Allswell Privacy Notice

Last Reviewed: Dec 20, 2022

Last Updated: Dec 20, 2022

Updates include:

Updated California Privacy Rights section
Addition of Virginia Privacy Rights
Revised disclosures about the categories of personal information we may collect
Revised disclosures about how we collect information
Revised disclosures about how we use your information
Clarification about how long we retain your personal information

This Privacy Notice explains how Altitude Collection, LLC (“Allswell”) collects, uses, and discloses your personal information. “Personal information” is information that identifies you or that can reasonably be linked to information that identifies you. Some laws define “personal information” differently, and we use those definitions when they are applicable. Rest assured, though, that no matter where you live, we treat your personal information with respect, and we collect, use, and share it only as described in this Notice.

This Notice applies when you visit any website (https://allswellhome.com/) or any official social media sites, or other online properties where this Notice is posted (collectively "Sites"). Allswell recognizes that you care about how your information is used, and your privacy is important to us. This Privacy Notice explains the choices you can make about what information we disclose. Please read this Privacy Notice carefully.

CHANGES TO THIS PRIVACY NOTICE

Please check our Privacy Notice periodically for changes. We will provide additional notice of significant updates. We will post the date our Notice was last updated at the top of the Privacy Notice.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

INFORMATION WE COLLECT

We may collect or receive the following categories of personal information. Not all categories may be collected or received about every individual:

Identifiers: Personal identifiers, such as name, telephone number, physical address, email address, government-issued identifiers (e.g., national identification numbers, driver’s license numbers), and signatures
Device Information and Online Activity: Device and online identifiers, account login information, keystroke patterns indicative of human or bot website/app usage, mobile and web network activity and related information (such as Mac address, IP address, cookie IDs, browser activity, and other information associated with your browsing history), and social media information
Commercial Information: Purchase and transaction history information (such as products or services you have purchased, rented, or returned), health and safety-related information, product testimonials, travel and vacation information, and competition entries
Communications: Communication details (such as the content of emails, text messages, or other communications), call logs, and calendar information where we are a party to the exchange
Demographic Information: Demographic information, such as age (including information about children under the age of 13 with respect to certain purchases and services (e.g., tobacco purchases), gender, citizenship, ethnicity, date of birth, family or marital status, household income, education, professional and employment information, family health, number of children, number of cars owned, and software or virtual assets owned
Financial Information: Financial information, such as credit or debit card numbers, financial account numbers, and claims information
Biometric Information: Biometric information, such as voice prints, imagery of the iris or retina, face geometry, and palm prints or fingerprints
Geolocation: Location information, such as geolocation information
Sensory Information: Audio, visual information, and other sensory information such as photographs and audio and video recordings
Background Information: Background and criminal information, such as background checks and criminal convictions
Inferences: Individual preferences and characteristics, such as inferences related to shopping patterns and behaviors, intelligence, and aptitudes

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
Collected from another company within our family of companies
Collected from another solution or asset
Collected from other sources, when it is appropriate, to help us correct or supplement our records, improve the quality or personalization of our services, increase the appeal and relevance of advertising, and to prevent or detect fraud

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 disclose it to our third-party payment processor service providers.

Information Collected from a Device Associated with You or Your Household: 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 may 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.

Information We Collect From Another Company Within Our Family of Companies: We may collect your personal information from another organization within our corporate family of companies, such as with Walmart or Sam's Club.

HOW WE USE INFORMATION WE COLLECT ABOUT YOU

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

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services
Providing advertising and marketing services, including targeted advertising
To conduct auditing and monitoring of transactions and engagement, including auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us
Helping to ensure security and integrity and prevent fraud
Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them
Debugging to identify and repair errors
To conduct business analysis, such as analytics, projections, identifying areas for operational improvement
To conduct research and development, including undertaking internal research for technological development and demonstration
To fulfill our legal function or obligations

We may use sensitive personal information for each of the purposes described above and to make inferences about customers, which we may use to promote certain products or services.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

WHEN WE SHARE AND DISCLOSE PERSONAL INFORMATION

We are careful to disclose your personal information in ways that respect your privacy and only as described in this Notice. All of the categories of personal information that we collect have been disclosed to other companies, including those within our corporate family, for a business purpose.

