submit a signed Power of Attorney naming the person who will be your authorized agent. This person may then submit privacy related requests on your behalf using any of the available methods we offer. Please mail the signed Power of Attorney to Attn: General Counsel-Privacy Request, JustFab, LLC, 800 Apollo Street, El Segundo, CA 90245.


Colorado and Connecticut Privacy Rights

 

***Effective July 1, 2023***

 

If you are a Colorado or Connecticut resident, the information in this section applies to you in addition to the rest of our Privacy Policy. Certain terms used in this section have the meanings given to them in the Colorado Privacy Act (the “CPA”) and the Connecticut Data Privacy Act (the “CTDPA”).

 

Collection of Personal Data


In this section, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable individual, but does not include de-identified data or publicly available information. The types of personal data we collect and process about you depend on your interactions with us. For example, we may collect and process the categories of personal data listed in the table above under Personal Information Collected, Sold or Shared in the Preceding 12 Months. This table also lists, for each category, how we obtain the personal data, the purpose for processing such data, and the categories of service providers and third parties with which we share the personal data.

 

Privacy Rights of Colorado and Connecticut Residents

  • Right to Access/Portability. You have the right to request and receive a copy of the personal data about you we have collected, used, disclosed or otherwise processed. You can also view and manage most of your personal data by logging into your account.

 

  • Right to Correct Inaccuracies. You have the right to request that we correct inaccurate personal data that we maintain about you. You can also view and manage most of your personal information by logging into your account.

 

  • Right to Delete. You have the right to request the deletion of your personal data we collect and maintain. Please be aware that deleting your personal data is irreversible and means that you will no longer have an account with us. By submitting a deletion request, you will be deleting your entire account including any member credits, reward points, and order history. If you have any member credits on your account, those credits will be deleted and can no longer be used. If you choose to use our Site at a later time, you will need to sign up again and create a new account. However, if you prefer to keep your account and member credits, and instead would like to cancel your monthly VIP Membership, you may do so by contacting our customer service representatives at 1-866-337-0906 or through live chat, or managing online.

 

  • Right to Opt-Out. You have the right to opt-out of targeted advertising, the sale of your personal information and from profiling that would produce legal or similarly significant effects. PLEASE NOTE, WE DO NOT SELL ANY OF YOUR PERSONAL INFORMATION TO THIRD PARTIES FOR PROFIT. LIKE MOST ONLINE BUSINESSES, WE DO SHARE SOME INFORMATION WITH CONTRACTED THIRD PARTIES IN ORDER TO PROVIDE BETTER SERVICES AND ADVERTISING TO YOU. Colorado and Connecticut law may classify our limited sharing with these contracted third parties as “targeted advertising,” and we do afford you the option to opt-out of sharing this information. Please be aware that even after submitting an Opt-Out request, you may still continue to see advertisements regarding our company online or through third parties. If you continue to visit or use the Site, you may also come across our ads. You will no longer receive personalized advertisements, but you may still see generic, non-personalized advertisements such as those based on the topic and content of the webpage that you visit.

 

You may also opt-out of the sale or sharing of your personal information by enabling an Opt-Out Preference Signal, such as the Global Privacy Control (“GPC”), available in certain browsers and extensions. We will treat the GPC browser signal as a valid opt-out request. If you do not have a JustFab account or if you are not logged into your JustFab account, your request to opt-out via the Global Privacy Control will be linked to your browser identifier only and not linked to any account because your connection between your browser and your account is not known to us. If you would like us to make the connection between your browser and your account, please sign-in to your account and enable the Global Privacy Control. You may need to take this step to opt-out on additional browsers and devices that you use. If you block or clear cookies from your browser, it may remove the Global Privacy Control settings, requiring you to opt-out again.

 

  • Right to Non-Discrimination. You have the right to exercise any of your Privacy Rights free from discriminatory practices prohibited by law. Unless permitted by applicable state law, we will not deny you any goods or services, charge you a different price or rate for goods or services, provide you with a different level or quality of goods or services if you make an access, correction, deletion, or opt-out request. Some of our products and Services, however, may require your personal data. If you choose not to provide your personal data that is necessary for any aspect of our products or Services, you may not be able to use those products or Services.

 

How to Exercise Your Privacy Rights


To submit a privacy related request, you may call us at 855-266-9947, contact us through live chat available 24 hours a day / 7 days a week, email us at CCPARequest@justfab.com, or fill out our privacy webform available here: Your Privacy Choices.

Prior to processing, we will authenticate your request through our standard verification procedures, such as by requesting you to log in to your account or by verifying the information you provided in your request with your account information we have on file. This information may include first name, last name, email and phone number. Please be aware that this information will only be used to verify and help process your request. However, we are required by law to keep information related to your request for record keeping purposes. Please allow up to 45 days for us to complete your request. Please note, these Privacy Rights are subject to exceptions, and in certain cases we may decline your request as permitted by law. For example, if you have placed an order or initiated a return or exchange within the last 90 days prior to submitting a deletion request, we will process your deletion request once the 90 days has passed so that we may fulfill your order and uphold our return and exchange obligations to you.


