PRIVACY POLICY

Last updated: January 10, 2020

Retail Success, LLC ("us", "we", or "our") operates the LuLaRoeBless.com website and the Bless mobile application (the "Service").

This Privacy Policy applies to our collection and use of information from all users of our Services and is incorporated into our General Terms of Service. Please note, this Privacy Policy does not address the privacy practices of Third Parties, including those with whom we may share information as set forth below. Please review the privacy policies of any Third Parties before you enter into agreements with them for Services.

We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Information Collection And Use

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your email address, name, phone number, postal address, other information ("Personal Information").

We collect this information for the purpose of providing the Service, identifying and communicating with you, responding to your requests/inquiries, servicing your purchase orders, and improving our services. All of the Information that we collect is necessary to complete the transaction.

We do not sell, rent, or otherwise provide your data to third parties for marketing use, other than as set forth herein. We provide your data to LuLaRoe, LLC, and its affiliates, for marketing and promotional use.

Log Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics. When you access the Service by or through a mobile device, this Log Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Service's functionality. These third party service providers have their own privacy policies addressing how they use such information. Please see the section regarding Location Information below regarding the use of your location information and your options.

Location Information

We may use and store information about your location depending on the permissions you have set on your device. We use this information to provide features of our Service, to improve and customize our Service. You can enable or disable location services when you use our Service at anytime, through your mobile device settings.

Cookies

Cookies are files containing small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and transferred to your device. We use cookies to collect information in order to improve our services for you.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie.

If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.

Do Not Track Disclosure

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

How we Share Information with Third Parties

We reserve the right to use and disclose anonymous information to third parties, at our discretion. Except as limited below, third parties may use information we share with them for any purpose for which we may use such information. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and in accordance with this Privacy Policy, and we may not obtain your consent to share with these parties.

We may provide information, including personal information of registered users to third party service providers that work on behalf of or with us to provide some of the aspects of our services, to help us communicate with you, or provide you with ancillary services offered by such service providers and referral partners. We may also receive information about you, including personal information, from our third-party service providers and referral partners. However, these service providers and referral partners do not have any independent right to disclose this information (except to the same extent we would have a right to disclose that information under this Privacy Policy).

You hereby agree that we may share some or all of your personal information with LuLaRoe, Merchants, vendors, suppliers, subsidiaries, joint ventures, or other related companies under common control with us (collectively, "Affiliates"). You also agree that we may share information with those third-party companies with which we have partnered to create and provide Services (Third Parties). To the extent possible, we will require our Affiliates and Third Parties to comply with this Privacy Policy where they do not have a published Privacy Policy of their own. If our company or some or all of our assets are acquired by another company, any personal or other information we possess may be a part of the assets transferred, and that company will possess any rights granted to us under this Privacy Policy.

Specific to the Services and as required to perform the Services, we will, on an ongoing basis share information with LuLaRoe, LLC. We are a vendor of LuLaRoe, LLC. In support of LuLaRoe, LLC's effort to comply with state sales tax agreements which require the payment of sales tax on behalf of Merchants by LuLaRoe, LLC. and Federal Trade Commission guidance, which strongly recommends that as a direct selling company, LuLaRoe provides a highly retail focused model for their independent businesses retailers to follow. The Bless Software and related Services allows LuLaRoe the technical capability to have visibility on actual Retail Profits, and Retail Sales, and in the future utilize the data to move towards a bonus structure based solely on Retail Sales. FTC guidance also recommends the retention of sales data for a period of years by LuLaRoe.

In addition to LuLaRoe, we may share information with Squire & Company, PC for purposes of sales tax calculations, and others as necessary to facilitate delivery of Services. Other services we share information with include: Exigo for handling of the inventory system, Shipping Easy for shipping and order fulfillment, Amazon AWS for Development Environments, Mailchimp for Email Marketing, and Stackify for Error Monitoring. Merchants may have cached information from customers on their mobile devices. Merchants you have done business with will still have access to data.

Finally, in extraordinary circumstances, we may share any personal or other information we possess when necessary or appropriate to: comply with the law; cooperate with law enforcement or national security requirements; respond to lawful requests; comply with law or credit card rules; protect the rights of Retail Success, other Merchants or customers, and third parties; or to investigate violations of or to enforce our Terms of Service. However, in doing so, we may: (i) dispute demands for release to the extent we believe, in our sole discretion, are unwarranted, illegitimate or overbroad; and (ii) when we determine that it is necessary or appropriate, we will notify you of any requests for release.

Business Transaction

If Retail Success, LLC is involved in a merger, acquisition or asset sale, your Personal Information may be transferred as a business asset. In such cases, we reserve the right to transfer this Personal Information, without advance notice to you, in order to continue providing uninterrupted Service. In the event that your Personal Information is transferred and/or becomes subject to a different Privacy Policy a notification will be provided in this Privacy Policy.

Security

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, loss, use, misuse, modification, or disclosure.

However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Only persons age 18 or older have permission to access our Service. Our Service does not address anyone under the age of 13 ("Children").

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children under age 13 without verification of parental consent, we take steps to remove that information from our servers.

Accessing, Correcting, and Deleting your Information

Retail Success does not own the data held on the Bless Software system or Services via our Licensing agreement with LuLaRoe. We have been authorized by LuLaRoe and you to collect the Personal Information because the information collected is necessary to complete the transaction contemplated when using the Service. We can only delete accounts at the request of LuLaRoe. Please consult LuLaRoe with any questions regarding this policy. In compliance with the CCPA, a customer of a Merchant may request to see the most recent twelve months of information that has been gathered or may request their information be obfuscated by contacting Retail Success using the contact information listed in the Contact section. Specific pieces of collected information may be requested or deleted in addition to all pieces of information. Identity must be verified before information may be requested or deleted. Information available to be viewed or deleted will vary based on the amount of verification that can be done for the requestor's identity. When identity has been verified, an Authorized Agent may be designated for future requests. An Authorized Agent is any individual other than the individual that the requested information refers to. Neither Merchants nor the customers of a Merchant will be discriminated against or face any form of punishment for requesting to view or delete any information. Information can only be obfuscated after 90 days have passed from the date of the transaction, in order to continue to facilitate returns of items. After information has been obfuscated, exact return will not be possible.

To verify your identity the following steps will need to be completed:

  1. LLR Home office or Retailer is to be contacted in regards to the purging of information.
  2. LLR Home office or Retailer will contact the Retail Success Support Team.
  3. Retail Success Support Team will confirm the email address on file.
  4. LLR Home office will send a confirmation email to the email address on file.
  5. Customer will confirm by responding to that email.
  6. LLR Home Office will contact Retail Success support team that Identity has been confirmed and that Retail Success may purge the information.
  7. Retail Success Development Team will purge the information requested.

Changes To This Privacy Policy

This Privacy Policy is effective as of April 07, 2017 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time without notice and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the terms of the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Contact Us

If you have any questions or concerns, please contact your Merchant who you have done business with or LuLaRoe Home Office at 951-737-7675. If you're a resident of California and wish to opt out of our sharing, please contact LuLaRoe Home Office. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. If we are unable to reach a resolution to the dispute, you and Retail Success will settle the dispute exclusively as set forth in the Terms of Use, which are incorporated herein by reference.

Contact Third Parties

Mailchimp Contact: personaldatarequests@mailchimp.com or use their contact form
AWS Contact: https://aws.amazon.com/contact-us/?nc1=f_m
Exigo Contact: (214) 367-9999 or sales@exigo.com
ShippingEasy Contact: (855) 202-2275 or help@shippingeasy.com