Allswell Privacy Policy

Updated July 1, 2020

We recently updated our Privacy Policy.

Updates include:

Clarifying our sources of personal information
Updating the description of rights available to California consumers under the California Consumer Privacy Act

This Privacy Policy explains how Altitude Collection, LLC (“Allswell”) collects, uses, and shares your personal information. (“Personal information” is information that identifies you or that can reasonably be linked to information that identifies you.) This policy applies when you visit any website (https://allswellhome.com/) or any, official social media sites, or other online properties where this policy is posted (collectively "Sites"). Allswell recognizes that you care about how your information is used, and your privacy is important to us. This Privacy Policy explains the choices you can make about what information we share. Please read this Privacy Policy carefully.

CHANGES TO THIS PRIVACY POLICY

We ask that you read this Privacy Policy from time to time. Allswell may modify this Privacy Policy at any time in its sole discretion. If we make material changes to this Privacy Policy that increase our rights to use personal information that we have previously collected about you, we will notify you either through an email to your registered email address or by prominent posting on the Sites and, where appropriate, we will obtain consent from you either through email or the Sites.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

INFORMATION WE COLLECT

We collect information to deliver the products and services you request and to help improve your shopping experience. We collect information from you in a variety of ways when you interact with our websites, and mobile services.
We may collect the following categories of personal information. Not all categories may be collected about every individual:

Personal identifiers, such as name and address
Device and online identifiers and related information, such as telephone number and email address
Internet, application, and network activity, such as cookie IDs and browser visits
Financial information, such as credit and debit card numbers and claims information
Purchase history information, such as products you have bought, rented, and returned
Location information, such as geo-location information
Audio, visual, and other sensory information, such as audio and video recordings
Individual preferences and characteristics, such as inferences related to shopping patterns and behaviors

HOW WE COLLECT INFORMATION

We collect information from you in a variety of ways. It may be:

Provided directly by you or a member of your household
Collected from a device associated with you or your household
Collected from an external third-party source

Our goal is to limit the information we collect to the information needed to support our business.

Information Provided Directly by You or a Member of Your Household: Allswell collects personal information about you when you interact with our Sites, including when you create an account, join our mailing list, make a purchase, or engage in an online chat with our customer service representatives. The information we may collect includes:

first and last name;
email address;
physical address;
items you are seeking to purchase; and
special requests and information that you choose to share with us.

If you make a purchase through our Sites, our third-party payment processor service providers may also collect billing information, such as your first and last name, email address, phone number, credit card or debit card number, and billing and shipping addresses. If you make a purchase over the phone, we will collect this personal information and share it with our third-party payment processor service providers.

Information Collected from a Device Associated with You or Your Household: We Automatically Collect: We may automatically collect personal information from devices that you use to interact with our Sites, as well as from your interaction with emails that we send to you. The personal information we automatically collect may include your IP address, browser type, device type, the webpage you visited before coming to our Site, pages you visited on our Sites, time spent on those pages, information you searched for on the Sites, when and for how long you visited the Sites, and similar information, which we collect through cookies, beacons, and other technologies. The information we automatically collect will be associated with any personal information that you have provided to us.

We may use this information to provide you location-based advertisements and social media posts. We may also use this personal information for analytics purposes.

Information Collected from External Third-Party Sources: We receive personal information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, prevent or detect fraud, and for other business purposes.

HOW WE USE INFORMATION WE COLLECT ABOUT YOU

Allswell may use the personal information it collects about you for a number of purposes, including:

To fulfill your order or requests for services and provide customer service
To create and maintain your account
To conduct auditing and monitoring of transactions and engagement
To conduct marketing and personalization
To protect the security and integrity of our websites, mobile services and our business, and help prevent fraud
To update our operational and technical functionality
To conduct business analysis, such as analytics, projections, identifying areas for operational improvement
To conduct research and development
To fulfill our legal function or obligations

If you decide at any time that you no longer wish to receive marketing and promotional materials from us, please follow the unsubscribe instructions provided in any of the communications you receive from us. You may also contact us at allstars@allswellhome.com to make your request to unsubscribe from further marketing emails from the respective sites.