If you wish to appeal a decision denying your request, please contact our customer service representatives via phone or live chat at the above contact information and please clearly indicate that it is an appeal to your privacy request. If you have concerns about your appeal, you have the right to contact your state’s Attorney General’s Office.


You may also allow an authorized agent to submit privacy related requests on your behalf. If you would like to do so, please submit a signed Power of Attorney naming the person who will be your authorized agent. This person may then submit privacy related requests on your behalf using any of the available methods we offer. Please mail the signed Power of Attorney to Attn: General Counsel-Privacy Request, JustFab, 800 Apollo Street, El Segundo, CA 90245.


UTAH PRIVACY RIGHTS

 

***Effective December 31, 2023***

 

If you are a Utah resident, the information in this section applies to you in addition to the rest of our Privacy Policy. This section describes how we collect, use and share personal data about Utah residents, and their rights with respect to their personal data. Certain terms used in this section have the meanings given to them in the Utah Consumer Privacy Act (“UCPA”).

 

Collection, Use and Sharing of Personal Data

In this section, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable individual, but does not include de-identified, aggregated or publicly available information. The types of personal data we collect and process about you depend on your interactions with us. For example, we may collect and process the categories of personal data listed in the table above under Personal Information Collected, Sold or Shared in the Preceding 12 Months. This table also lists, for each category, how we obtain the personal data, the purpose for processing such data, the categories of service providers and third parties with which we share the personal data, and if such data is sold to third parties or used for targeted advertising. If we collect sensitive personal data (as defined by Utah law), we will notify you at or before the time of collection and provide you with an opportunity to opt-out of the processing. However, please be aware, if you choose to opt-out or not provide your sensitive personal data that is necessary for any aspect of our products or Services, you may not be able to use those products or Services. 

 

Privacy Rights of Utah Residents

 

  • Right to Access/Portability. You have the right to confirm whether we are processing your personal data. You also have the right to access and receive a copy of the personal data you have provided to us along with your personal data we have collected, used, disclosed or otherwise processed. You can also view and manage most of your personal data by logging into your account.

 

  • Right to Delete. You have the right to request the deletion of the personal data you have provided to us. Please be aware that deleting your personal data is irreversible and means that you will no longer have an account with us. By submitting a deletion request, you will be deleting your entire account including any member credits and order history. If you have any member credits on your account, those credits will be deleted and can no longer be used. If you choose to use our Site at a later time, you will need to sign up again and create a new account. However, if you prefer to keep your account and member credits, and instead would like to cancel your monthly VIP Membership, you may do so by contacting our customer service representatives at 1-866-337-0906 or through live chat, or managing online.

 

  • Right to Opt-Out. You have the right to opt-out of targeted advertising and the sale of your personal data to third parties. PLEASE NOTE, WE DO NOT SELL ANY OF YOUR PERSONAL DATA TO THIRD PARTIES FOR PROFIT. LIKE MOST ONLINE BUSINESSES, WE DO SHARE SOME INFORMATION WITH CONTRACTED THIRD PARTIES AND SERVICE PROVIDERS IN ORDER TO PROVIDE BETTER SERVICES AND ADVERTISING TO YOU. Utah law may classify our limited sharing with these contracted third parties and service providers as “targeted advertising,” and we do afford you the option to opt-out of sharing this information. Please be aware that even after submitting an Opt-Out request, you may still continue to see advertisements regarding our company online or through third parties. If you continue to visit or use the Site, you may also come across our ads. You will no longer receive personalized advertisements, but you may still see generic, non-personalized advertisements such as those based on the topic and content of the webpage or online application that you visit. For more information on opting-out of targeted advertising, please see the “Cookies” and “Opting-Out” sections above.

 

  • Right to Non-Discrimination. You have the right to exercise any of your Privacy Rights free from discriminatory practices prohibited by law. Unless permitted by applicable state law, we will not deny you any goods or services, charge you a different price or rate for goods or services, provide you with a different level or quality of goods or services if you make an access, deletion or opt-out request. Some of our products and Services, however, may require your personal data. If you choose not to provide your personal data that is necessary for any aspect of our products or Services, you may not be able to use those products or Services.

 

How to Exercise Your Privacy Rights

To submit a privacy related request, you may call us at 1-855-266-9947 available 24 hours a day 7 days a week or contact us through live chat available 9am – 9pm (EST) 7 days a week.

 

Prior to processing, we will authenticate your request through our standard verification procedures, such as by requesting you to log in to your account or by verifying the information you provided in your request with your account information we have on file. This information may include first name, last name, email and phone number. Please be aware that this information will only be used to verify and help process your request. However, we are required by law to keep information related to your request for record keeping purposes. Please allow up to 45 days for us to complete your request. Please note, these Privacy Rights are subject to exceptions, and in certain cases we may decline your request as permitted by law. For example, if you have placed an order or initiated a return or exchange within the last 90 days prior to submitting a deletion request, we will process your deletion request once the 90 days has passed so that we may fulfill your order and uphold our return and exchange obligations to you.

