California PRIVACY POLICY

Last updated July 26th, 2022

Introduction

In addition to the information contained in our Privacy Policy (available here), under the California Consumer Privacy Act (“CCPA”), California residents have the right to know and request access to their personal information collected, used, and disclosed within the past 12 months, to delete their personal information in accordance with the CCPA, and to opt-out of selling where that occurs. The instructions for submitting requests pursuant to the CCPA are below. We will not discriminate against you if you choose to exercise any of your privacy rights under the CCPA.


How to submit a request to know, access, or delete?

If you are a California resident and you, or your agent on your behalf, would like to submit a request to know, access, or delete your personal information, you can contact us at the following toll-free number: 1-833-878-5327 complete a web form at https://www.surveymonkey.com/r/29WHK6Q, or print and submit this form at any one of our California retail locations.

If you are a California resident and you or your agent would like to submit a request to opt-out of selling, you or they may do so at any of our California retail locations, by clicking here, or by emailing us at cs@truereligion.com.


What happens after you submit a request to know, access, or delete?

Following a request to know, access, or delete your personal information, we must first verify your identity. We will take commercially reasonable steps to verify your identity, including verifying you via your existing password-protected account or asking you to provide us with information matching the information we already have about you, such as by identifying a recent product you’ve purchased from us, the dollar amount of a recent purchase, or other such historical information about your purchases with us. If you wish to designate an authorized agent to make a request on your behalf, the agent should indicate that when submitting your request. We will then verify both you and your authorized agent’s identity and your agent’s permission to act on your behalf.

We will make good faith efforts to provide you with access to, or delete, your personal information when you request it, but there may be circumstances under the CCPA in which we need not provide access or delete that information. For example, we are not required to delete personal information needed to complete the transaction for which the personal information was collected (such as completing a sale), to detect fraudulent or illegal activity, for bookkeeping or tax purposes, or for legal purposes. Also, we are not required to provide access or deletion where your identity could not be verified, where the information would compromise others’ privacy or other legitimate rights, like intellectual property rights, or where the information contains legally privileged material. If we determine that your request should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.

Any requests that can be processed by us will be done so in no more than 45 days from the date we receive your request, unless we notify you that an extension is required. In case of an extended completion period, we will process your request in no more than 90 days from the date of your original request. Consumers are limited to two requests to know/access their personal information within a 12-month period. “Do not sell” requests are processed within 15 business days of receipt of the request.


NOTICE OF FINANCIAL INCENTIVES

True Religion provides one-time discounts (i.e., percentages off purchases) for customers who sign up to receive communications from us or download the True Religion mobile application (“TR App”).

You may sign up to receive communications from us online, in-store or via the TR App by inputting your information into the Site’s pop-ups or providing your information to your cashier during in-store checkout. The information we request from you when you sign up to receive communications includes your name, phone number, clothing preferences, and/or email address. You can opt-out of text communications at any time by texting “STOP” in response to our text message and opt-out of emails by clicking the unsubscribe button in our emails.

You can opt-in to our TR App program by downloading the TR App to your phone and inputting the code provided to you, during checkout. If you download the TR App, you are not required to provide any particular information, but we will collect personal information from you when you use the TR App. The data we collect depends on your TR App use and your particular device settings and choices. We collect a name, device identifier, app usage information (such as your in-app search history and data we use for analytics purposes), email address, and marketing preferences from all TR App users, but we will only collect information about your use of other apps and/or your location if you opt-in to such sharing. When you make a purchase or create or use a True Religion Account within the TR App, we collect the same personal information detailed in our Privacy Policy. You can opt-out of the TR App by deleting the TR App.

The value of the discount we provide you depends on the special offer provided when you sign up, the amount you purchase using that special offer, and the value of future special offers you receive from us and use to make purchases. While we do not assign a monetary value to the personal information, we collect from you by including you in our email or text programs, or for your use of the TR App, we do receive value in the form of customer loyalty and increased purchase engagement. In determining the value to True Religion of your receiving communications from us and/or using the TR App, we considered the revenue generated from activities related to this loyalty and engagement, minus the expenses related to providing the communications and/or TR App.


Personal Information collected, used, and shared within the past 12 months

California residents also have the right to know what categories of personal information we have collected within the past 12 months from consumers generally, where that information came from, the business or commercial purpose for the collection, and the categories of service providers and/or third parties with whom that information was shared. Below you will find a chart that sets this out for you. Please note that these are categories of personal information as they are set forth under California law. We did not necessarily collect all of the specific pieces of personal information listed for any given person.

What Personal Information We Collect? Where We Get It? Why We Collect It? With Whom Do We Share It? Whether We “Sell” It?
Identifiers such as a real name, alias, postal address, Internet Protocol address, email address, and account name. The consumer directly, payment partners, marketing partners, and advertising partners. To fulfill and facilitate orders and payments, customer relationship management, and advertising. Order fulfillment service providers, customer service providers, advertising partners, payment partners, data analytics service providers, marketing partners, fraud prevention service providers, and transaction processors. Our sharing in some instances may be considered a “sale” under California law.
Categories of personal information described in subdivision (e) of Section 1798.80 (e.g., telephone number). The consumer directly. To facilitate orders, marketing, and customer relationship management. Customer service providers, advertising service providers, data analytics service providers, marketing service providers, and transaction processors. No.
Characteristics of protected classifications under California or federal law (e.g., age, gender). The consumer directly. To provide our products, conduct data analysis, pricing, marketing, market research, and for legal compliance. Customer Service providers, and marketing service providers. No.
Commercial information, including records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies. The consumer directly. To provide our products, to conduct data analysis, pricing, marketing, fraud/abuse prevention, for legal compliance and accounting requirements, and payment processing. Customer service providers, advertising service providers, data analytics service providers, marketing service providers, and transaction processors. No.
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. We collect consumers’ Internet Protocol addresses and other online interactions through web technologies and partner relationships, as explained more fully in our Privacy Notice. To provide our products, to conduct data analysis, pricing, advertising, and marketing. Advertising partners, data analytics service providers, and marketing partners. This sharing in some instances may be considered a “sale” under California law.
Geolocation data. We collect zip codes from consumers directly and may collect device geolocation data. To provide our services, inform consumers of the closest store, conduct data analysis, for fraud/abuse prevention, and for legal compliance. Order fulfillment service providers, customer service providers, and data analytics service providers. No.
Inferences drawn from any of the information identified in this chart to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. The consumer directly, based on purchases, returns, and preferences, and from our advertising and marketing partners For customer relationship management, marketing, and advertising. Marketing service providers and data analytics service providers. No.

Other than the categories of service providers and/or third parties set forth in the above chart, we have not sold or disclosed personal information to third parties for a business or commercial purpose within the past 12 months from the effective date at the bottom of this notice.

Contact for More Information or Questions?

If you have any questions about this California Privacy Policy or about exercising your rights described above, or if you need this privacy policy in an alternative format, you can contact us at any of our California retail locations or by email at: cs@truereligion.com

Effective Date

This California Privacy Policy is effective as of January 1, 2020, and was last updated on July 26, 2022.