Privacy Policy

CPO Commerce, Inc. ("CPO") operates the websites located at www.cpooutlets.com and other websites on which a copy of this privacy policy appears (cumulatively the “CPO Sites”) as a service to its customers residing in the United States of America, its territories and possessions. CPO is the owner or authorized user of the content displayed on the CPO Sites.

CPO has adopted this privacy policy to inform you of the following:

  • How we collect information on the CPO Sites.
  • The types of information we collect on the CPO Sites.
  • How we use information we collect.
  • The circumstances under which CPO may disclose information gathered on the CPO Sites to third parties.
  • The choices available to you on the CPO Sites regarding the collection and use of your information.
  • Security procedures that we have put in place to protect your Personal Information.

For the purposes of this privacy policy, “Personal Information” is personally identifiable information about an individual person, as more particularly described under applicable privacy laws. You should carefully review this privacy policy before using the CPO Sites.

If you have questions or concerns regarding this privacy policy or the CPO Sites, you should contact us (see section 12).

1. Policy Scope

This privacy policy applies to your use of the CPO Sites and CPO’s treatment of information, including Personal Information, collected by or on behalf of CPO through the CPO Sites. Your use of linked or associated websites, or websites to which you may be directed, may be subject to different or additional terms, notices and policies, and such terms, notices and policies shall control as to those websites. For information regarding the collection and use of information on any of those websites or other third party sites, please refer to the terms of use and policies provided by those websites.

NOTE: THIS PRIVACY POLICY DOES NOT APPLY TO INFORMATION YOU PROVIDE, EITHER VOLUNTARY OR INVOLUNTARILY, THROUGH RESPONSES TO SOME SURVEY REQUESTS INITIATED AT THE CPO SITES. SOME OF THESE SURVEYS ARE CONDUCTED BY YAHOO! INC. AND OTHER THIRD PARTIES. SUCH INFORMATION WILL BE GOVERNED BY THE APPLICABLE PRIVACY POLICY(IES) OF YAHOO! INC. OR OTHER THIRD PARTIES.

2. Our Information Collection Practices

Automatically Collected Information. When you visit the CPO Sites to place an order, browse, read, or download information, we may automatically collect and store the following types of non-personally identifiable information:

  • Information collected as server logs from information provided by your browser.
  • Click-through statistics.
  • Your IP address.
  • The type of web browser you are using to access CPO Sites.
  • The type of operating system you are using.
  • The name of the domain and host from which you access the Internet.
  • The date and time you access CPO Sites.
  • The Internet address of the sites from which you linked directly to CPO Sites.

Personal Information Provided Voluntarily by the User. You can use portions of the CPO Sites without providing any Personal Information. However, in order to take advantage of the full capabilities of the CPO Sites and to obtain access to, and use of, many of the features found on the CPO Sites, including placing orders for products offered for sale on the CPO Sites and receiving CPO e-mail exclusives, you must provide certain Personal Information. You may also provide Personal Information when you participate in various services and offerings on the CPO Sites. Personal Information may include, without limitation:

  • Your name, mailing address, email address, telephone number, fax number, billing information, and credit card number and related information.
  • Information concerning your interests, occupation, product use and preferences.

You may also be asked to respond to additional questions to help us meet your needs. Certain functionalities on the CPO Sites, such as the “Email This Page to a Friend” feature, may require you to provide information regarding third parties. Similarly, if you request that an order or gift be sent directly to an individual other than yourself, you will also be asked to submit information about the recipient of the order or gift. This information may include a third party’s name, address, phone number, fax number, email address, and other similar information.

3. Information Warranty

If you do provide Personal Information through the CPO Sites, including Personal Information regarding individuals other than yourself, you warrant that (i) you have the authority to provide that Personal Information and to grant CPO the right to use such Personal Information consistent with this privacy policy, (ii) you have provided that Personal Information voluntarily, and (iii) you consent to the use of that Personal Information consistent with this privacy policy.

4. Use and Disclosure of Information

Use of Automatically Collected Information
. Information collected automatically through the CPO Sites provides us with information regarding your use of the CPO Sites, including which pages are the most popular with CPO Sites users. That information also allows us to determine if the CPO Sites are working properly and to make changes to the CPO Sites to allow the user to have a better experience on the CPO Sites. We do not use that information to identify a particular user.

We may aggregate and use certain non-personally identifiable information for research or marketing purposes and may share, sell and rent or trade that information and statistical information derived therefrom with our marketing partners, advertisers, or other third parties.

Use of Non-personally Identifiable Information Provided Voluntarily by the User. By remaining opted in to our e-mail list, you are acknowledging that we may sell, rent, share, trade or otherwise provide or transfer your non-personally identifiable information such as demographic and occupational information to third parties. Such third parties may use such information for whatever purposes they wish or may transfer such information to other third parties.

