Effective Date: December 31, 2019.
Zulily Notice of Privacy Practices
Zulily respects your privacy and is committed to letting you know how we will collect and use your information. This Notice of Privacy Practices ("Notice") describes the privacy practices we follow in connection with the Zulily sites and mobile applications that link to it (collectively the "Sites"), as well as the related consumer services offered through the Sites. It also describes the options you have regarding our collection, use, and disclosure of your personal information when accessing the Sites.
By using our Sites and/or registering as a Zulily member, you are accepting the privacy practices described in this Notice and consenting to our collection, use and disclosure of your personal information as described below. If you do not agree with this Notice, please do not use the Sites. We reserve the right to modify the terms of these Privacy Practices at any time. We will post any changes to our website. Your continued use of our Sites following the posting of changes will mean you accept those changes.
- Information We Collect
- How We Use Your Information
- Interaction with Social Media
- Interest-Based Advertising
- Information You Share
- Information We Share
- Your Choices
- Accessing and Updating your Information
- Consent to Processing and Transfer of Information
- Data Security
- How to Contact Us
- California Privacy Practices
Information We Collect
Information you provide to us: Our services are offered on a members-only basis and focus on special deals and product offerings that may only be available for limited times and in limited quantities. In order to access and use the Zulily services, you must register through the Sites as a Zulily member and provide us with personally identifiable information, which includes your name, email address, physical address and phone number. You will also be required to create a Zulily password. This information allows us to authenticate your access to the Sites, keep you informed in a timely fashion of special deals and product offerings, and complete transactions you initiate. When you use our services, you may also provide payment account information (e.g., credit/debit card information, bank account number), photographs in which you may be recognized, and other information about yourself.
Information we collect automatically: We also collect information about your visit to and use of the Sites, such as your IP address and the location of your IP server, device IDs, device type, wi-fi connection information, general and precise geo-location data, product search history, type of browser and operating system used, date and time you access the services, pages you visit, and, if you came to the Sites from another website, the address of that website.
Information collected from other sources: We may collect information about you that we receive from other sources or from our offline interactions with you to, among other things, enable us to verify or update information contained in our records and to better customize services for you. We may also combine information we receive from third parties with the information we receive based on your use of the Sites and any other interactions with us.
How We Use Your Information
We may use the information we collect from you to:
- Provide content, products and services, including the operational, management, and billing support necessary to accomplish those business purposes
- Post content you provide to us
- Communicate about account or transactions and send information about features and enhancements
- Communicate about changes to our policies
- Personalize content and experiences, including providing recommendations based on your preferences
- Send offers or promotions for our products, services or special events
- Send offers or promotions for third-party products, services or special events
- Provide advertising including advertising based on your activity on the Sites or activity on third-party websites
- Administer contests, sweepstakes, promotions, or surveys
- Optimize or improve our products, services and operations
- Detect, investigate, and prevent activities that may violate our policies or be illegal
- Perform statistical, demographic, and marketing analyses of users of the Sites and their purchasing patterns
We may use the information from one portion of the Sites on other portions of the Sites, and we may combine information gathered from multiple portions of the Sites into a single record. We may also use or combine information that we collect offline or we collect or receive from third-party sources to enhance, expand, and check the accuracy of your customer records.
We may use your information in other ways not listed here, for which we will provide notice at the time of collection and as required by legal process.
Interaction with Social Media
We may include applications from third parties on this website or through our Sites, which allow interaction or content sharing by users. Some of these applications provide specific services or content from a third party, such as a Facebook "Share" or "Like" button, and are visible to you when you visit our Sites. Your interaction with these programs typically allows the third party to collect some information about you through cookies they place on your device and other tracking mechanisms. In some cases, the third party may recognize you through its cookies even when you do not interact with their application. If you choose to log in to your Zulily account with or through a social networking service, Zulily and that service may share certain information about you and your activities. We also may share information about your activities, including what you view and purchase on the Sites, with a social network, in accordance with your account settings with us or your social networking service, or with your permission. Please visit the third parties' respective privacy policies to better understand their data collection practices and controls they make available to you.
Zulily uses the information you make available to us when you interact with our Sites, content, or services to provide you with advertising and offers that are more relevant to you. We also partner with third party advertising companies to provide advertisements on our Sites and other Sites about goods and services that may be of interest to you, including advertisements for unaffiliated products and services on our Sites. The advertisements may be based on information collected through cookies, web beacons and other tracking technologies from our Sites, emails/communications and on other third-party websites you visit and mobile applications you use that participate in our advertising networks. These third parties may use persistent identifiers to track your Internet usage across other websites and mobile applications in their networks beyond these Sites. For information about how third parties may access your information, please see Information We Share below.
Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Sites or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms.