WHEN WE SHARE AND DISCLOSE PERSONAL INFORMATION

All of the categories of personal information that we collect have been shared with other companies, including those within our corporate family, for a business purpose. We may share your information with our Walmart Inc corporate family of companies, such as Walmart and Sam’s Club, for their business purposes as well as any of the business purposes set forth in this Privacy Policy. Allswell also may share your personal information with service providers who perform services and functions on our behalf to support our interactions with you including, for example, providing our products and services, processing your purchases, administering surveys or contests, or communicating with you.

Allswell may share your personal information with other third parties, including law enforcement authorities, where we determine that doing so is appropriate to:

enforce our Terms of Service;
protect our property, services, and legal rights, and the rights of others;
provide maintenance services, database management, and similar site-related services;
prevent physical harm to persons or the property of others;
prevent fraud or other illegal activity against Allswell and others;
support auditing, compliance, and corporate governance functions;
comply with subpoenas, court orders, or similar legal processes, including to law enforcement agencies, regulators and courts; or
comply with applicable laws.

Finally, Allswell may provide your personal information to third parties for these third parties' direct marketing of their products and other business purposes. You may opt out of our continuing to share your information for these purposes by contacting us at allstars@allswellhome.com.

Aggregated, Non-Identifying Information: Allswell may share aggregated information that is not individually identifiable (or personal information) with third parties for industry analysis, demographic analysis, and targeted ad delivery.

CATEGORIES OF PERSONAL INFORMATION WE DISCLOSE TO EACH TYPE OF THIRD PARTY:

We may share your personal information with certain categories of third parties, as described below.

Categories of personal information we disclose to each type of third party
Types of Third Parties to Which the Personal Information Was Disclosed for a Business Purpose	Categories of Personal Information Disclosed for a Business Purpose
Those we are legally required to share with	Audio, visual, and other sensory information Device and online identifiers and related information Financial information Individual preferences and characteristics Internet, application, and network activity Location information Personal identifiers Purchase history information
Service providers that receive data in order to provide services to us (e.g. technology providers, cloud storage providers, etc.)	Device and Online Identifiers Internet, application, and network activity Personal identifiers Purchase history information
Our suppliers or marketplace vendors	Device and Online Identifiers Internet, application, and network activity Personal identifiers Purchase history information

HOW ALLSWELL USES COOKIES AND OTHER TECHNOLOGIES

When you visit our Sites, Allswell may place pieces of code, commonly referred to as "cookies," or similar technology on your devices. Allswell may begin collecting information about you or your activity on devices associated with you through cookies or similar technologies as soon as you visit our Sites. By using our Sites, you permit Allswell to collect and use your personal information from activity on devices associated with you in accordance with this Privacy Policy.

Allswell may use cookies for a number of purposes: First, we may use persistent cookies to save your login information for future logins to our Sites and to collect and analyze information about your online activity to help us improve our services. Second, we may use session ID cookies to enable certain features of the Sites to better understand how you interact with the Sites, and to monitor aggregate use of our Sites by Allswell users. Unlike persistent cookies, session cookies are deleted from your computer when you log off of the Sites and close your browser.

We also may use "pixel tags," "web beacons," and other technologies on our Sites to collect usage, demographic, and geographic location data, which allow us to count users who have visited certain pages of the Sites, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns.

Some internet browsers (e.g. Internet Explorer, Safari, Chrome) offer their own opt outs for interest-based advertising. The ad networks and ad service providers we participate with may not recognize these opt outs. Information about how to opt out of certain online interest-based advertising is discussed in the next section of this policy.

THIRD-PARTY ADVERTISEMENTS

Third parties, including advertisers, may collect information, potentially including personal information, about your activities over time and across different websites when you use the Sites. Those third parties may use cookies, pixel tags, web beacons, mobile application advertising identifiers and other technologies. Those third parties may also provide Allswell with information and reports about data collection, ad response measurement, analytical information, and assist with delivery of relevant marketing messages and advertisements.

