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Privacy Policy

Last Updated September 6, 2021:

This website or mobile application (“Site”) is owned and operated by a Transform Holdco LLC (“Transformco”) entity or licensee. At Transformco, we want to ensure that you know that your privacy is important to us. We also want you to understand what information we gather about you, how we use it, and the safeguards we have in place designed to protect it. This Privacy Policy applies to information collected through this Site, call centers, and our mobile applications.

Transformco may update this Privacy Policy from time to time. Please check this Privacy Policy periodically for changes. If we make any changes, the updated Privacy Policy will be posted to this Site with a revised “last updated” date. We encourage you to periodically review this page for the latest information on our privacy practices.

Your use of this Site, and any disputes arising from it, are subject to this Privacy Policy as well as our Terms of Use and all of its dispute resolution provisions, including arbitration, class action waiver, limitation on damages and choice of law.

Get answers and information about:

 

 

 

 

 

 

  • What Type of Information Do We Collect and How Do We Use It?
  • What Information Do We Share and With Whom?
  • Can I Disable Cookies?
  • How Do We Handle Personally Identifiable Information Collected from Children?
  • I Am a Minor, How Can I Remove My Posted Content?
  • What About Links to Other Sites?
  • Interest-Based Ads - Online Advertisements
  • Is My Information Secure?
  • How Can I Access My Information?
  • Can I “Opt-Out” of Receiving Promotional Emails?
  • California Residents
  • Nevada Residents
  • Where Is My Information Stored?
  • How May I Contact You?
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    What Type of Information Do We Collect and How Do We Use It?

    We may collect personally identifiable information ("PII" - for example, your full name, email address, mailing address, telephone number, mobile phone number or payment information) from you when you voluntarily submit the information to us, such as when you purchase items from us, sign up for one of our services or programs, or register with our Site. We may also collect PII from you--either directly or via one of our vendors--in other ways, including, without limitation, if you choose to subscribe to our email program; participate in sweepstakes, contests, surveys, and polls; participate in our Personal Shopper program; post content or suggestions on this Site; or use any of this Site’s other features that otherwise permit you to provide information or other content.

    We also may collect other information about you, including, without limitation, demographic information (such as number of household members, age, and gender) and information about your purchase preferences directly from you (whether online or offline) or from vendors such as public databases, social media platforms, data append services, and others. In addition, we may collect information (such as your interests, hobbies, and lifestyle choices; groups with which you are affiliated; and products you want, like, or own) from you as you use this Site and when you choose to provide this information to us through any interaction with this Site or otherwise.

    We may use the information we collect from and about you to: process and fulfill your order, notify you of your order status, prevent fraud, and otherwise provide you with customer service; respond to your inquiries and requests; create an account and register you as a registered Site user ("Registered User") and/or Shop Your Way member ("Member"); for marketing purposes and to send you information regarding this Site and other Transformco Sites, as well as about our products, programs or services; provide you with mobile alerts, if you have requested them; customize your experience on this Site and on other Transformco Sites; provide you with relevant offers, products and services; permit you to use this Site’s social networking features; or provide you with other services. Please note that message and data fees may apply if you register for mobile alerts. We may also use the PII we collect from and about you for our business purposes, such as data analysis, audits, developing new products and services, enhancing our Sites, improving our services, personalizing your experiences, identifying usage trends and determining the effectiveness of our promotional campaigns.

    We may use single sign-on services that allow you to sign into this Site using social networking login credentials for accounts such as Facebook or Google. This allows you to link your existing social network profile to your Site account. Once connected, you may be able to post content on the social networking website from this Site and interact with your friends from the social networking site(s). Any information or content that you post to the social networking website will be subject to that website’s own privacy policy. We may also access and use available information from your social network profile, such as your name, location, and profile picture.

    Some Site features may make use of your device attributes and settings that will allow our Site to determine your physical location. Such technologies may include IP address mapping, WiFi, GPS signals, cell tower positioning or other technologies. We use this information to enhance and personalize your experience and provide you with offers, products and services that may be of interest to you. For example, this Site may help you find your closest store or send you messages that may be of interest to you based on your current location. Transformco has no control over your device settings, but we do recommend enabling location services on your device so you can take advantage of the location-based features and functionality offered by this Site.

    Non-PII may be collected from you by means of cookies, pixel tags (also called web beacons or clear gifs), local shared objects and other technologies. Cookies are small bits of information that this Site places on your computer. We and our vendors use these technologies to identify your IP address, browser type, device characteristics, domain name, referring URLs and specific links and web pages through which you click. This data is collected automatically and utilized for data analytics, site operations, fraud prevention, and to help us improve this Site and your overall experience. This technology also allows us to recognize you when you return to this Site and to provide you with a customized experience that we feel will be of value to you. We may use and disclose non-PII in any manner for any purpose, except where prohibited under applicable law.

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    What Information Do We Share and With Whom?

    We may share your PII with selected vendors with which Transformco or its affiliates have a relationship and which have agreed to appropriate restrictions on the disclosure and use of your information.

    We may disclose your PII to identify you to anyone to whom you send messages through this Site. You may disclose your own PII on message boards, chat, profile pages, blogs and other social networking features and services to which you are able to post information and materials. Please note that any information you post or disclose through these services may be available to Site visitors and to the general public, depending on the particular service and any privacy settings in place (such as through your profile).

