CPO Privacy Policy

Last Updated December 2021

CPO Commerce, LLC ("CPO," “we,” “us,” or “our”) operates the websites located at www.cpooutlets.com and other websites that link to this privacy policy (cumulatively the “CPO Sites”) as a service to its customers residing in the United States of America, its territories and possessions. 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.

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 14).

1. Policy Scope

This privacy policy applies to your use of the CPO Sites and CPO’s treatment of 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.

2. Our Information Collection Practices

We collect information about you when you visit the CPO Sites. What types of information we collect depends on how you interact with us.

Automatically Collected Information. When you visit the CPO Sites, we may automatically collect and store the following types of information:

Information about your device and usage: We may collect information including your Internet protocol (IP) address, web browser type, operating system type, Internet service provider, name of the domain and host from which you access the CPO Sites, access date and time, information collected as server logs from information provided by your browser, click-through statistics, the type of device that you use, unique device identifiers, mobile carrier, the Internet address of the sites from which you linked directly to CPO Sites, information about the links you click and content you interact with on CPO Sites, the frequency and duration of your visits to CPO Sites, and the Internet addresses of sites you visited during your visit to and upon exiting CPO Sites.

Location information: We may use precise location information, such as your GPS coordinates, for purposes such as to autofill your delivery address and determine estimated shipping times. If you do not want to share your location, you can disable location sharing in the settings on your device. We may also collect general location information via your IP address.

Cookies and other electronic technologies: We may use cookies, pixel tags, and other electronic technologies that help the CPO Sites function, improve our advertising and services, and perform research and analytics.

Information from social media platforms: If you connect with us through social media by “liking” or “following” us on Facebook, Instagram, YouTube, or other social media platforms, we may collect information including your username, name, email address, and any comments or content you post on our social media pages.

Information Provided Directly by the User. 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, you must provide certain information. The information you provide to us directly may include, without limitation, your:

  • Contact information, such as name, mailing address, email address, telephone number, and fax number;
  • Account information you provide when you register for an account with us, such as your email address and password;
  • Preference information, such asInformation concerning your interests, occupation, product use and preferences.
  • Customer service interaction information, such as messages submitted to us through online forms or email, and phone recordings from interactions with our customer service representatives.
  • Information you provide in connection with surveys and sweepstakes, such as your interests, preferences, demographic data (e.g., gender), and information needed for you to participate and for us to fulfill your prize or participation incentives (if any).
  • Affiliate Program. We partner with Commission Junction LLC, a third party, to offer our Affiliate Program. We may collect certain contact information from participants in our Affiliate Program. However, all payment information and other information collected as part of the program is directly collected by Commission Junction LLC and not shared with CPO. Please review Commission Junction LLC’s Privacy Policy for more information about its data collection and use practices.
  • Other information you provide us in any medium, such as any information you include in emails to us or submissions made through our “contact us” page.

Information Obtained from Third Parties. We may receive information about you from other sources, such as business partners, marketers, public websites, survey administrators, social network services, and other parties, and combine this information with other information we have about you. We may also receive information about you through certain functionalities on the CPO Sites, such as the “Email This Page to a Friend” feature. Similarly, if a customer requests that an order or gift be sent directly to another individual, we may receive information about the recipient of the order or gift. This information may include name, address, phone number, fax number, email address, and other similar information.

4. Use of Information

We use information collected through the CPO Sites for business and commercial purposes, including:

  • To process, confirm, and ship your orders, exchanges, and returns;
  • To communicate with you, for example, by sending you updates about your purchases and shipments, updates to our site and services, and changes to our terms, conditions and policies;
  • For marketing and advertising purposes, including providing you with the latest product announcements, promotions, and information about upcoming events;
  • To personalize your experience and customize our site, such as customizing the site to your preferences and delivering relevant content;
  • To improve our site, including bug detection and error reporting;
  • To analyze how users interact with our site and our advertisements on our site and third-party platforms, improve usability and effectiveness of our site, perform research and analytics, and to test and create new features and services;
  • For our business operations, including maintaining your account, reviewing and processing employment applications, and for security, fraud prevention, and legal compliance, such as detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity. This may also Include exchanging information with other companies and organizations for credit fraud protection and risk reduction purposes;
  • To recognize users across our and our affiliates’ websites, browsers, and devices (for example, by linking activity associated with the same username, IP address, and unique device identifiers) to provide you with a more seamless and personalized experience across these channels; and
  • Other purposes for which we obtain your consent, in accordance with applicable law.

We may aggregate and de-identify information to use for any purpose and may share, sell and rent or trade such de-identified and aggregate information and statistical information derived therefrom with our marketing partners, advertisers, or other third parties.

5. Disclosure of Information

Service Providers and Vendors. We may share your information with certain third parties and affiliates 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 information for any purpose other than to perform the services designated by CPO or as required under applicable law.

Business Transfers. Information we collect 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.

Disclosures for Legal and Safety Purposes. CPO may also provide your 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; to enforce our terms of service; or to protect the rights, property, or personal safety of CPO or others. For example, CPO may be required to disclose your information to respond to a subpoena, court order or other legal process.