Collection of your information by third parties is not governed by this Privacy Policy. Please consult the privacy policies of those third parties to determine how they collect and use your information. Many third-party advertisers and some web browsers and mobile devices allow you to opt out of third-party advertising. Information and resources regarding how to opt out of interest-based advertising are available from the Digital Advertising Alliance at http://www.aboutads.info/choices/.

ADVERTISING RELATED ACTIVITIES

We may share aggregated or pseudonymous information (pseudonymous information includes things like: device identifier, type of device, IP addresses, cookies and other information associated with your browsing and app usage) with other companies, such as publishers, advertisers, measurement analytics providers, and others. We do not share information that directly identifies you (information such as name or email address) with these companies.

We also allow companies that show advertisements on our webpages or our apps to collect information from your browsers or devices via the use of cookies or other technologies. Other companies' use of cookies and other data collection technologies are subject to their own privacy policies, not this one. Like many companies, we may allow cookie matching with select partners. However, these parties are not authorized to access information from our cookies.

HOW TO MODIFY OR DELETE PERSONAL INFORMATION

You can request that we review, modify, and delete your personal account information by contacting us. If you request that we delete your personal information, your account may become deactivated. If you would like us to modify or delete your account information, please contact us at allstars@allswellhome.com with a request that we delete your personal information. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

HOW ALLSWELL PROTECTS PERSONAL INFORMATION

Allswell has implemented an information security program that includes administrative, technical and physical controls designed reasonably to safeguard your personal information.

BUSINESS TRANSFERS AND CORPORATE CHANGES

We reserve the right to disclose, sell, or transfer all information related to the Sites, including personal information:

to a subsequent owner, co-owner or operator of one or more of the Sites; or
in connection with a corporate merger, consolidation, or restructuring; the sale of substantially all of our stock and/or assets; or other corporate change, including, without limitation, during the course of any due diligence process.

INFORMATION WE TRANSFER

The Sites to which this Privacy Policy applies are subject to U.S. law, unless otherwise stated in this Privacy Policy. By using the Sites or providing us with your information, you are directly transferring your information to us in the United States. In addition, we may transfer the information that we collect through the Sites to other countries where we do business. These countries may not have the same data protection laws as the country in which you reside. When we transfer personal information we collect about you to other countries, we will protect that information as described in this Privacy Policy, even though a given country may not have the same privacy and data protection laws as the country in which you reside. You agree to and acknowledge our collection, transfer, and processing of your personal information in accordance with this Privacy Policy.

CHILDREN'S PRIVACY

Our Sites are general audience sites not directed at children under the age of 13. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 13, we will promptly delete that information.

CALIFORNIA PRIVACY RIGHTS

California Consumer Privacy Act:

If you are a California resident, you can make certain requests regarding your personal information. We will fulfill each of these requests to the extent required by law.

You can ask us what personal information we have about you, including a list of categories of your personal information that we have sold and a list of categories of your personal information that we have shared with another company for a business purpose.
You can ask us to delete your personal information.
You can ask that we stop selling your personal information.

More information on each of these requests is below.

What personal information do you collect about me? If you make this request, we will return to you (to the extent required by law):
The categories of personal information we have collected about you.
The categories of sources from which we collect your personal information.
The business or commercial purpose for collecting or selling your personal information.
The categories of third parties with whom we share personal information.
The specific pieces of personal information we have collected about you.
A list of categories of personal information that we have sold, along with the category of any other company we sold it to. Any of the categories of personal information that we collect could be included in a sale to other companies, including those within our corporate family. If we have not sold your personal information, we will inform you of that fact.
A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
Delete My Personal Information: You have the right to ask that we delete your personal information. Once we receive a request, we will delete the personal information (to the extent required by law) we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. Choosing to delete your personal information may impact your ability to use our websites and online features, including closure of your online account, and limit your use of functions that require your personal information.
Stop Selling My Personal Information: We do not share your personal information for money. We do share personal information within our Walmart family of companies and with certain third parties, which may be considered a “sale” under California law even if we don’t receive money in exchange for the information. For purposes of California law, we may share with these parties all categories of personal information. We do not knowingly sell the personal information of minors under 16 years of age. If you are a California resident, you have a right to opt-out of the sale of your personal information. To do so, click “Do Not Sell My Personal Information” at the bottom of this page to submit your request.