    We may share your PII with our vendors that need access to your information to provide operational or other support services, such as payment processors, shipping agents, and product fulfillment vendors. These vendors must agree to appropriate restrictions on the disclosure and use of your information. Unless otherwise disclosed to you, these vendors are prohibited from using your PII for their own marketing purposes.

    We may provide information about you, which may include PII, to regulatory authorities and law enforcement officials in accordance with applicable law, when we otherwise believe in good faith that the law requires it or to respond to requests from government authorities. There may be instances when we may use or disclose your PII in order to protect or defend the legal rights, property or operations of Transformco or our employees or agents; to protect the rights, privacy, safety or security of users, members or others; to protect against fraud; and to allow us to pursue available remedies or limit the damages that we may sustain.

    Transformco may sell, transfer and/or share PII in connection with a merger, reorganization, joint venture, assignment, spin-off, transfer or sale or disposition of all or any portion of our business, and in the event of a store closing or bankruptcy.

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    Can I Disable Cookies?

    Most web browsers allow you to exercise control over cookie files on your computer by erasing them, blocking them, or notifying you when such a file is stored. Please take a look at your particular browser for instructions on this function. If you do elect to disable cookies, please note that you may not be able to take full advantage of a personalized experience on this Site and on other Transformco Sites.

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    How Do We Handle Personally Identifiable Information Collected from Children?

    This Site is intended for a general audience and not directed to children less than 13 years of age. We do not intend to collect PII in a manner that is not permitted by Children’s Online Privacy Protection Act (“COPPA”). If you are under 13, do not provide any PII to us. If we obtain actual knowledge that we have collected Children’s PII in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA. If you believe your child may have provided us with their PII, you can contact us at dataprivacy@transformco.com and we will delete their PII to the extent required by law.

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    I Am a Minor, How Can I Remove My Posted Content?

    If you are under 18 and a Registered User or Member, you may ask us to remove content or information that you have posted to the Site.

    To remove posted content or information on shopyourway.com, please write to sywsolutions@syw.com. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

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    What About Links to Other Sites?

    This Site may contain links to content from other websites or applications that are not owned and operated by Transformco. Transformco is not responsible for the privacy practices of non-affiliated websites or applications, including, without limitation, those that are linked to or framed on this Site. You should read the privacy statements of each and every website and application that collects PII.

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    Interest-Based Ads - Online Advertisements

    This Site may display ads from other companies. We also partner with vendors to serve ads on our behalf on other non-affiliated sites or apps. Some of the ads on this Site or on other sites or apps may be personalized, meaning that they are intended to be relevant to you based on what we or the online advertising network serving the ad know about you or your device’s browsing activity. For example, anonymous information collected by our ad networks or other vendors across multiple sites that you visit may enable the ad network to predict your preferences and show you ads that are most likely to be of interest to you. We may share your information with our service providers to permit them to recognize and serve targeted ads to you across the different devices you use. Before we share your information, we transform, or “hash”, it so that it is not in personally identifiable form.

    Our vendors, including Facebook and Google, may use cookies, web beacons, and other storage technologies to collect or receive information about your internet usage, including your use of this Site, and use that information to provide measurement services and target ads.  We and our vendors may use first-party cookies or other first-party identifiers as well as cookies or other identifiers operated by our vendors to deliver advertisements, create a profile of you, measure your interests, detect your demographics, detect your location, and personalize content.

    We may use certain web analytics services, including Google Analytics, to help us understand and analyze how visitors use the Site and to serve ads on our behalf across the Internet.  We’ve implemented Google Analytics Advertising Features such as remarketing with analytics, interest-based advertising, demographics and interests reporting, user segment analysis, and impression reporting.  For more information on how Google Analytics uses data collected through the Site, visit policies.google.com/technologies/partner-sites.  You may also be able to opt out of Google Analytics by visiting tools.google.com/dlpage/gaoptout.

    If you do not wish to receive personalized advertising from us on other mobile or desktop sites, please visit the Network Advertising Initiative Opt-Out page. You may download the AppChoices app at www.aboutads.info/appchoices to opt out of personalized in-app advertising. The Network Advertising Initiative offers useful information about internet advertising companies, including information about how to opt-out of interest-based advertising by their members. See http://www.networkadvertising.org for general information about the NAI and http://www.networkadvertising.org/managing/opt_out.asp for the opt-out page. You may also visit http://www.aboutads.info/consumers/ to learn about online behavioral advertising and how to opt-out from online or in-app behavioral ads served by some or all participating companies. To opt out of Google’s network of interest-based advertising, visit adssettings.google.com.

    These opt-out mechanisms rely on cookies to remember your choices with respect to ad-serving on websites. If you delete your cookies, use another computer or device, or change browsers, you will need to repeat this process. In addition, opting out of interest-based ads will not opt you out of all ads, but rather only those ads that are personalized to your interests based on activities observed on our Site and/or web sites or mobile apps not owned and operated by Transformco.

    We participate in the Adobe Marketing Cloud Device Co-op. This helps us understand how you use our website and apps across different devices to better tailor content based on your interests. You can learn more about how Adobe does this and manage your preferences at https://cross-device-privacy.adobe.com/.

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    Is My Information Secure?

    We maintain reasonable and appropriate physical, electronic and procedural safeguards to protect your PII. While we work very hard to protect your privacy, no method of security is 100% effective, and we cannot be responsible for the actions of those who may gain unauthorized access to your PII. Transformco makes no warranties, express, implied or otherwise, as to the ultimate effectiveness of its reasonable and appropriate safeguards.

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    How Can I Access My Information?