Business Uses of Information. CPO uses Personal Information you provide to us for internal business purposes, such as (i) for verification at login as a registered user, if applicable; (ii) for marketing purposes; (iii) to contact you regarding the products or services that you have ordered or requested and to provide the same; (iv) for fulfillment of promotions, including but not limited to sweepstakes, contests or subscriptions that you have entered; (v) to process and ship orders; (vi) to send order and shipping confirmations; (vii) to provide customer service, respond to your requests and inquiries and enhance product and service offerings; (viii) to keep records regarding orders, returns and exchanges; (ix) to protect both you and us against error and fraud; (x) to send information, product and service alerts and exclusive offers; (xi) to record usage of the CPO Sites; (xii) to adjust the CPO Sites to your personal preferences; and (xiii) to customize advertising and CPO marketing information regarding our products and services. We may also exchange information, including Personal Information, with other companies and organizations for credit fraud protection and risk reduction.

Service Providers and Vendors. We may also share your Personal Information with certain third parties that perform services for CPO. Those third parties may host the CPO Sites, operate certain features on the CPO Sites, print or send mailings, provide marketing materials for the CPO Sites, authorize and process your payments, provide customer service, analyze data and assist in fulfilling your orders, send e-mails on CPO’s behalf, or otherwise assist CPO with the operation of the CPO Sites. Those third parties are not authorized to use or disclose your Personal Information for any purpose other than to perform the services designated by CPO. Business Transfers. Automatically collected information and your Personal Information may be transferred as an asset in connection with a merger or sale involving all or part of CPO or as part of a corporate reorganization, stock sale or other change of control.

Required Disclosures. CPO may also provide your Personal Information to a third party if CPO in good faith believes that access, use, preservation or disclosure is reasonably necessary to satisfy any applicable law, regulation, legal process or enforceable government request. For example, CPO may be required to disclose your Personal Information to respond to a subpoena, court order or other legal process.

5. Consent to Processing and Transfers of Information

CPO may transfer information that you send to us, including, without limitation, Personal Information, to recipients in countries that do not provide the same level of legal data protection as the country from which you access the CPO Sites. By using the CPO Sites, you consent to those transfers and to the processing by CPO of that information.

6. Notice for Parents

The CPO Sites are considered to be general audience Sites and are not to be used by children. CPO does not sell products that are intended for children and does not intend to collect Personal Information from individuals under the age of eighteen (18). If you are the parent or guardian of a child who has provided personal information to us, please inform us as provided under Section 12 below, and we will delete that Personal Information.

7. Use of Cookies

Cookies are pieces of information that are transferred from websites to your computer’s hard drive and they may serve a variety of purposes. Web beacons, flash cookies and other similar technologies may also be used for these purposes. For example, cookies “remember” you when you return to a website and make your experience more user-friendly. Cookies identify which web pages are visited and how often. Cookies are also used to allow companies to better understand how their websites are used to improve their services CPO uses cookies to store information about your visit to the CPO Sites in order to enhance your visit to the CPO Sites. For example, storing that information will allow us to, on occasion, customize account pages for you.

Types of cookies, how they’re used, and the potential impact if disabled:

TYPE

PURPOSE

POTENTIAL IMPACT IF DISABLED

Session Cookies

Used to support website functionality

Access to website content and features may be limited

Preference Cookies

Used to remember user preferences from one visit to the next

Preference will need to be reset on each visit to the website. This may also disable the ability have websites “remember” you at time of login

Advertising Cookies

Used to serve you advertisements that may be relevant to you and your interests

Advertisements will still be displayed but will be more random and may be less relevant to you and your interests

Security Cookies

Used as a component of a website’s general security and user authentication processes

Access to website and features may be limited



In addition, we currently contract with several online partners to help manage and optimize the CPO Sites. We use the services of a marketing company to help us measure the effectiveness of our advertising and how visitors use our sites. To do this, we use Web beacons and cookies provided by our marketing company on the CPO Sites. The type of information we collect includes which pages are visited, which products are put into the shopping cart, which orders enter the checkout process, which checkouts are executed with payment, etc. By supplementing our records, this information helps us learn things like what pages are most attractive to our visitors, which of our products most interest our customers, and what kinds of offers our customers like to see. Although our marketing company manages the information coming from our sites on our behalf, we control how that data may and may not be used. If you do not want to help us learn how to improve our sites, products, offers and marketing strategy, you can “opt-out” of our ability to analyze such data by contacting us (see Section 12).

