PRIVACY POLICY

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Last updated July 1st, 2022

Introduction

Thank you for visiting our Privacy Policy (“Policy”). This Policy applies to any information that identifies or can be reasonably used to identify you ("Personal Information") and that is collected on truereligion.com, through any mobile application, in-store computerized device or data collection form, and through any location where this Policy is posted (collectively referred to herein as the "Sites," "True Religion," "our," "we," or "us").

In order to ensure your experiences with us are as enjoyable as possible and so that we can focus on doing what we do best, we may partner with trusted service providers or partners who specialize in technical things like order fulfillment, web development, payment processing, and digital advertising.

We want you to know that we take the privacy, security and confidentiality of your Personal Information seriously. We also want you to know what information we collect, why, and how we will treat it once collected. Finally, we want you to have control over your Personal Information so that if you need to update or correct your information or want to opt-out of receiving certain communications, you can do that easily. In short, this Policy is for you. Please read it carefully.

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CONSENT

BY ACCESSING THE SITES, CREATING AN ACCOUNT WITH US, OR OTHERWISE PROVIDING US WITH YOUR PERSONAL INFORMATION OR ALLOWING SOMEONE TO DO SO ON YOUR BEHALF, YOU ARE CONSENTING TO THE COLLECTION, USE, DISCLOSURE, TRANSFER AND STORAGE OF PERSONAL OR OTHER INFORMATION RECEIVED BY US AS A RESULT OF SUCH USE OR PROVISION IN ACCORDANCE WITH THIS POLICY.

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California Residents

For residents of California, please refer to our California Privacy Policy for additional information concerning your rights about the Personal Information we collect, use, and disclose. To the extent this Notice in any way conflicts with the California Privacy Policy, the California Privacy Policy controls.

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What Information Is Collected?

We may collect and store information that you provide to us as described below. We gather this information either from you directly, through partnerships with other companies, or via automatic data collection tools like cookies and other commonly used technologies. Some of the collection of Personal Information is required (e.g., for the purpose of registration to the Sites or for completion of a transaction), so if you do not provide us with the requested information, we may not be able to provide certain services to you.

We may collect Personal Information in several instances. The below section explains the Personal Information that we may collect and the manner in which we may use such Personal Information. If you do not want us to collect your Personal Information, please do not provide it to us.

• We may collect Personal Information such as your name, phone number, email address, billing and shipping address, payment information, and preferences if you complete a form or make a purchase. This information may be used to process your transaction, provide you with products or information that may be of interest to you, send you transactional information like order and shipping confirmations, and to provide you with information that you request.
• We may collect your name, email address, mailing address, zip code, date of birth, and gender if you create an account with us. This information will be used to help you manage your account, track your orders, update you about special offers or site updates, and facilitate checkout during purchases.
• We may collect your name, email address, phone number, gender, and postal code if you sign up to receive promotional materials from us. This information may be used to contact you about sales, special offers, and new site features.
• We may collect your name, email address, and order information if you contact us with a question or request a Live Chat with us. This information may be used so that we can respond to your question or contact you should we disconnect from our Live Chat.
• We may collect your name, email address, and other contact information if you participate in a promotion (e.g., contest, sweepstakes) that we sponsor or complete a survey. This information will be used to fulfill the terms of the promotion or survey and contact you regarding promotional and special offers, sales, and new site features. It will also be subject to the terms accompanying such promotion.
• We may collect your name, age, zip code, shopping habits, email address and/or mailing address if you choose to participate in one of our on-line surveys. This information will be used to help provide us with relevant information about our consumers.
• We may collect information regarding your location if you use our App. We use this information only to provide you with information on our nearest store.

We also obtain, collect and aggregate information (including Personal Information) provided to us by our marketing service providers, partners, and other vendors. That information is used for a number of things including enabling us to send you the most relevant, timely, and exciting offers and announcements specifically tailored for you and your interests. Of course, you can update your information or change your preferences regarding information sharing and receiving announcements and other information at any time.(For more information, see below section entitled How Can I Access, Correct and Update My Personal Information?)