    You can personalize your experience on this Site and other Transformco Sites by becoming a Registered User or Member. By registering, you will be able to tell us what products and services interest you, and whether you wish to receive information about special sales, promotions and other events. Once registered, you can submit, review and maintain your account profile information at any time by accessing your profile from within the particular Site. Your account information is accessible by using a password that you select or, if available and you choose to enable this feature, by using social networking login credentials for other non-affiliated sites such as Facebook or Google.

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    Can I "Opt-Out" of Receiving Promotional Emails?

    From time to time, we may send you emails with promotional offers and messages. If you would no longer like to receive emails with promotional offers and messages from this Site, you can unsubscribe from these emails by following the unsubscribe link located at the bottom of each promotional email. Please note that you may still receive transactional notices in email or other non-promotional emails (e.g. order confirmations, shipping notices, account statements, or important information regarding a product you have purchased) which will not have an unsubscribe link as they are not marketing emails.

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    California Residents

    This California Consumer Privacy Act (CCPA) Notice (“Notice”) applies to California residents that are “Consumers” as defined by the CCPA and is a supplement to Transformco’s other privacy policies or notices, including the remainder of the Privacy Policy on this page. In the event of a conflict between this Notice and the remainder of the Privacy Policy, or other Transformco privacy policies, this Notice shall govern as to our rights or obligations under the CCPA. Capitalized terms that are used herein shall have the meaning given to them in the remainder of the Privacy Policy except that capitalized terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.

    This Notice covers our Collection, use, and disclosure of Consumers’ Personal Information (PI) for the twelve months preceding the date at the top of this Privacy Policy, except to the extent such PI is exempt from the notice obligations of the CCPA. For example, this Notice does not apply to PI Collected from job applicants, current and former employees and contractors of Transformco, and persons with whom we interact with in their capacity of representing another business. If we Collect information about you in any of these contexts, this Notice will not be applicable to you.

    Collection, Use and Disclosure of PI

    The table below describes each category of PI we Collect and includes examples of types of PI that may fall into a specific category. We Collect the below categories of PI directly from you, your Device or browser, our Vendors (defined in the table below), suppliers, public databases, social media platforms, and data append services. We Collect, use and share the PI we Collect for the Business Purposes in the bulleted list below. We share your PI for our Business Purposes with the categories of recipients set forth in the table below.

    Business Purposes

    • Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services
    • Detecting security incidents and protecting against malicious, deceptive, or illegal activity
    • Debugging the Site to identify and repair errors
    • Internal research and development
    • Quality and safety assurance, and improving, upgrading, and enhancing the Site and our products and services
    • Processing and managing interactions and transactions on the Site and our products and services

    Category of Personal Information

    Categories of Recipients of
    Business Purposes Disclosures

    1. Identifiers (e.g., name, nicknames, aliases, social media handles, contact information including email, phone, and address, User IDs, passwords, IP addresses, device IDs, account names and numbers)

    Vendors that assist us in providing the Site, our products and services, and/or running our internal business operations (“Vendors”); Analytics and advertising partners

    2. Personal Records (e.g., education, employment history, financial account information)

    Vendors

    3. Personal Characteristics and traits (e.g., age, gender, household information, marital status, veteran or military status)

    Vendors

    4. Customer Account Details / Commercial Information (e.g., purchase history or service history)

    Vendors

    5. Internet Usage Information (e.g., browsing history, referring URLs, search history, interactions with advertising links, mobile application usage, social media information linked to your account with us)

    Vendors; Analytics and advertising partners

    6. Geolocation Data (e.g., your location we infer based on your IP address)

    Vendors; Analytics and advertising partners

    7. Sensory Data (e.g., voice recordings from call centers, profile photos you place on your Shop Your Way profile, or security video footage from our stores)

    Vendors

    8. Professional or Employment Information (e.g., education level, employment status)

    Vendors

    9. Inferences from PI Collected (e.g., customer profiles including shopping preferences, product preferences, customer characteristics and behaviors)

    Vendors; Analytics and advertising partners

    Your CCPA Rights

    Right to Opt-Out of Sale of Personal Information

    We may disclose your PI for the following purposes, which are not a Sale under the CCPA: (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.

    We do not believe that cookies operated by our vendors that facilitate online advertising or other activities in connection with our online services, which themselves Collect and share PI, are a sale by us of your PI under the CCPA. However, we provide Consumers who use our online services a way to manage their cookie preferences based on categories of cookies through our management tool available here [link to open OneTrust controls]. You will need to do this on each browser that you use to access our Site, and clearing cookies on your browser(s) may disable your preference settings.

    In addition, some third-party cookie operators that Collect PI in connection with our online services for advertising, analytics and other purposes offer you the ability to opt-out of their own downstream Sales. Please visit here to opt-out of the Sale of PI by these third parties. This is a third-party program and we are not responsible for its effectiveness. You must opt-out on every Device and browser you use in order to effectuate your requests to opt-out of the Sale of PI by these parties. For more information on how to exercise choices regarding cookies and interest-based advertising, see the section above titled "Interest-Based Ads - Online Advertisements" [hyperlink to above section titled "Interest-Based Ads - Online Advertisements"].

    Some browsers have signals that may be characterized as do-not-track signals, but like many website operators, we currently do not understand them to operate in that manner or to signify a request to opt-out of the Sale of your PI. We understand that various parties are developing signals to communicate such requests, and we may recognize certain such signals if we conclude such a program is appropriate.