8. Security

CPO and authorized third parties employ reasonable measures, including administrative, technical, and physical measures, to protect your Personal Information from unauthorized access, loss, alteration, use or disclosure. For example, any Personal Information you enter when you place an order for a product, including, without limitation, your credit card and other Personal Information, is encrypted before transmission to CPO Sites servers by using Secure Sockets Layer 128-bit encryption, if supported by your browser. In addition, we use reasonable measures to limit the disclosure of your Personal Information consistent with this privacy policy. However, your Personal Information can never be 100% secure: information may be transmitted over networks without appropriate security measures and may be accessed, deleted, altered, used or disclosed by unauthorized persons. You can help us to protect your Personal Information by (i) not sharing your password or other account information with others, (ii) using a secure web browser, and (iii) changing your password frequently.

9. Managing Your Information

CPO reserves the right to retain any Personal Information reasonably necessary to appropriately document its business activities and for archival and record retention purposes. We will store your Personal Information for as long as reasonably necessary for the purposes described in this privacy policy. You may find out more details regarding this privacy policy by contacting us (see Section 12).

To Stop Certain Collection and Use of Your Information:

Marketing Email, Texts, and Mail. You may “opt-out” of receiving future e-mail or other communications from us by clicking the “unsubscribe” link at the bottom of any e-mail that you receive from us, or by contacting us (see Section 12). Please note that removal of your Personal Information from our database or “opting-out” will not stop (i) marketing or advertising content that is ready to be mailed or is queued for transmission to you prior to the time when we can implement your request, or (ii) the use of your Personal Information by third parties with whom CPO may have already shared your information.

Interest Based Advertising

Some of our websites support Interest Based Advertising efforts by Third Parties. Industry groups such as the Digital Advertising Alliance have developed services to help you manage your Interest Based Advertising preferences

Website Analytics

You can opt-out of tracking used to understand website utilization provided by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

Do Not Track

Some browsers have a “Do Not Track” feature that lets you send a request to websites to not track your online activities. We, like many other retailers, do not honor those requests

To Change or Correct Your Information:

At any time, you can request access to your personal information, request that any inaccuracies be corrected, or request that comments or explanations be added to records about you. You may contact us with changes as described in Section 12. To prevent unauthorized changes, we may ask for certain information to verify your identity before we process such requests.


10. Updates and Changes to Policies

CPO may change this privacy policy from time to time by posting updated versions of the privacy policy here. As we may make changes to this privacy policy at any time without notifying you, we suggest that you review this privacy policy each time you access or use the CPO Sites. Please note that our rights to use your Personal Information will be based on the privacy policy in effect at the time the information is collected.

11. Customer Specific Disclosures
a. Contract Customers

If you are a contract customer and would like to opt-out of receiving promotional postal mail and/or email from us, please notify your Account Manager. You may still receive promotional postal mail or email from other affiliated companies and Third Parties if they have received your email or postal address from other sources or as a result of their own transactions or experiences with you. You will also continue to receive promotional postal mail or email if you request to hear from us again.

b. Nevada Residents

Under Nevada SB 220, Nevada residents may submit an opt-out request regarding the sale of their Personally Identifiable Information (PII) collected through a website or online service.Where applicable, you may submit your request to Opt-Out of the sale of Personal Information to Third Parties by submitting an online request at: Do Not Sell My Personal Information

c. California Residents 1. California Shine the Light Law

Under California Civil Code sections 1798.83–1798.84 California residents may request the names and addresses of affiliated companies and categories of Personal Information we share for their direct marketing purposes. If you are a California resident and would like to make such a request, please Contact Us 2. California Consumer Privacy Act of 2018

California residents have the following rights:

  1. The Right to Disclosure
    1. About information collected
    2. About information sold
      1. Categories of personal information sold
      2. Categories of Third Parties with whom the personal information was sold
    3. The Right to Deletion of Personal Information
    4. The Right to Opt-Out of the sale of Personal Information to Third Parties
    5. The Right to Sue for Security Breaches
    6. The Right to not be Discriminated Against Based on Exercising any of the Above Rights

California residents may submit a Data Disclosure or Deletion request by:

  1. Submitting an online request here: Data Disclosure or Deletion Request
  2. Submitting a phone request by calling 1-866-577-3014

Where applicable, you may submit your request to Opt-Out of the sale of your Personal Information to Third Parties by:

  1. Submitting an online request here: Do Not Sell My Personal Information
  2. Clicking the “Do Not Sell My Personal Information” button on our applicable website

Unless indicated with a “Do Not Sell My Personal Information” button on our websites, we do not sell Personal Information as defined by the California Consumer Privacy Act (CCPA).

We will take reasonable steps to verify your identity prior to fulfilling the above requests.

Authorized Agents may submit requests on behalf of a California resident using the above processes and providing the appropriate documentation.

The following section describes:

  1. Categories of personal information we collect
  2. The purpose for which the personal information is collected
  3. Specific personal information collected
  4. Categories of sources from which that information is collected
  5. Categories of Third Parties (who are not classified service providers) with whom the information may be shared
  6. The purpose for selling or sharing of personal information

Categories of Personal Information as defined by CCPA

Do we collect this type of Personal Information?