Information You Share
The Sites may allow you to connect and share your actions, comments, content, and information publicly or with other people you specify. You may also connect to and share your information on third party social media platforms, websites, applications, and services through "plug-ins," widgets, buttons, and other third party features on and connected with our Sites. You may also share with Zulily contact information of friends and people in your address book so that we can help you invite others to become Zulily members or let them know about special offers and help facilitate deliveries. Please be mindful of your own privacy needs and those of others as you choose with whom to connect, what you share with us and others, and what you make public. We cannot control the privacy of information you choose to make public or share with others. We also cannot control and are not responsible for any third party sharing services or their actions including the data that they collect from you and your device or how they use such data. Please review their privacy policies to understand their privacy practices.
Information We Share
We may share your information with third parties as described below:
- Affiliates. We may share your information with any related entities of Zulily ("Affiliates") that use and disclose your information for their purposes in ways consistent with this Notice.
- Service Providers. We may allow third parties who perform business services for us to access, store, and process your information in order to provide those services. Our service providers will not use your personally identifiable information for their own marketing or other business purposes without your consent.
- Business Partners. We may engage in activities that include sharing your information with business partners who provide products and services that we think may be of interest to you. In such instances, we will restrict our business partners' use of any information that personally identifies you to our joint marketing activities. To learn how to limit the sharing of your information for these joint marketing activities, go to the Your Choices section of this policy.
- Surveys/Sweepstakes/Promotions. In the event that you participate in a survey, sweepstakes, contest, or other promotion that is sponsored by Zulily and a third party, such participation serves as your consent for Zulily to share your information collected in conjunction with the survey, sweepstakes, contest or promotion, with that co-sponsoring third party. After the information is provided to such third parties, the subsequent use or disclosure of such information is subject to those third parties' privacy policies and practices.
- Legal Disclosures. We may disclose information, including information that personally identifies you, to: (i) protect or defend the legal rights, interests or property of Zulily and our Affiliates; (ii) protect the safety and security of our customers or members of the public; (iii) protect against fraud or for risk management purposes; or (iv) comply with applicable law or legal process. In addition, we may disclose or transfer your information in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, or any other transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company. Under such circumstances, we would, to the extent possible, require the acquiring party to follow the practices described in this Notice, as it may be amended from time to time. Nevertheless, we cannot promise that an acquiring company party or the merged company entity will have the same privacy practices or treat your information the same as described in this Notice of Privacy Practices.
We may share information about your visit to and use of the Sites, including browser or device information, with third parties, including our Affiliates, advertising networks, analytics providers and others who may use the data for any legally permissible purpose and without notice to you.
Personally Identifiable Information. Visitors to our Sites can choose not to provide the personally identifiable information needed to register as a Zulily member, however, they will not be able to use the Zulily services.
Emails and Other Communications. By becoming a member, you are requesting that we inform you about limited time and quantity deals and agreeing to receive communications from us, including promotional emails. If you would like to alter the frequency and type of communications you receive from us, you may do so at any time by updating the communication preferences specified in your Account Profile here, or by going to our website, and clicking on my account. If you no longer wish to receive promotional communications from us, you may do so by changing your preferences as noted above. Please note that this may affect your ability to access certain products and services, and we may continue to send non-promotional communications such as order confirmations, surveys, and other information about your transactions. If you refer others to us using our email functionality, please note that they may choose not to receive any promotional emails from us in the future by following the opt-out instructions in the email invitation. If you want to receive our emails, but do not wish for us to track the emails we send you, some email services allow you to adjust your display to turn off HTML or disable download of images that should effectively disable our email tracking.
Tracking. You also have choices to limit some tracking mechanisms that collect information when you use the Sites. Many web browsers automatically accept cookies, but you can usually modify your browser's setting to decline cookies if you prefer. If you choose to decline cookies, certain features of our website, including the Sites themselves, may not function properly or remain accessible to you. In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies. Note that if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences.
You may opt out of the collection and use of your information by some advertising networks as described in the Interest-Based Advertising section of this Notice.
You may opt out of tracking of analytics data by Google Analytics, one of our customer usage analytics providers, by clicking here.
You may choose not to share your precise geo-location information with us by adjusting the device's location services settings or the settings on our mobile applications.
Your browser or device may include "Do Not Track" functionality. Note that Zulily's information collection and disclosure practices, and the choices that we provide to customers, will continue to operate as described in this Notice, whether or not a Do Not Track signal is received.
Third Party Links. The Sites may contain links to other sites that Zulily does not own or operate. This includes links from advertisers, vendors, social media, co-branded sites, and other third parties. These other sites may send their own cookies to your device, they may independently collect data or solicit personal information and may or may not have their own published privacy policies. We do not control, recommend or endorse and are not responsible for these sites or their privacy policies or practices. This Notice of Privacy Practices only applies to the Sites and information collected by Zulily or its Affiliates.