    Rights to Know and Delete Personal Information

    California Consumers have the right to exercise certain privacy rights under the CCPA. Any request you submit to us is subject to an identification and residency verification process. We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we Collected PI.

    If you are unable to provide us with certain information about yourself or, in some cases, about your transaction history with us, we will be unable to verify your identity to fulfill a request to know or delete. As an initial matter, we require you to provide your name, address, email address, and phone number to be submitted via our online request form or toll-free telephone number below. In some cases, we may verify identity by confirming that you are the owner of the email address we have on file. For your specific pieces of information, as required by the CCPA, we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above.

    Some PI we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s PI (e.g., clickstream data tied only to a Pseudonymous browser ID). As required by the CCPA, we do not include that PI in response to verifiable Consumer requests. If we cannot comply with a request, we will explain the reasons in our response.

    We will make commercially reasonable efforts to identify Consumer PI that we Collect, Process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

    You may use an authorized agent who meets the agency requirements of the CCPA to submit a consumer rights request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.

    a. The Right to Know

    i. Categories

    You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

    • The categories of PI we have Collected about you.
    • The categories of sources from which we Collected your PI.
    • The Business or Commercial Purposes for our Collecting or Selling your PI.
    • The categories of third parties to whom we have shared your PI.
    • A list of the categories of PI disclosed for a Business Purpose in the prior 12 months, or that no disclosure occurred.
    • A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred. If we Sold your PI, we will explain: 
      • The categories of your PI we have Sold.
      • The categories of Third Parties to which we Sold PI, by categories of PI Sold for each Third Party.

    ii. Specific Pieces

    You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have Collected in the period that is 12 months prior to the request date and are maintaining.

    Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

    b. The Right to Deletion

    You may request that we delete your PI that we have Collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not Collect directly from you. Exceptions do apply, including, without limitation, where we need to retain your PI for regulatory reasons, to complete a warranty or other contract with you, or other internal uses of the information that are compatible with the context in which you provided it.

    To exercise the right to know or right to delete, you may submit a request by calling us at 888-527-6415 or online at https://transformco.com/privacy/request. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so. Transformco will not discriminate against any consumer for exercising these rights.

    Notice of Financial Incentive and Non-Discrimination

    This Financial Incentives and Non-Discrimination Disclosure applies to loyalty and rewards programs run by Transformco. Currently we operate the Shop Your Way Program (“Shop Your Way” or the “Program”). A separate notice for it follows below. We may add or change programs and/or their terms by posting notice on the program descriptions, so check them regularly. We will not discriminate against you if you exercise any of the rights provided by the CCPA. You can opt-out of non-Program marketing emails or delete your PI from our active marketing lists and retain your Program account and benefits.

    Participating in Shop Your Way is entirely optional but is subject to additional Shop Your Way Program Terms and Conditions.

    We treat the value of Consumer data Collected through the Program as the equivalent of relevant expenses related to the Collection and retention of Consumers’ PI as part of the Program. We value the benefits of the Shop Your Way Program as the value of rewards given to members, which are outlined in the Shop Your Way Program Terms and Conditions.

    We pay these expenses and provide the Program benefits, which vary depending upon Program participation, to foster a positive relationship with our members that is invaluable.

    California Consumers may make a PI deletion request under the CCPA by calling us at 888-527-6415 or online at https://transformco.com/privacy/request.  If this request includes deleting your email address, then it will terminate your Program membership because that information is necessary for us to provide the Program. Upon a termination request, some Program data associated with the terminated account may be retained for record keeping, tax reporting, and other legally permissible purposes.

    California Shine the Light Law

    California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. Separate from your CCPA opt-out rights, you have additional rights regarding disclosure of your information to third parties for their own direct marketing purposes.

    We do not share personal information with third parties for their direct marketing purposes. If you are a California resident, you may request information about our compliance with Shine the Light by contacting us at dataprivacy@transformco.com or by sending a letter to

    Transform SR Holding Management LLC
    ATTN: Legal Intake/Privacy
    3333 Beverly Road
    Hoffman Estates, IL 60179

    Any such request must include “California Shine the Light Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

    As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately

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    Nevada Residents

    Nevada consumers have the right to instruct website operators to not sell certain personal information to third parties (often called “data brokers”) who will license or sell your information to other companies. Transformco does not sell such information to data brokers and we have no plans to ever do so. If we consider selling this information in the future, we will update this privacy policy to give you notice of this change and provide a formal method for Nevada consumers to exercise their opt-out rights under that law.

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    Where Is My Information Stored?

    Your PII may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our Site, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than in your country. This Site is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.

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    How May I Contact You?

    If you have any questions about this Privacy Policy, please contact us at dataprivacy@transformco.com. Because email communications are not always secure, please do not include credit card or other financial information, health or prescription-related information, or other sensitive information in your email to us. If you prefer to contact us via US Mail, please address your inquiry to

    Transform SR Holding Management LLC
    ATTN: Legal Intake/Privacy
    3333 Beverly Road
    Hoffman Estates, IL 60179

     

     

    Privacy Policy

    Last Updated September 6, 2021:

    This website or mobile application (“Site”) is owned and operated by a Transform Holdco LLC (“Transformco”) entity or licensee. At Transformco, we want to ensure that you know that your privacy is important to us. We also want you to understand what information we gather about you, how we use it, and the safeguards we have in place designed to protect it. This Privacy Policy applies to information collected through this Site, call centers, and our mobile applications.