Below is a chart showing the types of personal identifiers that we may have sold in the previous 12 months.

Types of personal identifiers that we may have sold in the previous 12 months
Categories of Third Parties to whom the Personal Information may be Sold	Categories of Personal Information Sold
Advertising companies (like ad servers, advertising agencies, technology vendors, providers of sponsored content, and others)	Device and Online Identifiers Internet, application, and network activity Personal identifiers Purchase history information
Other entity in the Walmart family of companies	Audio, visual, and other sensory information Device and online identifiers and related information Financial information Individual preferences and characteristics Internet, application, and network activity Location information Personal identifiers Purchase history information

We will not discriminate against you for exercising your rights. This generally means we will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods. Please know, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require usage of your personal information to function.

To exercise the California privacy rights for requesting or deleting your personal information, please click “Request for Personal Information” at the bottom of this page or call 1.833.225.7935.

To exercise your right to opt out of the sale of personal information, click “Do Not Sell My Personal Information” at the bottom of this page to submit your request.

Verifying Your Identity for Requests to Access or Delete Personal Information

We take the privacy of your personal information seriously and want to ensure that we provide only you or your authorized agent with your personal information. The CCPA also requires that we verify the identity of each person who makes a request to know what personal information we have about you or to delete the personal information we have about you.

What personal information do I provide to verify my identity?
To verify your identity, we ask you to provide your:
First name*
Last name*
Middle initial
Email address*
Phone number
Address*
*required field

How do you verify my identity?
We may verify your identity in a few different ways. We’ve partnered with a third party identification service to help us verify your identity and prevent fraudulent requests. When you make your request, you will be asked to answer a few questions about yourself to help us validate your identity. If you have an online account, we may ask you to log into your account and complete a one-time passcode validation.

In some instances, we may ask you to provide other documentation to verify your identity. If this happens, we will reach out to you directly with this request.

What if you can’t verify my identity?
If we can’t verify your identity, we will not be able to process your request to know what personal information we have about you or to delete the personal information we have about you. If we are unable to verify your identity with a high degree of certainty, we will only be able to provide a report with category-level information and we may not be able to delete some of your information.

How to Submit a Request Using an Authorized Agent
An authorized agent is a person or business who has authorization to request to know what personal information we have about you, to delete the personal information we have about you, or to opt out of the sale of personal information on behalf of a California resident. Authorized agents use the same links described above to submit requests.
If you are submitting a request on behalf of another person, we require a valid power of attorney and a signed attestation form. If you do not have a valid power of attorney, we require an authorization document and a copy of the consumer’s government-issued photo identification in addition to our attestation form. Our attestation form can be downloaded from the request form.

How do I send you my documentation?
If you submit a request on our website, you will be asked to upload this documentation when you submit your request. If you submit your request over the phone, you will be asked to email your forms to consumerprivacy@wal-mart.com. Please note, you will have 10 business days to provide all required documentation.

Your California Privacy Rights – Shine the Light

If you are a California resident, California law permits you to request information regarding the disclosure of your personal information by Allswell to third parties for the third parties' direct marketing purposes within the immediately preceding calendar year. Allswell will provide you with a list of the categories of personal information disclosed and a list of the names and addresses of the third parties. To make such a request, please write us at:

Allswell
Attn: Legal
45 W. 25th Street, 5th Floor
New York, NY 10010

HOW TO CONTACT ALLSWELL

Please contact us if you have any questions or comments about our privacy practices or this Privacy Policy. You can reach us online at allstars@allswellhome.com or you can write to us at: