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 through 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.

We may provide information about you, which may include PII, to regulatory authorities and law enforcement officials in accordance with applicable law, when we 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.

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 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.

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 (888) 823-0650 and we will delete their PII to the extent required by law.

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 or Member.

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.

Is My Information Secure?

We ​protect your PII using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Although we implement reasonable security measures on our Site, you should be aware that we cannot guarantee the security of your information submitted via the Internet. It is your responsibility to make sure that your passwords and account registration information are secure and not shared with third parties.

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.

California Residents

This California Consumer Privacy Notice section (“California Notice”) applies to Consumers as defined by the California Consumer Privacy Act (as amended the “CCPA”) and should be read along with our other notices found on Transformco.com, and other websites in our family of brands (including but not limited to Sears, Kmart, and ShopYourWay). In the event of a conflict between any other Transformco policy, statement or notice and this California Notice, this California Notice will prevail as to California Consumers’ rights under the CCPA.

This California Notice applies to California Consumers that visit our Site. If you are a current employee of Transformco, you may view your California Notice by visiting MPI. If you are a job applicant, you may view your California Notice by visiting our Careers page. If you interact with us in other contexts and have questions about your privacy rights or our Information Practices you can contact us at (888) 823-0650.

Capitalized terms that are used herein shall have the meaning given to them in the remainder of the Privacy Policy except capitalized terms defined in the CCPA that are used in this California Notice shall have the same meaning as in the CCPA. Unless otherwise noted, the disclosures contained within this California Notice cover our activities in the prior 12 months from the effective date noted atop this Privacy Policy, as well as our current practices.

How and Why We Collect Your Personal Information

We Collect, use, and disclose the categories of Personal Information about California Consumers that are indicated in the chart below. Note that the specific pieces of Personal Information we Collect, use, and disclose about you may vary depending on the nature of your interactions with us, and may not include all of the examples listed.

Sources of Personal Information

We Collect Personal Information directly from you, your devices or browser, vendors that assist us in providing our services and running our internal business operations, data analytics providers, advertising networks, suppliers, public databases, social media platforms, data enrichment services, other companies in the Transformco family of businesses, and other data providers.

Recipients to Which Personal Information is Disclosed

We use Service Providers to help us operate our websites and provide other services on our behalf such as credit and collection agencies, marketing services companies, call center vendors, and field services technicians. Our Service Providers only use Personal Information they Collect or Process on our behalf to provide us services.

Retention of Personal Information

We keep the categories of Personal Information described above for the purposes described in this California Notice or otherwise authorized by law. This generally means holding the Personal Information for as long as one of the following criteria apply:

• to manage our operations, to manage your relationship with us, to provide you with information regarding our products or services, or to satisfy another purpose for which we Collected the information;

• to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was Collected;

• to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or

• we are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.

Where Personal Information is used for more than one purpose, we may retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

Selling and Sharing of Personal Information

We may Sell or Share Identifiers, Internet or other electronic network activity information and/or geolocation data for advertising and marketing purposes with Third Parties including our advertising and analytics partners.

Your CCPA Rights

Right to Opt Out of the Sale and Sharing

You can opt out of Sales and Sharing of your Personal Information in the context of Cookies by clicking on the “Do Not Sell or Share My Personal Information” link in the footer of the Site you are visiting. Opting out will not affect our ability to personalize your experience on our Site. We may still present contextual advertisements or you may still receive non-personalized advertisements that do not rely on “Sales” or “Sharing” to our advertising partners. Because of the way some Third Parties operate, you may need to also opt out on your other browsers and devices. Cookie-enabled opt-out signals may no longer be effective if you block or clear Cookies. For more information on how to exercise choices regarding Cookies and interest-based advertising, see the section above titled " Interest-Based Ads - Online Advertisements ."