When you use the Sites or otherwise interact with content online, including, for example, by browsing our merchandise, interacting with our ads or partners, and/or contacting us with inquiries, we or our partners collect certain electronic information, some of which may not identify you ("Electronic Information"). The Electronic Information we or our partners collect includes, without limitation, Internet Protocol (IP) addresses, Internet browser information, other characteristics of your device and software, domain names of your Internet Service Provider (ISP), your approximate geographic location, a record of your usage of our Sites or engagement with other content, the time of your usage, and Personal Information. Such information is collected passively using various technologies, both on our Sites and on other third-party sites you visit or whose products or services you use. The Electronic Information we receive from third parties may be combined with the information we collect, including Personal Information. We use this information to analyze and improve the Sites, provide our customers with a fulfilling shopping experience, and provide you the most relevant advertisements.

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Cookies and Other Session Identifiers:

Like many sites, we utilize a variety of technologies, such as cookies, web or hardware beacons, pixel tags, log files, local shared objects, and similar technologies. A cookie is a piece of information that is placed on your browser when you access the Sites. In many cases, the information collected using cookies (and related technologies) are used in non-identifiable ways, without any reference to Personal Information. For example, we use information we collect about users of the Sites to optimize our Sites and to understand traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Policy governs how we use that information. Additionally, if the settings on your location-aware device allow us to receive geo-location data or information, we may collect that information automatically.

Cookies help provide additional functionality to the Sites and help us to more accurately analyze usage of the Sites. For instance, the Sites may set a cookie on your browser that allows you to access the Sites during future visits, to monitor and maintain information about your use of the Sites, or track other websites you visit or other online activity (either with us or with others). Cookies also allow us to hold selections in a shopping cart when a user leaves the Sites without checking out. Cookies are not used on the Sites to store your account information as this information is stored securely on a server. When you log in at the Sites with your username and password, we will assign you a secure session id. The server then passes your information to you through this secure session ID. Cookies may be session cookies (i.e., last only for one browser session) or persistent cookies (i.e., continue in your browser until they are deleted or expire). Some of the cookies we use may be flash cookies or Adobe cookies, which may contain demographic information and depending on your browser these cookies may not normally be deleted when your cookies are deleted. Please check your browser to determine where these types of cookies are stored and how they may be deleted. If you sign up for our text messaging program, cookies may be used to personalize your experience (e.g., send you personalized text messages such as shopping cart reminders). Among other cookies, we use Google Analytics and Google Ads. You can learn more about how those cookies work by visiting “How Google uses information from sites or apps that use our services,” located at https://policies.google.com/technologies/partner-sites. You may install a Google Analytics Opt-out Browser Add-on by going here: https://tools.google.com/dlpage/gaoptout here. You can learn more about cookies more generally, see what cookies have been set on your computing device, and learn how to manage and delete them by visiting http://allaboutcookies.org.

While we recommend that you leave cookies turned on as they allow you to take advantage of some of the features of the Sites, you have the ability to control the use and moderation of our cookies. Specifically, you can configure your browser settings to (i) receive notifications when you are receiving new cookies, (ii) disable cookies or (iii) delete cookies. Please refer to your Web browser's help section for information on how to do this. Depending on where you live, you can also choose whether or not to accept cookies by using the cookie banner found on our Sites. If you elect not to allow cookies to be placed as provided herein, you may not be able to use or to enjoy all of the services and features of the Sites.