Accessing and Updating your Information
You may access and update your account information at any time after signing in to the Sites by visiting your Account Profile here. To help us maintain accurate, current and complete information about you, please submit only true, accurate and complete information whenever you provide personally identifiable information to us, and promptly update your account whenever it changes. For additional assistance, please contact us in in the manner specified below.
We do not knowingly collect, use or disclose personally identifiable information from anyone under 16 years of age. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 16, we will make reasonable efforts to delete such information from our records.
Consent to Processing and Transfer of Information
Given that we are an international business, our use of your information necessarily involves the transmission of data on an international basis. If you are located outside of the United States, please be aware that information we collect may be transferred to and processed by servers located in the United States. By using the Sites, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States.
We employ certain administrative, technical, and physical security measures to help reduce the risks of loss, theft and unauthorized access associated with the information that is in our possession. We cannot, however, guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
How to Contact Us
If you have any questions or comments about this Notice or if you would like us to help you adjust your preferences, please contact us by email at firstname.lastname@example.org or call us at 1-877-779-5615.
If preferred, you may write to us at:
Attn: Privacy Inquiry
2601 Elliott Avenue, Suite 200
Seattle, WA 98121
California Privacy Practices
The California Consumer Privacy Act ("CCPA") provides new rights to California residents ("consumers"). This section ("CCPA Notice") explains how Zulily collects and uses the personal information of California consumers and how those consumers can exercise their rights under CCPA. This CCPA Notice will be updated every 12 months, or as needed to address changes in the law or our practices.
This CCPA Notice supplements our other privacy notices and policies and shall govern in the event of a conflict.
Note for non-members or prospective members. Please note that this CCPA Notice does not apply to human resources data or business-to-business communications data. If you would like information about human resources data or business-to-business communications data, please reach out to your contact at Zulily.
Collected personal information.
- Categories of personal information. Zulily may collect personal information about members and other users of our services who are California consumers including personal information within the following categories: identifiers (e.g. your name and other contact information, IP address and device ID); characteristics of protected classifications under California or federal law; commercial information (e.g. your order information, payment information and feedback information); internet or other electronic network activity information (e.g. your browsing history); geolocation data; audio, electronic, visual, or similar information (e.g. pictures and videos that you send to us, or recordings of your calls to our customer service centers); professional or employment-related information; inferences information (e.g. your interests, demographics and shopping preferences); and individual records (e.g. any other information that may identify or relates to you).
- Non-personal information. Zulily may also collect, generate or share deidentified or aggregate information. This is not personal information under CCPA and we reserve the right to convert, or permit others to convert, personal information into deidentified data or aggregate consumer information.
Sources of personal information. Zulily collects personal information from different sources.
- Personal information we collect from you.Zulily collects some personal information that you provide directly to us. This can include contact information, order information, payment information, communication information, feedback information, preferences information, pictures and videos that you send to us, and other information you provide to us. In addition, you may provide us with the personal information of other people if you invite others to become Zulily members or send a package to another person.
- Personal information we collect from cookies, pixels and similar technologies.Zulily or its vendors collect some personal information automatically from cookies, pixels and similar technologies when you use our services. This can include your browsing activities when you are on our Sites; information about devices that you use to access Zulily’s services; and other information collected through cookies, pixels, and similar technologies.
- Personal information we create.Zulily creates some personal information when you use our services. This can include analytics and inferences about your interests, demographics and shopping preferences.
- Personal information we collect from third parties. Zulily collects personal information from other companies. This can include updated address and shipping instructions information; credit information; information from advertisers; information from Facebook, Twitter and other similar platforms; personal information from third parties that supplements the personal information we already have.