We view you as a valued customer, not a product, and we do not sell or rent your personal information to others for money. We may disclose your personal information in the following circumstances:

Other Businesses in our Corporate Family: We may disclose your personal information to other brands and businesses within the Walmart corporate family. When we do, the information will be used in ways that are consistent with this Notice.

Service Providers: Allswell also may disclose your personal information to 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.

Legal Requirements and Protection of Our Company and Others: Allswell may disclose your personal information to 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.

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

We may disclose your personal information to 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 disclose to	Audio, visual, and other sensory information Characteristics of protected classifications under state or federal law Device and online identifiers and related information Demographic 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.)	Audio, visual, and other sensory information Device and Online Identifiers Internet, application, and network activity Personal identifiers Purchase history information
Our suppliers or marketplace vendors	Audio, visual, and other sensory information 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 Notice.

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 Notice.

DEIDENTIFIED & AGGREGATED PERSONAL INFORMATION

We continually strive to make customer shopping experiences more relevant and with less friction and may offer related services and insights to our suppliers and others. As a result, we may disclose to others insights that combine information from many customers in ways that do not directly identify you. For example, we may combine your shopping history with that of other customers to deliver generalized insights to our suppliers. These insights do not identify individual customers. This information helps our suppliers provide products and services relevant to our customers. We may receive payment for these insights.

To deliver information about products and services that may be of interest to you, we may disclose information to other companies, such as publishers, advertisers and measurement analytics providers. For example, we may disclose device-related data (such as device identifier, type of device, IP address, cookies and other information associated with your browsing and app usage) and individual preferences and characteristics (such as insights and inferences related to shopping patterns and behaviors). This information does not identify you directly, but is necessary to personalize the advertisements you receive. We do not receive payment for this information.

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. 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 Notice applies are subject to U.S. law, unless otherwise stated in this Privacy Notice. 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 Notice, 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 Notice.

DATA RETENTION

We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in this Privacy Notice or any other notice provided at the time of data collection, but no longer than as required or permitted under applicable law or our internal policy. We dispose of the information we collect in accordance with our retention policies and procedures.

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 delete that information.

STATE PRIVACY RIGHTS

Virginia Privacy Rights

Virginia residents can exercise the following rights by going to the footer of our website or settings section of our app and selecting the “Request My Personal Information” link:

Request to Access My Personal Information
Delete My Personal Information
Correct My Personal Information

Virginia residents can exercise the following rights by going to the footer of our website or the settings section of our app and selecting the “My Privacy Choices” link:

Opt Out of the Processing of My Personal Information for Purposes of Targeted Advertising

If we decline to take action on one of your rights as a Virginia resident, you can submit an appeal by going to our privacy request page.

California Consumer Privacy Act:

Note: This California section uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations.

Sale and Sharing of Personal Information

We may sell or share personal information with third parties for various purposes including cross-context behavioral advertising or sharing among Walmart-affiliated entities. These kinds of disclosures may be deemed selling or sharing personal information under California law and you have the right to opt out of these disclosures. We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the Last Updated date of this Notice) the following categories of personal information to the following categories of third parties:


Category of Personal Information Sold or Shared	Category of Third-Party Recipient
Identifiers	Service providers (such as advertising networks, marketplace sellers, analytics providers, etc.)
Device Information and Online Activity	Business partners that receive data for their own independent use and not to provide services to a Walmart entity
Demographic Information	Business partners that receive data for their own independent use and not to provide services to a Walmart entity; Service providers that receive data to provide services to a Walmart entity (e.g., analytics providers, advertising networks, cloud storage providers, etc.); Business partners
Geolocation	Business partners that receive data for their own independent use and not to provide services to a Walmart entity
Inferences	Business partners that receive data for their own independent use and not to provide services to a Walmart entity; Business partners

Sale or Share of Personal Information of Consumers under 16 Years of Age

We do not knowingly sell or share (for cross-context behavioral advertising) the personal information of consumers under 16 years of age. For more information about treatment of children’s personal information, see the Children’s Privacy section above.

What Are Your California Privacy Rights?

If you are a California resident, you can make certain requests regarding your personal information, and we will fulfill each request to the extent required by law. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial.

As stated in more detail below, you can request that we:

Provide you with access to a copy of and certain details regarding the personal information we have about you.
Delete your personal information.
Stop selling your personal information or sharing your personal information for cross-context behavioral advertising.
Correct your inaccurate personal information.
Limit the use or disclosure of your sensitive personal information (SPI).