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OTHER WEBSITES, CONNECTED DEVICES, MOBILE APPLICATIONS, AND SOCIAL MEDIA:

If you use a social media platform, connected television, or your mobile device (or other method of communication), including to interact with the Sites or otherwise engage with us or others online, that platform or application may have a specific privacy statement that governs the use of Personal Information related to it. For example, if you use a mobile application and your mobile device's settings allow it, we may collect mobile location information from your device. Similarly, if you have a connected television, we may collect information about you and your viewing activity, which we use to target more relevant advertising to you. If you have questions about the security and privacy settings of your device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings. We do not control the data collection or privacy practices of any third-party platform through which you access our Sites or contact us. You should review the privacy policy and terms of use of any third-party site before using or downloading any app or device and review and use available controls and settings on your device to reflect your preferences.

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WHY WE COLLECT YOUR INFORMATION

We use your Personal Information for the following purpose(s):

Purpose	Lawful Basis
To enable access and navigation on the Sites and process data for the purpose of anonymous statistics regarding the use of the Sites, supervise the correct functioning of the Sites, and ascertain liability in the event of illegal behavior during navigation on the Sites	We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are as effective and efficient as we can be
To provide registration service on the Sites	To manage and perform our contract with you; we have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are as effective and efficient as we can be
For fraud prevention and detection and to comply with applicable laws, regulations, or codes of practice	To comply with our legal obligations
To process your order and communicate with you about the goods you have ordered from us or your relationship with us and to resolve complaints	To manage and perform our contract with you; we have a legitimate interest to respond to your requests and enquiries for ongoing business administration
For our own management information purposes, maintaining records, analysis of financial records, and internal audit	We have a legitimate interest in our ongoing business administration
To recommend offers, merchandise, events, and competitions that may be of interest to you	With your consent, which you can withdraw at any time
To record telephone communications for the purposes of monitoring our customer service standards, for training, and for security purposes	We have a legitimate interest in the prevention and detection of fraud to ensure that your identity and transactions are secure, ongoing business administration, and improving our customer experience

Right to Object: If you are a U.K. or E.E.A. resident, you have the right to object to processing of your Personal Information whether that processing is carried out for our legitimate interest or for direct marketing.

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HOW CAN I ACCESS, CORRECT OR UPDATE MY PERSONAL INFORMATION?

You can access, correct, and/or update certain Personal Information that you have provided to us by clicking on "Update Account" within the "My Account" area of the Sites. If you do not have an account, you can do so by contacting us using the methods in the “Contact Us” section below.

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How Do We Use the Information Collected?

We may use Personal Information in the following ways:

Access and Use: If you provide Personal Information in order to obtain access to or use of the Sites or any functionality thereof, we will use your Personal Information to provide you with access to or use of the Sites or functionality and to monitor your use of the Sites or specific functionalities.

Internal Business Purposes: We may use your Personal Information for internal business purposes, including without limitation, to help us improve the content and functionality of the Sites, better understand our users, protect against, identify or address fraudulent activities, manage your account, provide you with customer service, and generally manage our business.

Marketing: We may use your Personal Information to contact you for certain marketing and advertising purposes, including without limitation, to inform you about offers, contests or surveys which may be of interest to you and to display content and advertising on or off the Sites which may be of relevance to you. If you wish to change or update your Personal Information or to change your subscription preferences, you may do so as provided herein.

Specific Reason: If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Information you provide to answer your question or to attempt to resolve your issue and will respond to the email address from which the contact came.

Aggregated Data: In an ongoing effort to better understand and to serve the users of the Sites, we (either directly or working in concert with our service providers or partners) may on an aggregate basis conduct research on our customer demographics, interests and behavior based on Personal Information and other information that has been provided or received by us. For example, we may combine information about visitors to the Sites in a way that does not identify them to determine how best to target our marketing and the products that we offer. This research may be compiled and analyzed on an aggregate basis and is not treated as Personal Information under this Policy.

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With Whom Do We Share Your Information?

We only share Personal Information provided to us with your consent or as described in this Policy. The entities with which we share your Personal Information include:

Third Parties related to Business Transfers: As with any business, it is possible that we might sell, assign, buy, transfer, merge or otherwise acquire or dispose of certain businesses or corporate assets. In the event of such, or a similar, event, Personal Information may be part of the transferred assets and be shared with an actual or prospective buyer. You acknowledge and agree that any successor to or acquirer of us and/or our service provider(s) will continue to have the right to use your Personal Information and other information in accordance with the terms of this Privacy Policy.