6. Consent to Processing and Transfers of Information

CPO may transfer information that you send to us 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.

7. 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 (as that term is defined in the Children’s Online Privacy Protection Act (COPPA)) 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 contact us as provided in Section 14 below, and we will make reasonable efforts to delete that Personal Information.

8. 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 experience. For example, we use cookies to store information that 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

Review your cookie use settings by visiting www.cpooutlets.com and clicking the “Cookie Preferences” link at the bottom of the page.

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 14).

9. Retention of Your Information

We will store your information for as long as reasonably necessary for the purposes described in this privacy policy. You may find out more details regarding our privacy practices by contacting us (see Section 14).

10. Your Choices

To Stop Certain Collection and Use of Your Information:

Marketing Email, Texts, and Mail. You may opt-out of receiving future email or other communications from us by clicking the “unsubscribe” link at the bottom of any email that you receive from us, or by contacting us (see Section 14). Please note that removal of your information from our records or opting-out of receiving future communications 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 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, in which information gathered through your browser or mobile device about online activity is used to help show you ads that are more likely to be of interest to you. 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 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 14. To prevent unauthorized changes, we may ask for certain information to verify your identity before we process such requests.

11. Security

CPO and authorized third parties employ a variety of administrative, technical, and physical measures, to protect your information from unauthorized access, loss, alteration, use or disclosure. In addition, we use reasonable measures to limit the disclosure of your information consistent with this privacy policy. However, your 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 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.

12. 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. If we make material changes to this policy, we will notify you as required by law. Please note that our rights to use your information will be based on the privacy policy in effect at the time the information is collected. By continuing to use the CPO Sites, you are agreeing to be bound by any changes or revisions made to this privacy policy.

13. State-Specific Disclosures

a. Nevada Residents

Under Nevada SB 220, Nevada residents have the right to opt-out of the sale of Personally Identifiable Information—which includes first and last name, address, email address, phone number, Social Security Number, and any other identifier that allows a specific person to be contacted either physically or online— collected through a website or online service. If you are a Nevada resident and wish to opt-out of the sale of your Personally Identifiable Information, 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

b. California Residents
1. California Shine the Light Law

Under California Civil Code sections 1798.83–1798.84 California residents may, free of charge, request the names and addresses of affiliated companies to whom we have disclosed their Personal Information (as defined by Cal. Civil Code section 1798.83(e)(6)(A)) for direct marketing purposes in the prior calendar year, as well as the categories of Personal Information we have disclosed, once per year. If you are a California resident and would like to make such a request, please contact us as provided in Section 14.

2. California Consumer Privacy Act of 2018

California residents have the following rights with regard to their Personal Information, as that term is defined in the California Consumer Privacy Act (“CCPA”):

  1. The right to disclosure
    • About what Personal Information we collect
    • About Personal Information sold
      • Categories of Personal Information sold
      • Categories of third parties to whom Personal Information is sold
  2. The right to deletion of Personal Information
  3. The right to opt-out of the sale of Personal Information to third parties
  4. The right to sue for security breaches
  5. The right to not be discriminated against based on exercising any of the above rights

The CCPA defines the “sale” of Personal Information in a manner that includes a wide range of information-sharing practices. The following section describes:

  1. Categories of personal information we collect
  2. Specific personal information collected
  3. Categories of sources from which that information is collected
  4. Categories of Third Parties (who are not classified service providers) with whom the information may be shared.
Categories of Personal Information as defined by CCPA Do we collect this type of 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
Identifiers Yes Names, Account ids, emails, addresses, IP Addresses, Device Identifiers, Loyalty Program Ids, Tax Exempt Numbers From you, From Marketing Firms Yes Marketing Partners
Commercial Information Yes Quotes, Sales Transactions, Your transactions with us Yes Marketing Partners
Biometrics In limited circumstances Behavioral biometrics and device usage From you No N/A
Network Activity Yes
(if you access our websites or mobile apps)
Access to our properties From you No N/A
Geolocation Data Yes
(if you access our websites or mobile apps)
Unique Identifiers and your location and ZIP code From you and your devices No N/A
Recordings (e.g. audio, visual) Yes (if you call customer service) Voice and CCTV Recordings From you No N/A
Professional or Employment-Related Information Yes Employment History including Companies and Job Titles From you Yes Prior Employers and Background Check Services
Education Information Yes Educational History including Schools and programs From you Yes Verification Services
Inferences Yes Product Affinities From you and external data sources In limited circumstances Marketing Partners

California residents may exercise their rights under the CCPA, including to learn more about how we collect, use, and share their Personal Information, and to have their Personal Information deleted, by:

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

California residents may also opt-out of the sale of Personal Information. To do so:

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

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

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. An adult may also make such a request on behalf of his or her minor child. To designate an authorized agent, please contact us as described in Section 14 in order to provide written authorization signed by you and your designated agent.

14. 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,

by mail at:

CPO Commerce
P.O. Box 50768
Pasadena, CA 91115

or by phone at: 1-866-577-3014

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.