We use Service Providers to help us operate our Sites and provide other services on our behalf. Our Service Providers only use Personal Information they Collect or Process on our behalf to provide us services. Opting out will not affect Cookies deployed by our Service Providers.

Opt-Out Preference Signals

You may also opt out of the Sale or Sharing of your Personal Information through an opt-out preference signal. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use.

Non-Discrimination

We will not discriminate against you in a manner prohibited by the CCPA because you exercised your CCPA rights

Rights to Know, Delete and Correct 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 ​Personal Information.

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. In some cases, we may verify identity by confirming that you are the owner of the email address we have on file. For specific pieces of ​Personal Information, we will apply heightened verification standards, and reserve the right to request further information from you.

We will make commercially reasonable efforts to identify Consumer ​Personal Information that we Collect, Process, store, disclose, and otherwise use 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 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:

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 ​Personal Information that we have Collected in the period that is 12 months prior to the request date and are maintaining.Please note that ​Personal Information 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 Del etion

You may request that we delete your Personal Information that we have Collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your ​Personal Information 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.

c. Right to Correct

You may request that we correct Personal Information that we maintain about you if you believe such Personal Information is inaccurate. We may request documentation from you in connection with your request where we have reliable documentation showing the accuracy of the information. As with a Right to Know or Right to Delete request, to protect you, we will require you (or your agent) to be verified before honoring your correction requests. Upon receipt of a verifiable request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the information as you direct. You may be able to correct certain Personal Information that we maintain about you by visiting your “My Account.”

d. Exercise Your Rights

To exercise the right to know, correct, or right to delete, you may submit a request by calling us at (888) 527-6415 or online at by clicking here . 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.

Notice of Financial Incentive

This Financial Incentives disclosure applies to 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 a 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 Personal Information from our active marketing lists and retain your Program account and benefits.

a. Shop Your Way Financial Incentive Notice

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 ShineTheLightCA@transformco.com or by sending a letter to

Transform SR Holding Management LLC
ATTN: Legal Intake/Privacy
TEAM
5407 Trillium Boulevard, Suite B120
Hoffman Estates, Illinois 60192

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.

Virginia Residents

This section applies to Virginia residents that visit our stores, access or use our websites, services, or mobile applications. You can learn more about: the categories of personal data we process here and disclose to third parties here , and the purpose for processing your personal data here .

If you are a Virginia resident, subject to certain conditions and restrictions set out in the Virginia Consumer Data Protection Act (“VCDPA”) and other applicable laws, you have the following rights with regard to your “personal data” (as defined in the VCDPA):

1. Right to access. You have the right to request access to and obtain a copy of any personal data that we may hold about you.
2. Right to correct. You have the right to request that we correct inaccuracies in your personal data.
3. Right to delete. You have the right to request that we delete personal data that we have collected from or obtained about you.
4. Right to opt out of sales. You have the right to opt-out of the sale of personal data. However, we do not sell personal data as defined under the VCDPA, and as such do not offer this right.
5. Right to opt out of targeted advertising. You may request that we stop disclosures of your personal data for targeted advertising.
6. Right to opt out of profiling. You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not engage in profiling that results in any legal or similarly significant effects and as such do not offer this right.
7. Right to appeal. If you are unsatisfied with our actions related to our resolution of your privacy request, you may appeal our decision.
8. Right to non-discrimination. If you choose to exercise any of the privacy rights described above, we will not deny our products or services to you, charge you different prices or provide a different level or quality of products or services to you.

You may opt out of targeted advertising by clicking the “Do Not Sell or Share My Personal Information” link in the footer of the Site you are visting. You may exercise your other privacy rights under the VCDPA here [INSERT link to VA OneTrust Form].

You may also call us at (888) 527-6415. When you submit a request to us, we will authenticate your request to protect your privacy and security and comply with the VCDPA’s requirements. We will use the personal data provided in a privacy rights request only to verify your identity or authority to make the request and to track and document request responses unless you also gave it to us for another purpose.