Subsidiaries and Affiliates: We may also share your Personal Information with our subsidiaries and/or affiliates, including True Religion Apparel, Inc., consistent with this Privacy Policy, including but not limited to for purposes of Customer Relationship management, site management, analytics, and marketing. Our subsidiaries and affiliates will be bound to treat and to maintain any Personal Information in accordance with this Privacy Policy.

Service Providers, Agents, Consultants and Related Third Parties: We, like many businesses, sometimes engage other companies to perform certain business-related functions on our behalf so that we can focus on our core business. Examples of these services include, but are not limited to, payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfillment and shipping, marketing and promotional material distribution, website evaluation, technical support for the Sites, customer support, data analysis and data cleansing. In connection with services those partners provide for us, we may provide or otherwise give them access to certain Personal Information, but we authorize them to use this information only in connection with the services they are retained to perform.

Marketing Partners: The Personal Information that you provide to us, and information about your order, may be combined with other personally identifiable information from our records and from third party sources. This information may be used to enhance our future marketing efforts. This information may also be shared with our third party service providers and other marketers whose products or services may be of interest to you. If you prefer we do not share your Personal Information with these types of parties, please email us at optout@truereligion.com. This right to opt out does not extend to aggregate information that we share with our marketing partners, advertisers and others from time to time that does not constitute Personal Information.

Others, as Required by Law: We may disclose your Personal Information to others if required to do so by law (including, without limitation responding to a subpoena or request from law enforcement, court or government agency) or in the good faith belief that such action is necessary (i) to comply with a legal obligation, (ii) to protect or defend our rights, interests or property or that of other customers or users, (iii) to act in urgent circumstances to protect the personal safety of users of the Sites or the public or (iv) to protect against legal liability or potential fraud, in each case as determined in our sole discretion.

Others, At Your Direction or With Your Permission: We will also share your Personal Information if you request we do so, or with your permission. For example, we may share your Personal Information to facilitate your use of certain credit-based payment forms. If we intend to use any Personal Information in any manner that is not specified herein, we will inform you of such anticipated use prior to or at the time at which the Personal Information is collected or we will obtain your consent subsequent to such collection but prior to such use. We will honor the choices you make regarding your Personal Information and will inform you about any other intended uses of such information.

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What Steps Are Taken To Keep My Information Secure?

We have implemented information security measures that contain administrative, technical and physical controls designed to reasonably safeguard Personal Information. Even though we have taken and will continue to take significant steps to protect this information, please understand that no company, including us, can fully eliminate all security risks associated with Personal Information.

We use various security measures, including Transport Layer Security (TLS) encryption technology, to protect information collected, transferred and retained. If you elect to set up an account on the Sites, you will be asked to provide an email address and password. You must provide a valid email address and password in order to create and maintain an account, as well as to access account information. We recommend you select a password with at least 8 characters and consider adding numbers or special characters to further strengthen your password. In order to help protect your personal information, you should be careful about providing your password to others and change it periodically. If you wish to update a password or learn more about how we safeguard your information, or if you become aware of any loss, theft or unauthorized use of a password, please contact us at privacy@truereligion.com.

Please be aware that we may store Personal Information or such information may be included in databases owned and maintained by our affiliates, agents or third party service providers or partners. We take commercially reasonable steps to protect the security and confidentiality of all Personal Information provided from loss, misuse, unauthorized access, inadvertent disclosure, alteration and/or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Sites may not always be secure. Please keep this in mind when disclosing any Personal Information via the Internet or by email.

We do not, and will not, at any time, ask you to provide your Personal Information in a non-secure or unsolicited email or telephone communication. Identity theft and the practice currently known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is one of our priorities. If you receive such an email from someone impersonating True Religion, please contact us to bring it to our attention. For more information about phishing, visit the Federal Trade Commission at http://www.consumer.ftc.gov/articles/0003-phishing.

