California Privacy Policy

Last Revised: xx/xx/2021

This Privacy Policy for California Residents (“California Privacy Policy”) supplements the information contained in iMedia Brands, Inc.’s general privacy policy. iMedia Brands, Inc. and its subsidiaries  (“iMedia Brands,” “we,” “us,” or “our”) has adopted this California Privacy Policy in accordance with the notice requirements under the California Consumer Privacy Act and its associated regulations (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this California Privacy Policy.

This California Privacy Policy applies to California residents only and it describes how we collect, use, and share information that relates to you, including through interactions you may have with us outside of our websites or a mobile application. For example, when you call our customer service number.

Definitions Specific to this Policy

The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to our general privacy policy, including the following terms:

Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include publicly available information obtained from government records, deidentified or aggregated consumer information that cannot be reconstructed to identify you, or certain information governed by existing federal laws.

Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by us to another business or a third party for monetary or other valuable consideration.

Service Provider” means for-profit entity that processes information on our behalf and to which we disclose Personal Information for a business purpose pursuant to a written contract.

Third Party” means a person or entity, other than a Service Provider, that collects Personal Information on our behalf or receives it from us.

The Personal Information We Collect and Disclose

The chart below shows the categories of Personal Information we collect; examples of the type of Personal Information in each category; the types of sources from which each category of Personal Information is collected; the business purpose(s) for which that category of Personal Information is collected; and the types of third parties with whom that category of Personal Information is shared. As this chart shows, we disclose certain Personal Information to Service Providers and third parties for business and commercial purposes. We do not sell the personal information of minors under 16 years old without affirmative authorization. This information covers the past 12 months.

Categories of Personal Information Description or Examples Sources of Personal Information Business Purpose(s) for Collection Third-Party Recipient(s) of Personal Information that is Shared or Sold (indicated by italics)
Unique identifiers Name, signature, address, telephone email, account name, SSN, driver’s license number, passport number, online identifier, IP address      
Government ID number Social Security number, passport number, driver’s license or state identification card number      
Physical description Physical characteristics or description      
Financial information Bank account number, credit card number, debit card number, or any other financial information      
Health/medical information Medical information or health insurance information      
Insurance information Insurance policy number or health insurance information      
Protected class data Characteristics of protected classifications under California or federal law, including race, ancestry, national origin, age (40 years or older), marital status, sex, sexual orientation, medical condition, disability, genetics, and veteran or military status      
Purchase history Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies      
Biometric data Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings,
faceprint, voiceprint, keystroke patterns or rhythms, gait
patterns or rhythms, and sleep, health, or exercise data
     
Internet activity Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement      
Geolocation data Longitude and latitude coordinates or other precise geolocation information      
Audio, visual, olfactory information Audio, electronic, visual, thermal, olfactory, or similar information      
Employment information Professional or employment-related information      
Education information Personally-identifiable education information that is not publicly available (e.g. grades or financial aid)      
Inferences Inferences drawn from collected information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes      

 We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.

Access to Your Personal Information

You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12 months.  You may make such a request up to twice in a 12-month span.  Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements.  We will notify you following submission of your request if that is the case.

  • Categories of Personal Information Collected

Deletion of Your Personal Information

You have the right to request that we delete certain Personal Information that we have collected.  Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements.  We will notify you following submission of your request if this is the case.

  • If you would like to request that we delete your Personal Information pursuant to the requirements of the CCPA, click [here] or call [toll-free no]. The link will take you to an interactive webform that you can complete and submit to make a request for deletion that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.

Right to Opt-Out

You have the right to request that we not sell Personal Information that we have collected.  If you exercise that right, please note that pursuant to the CCPA we may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated.  If opting-in is required, we will provide you with the necessary instructions.

  • If you would like to request that we not sell your Personal Information pursuant to the requirements of the CCPA, click [here] or call [toll-free no]. The link will take you to an interactive webform that you can complete and submit to make a request for deletion; if you use the telephone number, you will be guided through a process that will allow you to submit a request.
  • If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that the agent has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.

If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may sell your Personal Information.

You have the right to opt-in to the sale of your Personal Information after you have opted out.  If you would like to opt-in to the sale of your Personal Information, click [here] or call [toll-free no].  Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.

Verification Process

After you submit a request as described in this California Privacy Policy, we will verify your request before providing you with a response.  We will verify your identity by asking you to provide a few pieces of information; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.  After you submit a request, to ensure the privacy and security of our customers’ information, we may reach out to you for additional information if it is needed to verify your identity.

Financial Incentives and Non-Discrimination

We will not discriminate against you if you exercise any of the rights provided by the CCPA set forth in this California Privacy Policy.  Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.

However, we may provide financial incentives to consumers who allow us to retain and disclose their Personal Information.  These incentives may include payments to consumers, a lower price for goods or services, and/or a higher level of goods or services.

The incentive[s] we provide is/are as follows:

  • [short summary of incentive, including material terms]
  • [categories of personal information implicated by incentive]
  • You may withdraw from the incentive at any time. If you have previously opted-in to the incentive below and wish to opt-out, click [here]

To opt-in to the incentive, click [here]

Our incentive is permissible under the CCPA because [description of how the financial incentive is reasonably related to the value of the consumer data].  We estimate that value at $_____, and we arrived at that figure by ___________________.]

Authorized Agents

You may designate an authorized agent to exercise your rights under the CCPA on your behalf. 

Pursuant to the CCPA:

  • Only an individual with power of attorney, or a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
  • We may require that you or the authorized agent do the following:

Provide proof of your signed written permission for the authorized agent to submit a request on your behalf – We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.

Verify your identity with us directly – This does not apply if you have provided a valid power of attorney to the authorized agent.

Personal Information of Minors [Choose one of the two options below]

[[1] We do not sell the Personal Information of minors who are at least 13 years old and less than 16 years old unless those individuals have opted in to the sale of their Personal Information.  To opt in, such a minor must first clearly request to opt in via the link below, after which the minor will be required to separately confirm that election.  As part of that confirmation process, the minor will be informed that he or she has the right to opt out at a later date and what the process is for doing so.

We do not sell the Personal Information of minors who are under 13 years old unless a parent or guardian of that minor affirmatively authorizes the sale of that Personal Information.  We verify that the individual making such an authorization is the minor’s parent or guardian by _________________________ [examples of appropriate verifications in this circumstance are listed in CCPA regulation §§ 999.330(a)(2)(a)-(f)].  As part of that verification process, the parent or guardian will be informed that he or she may opt out on behalf of the minor at a later date and what the process is for doing so.

[[2] Our websites and mobile applications are not intended for children or minors under 16 years old. Accordingly, we do not store information from minors under 16 years old. If you believe that a child has submitted Personal Information to us, please contact us at [insert email].]

Personal Information Metrics

Type of Request Number received Number complied with (in whole or in part) Number denied Median [Mean] number of days to provide a substantive response
Request to Know        
Request to Delete        
Request to Opt-Out        

The above information is for the prior calendar year.

Additional Information

If you would like additional information regarding our California Privacy Policy or need assistance accessing the policy in an alternative format, please [call or email – should be the “manner in which the business primarily interacts with the consumer”] us at [toll-free no. or email address – consider using a dedicated phone no./email for this purpose rather than a generic customer service contact point].

Additional California Privacy Rights

California Civil Code Section § 1798.83 permits users of our website who are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to [insert email ] with the subject “Shine the Light Request.”

You may view our main privacy policy here or contact us at [same specific shine the light email address] or [toll-free no] with any questions.

Changes to Our California Privacy Policy

iMedia Brands reserves the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post an updated notice on our website with a new revised date.