To exercise any of these privacy rights, call 1-833-225-7935, press one, and say, “I’d like to exercise my privacy rights.” Or follow the instructions below specific to the type of request.

Request my Personal Information: You have the right to request access to the personal information we may have collected about you. To access your personal information, click "Request My Personal Information."

Requests to access your personal information may be submitted up to two times in a rolling twelve-month period. In response, we will return to you the following categories of information, 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, selling, or sharing your personal information.
- The categories of third parties to whom we disclose personal information.
- The specific pieces of personal information we have collected about you.
- A list of categories of personal information that we have sold or shared for cross-context behavioral advertising, along with the categories of third parties we sold it to or shared it with for cross-context behavioral advertising.
- A list of categories of personal information that we have disclosed for a business purpose, along with the categories of third parties we disclosed it to.
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 our service providers to do the same. 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 in-store functions that require your personal information. To delete your personal information, click “Request My Personal Information.”
Stop Selling My Personal Information: You have the right to opt-out of the sale of your personal information or sharing of your personal information for cross-context behavioral advertising and can request that we stop by clicking “My Privacy Choices” or by using the Global Privacy Control as described below.

Your opt-out request may be processed differently depending on whether you are logged into your account. If you are logged in, your preference will be associated with your account, and the device on which you exercised your choice. When you log in from another device or browser, it too will be automatically opted out. If you are not logged into your account, your request will only be associated with that one browser. We also support your use of the Global Privacy Control (GPC). If you notify us of your privacy preferences through GPC, we will honor your request with respect to the browser or device that sends us the GPC signal, and when you login to your account from that device, the opt-out will extend to your account, as well.

If you change your preference from opt-in to opt-out, you may be asked to confirm your preference prior to it taking effect. After opting out of the sale of your personal information or sharing of your personal information for cross-context behavioral advertising, you may still receive ads from us, however they will not be tailored to you.
Correct My Personal Information: You have the right to ask that we correct the personal information we may have collected about you if that information is inaccurate. We reserve the right to request identifying documentation from you in certain circumstances, as permitted by law. To correct your personal information, click “Request My Personal Information.”
Limit the Use and Disclosure of SPI: You have the right to ask that we limit our use and disclosure of your SPI to certain purposes permitted by law and can do so by clicking “My Privacy Choices.”

We will not discriminate against you for exercising your rights. 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. Some programs or membership services require usage of personal information to function, so compliance with your request may impact those experiences.

How Do We Verify Your Identity to Complete Your Access, Correction and Deletion Requests:
If you request access to, or the correction or deletion of, your personal information we will verify your identity before disclosing the requested information. To do so, we may ask that you log into your account or provide us with your:

First name*, Middle initial, Last name*
Address*
Email address
Phone number

*Required field

When you make a request, you will be asked to answer a few questions about yourself to help us verify your identity. Third-party identification services may help us with verification to prevent disclosure of your personal information resulting from fraudulent requests. You may be asked to log into your online account and complete a one-time passcode validation. In the event more documentation is necessary to verify your identity, we will notify you directly.

What If You Can’t Verify My Identity?
If we can’t verify your identity, we will notify you, and your request(s) to access, request, or delete your personal information may not be processed. Any requests may be denied if we have reason to believe they are fraudulent.

How Do I Submit a Request Using an Authorized Agent?
If you’d like an authorized agent to exercise your rights for you, they may use the same links described above to submit requests. We require documentation demonstrating your agent’s authority to submit requests on your behalf. For example, a valid power of attorney or other documentation, including a letter, signed by you (the California resident) authorizing the agent to submit your requests. You can download a sample letter from the request form. Documentation may be uploaded at the time you submit your request on our website or provided to us up to 10 business days after. If you submit your request by calling, you can email your forms to consumerprivacy@wal-mart.com.

Number of Requests Received in 2022
To view metrics about our privacy requests, click How Many California Consumer Privacy Act Requests Did We Fulfill Last Year?.

Shine the Light
California residents also have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties. To exercise this right, contact us at the address provided in the How to Contact Allswell section below.

Notice of Financial Incentive
If we provide a financial incentive, we will provide you with the details, including how the incentive is related to your data before you participate so that you may make an informed decision about whether and how to participate. In the event you decide to take advantage of a financial incentive, you will always have the right to withdraw from participation and we will provide you with directions on how to do so.

HOW TO CONTACT ALLSWELL

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

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

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