    Transformco may update this Privacy Policy from time to time. Please check this Privacy Policy periodically for changes. If we make any changes, the updated Privacy Policy will be posted to this Site with a revised “last updated” date. We encourage you to periodically review this page for the latest information on our privacy practices.

    Your use of this Site, and any disputes arising from it, are subject to this Privacy Policy as well as our Terms of Use and all of its dispute resolution provisions, including arbitration, class action waiver, limitation on damages and choice of law.

    Get answers and information about:

     

     

  • What Type of Information Do We Collect and How Do We Use It?

  • What Information Do We Share and With Whom?

  • Can I Disable Cookies?

  • How Do We Handle Personally Identifiable Information Collected from Children?

  • I Am a Minor, How Can I Remove My Posted Content?

  • What About Links to Other Sites?

  • Interest-Based Ads - Online Advertisements

  • Is My Information Secure?

  • How Can I Access My Information?

  • Can I “Opt-Out” of Receiving Promotional Emails?

  • California Residents

  • Nevada Residents

  • Where Is My Information Stored?

  • How May I Contact You?
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    What Type of Information Do We Collect and How Do We Use It?

    We may collect personally identifiable information ("PII" - for example, your full name, email address, mailing address, telephone number, mobile phone number or payment information) from you when you voluntarily submit the information to us, such as when you purchase items from us, sign up for one of our services or programs, or register with our Site. We may also collect PII from you--either directly or via one of our vendors--in other ways, including, without limitation, if you choose to subscribe to our email program; participate in sweepstakes, contests, surveys, and polls; participate in our Personal Shopper program; post content or suggestions on this Site; or use any of this Site’s other features that otherwise permit you to provide information or other content.

    We also may collect other information about you, including, without limitation, demographic information (such as number of household members, age, and gender) and information about your purchase preferences directly from you (whether online or offline) or from vendors such as public databases, social media platforms, data append services, and others. In addition, we may collect information (such as your interests, hobbies, and lifestyle choices; groups with which you are affiliated; and products you want, like, or own) from you as you use this Site and when you choose to provide this information to us through any interaction with this Site or otherwise.

    We may use the information we collect from and about you to: process and fulfill your order, notify you of your order status, prevent fraud, and otherwise provide you with customer service; respond to your inquiries and requests; create an account and register you as a registered Site user ("Registered User") and/or Shop Your Way member ("Member"); for marketing purposes and to send you information regarding this Site and other Transformco Sites, as well as about our products, programs or services; provide you with mobile alerts, if you have requested them; customize your experience on this Site and on other Transformco Sites; provide you with relevant offers, products and services; permit you to use this Site’s social networking features; or provide you with other services. Please note that message and data fees may apply if you register for mobile alerts. We may also use the PII we collect from and about you for our business purposes, such as data analysis, audits, developing new products and services, enhancing our Sites, improving our services, personalizing your experiences, identifying usage trends and determining the effectiveness of our promotional campaigns.

    We may use single sign-on services that allow you to sign into this Site using social networking login credentials for accounts such as Facebook or Google. This allows you to link your existing social network profile to your Site account. Once connected, you may be able to post content on the social networking website from this Site and interact with your friends from the social networking site(s). Any information or content that you post to the social networking website will be subject to that website’s own privacy policy. We may also access and use available information from your social network profile, such as your name, location, and profile picture.

    Some Site features may make use of your device attributes and settings that will allow our Site to determine your physical location. Such technologies may include IP address mapping, WiFi, GPS signals, cell tower positioning or other technologies. We use this information to enhance and personalize your experience and provide you with offers, products and services that may be of interest to you. For example, this Site may help you find your closest store or send you messages that may be of interest to you based on your current location. Transformco has no control over your device settings, but we do recommend enabling location services on your device so you can take advantage of the location-based features and functionality offered by this Site.

    Non-PII may be collected from you by means of cookies, pixel tags (also called web beacons or clear gifs), local shared objects and other technologies. Cookies are small bits of information that this Site places on your computer. We and our vendors use these technologies to identify your IP address, browser type, device characteristics, domain name, referring URLs and specific links and web pages through which you click. This data is collected automatically and utilized for data analytics, site operations, fraud prevention, and to help us improve this Site and your overall experience. This technology also allows us to recognize you when you return to this Site and to provide you with a customized experience that we feel will be of value to you. We may use and disclose non-PII in any manner for any purpose, except where prohibited under applicable law.

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    What Information Do We Share and With Whom?

    We may share your PII with selected vendors with which Transformco or its affiliates have a relationship and which have agreed to appropriate restrictions on the disclosure and use of your information.

    We may disclose your PII to identify you to anyone to whom you send messages through this Site. You may disclose your own PII on message boards, chat, profile pages, blogs and other social networking features and services to which you are able to post information and materials. Please note that any information you post or disclose through these services may be available to Site visitors and to the general public, depending on the particular service and any privacy settings in place (such as through your profile).

    We may share your PII with our vendors that need access to your information to provide operational or other support services, such as payment processors, shipping agents, and product fulfillment vendors. These vendors must agree to appropriate restrictions on the disclosure and use of your information. Unless otherwise disclosed to you, these vendors are prohibited from using your PII for their own marketing purposes.

    We may provide information about you, which may include PII, to regulatory authorities and law enforcement officials in accordance with applicable law, when we otherwise believe in good faith that the law requires it or to respond to requests from government authorities. There may be instances when we may use or disclose your PII in order to protect or defend the legal rights, property or operations of Transformco or our employees or agents; to protect the rights, privacy, safety or security of users, members or others; to protect against fraud; and to allow us to pursue available remedies or limit the damages that we may sustain.