Purpose of collecting the Personal Information

Specific Personal Information that may be Collected

Categories of Sources from which the Personal Information is Collected

Is this category of Personal Information shared with Third Parties?

Categories of Third Parties with which the Personal Information may be Shared

Purpose of Selling or Sharing Personal Information

Can you opt-out of this Sharing?

Identifiers

Yes

To uniquely identify an individual in support of business activities

Names, Account ids, emails, addresses, IP Addresses, Device Identifiers, Loyalty Program Ids, Tax Exempt Numbers

From you, From Marketing Firms

Yes

Marketing Partners

Marketing

Yes

Commercial Information

Yes

To support business transaction

Quotes, Sales Transactions,

Your transactions with us

Yes

Marketing Partners

Marketing

Yes

Biometrics

In limited circumstances

Fraud Protection

Behavioral biometrics and device usage

From you

No

N/A

N/A

N/A

Network Activity

Yes

(if you access our websites or mobile apps)

To allow access to and optimize our websites

Access to our properties

From you

No

N/A

N/A

N/A

Geolocation Data

Yes

(if you access our websites or mobile apps)

Personalization and Store Locations

Unique Identifiers and your location and ZIP code

From you and your devices

No

N/A

N/A

N/A

Recordings (e.g. audio, visual)

Yes (if you call customer service or visit a store using closed circuit TV)

Customer Service, Fraud Prevention

Voice and CCTV Recordings

From you

No

N/A

N/A

N/A

Professional or Employment-Related Information

Yes

For employment and credit purposes

Employment History including Companies and Job Titles

From you

Yes

Prior Employers and Background Check Services

Employment Background

No

Education Information

Yes

For employment and credit purposes

Educational History including Schools and programs

From you

Yes

Verification Services

Employment and Credit Verification

No

Inferences

Yes

Personalization

Product Affinities

From you and external data sources

In limited circumstances

Marketing Partners

Marketing

Yes

d. Canadian Residents

We consider "personal information" to be information about an identifiable individual. We do not consider public information found in directories and listings, or business names, addresses and/or contact numbers to be personal information. 

We have adopted, as Company policy, the 10 personal information privacy principles stated in the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information. The 10 principles are:

  1. Accountability
  2. Reason for Collection
  3. Consent
  4. Limiting Collection
  5. Limiting User, Disclosure and Retention
  6. Accuracy
  7. Safeguards
  8. Openness
  9. Individual Access
  10. Challenging Compliance

Interest Based Advertising

Some of our websites support Interest Based Advertising efforts by Third Parties. In Canada industry groups such as Digital Advertising Alliance of Canada have developed services to help you manage your Interest Based Advertising preferences.

e. European Union (EU) Residents

CPO Commerce and its affiliated companies are based in the United States (U.S.) and the information CPO Commerce and its service providers collect is governed by U.S. law. If you are accessing the Services from outside of the U.S., please be aware that information collected through the services may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the services or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Notice. 

As residents of the EU, you will have certain additional rights with respect to your Personal Data under the General Data Protection Regulation including:

  1. The right to be informed.
  2. The right of access.
  3. The right to rectification.
  4. The right to erasure.
  5. The right to restrict processing.
  6. The right to data portability.
  7. The right to object.

Interest Based Advertising

Some of our websites support Interest Based Advertising efforts by Third Parties. In Europe industry groups such as European Interactive Digital Advertising Alliance have developed services to help you manage your Interest Based Advertising preferences.

We will retain your EU Personal Information for as long as your account is active, as needed to provide you services and to fulfill the purposes for which the data was collected, and as necessary to comply with our legal obligations and fulfill our business needs.

12. Contact CPO

If you have questions regarding the CPO Sites, the privacy policy or your privacy on the CPO Sites, you can send a request with any further questions to our Customer Service Department by e-mail to privacyteam@cpocommerce.com or by mail at:

CPO Commerce
P.O. Box 50768
Pasadena, CA 91115
Phone: 1-800-955-0039

Upon receiving a written request, we will contact you directly, investigate your request, and work to address your concerns. We will respond to your request without undue delay. We reserve the right to take reasonable steps to verify your identity prior to granting access or processing changes or corrections.

Privacy Notice Updates 

This Privacy Statement may change from time to time, and we will post on our websites any updated Privacy Notice. Recent changes to the Privacy Notice are documented below. Each version of this Privacy Notice will be identified by its effective date displayed at the top of this Privacy Notice. 

Effective December 31, 2007

Updated January 01, 2020. Added. California Consumer Privacy Act (CCPA) rights. Expanded Customer Specifics Disclosures section.