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What Choices Do I Have Regarding my Personal Information?

You have several choices available when it comes to your Personal Information. We will honor the choices you make regarding your Personal Information. If you have created and maintained a User Account on the Sites, you will be able to sign in and update your account (including contact) information. You may also write to us at the address provided herein, or:.

Limit the Personal Information You Provide: You can use the Sites and limit the Personal Information you provide either by disabling cookies or by not registering an account with us. If you choose to limit the Personal Information you provide and/or to disable cookies, you may not be able to use certain functionalities of the Sites. For instance, in order to purchase goods and services on the Sites, payment and shipping information must necessarily be provided.

Manage your Subscription Preferences: We may send you information by email or text message. If you provide your mobile phone number and ask to receive information by text message, we may provide information in that manner. Additionally, we may send automated text messages (if you consent). Where you consent to receive automated text messages from us, please note that your consent includes consent to receive both autodialed and/or pre-recorded telemarketing text messages or non-automated messages from or on behalf of True Religion and its affiliated companies at the telephone number you provided. You further understand that consent is not a condition of purchase and that message and data rates may apply. Additional terms and conditions, including message frequency, are provided at sign-up for any automated messages.

Use the “Unsubscribe” Hyperlink: For email marketing, you will have an opportunity to change your subscription preferences by clicking on an "unsubscribe" hyperlink contained in all promotional emails sent by us or on our behalf. Please note that while we honor all subscription requests as timely as possible, it may take up to ten business days to become effective. Please be aware that even if you opt-out of receiving future promotional communications, you may,if you utilize the eCommerce features of the Sites, still be sent certain transactional communications related to the purchase or shipment of items purchased. Thus, if you order online, we will send you an email confirming your order and may need to contact you by phone, email or regular mail if we have questions about your order. Additionally, an opt-out will not remove you from messages that we are required to send under relevant laws or regulations. You may ask us not to contact you by text message at any time by responding to a text message after it is received. For automated text messages, you will have the opportunity to opt-out by replying "STOP" to any message received. Please note that you hereby consent to receiving a confirmatory message in response to any opt-out request.

Social Media & Other Public Platforms: You may also manage the sharing of certain Personal Information with us when you connect with us through a social media platform or application. Please refer to the privacy settings of the social media website or application to determine how you may adjust your permissions and manage the interactivity between us and your social media platform(s) or application(s). That said, we want you to be aware that when you post information to public forums, including publicly viewable social media platforms, that information will become available to all who access such platform pages. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.

Third Party Advertisers: We may use advertisers, third party ad networks, and other advertising companies, to serve advertisements on our Sites and on third-party websites or devices. Please be advised that such advertising companies may gather information about your visit to our Sites (such as through cookies, web beacons and other technologies) to enable such advertising companies to market products or services to you, to monitor which ads have been served to your browser and which web pages you were viewing when such ads were delivered. If you would like more information about this practice and to know your choices please visit http://www.networkadvertising.org/managing/opt_out.asp or http://preferences.truste.com/truste/.

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What Happens When I Link To or From Another Web Site?

The Sites may contain links to other websites not operated or controlled by us (the "Third Party Sites"). The policies and procedures set forth herein do not apply to any Third Party Sites. The owners and operators of all Third Party Sites are responsible for all Personal Information provided, collected, maintained, stored, or otherwise disclosed on those sites, if any. The links on the Sites do not imply that we endorse or have reviewed the Third Party Sites, including their privacy policies, if any. We strongly encourage contacting those sites directly for information on their privacy policies.

If you have accessed the Sites through a link from certain of our advertising or marketing partners, the Sites may include a frame of the applicable advertising or marketing partner. Nevertheless, the information you provide to us through these framed Web pages is collected by us, and our use of such information is governed by this Policy.