    Transformco may sell, transfer and/or share PII in connection with a merger, reorganization, joint venture, assignment, spin-off, transfer or sale or disposition of all or any portion of our business, and in the event of a store closing or bankruptcy.

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    Can I Disable Cookies?

    Most web browsers allow you to exercise control over cookie files on your computer by erasing them, blocking them, or notifying you when such a file is stored. Please take a look at your particular browser for instructions on this function. If you do elect to disable cookies, please note that you may not be able to take full advantage of a personalized experience on this Site and on other Transformco Sites.

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    How Do We Handle Personally Identifiable Information Collected from Children?

    This Site is intended for a general audience and not directed to children less than 13 years of age. We do not intend to collect PII in a manner that is not permitted by Children’s Online Privacy Protection Act (“COPPA”). If you are under 13, do not provide any PII to us. If we obtain actual knowledge that we have collected Children’s PII in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA. If you believe your child may have provided us with their PII, you can contact us at dataprivacy@transformco.com and we will delete their PII to the extent required by law.

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    Am a Minor, How Can I Remove My Posted Content?

    If you are under 18 and a Registered User or Member, you may ask us to remove content or information that you have posted to the Site.

    To remove posted content or information on shopyourway.com, please write to sywsolutions@syw.com. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

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    What About Links to Other Sites?

    This Site may contain links to content from other websites or applications that are not owned and operated by Transformco. Transformco is not responsible for the privacy practices of non-affiliated websites or applications, including, without limitation, those that are linked to or framed on this Site. You should read the privacy statements of each and every website and application that collects PII.

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    Interest-Based Ads - Online Advertisements

    This Site may display ads from other companies. We also partner with vendors to serve ads on our behalf on other non-affiliated sites or apps. Some of the ads on this Site or on other sites or apps may be personalized, meaning that they are intended to be relevant to you based on what we or the online advertising network serving the ad know about you or your device’s browsing activity. For example, anonymous information collected by our ad networks or other vendors across multiple sites that you visit may enable the ad network to predict your preferences and show you ads that are most likely to be of interest to you. We may share your information with our service providers to permit them to recognize and serve targeted ads to you across the different devices you use. Before we share your information, we transform, or “hash”, it so that it is not in personally identifiable form.

    Our vendors, including Facebook and Google, may use cookies, web beacons, and other storage technologies to collect or receive information about your internet usage, including your use of this Site, and use that information to provide measurement services and target ads.  We and our vendors may use first-party cookies or other first-party identifiers as well as cookies or other identifiers operated by our vendors to deliver advertisements, create a profile of you, measure your interests, detect your demographics, detect your location, and personalize content.

    We may use certain web analytics services, including Google Analytics, to help us understand and analyze how visitors use the Site and to serve ads on our behalf across the Internet.  We’ve implemented Google Analytics Advertising Features such as remarketing with analytics, interest-based advertising, demographics and interests reporting, user segment analysis, and impression reporting.  For more information on how Google Analytics uses data collected through the Site, visit policies.google.com/technologies/partner-sites.  You may also be able to opt out of Google Analytics by visiting tools.google.com/dlpage/gaoptout.

    If you do not wish to receive personalized advertising from us on other mobile or desktop sites, please visit the Network Advertising Initiative Opt-Out page. You may download the AppChoices app at www.aboutads.info/appchoices to opt out of personalized in-app advertising. The Network Advertising Initiative offers useful information about internet advertising companies, including information about how to opt-out of interest-based advertising by their members. See http://www.networkadvertising.org for general information about the NAI and http://www.networkadvertising.org/managing/opt_out.asp for the opt-out page. You may also visit http://www.aboutads.info/consumers/ to learn about online behavioral advertising and how to opt-out from online or in-app behavioral ads served by some or all participating companies. To opt out of Google’s network of interest-based advertising, visit adssettings.google.com.

    These opt-out mechanisms rely on cookies to remember your choices with respect to ad-serving on websites. If you delete your cookies, use another computer or device, or change browsers, you will need to repeat this process. In addition, opting out of interest-based ads will not opt you out of all ads, but rather only those ads that are personalized to your interests based on activities observed on our Site and/or web sites or mobile apps not owned and operated by Transformco.

    We participate in the Adobe Marketing Cloud Device Co-op. This helps us understand how you use our website and apps across different devices to better tailor content based on your interests. You can learn more about how Adobe does this and manage your preferences at https://cross-device-privacy.adobe.com/.

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    My Information Secure?

    We maintain reasonable and appropriate physical, electronic and procedural safeguards to protect your PII. While we work very hard to protect your privacy, no method of security is 100% effective, and we cannot be responsible for the actions of those who may gain unauthorized access to your PII. Transformco makes no warranties, express, implied or otherwise, as to the ultimate effectiveness of its reasonable and appropriate safeguards.

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    How Can I Access My Information?

    You can personalize your experience on this Site and other Transformco Sites by becoming a Registered User or Member. By registering, you will be able to tell us what products and services interest you, and whether you wish to receive information about special sales, promotions and other events. Once registered, you can submit, review and maintain your account profile information at any time by accessing your profile from within the particular Site. Your account information is accessible by using a password that you select or, if available and you choose to enable this feature, by using social networking login credentials for other non-affiliated sites such as Facebook or Google.

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    Can I "Opt-Out" of Receiving Promotional Emails?