Uses of personal information. Zulily uses personal information for the following business or commercial purposes:
- Account provision and maintenance, including creating and managing your account with Zulily; providing customer service; verifying member information; and providing other services in the course of Zulily’s business operations
- Product sales and fulfillment, including selling products; processing and shipping orders to you or to other people you designate; managing returns; processing refunds; managing any warranties
- Customer service and communications, including responding to requests, comments, or questions through emails, Facebook messenger messages, text messages, push notifications, telephone calls, postal mail, chat functions; providing interest-based advertising and other advertising, marketing and promotional content and messaging, managing and communicating through Zulily presences on social media platforms and other platforms; maintaining product review capabilities; reviewing recorded calls or content of other communications for quality or customer service purposes; responding to requests for information and taking action that may be requested under CCPA
- Improving services and user experience, including creating and updating applications, websites, and other features or functionality used by Zulily; debugging to identify and repair errors that may affect how the services function; engaging in analytics related to improving services or user experience
- Personalizing user experience and marketing, including targeted product display; targeted marketing and advertising through the services; marketing through emails, Facebook messenger messages, text messages, push notifications and other communications methods; re-targeted marketing and advertising across other websites, devices, and platforms; auditing related to the performance of Zulily’s advertising and marketing efforts; engaging in analytics to personalize user experience
- Fraud prevention and information security, including measures to verify identity when an account is used for ordering or when the account is otherwise accessed; detecting and responding to fraud or security incidents; protecting against other malicious, deceptive, or illegal activity
- Legal obligations, including prosecuting people responsible for fraudulent, malicious, deceptive or illegal activities; defending claims; notifying of product recalls or other issues related to products; enforcing and notifying of Zulily’s terms and conditions, notice of privacy practices and other policies and changes to such terms and conditions, notice of privacy practices and other policies
- Payment-related activities, including processing payments, evaluating payment options, managing Smart-pay and similar payment programs, and managing private label credit card programs
- Conducting research, analytics, surveys, and focus groups to improve member experiences, develop services and products, provide better marketing and advertising
- Product safety or quality activities
- Any other legal purpose consistent with our applicable notice of privacy practices.
Disclosures of personal Information.
- Sales of personal information. The concept of a "sale" under CCPA is different from what has traditionally been considered a "sale", e.g., selling a customer list for money. Under CCPA, a "sale" potentially includes other uses or disclosures of personal information to third parties outside Zulily in a commercial context (unless an exception to "sale" as provided by CCPA exists). Because the concept of "sale" is so broad under CCPA, Zulily may be deemed to "sell" the following personal information even though we may not disclose your personal information in exchange for money: identifiers; characteristics of protected classifications under California or federal law; commercial information; internet or other electronic network activity information; geolocation data; audio, electronic, visual, or similar information; professional or employment-related information; inferences information; and individual records.
- Disclosures for business purposes. Please note that Zulily may share your personal information with vendors that help us fulfill your transactions and provide other services to us. Examples of these vendors include payment processors, fraud prevention services, and shippers. We do not treat these disclosures as sales. Zulily may disclose the following personal information to our vendors: identifiers; characteristics of protected classifications under California or federal law; commercial information; internet or other electronic network activity information; geolocation data; audio, electronic, visual, or similar information; professional or employment-related information; inferences information; and individual records.
- Right to delete personal information. If you are a California consumer, you have the right to request that Zulily delete any personal information about you that Zulily has collected from you. Note that Zulily may retain some personal information, as permitted under CCPA.
- How to exercise right of deletion: If you are a California consumer, you may exercise your right to request deletion of your personal information by clicking here or by emailing CCPA.email@example.com. In order to verify your identity, you must enter the email address and password associated with your Zulily account. There is no reasonable method by which Zulily can verify the identity of a consumer who does not have a Zulily account.
- Right to opt-out of sales. Zulily may sell certain personal information that Zulily has collected about you as described in the "Sales of personal information" section above. If you are a California consumer, you have the right to opt-out of some sales of your personal information.
- Right to receive a copy of your personal information and other information. If you are a California consumer, you have the right to request that Zulily disclose to you the following information:
- The categories of personal information Zulily has collected about you.
- The categories of sources from which the personal information about you is collected.
- The business or commercial purpose for collecting or selling personal information about you.
- The categories of third parties with whom Zulily shares personal information about you.
- The categories of personal information Zulily sold about you and the categories of third parties to whom the personal information about you was sold.
- The categories of personal information Zulily disclosed about you for a business purpose.
- The specific pieces of personal information Zulily has collected about you.
- How to exercise right to receive a copy of personal information and other information: If you are a California consumer, you may exercise your right to request a copy of the information described under this "Right to receive a copy of personal information and other information" section by clicking here or by emailing CCPA.firstname.lastname@example.org. In order to verify your identity, you must enter the email address and password associated with your Zulily account. There is no reasonable method by which Zulily can verify the identity of a consumer who does not have a Zulily account.
- Right to non-discrimination. If you are a California consumer, you have the right that a business shall not discriminate against you because you exercised rights under CCPA. However, we reserve the right to provide loyalty programs and other differential pricing and services as permitted by CCPA, which will be subject to applicable terms and conditions of such programs.
Limitation of rights; compliance with applicable law. Notwithstanding anything to the contrary in this CCPA Notice, we may collect, use and disclose personal information as required or permitted by applicable law and this may override CCPA rights. In addition, we need not honor any requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
California's "Shine the Light" law. If you are a California resident, California law gives you the right to request a list of all third parties to which Zulily has disclosed your personal information (as defined by CA Civil Code § 1798.83) for those companies’ direct marketing purposes. California consumers who wish to request further information about the entities with which we have shared their personal information, if any, should email us at email@example.com and place "California Shine the Light Request" in the subject line.