 

EU-US DPF and the UK Extension to the EU-US DPF


JustFab complies with the EU-US Data Privacy Framework (“EU-US DPF”) and the UK Extension to the EU-US Data Privacy Framework (the “UK Extension to the EU-US DPF”) as set forth by the U.S. Department of Commerce JustFab has certified to the U.S. Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (“EU-US DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF. If there is any conflict between the terms in this Privacy Policy and the EU-US DPF Principles, the EU-US DPF Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visithttps://www.dataprivacyframework.gov/.


Types of Data Collected Under the EU-US Privacy DPF and the EU-US DPF and the UK Extension to the EU-US DPF


The following personal data may be collected from EU customers:


Personal data such as your name, email address, mailing address, credit card information, phone number and IP address are collected. This personal data is used for the following purposes: to process and fulfill orders, communicate with you about orders, any JustFab service, marketing and sales, internal research, and compliance with federal, state and local laws and regulations. JustFab also collects aggregate data such as your Site preferences, sizes, age, gender, geographical location, language, time zone, income and education. This aggregate data is used for the following purposes: marketing and sales activities, to optimize shopping experience and types of goods sold, internal research, partnerships or agreements with affiliates, agents and business partners, and to describe our Services to current and prospective business partners.Personal Retailing, Inc. (d/b/a FabKids) collects the following types of personal data: name, email address, mailing address, credit card information, phone number and IP address. The following aggregate data may also be collected: Site preferences, age, gender, geographical location, language, time zone, income and education.


JustFab, LLC (d/b/a JustFab and ShoeDazzle) collects the following types of personal data: name, email address, mailing address, credit card information, phone number and IP address. The following aggregate data may also be collected: Site preferences, age, gender, geographical location, language, time zone, income and education.


Who We Share Information With Under the EU-US Privacy DPF and the EU-US DPF and the UK Extension to the EU-US DPF


JustFab may disclose personal and non-personally identifiable aggregate data with affiliates, subsidiaries, business partners, advertisers and vendors. The purpose for disclosure to affiliates, subsidiaries and business partners is to improve customer experience, for internal research and marketing and sales purposes. We may share information with advertisers and vendors to comply with lawful agreements and for advertising purposes. JustFab retains potential liability in cases of onward transfer of information to third parties.JustFab may also be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.


Individuals will be notified by JustFab in the event it uses or discloses information for a purpose other than that for which the information was originally collected or discloses information to a non-agent third party. Notice may take a variety of forms, including through amendments or modifications to this Privacy Policy.


Accessing and Updating Your Personal Information


You have the right to access, correct or delete personal data which has been provided to JustFab. At any time, you may update or correct your online account information by logging into your account and navigating to the "My Account" page or by contacting us. You may also delete your personal data by contacting us to deactivate your account, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.


If you do not want JustFab to use or disclose your information or provide your information to third parties for marketing and sales purposes, please contact JustFab at the address provided below under “Inquiries or Complaints Regarding the EU-US DPF and the UK Extension to the EU-US DPF”. If you have already received a non-administrative communication that you did not wish to receive, you may opt-out by clicking the unsubscribe link or by following the instructions included in the communication.


Inquiries or Complaints Regarding the EU-US Privacy DPF and the EU-US DPF and the UK Extension to the EU-US DPF


In compliance with the EU-US DPF and the UK Extension to the EU-US DPF, JustFab commits to resolve EU-US DPF Principles-related complaints about our collection and use of your personal information. European Union and UK individuals with inquiries or complaints regarding this Privacy Policy should first contact JustFab at:


Attn: Privacy Department

25 Wilton Road

London, SW1V 1LW

United Kingdom

 

JustFab has further committed to refer unresolved EU-US DPF Principles-related complaints concerning our handling of personal data received in reliance on the EU-US DPF and the UK Extension to the EU-US DPF to a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information or to file a complaint. There is no charge to consumers for calling or using this independent dispute resolution mechanism.


Under certain limited conditions, European Union and UK individuals may be able to invoke binding arbitration before a panel to be established by the U.S. Department of Commerce, the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA).


JustFab is subject to the jurisdiction and investigatory and enforcement powers of the Federal Trade Commission (FTC).



 

Amendments or Modifications to this Privacy Policy

 

We reserve the right to amend this Privacy Policy at any time without prior notice. Notice of any change will be posted on this Site. Please check this page periodically for changes. Your continued use of the Site after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

 


Contact Us

 

If you have any questions regarding the use of our Site or Privacy Policy, please contact us at:

 

Justfab, LLC

Attn: Privacy Department

800 Apollo St.

El Segundo, CA 90245

Or 1-866-337-0906

Or contact us via live chat or Facebook messenger

 


Updated on 12/14/2023