    From time to time, we may send you emails with promotional offers and messages. If you would no longer like to receive emails with promotional offers and messages from this Site, you can unsubscribe from these emails by following the unsubscribe link located at the bottom of each promotional email. Please note that you may still receive transactional notices in email or other non-promotional emails (e.g. order confirmations, shipping notices, account statements, or important information regarding a product you have purchased) which will not have an unsubscribe link as they are not marketing emails.

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    California Residents

    This California Consumer Privacy Act (CCPA) Notice (“Notice”) applies to California residents that are “Consumers” as defined by the CCPA and is a supplement to Transformco’s other privacy policies or notices, including the remainder of the Privacy Policy on this page. In the event of a conflict between this Notice and the remainder of the Privacy Policy, or other Transformco privacy policies, this Notice shall govern as to our rights or obligations under the CCPA. Capitalized terms that are used herein shall have the meaning given to them in the remainder of the Privacy Policy except that capitalized terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.

    This Notice covers our Collection, use, and disclosure of Consumers’ Personal Information (PI) for the twelve months preceding the date at the top of this Privacy Policy, except to the extent such PI is exempt from the notice obligations of the CCPA. For example, this Notice does not apply to PI Collected from job applicants, current and former employees and contractors of Transformco, and persons with whom we interact with in their capacity of representing another business. If we Collect information about you in any of these contexts, this Notice will not be applicable to you.

    Collection, Use and Disclosure of PI

    The table below describes each category of PI we Collect and includes examples of types of PI that may fall into a specific category. We Collect the below categories of PI directly from you, your Device or browser, our Vendors (defined in the table below), suppliers, public databases, social media platforms, and data append services. We Collect, use and share the PI we Collect for the Business Purposes in the bulleted list below. We share your PI for our Business Purposes with the categories of recipients set forth in the table below.

    Business Purposes

    • Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services
    • Detecting security incidents and protecting against malicious, deceptive, or illegal activity
    • Debugging the Site to identify and repair errors
    • Internal research and development
    • Quality and safety assurance, and improving, upgrading, and enhancing the Site and our products and services
    • Processing and managing interactions and transactions on the Site and our products and services

    Category of Personal Information

    Categories of Recipients of
    Business Purposes Disclosures

    1. Identifiers (e.g., name, nicknames, aliases, social media handles, contact information including email, phone, and address, User IDs, passwords, IP addresses, device IDs, account names and numbers)

    Vendors that assist us in providing the Site, our products and services, and/or running our internal business operations (“Vendors”); Analytics and advertising partners

    2. Personal Records (e.g., education, employment history, financial account information)

    Vendors

    3. Personal Characteristics and traits (e.g., age, gender, household information, marital status, veteran or military status)

    Vendors

    4. Customer Account Details / Commercial Information (e.g., purchase history or service history)

    Vendors

    5. Internet Usage Information (e.g., browsing history, referring URLs, search history, interactions with advertising links, mobile application usage, social media information linked to your account with us)

    Vendors; Analytics and advertising partners

    6. Geolocation Data (e.g., your location we infer based on your IP address)

    Vendors; Analytics and advertising partners

    7. Sensory Data (e.g., voice recordings from call centers, profile photos you place on your Shop Your Way profile, or security video footage from our stores)

    Vendors

    8. Professional or Employment Information (e.g., education level, employment status)

    Vendors

    9. Inferences from PI Collected (e.g., customer profiles including shopping preferences, product preferences, customer characteristics and behaviors)

    Vendors; Analytics and advertising partners

    Your CCPA Rights

    Right to Opt-Out of Sale of Personal Information

    We may disclose your PI for the following purposes, which are not a Sale under the CCPA: (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.

    We do not believe that cookies operated by our vendors that facilitate online advertising or other activities in connection with our online services, which themselves Collect and share PI, are a sale by us of your PI under the CCPA. However, we provide Consumers who use our online services a way to manage their cookie preferences based on categories of cookies through our management tool available here. You will need to do this on each browser that you use to access our Site, and clearing cookies on your browser(s) may disable your preference settings.

    In addition, some third-party cookie operators that Collect PI in connection with our online services for advertising, analytics and other purposes offer you the ability to opt-out of their own downstream Sales. Please visit here to opt-out of the Sale of PI by these third parties. This is a third-party program and we are not responsible for its effectiveness. You must opt-out on every Device and browser you use in order to effectuate your requests to opt-out of the Sale of PI by these parties. For more information on how to exercise choices regarding cookies and interest-based advertising, see the section above titled "Interest-Based Ads - Online Advertisements"

    Some browsers have signals that may be characterized as do-not-track signals, but like many website operators, we currently do not understand them to operate in that manner or to signify a request to opt-out of the Sale of your PI. We understand that various parties are developing signals to communicate such requests, and we may recognize certain such signals if we conclude such a program is appropriate.

    Rights to Know and Delete Personal Information

    California Consumers have the right to exercise certain privacy rights under the CCPA. Any request you submit to us is subject to an identification and residency verification process. We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we Collected PI.

    If you are unable to provide us with certain information about yourself or, in some cases, about your transaction history with us, we will be unable to verify your identity to fulfill a request to know or delete. As an initial matter, we require you to provide your name, address, email address, and phone number to be submitted via our online request form or toll-free telephone number below. In some cases, we may verify identity by confirming that you are the owner of the email address we have on file. For your specific pieces of information, as required by the CCPA, we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above.