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How Do We Respond to Do Not Track Signals?

Please note that our Sites do not support "Do Not Track" browser settings and do not currently participate in any "Do Not Track" frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal or non-personally identifiable information.

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Is Information Collected From Children?

The Sites are not directed at nor intended for use by children. We do not knowingly collect or intend to collect Personal Information from anyone who is under the age of 13. If you are under the age of 13, you should not provide any Personal Information to us and you should use the Sites only with the knowledge, permission and involvement of a parent or guardian. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Policy by instructing their children never to provide Personal Information through the Sites without parental consent. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us and we will endeavor to delete that information from our databases.

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HOW LONG DO YOU KEEP MY DATA?

We retain Personal Information for as long as needed or permitted for the purpose(s) for which we obtained it, and as consistent with applicable law. The criteria used to determine our retention periods include:

• How long the Personal Information is needed to provide our products and operate our business;
• The type of Personal Information collected;
• How recently you made a purchase from us;
• Whether you have an account with us;
• Whether we are legally or contractually required to maintain your information for a certain period of time; and
• Whether retention is advisable in light of legal considerations (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

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What If I Access the Sites from Outside of the United States?

Please note that by using the Sites or otherwise engaging with us you will be sending information (including Personal Information) to the United States where our servers are located. We will hold and process your Personal Information in accordance with privacy laws in the United States and this Policy. Please note that privacy laws in the United States may not be the same as, and in some cases may be considered less protective than, privacy laws in other countries. Therefore, by providing your Personal Information, you consent to the use of your Personal Information for the uses identified in this Policy and to the transfer of your Personal Information to the United States as indicated above. Any transfer of U.K. or E.E.A. consumer data to the United States is done according to the established Standard Contractual Clauses for international data transfers. Additional detail can be obtained by contacting us using the contact details in the “Contact Us” section.

You may also have additional privacy rights based on your country’s privacy laws. For example, Canadian law includes a right to request access to Personal Information, as well as a right to correct incomplete or incorrect Personal Information. U.K. or E.E.A. resident rights include the right to:

• request access to Personal Information we hold about you;
• correct your Personal Information when incorrect, out of date or incomplete;
• request that we erase your Personal Information;
• opt out of any marketing communications that we may send you and to object to us using / holding your Personal Information if we have no legitimate reasons to do so;
• request that we restrict the processing of your Personal Information;
• withdraw your consent at any time; and
• port your Personal Information (i.e., ask for a copy of your personal data to be provided to you, or a third party, in a digital format).

All such requests should be made to True Religion using the contact details below. Please be advised that if you request that your Personal Information be deleted, you may no longer be able to access or use certain parts of the Sites. By accessing your personal account on the Sites, you may at any time modify or delete personal details such as name, surname, address, country of residence, and credit card details. You may also delete your personal account at any time.

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How Will I Be Informed About Changes Regarding This Policy?

The Sites and our business may change from time to time. As a result (and for other business and/or technological reasons), it may be necessary for us to make changes to this Policy. We reserve the right to update, change, amend or modify this Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Information.

If we make any material changes to this Policy (as determined by us), we will post a notice on the Sites notifying users of the changes and may provide an opportunity for you to take action relative to those changes prior to their implementation, if appropriate. In some cases, we also may send an email notifying registered users of upcoming changes.

This Policy was last updated on the date indicated above. Your continued use of the Sites after any changes or revisions to this Policy become effective shall indicate your agreement with the terms of such revised and then-current Policy.

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COMPLAINTS

If you have any concerns about our use of your Personal Information, please contact us using the methods in the “Contact Us” section below so we can help make it right. If you are unhappy about how we resolve your issue, you also have the right to complain to your local privacy regulator. In the U.K., the regulator is the Information Commissioner’s Office (www.ico.org.uk), which you can call at 0303 123 1113.

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Contact Us

For additional information regarding our privacy practices or to exercise any of your privacy rights, please contact us via email at cs@truereligion.com.

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