    Some PI we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s PI (e.g., clickstream data tied only to a Pseudonymous browser ID). As required by the CCPA, we do not include that PI in response to verifiable Consumer requests. If we cannot comply with a request, we will explain the reasons in our response.

    We will make commercially reasonable efforts to identify Consumer PI that we Collect, Process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

    You may use an authorized agent who meets the agency requirements of the CCPA to submit a consumer rights request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.

    a. The Right to Know

    i. Categories

    You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

    • The categories of PI we have Collected about you.
    • The categories of sources from which we Collected your PI.
    • The Business or Commercial Purposes for our Collecting or Selling your PI.
    • The categories of third parties to whom we have shared your PI.
    • A list of the categories of PI disclosed for a Business Purpose in the prior 12 months, or that no disclosure occurred.
    • A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred. If we Sold your PI, we will explain:
      • The categories of your PI we have Sold.
      • The categories of Third Parties to which we Sold PI, by categories of PI Sold for each Third Party.

    ii. Specific Pieces

    You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have Collected in the period that is 12 months prior to the request date and are maintaining.

    Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

    b. The Right to Deletion

    You may request that we delete your PI that we have Collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not Collect directly from you. Exceptions do apply, including, without limitation, where we need to retain your PI for regulatory reasons, to complete a warranty or other contract with you, or other internal uses of the information that are compatible with the context in which you provided it.

    To exercise the right to know or right to delete, you may submit a request by calling us at 888-527-6415 or online at https://transformco.com/privacy/request. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so. Transformco will not discriminate against any consumer for exercising these rights.

    Notice of Financial Incentive and Non-Discrimination

    This Financial Incentives and Non-Discrimination Disclosure applies to loyalty and rewards programs run by Transformco. Currently we operate the Shop Your Way Program (“Shop Your Way” or the “Program”). A separate notice for it follows below. We may add or change programs and/or their terms by posting notice on the program descriptions, so check them regularly. We will not discriminate against you if you exercise any of the rights provided by the CCPA. You can opt-out of non-Program marketing emails or delete your PI from our active marketing lists and retain your Program account and benefits.

    a. Rewards Program Financial Incentive Notices

    Program

    Incentive Offered

    Material Terms

    How to Opt-In

    Shop Your Way

    Your Shop Your Way account earns points for purchases at eligible stores, special offers, and eligible credit card purchases. Points are accumulated to earn Rewards that may be redeemed for discounts on future purchases.

    ·        Available at participating merchant brands.

    ·        Categories of PI Collected:

    o   Identifiers (e.g., name, email address, telephone number, zip code)

    o   Personal Records (e.g., signatures, financial account information).

    o   Personal Characteristics and Traits (e.g., age, gender, household information, marital status, veteran or military status)

    o   Customer Accounts/Commercial Information (e.g., purchase history, service history)

    o   Internet Usage Information (e.g., IP address, activity logs, browsing history)

    o   Geolocation Data (e.g., your location we infer based on your IP address)

    o   Sensory Data (e.g., voice recordings from call centers, profile pictures on accounts)

    o   Professional or Employment Information

    o   Inferences from PI Collected (e.g., customer profiles including shopping preferences, product preferences, customer characteristics and behaviors)

    ·     Register for an account online or on the mobile app.

    Participating in Shop Your Way is entirely optional but is subject to additional Shop Your Way Program Terms and Conditions.

    We treat the value of Consumer data Collected through the Program as the equivalent of relevant expenses related to the Collection and retention of Consumers’ PI as part of the Program. We value the benefits of the Shop Your Way Program as the value of rewards given to members, which are outlined in the Shop Your Way Program Terms and Conditions.

    We pay these expenses and provide the Program benefits, which vary depending upon Program participation, to foster a positive relationship with our members that is invaluable.

    California Consumers may make a PI deletion request under the CCPA by calling us at 888-527-6415 or online at https://transformco.com/privacy/request.  If this request includes deleting your email address, then it will terminate your Program membership because that information is necessary for us to provide the Program. Upon a termination request, some Program data associated with the terminated account may be retained for record keeping, tax reporting, and other legally permissible purposes.

    California Shine the Light Law

    California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. Separate from your CCPA opt-out rights, you have additional rights regarding disclosure of your information to third parties for their own direct marketing purposes.

    We do not share personal information with third parties for their direct marketing purposes. If you are a California resident, you may request information about our compliance with Shine the Light by contacting us at dataprivacy@transformco.com or by sending a letter to

    Transform SR Holding Management LLC
    ATTN: Legal Intake/Privacy
    3333 Beverly Road
    Hoffman Estates, IL 60179

    Any such request must include “California Shine the Light Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

    As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately

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    Nevada Residents

    Nevada consumers have the right to instruct website operators to not sell certain personal information to third parties (often called “data brokers”) who will license or sell your information to other companies. Transformco does not sell such information to data brokers and we have no plans to ever do so. If we consider selling this information in the future, we will update this privacy policy to give you notice of this change and provide a formal method for Nevada consumers to exercise their opt-out rights under that law.

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    Where Is My Information Stored??

    Your PII may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our Site, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than in your country. This Site is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.

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    How May I Contact You?

    If you have any questions about this Privacy Policy, please contact us at dataprivacy@transformco.com. Because email communications are not always secure, please do not include credit card or other financial information, health or prescription-related information, or other sensitive information in your email to us. If you prefer to contact us via US Mail, please address your inquiry to

    Transform SR Holding Management LLC
    ATTN: Legal Intake/Privacy
    3333 Beverly Road
    Hoffman Estates, IL 60179