Privacy Policy

Last Updated: June 30, 2023

Clarus Direct, LLC, d.b.a. FreeShipping.com ("FreeShipping.com", "we," "us"), is the owner of the site www.FreeShipping.com (the "Site") and has developed this Privacy Policy, which details important information regarding the collection, use and disclosure of user information collected on the Site. FreeShipping.com provides this Privacy Policy to help you make an informed decision about whether to use or continue using the services found at its Site ("Services").

This Privacy Policy is incorporated into and subject to the Terms of Use and Terms of Service. Each time that you access or use the Site or our Services, you signify that you agree to be bound by the Terms of Use, the Terms of Service, and this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you must discontinue using the Site and accessing the Services available on the Sites.

I. INFORMATION WE COLLECT

1. Information Provided by You.

Registration and Membership. We will collect personal information from you when you visit our Site, sign up for our Services, interact with our Site, register with us, or use various features of our Site.  We only collect your personal information as described herein and for the purposes described herein. In order to register on our Site, you must first complete the registration form providing contact information (such as name, email, and address). To become a member, you must also provide billing information (such as credit and/or debit card account information).

Surveys and Sweepstakes. From time to time, we may request information from users or members via surveys or sweepstakes. Participation in these surveys or sweepstakes is completely voluntary, and you therefore have a choice whether or not to disclose this information. Contact information may be used to notify the winners, award prizes, and file winners as required by law. Survey information will be used for purpose of the survey, including for the monitoring or improvement of the use and satisfaction of the Site.

 

2. Information Collected About Your Use of the Site and Services.

Web Logs. Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) in order to improve security, analyze trends, and administer the Site. We may track your movement within the Site and through our offers on affiliate websites, the pages from which you were referred, access times, and browser types. This information may include the browser you are using, the Internet address from which you linked to our Site, the operating system of your computer, the unique IP address of the computer you used to access our Site, and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness of our Site, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather broad demographic information.

Cookies. To help make sure you receive information that is relevant to you, our Site and advertisements on affiliate sites use data "cookies." We use session cookies to make it easier for you to navigate our Site. A session ID cookie expires when you close your browser. We use persistent cookies to differentiate visitors to our Site from registered users and members, to customize the content of certain sections of the Site, and to enable us to track and cater to the interests of users, in order to enhance their experience on the Site. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "help" file. Cookies help us learn which areas of our Site are useful and which areas need improvement. You may configure your browser to prevent cookies from being set on your computer. If you reject cookies, you may still use the Site, but your ability to use some areas of the Site may be limited, and you may not be able to use certain features of the Site.

Web Beacons. Our web pages contain "web beacons." Web beacons allow us to count users that have visited a web page or opened an email that contains a web beacon and collect other types of aggregate information. Using this information, we are able to measure the effectiveness of our advertising and how visitors use our Site. This allows us to learn what pages are most attractive to our visitors, which parts of our Sites are the most interesting, and what kind of offers our registered users like to see. Some of the web beacons that are in place on our Site are used only by us, and other web beacons are from our affiliates, vendors, and advertisers, which use this data to assist us in analyzing how our offers and Site are accessed and used.

Ad Serving. You may see certain ads on other websites because we work with advertising partners to engage in remarketing and retargeting activities. We and third parties may collect information about your online activities over time on our website to provide you with advertising about offers tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. For example, we may use Remarketing with Google Analytics Remarketing, Demographics and Interest Reporting and Google Display Network Impression Reporting. You can learn more about interest-based advertising and about the options available to limit these third parties’ collection and use of your information by visiting http://optout.aboutads.info/#!/ and http://optout.networkadvertising.org/#!/.

Supplemental Information. We may supplement information you give us with information from other sources, such as information to validate or update your address, payment card, or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to enable us to fulfill our products and services, to target our communications so that we can inform you of products, services, and offers that may be of interest, and for internal business analysis or other business purposes. In the event that additional information is requested from a member to support a claim made under a specific benefit provided, we will use this information to validate the nature of the claim. This may include contacting the retailer where a purchase was made to verify that an item was purchased, the amount paid, if a benefit was utilized, or if an item has been returned.

II. HOW WE USE YOUR INFORMATION

We use your personal information for enrollment and billing purposes; to verify customer membership; to fill customer orders; to process and issue payments; and for any other purposes identified or implied at the time of collection or described in this Policy. If we have trouble processing an order or payment, the information may be used to contact you. When you provide us with information in connection with a particular activity or otherwise register for our Services or provide your contact information, including an email address or telephone number in connection with that activity, product, or service, you agree that this action constitutes a purchase or inquiry establishing a business relationship with us. You consent to us communicating with you regarding future information about our Services using the information you provided to us. With your consent, we may contact you with pre-recorded calls and calls and text messages to your mobile telephone number (including use of automated dialing equipment). We may also use any information that you provide to us to inform you of other company products and services, including reaching out to you if you started but did not complete a product registration process (where permissible).

Service Providers. We may use third-party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending emails, processing and approving orders, order fulfillment, processing and issuing payments, sweepstakes administration, and state filings. We may also work with third parties to serve ads to you as part of a customized campaign on other websites or platforms. We may share your personal and account information with these third parties for those limited purposes. Our third party service providers are required to agree with our privacy standards, and when required, provide information regarding their compliance to relevant privacy and security standards. Our service providers may be located outside of your country of residence, in which case that country's courts, governments or law enforcement agencies could obtain disclosure of your information in accordance with that country's laws.

Strategic Partners. We have entered into agreements with third-party-affiliated companies to enable us to provide our Services in connection with sales our members have made with those companies, such as shipping fees charged by those companies. In certain situations, we may provide your information to those companies informing them of your membership or to investigate a claim or inquiry regarding any benefit you may make pertaining to our Services and your interactions with those companies.

Other Uses: We may use your personal information to contact you about the Services on our Site for which you have expressed an interest; for example, if you have contacted customer service or made an inquiry. Unless prohibited by law, we may also use information you provide to us, such as your email address, when you start, but do not finish, the registration process for the Services.

Announcements. We may send you service-related announcements and emails from time to time relating to your account. These include emails such as order confirmations, renewal/expiration notices, and payment-card problem notifications. We may also send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if any service is temporarily suspended for maintenance, the delivery of a service is delayed, or if there is some service issue with something you might have requested, we might send you a notice. Even if you have opted out receiving marketing communications from us, please be aware that we may still contact you with these service-related messages.

Legal Matters; Safety. We may, without your express consent, access and disclose your information, any communications sent or received by you, and any other information that we may have about you or your account as may be permitted or required by law (including, but not limited to, court order or subpoena), or to prevent or investigate suspected fraud, violations of our Terms and Conditions, or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information in situations that we believe to be emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat.

Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets, or otherwise, or in the event of an insolvency, bankruptcy, or receivership, personal and non-personal information of our visitors and registered users and members may be one of the assets sold or merged in connection with that transaction. Information about our visitors may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support, or funding. In such transactions, personal information will be subject to the pre-existing Privacy Policy in effect when the information was obtained.

III. ACCESS TO YOUR INFORMATION

If you have an online account with us, you also may choose to resign and deactivate your account at any time. Please visit our "FAQ" for removal information for your particular product. After you close your account, you will not be able to sign in to our Site or access any of your personal information. If for any reason you are concerned that the personal information you provided to us is not correct and you cannot change it by accessing your account, or should you wish to have your email address removed from our mailing list or contact information changed, please contact us at the contact information below. We will be happy to review, update, or remove information as appropriate. If you deactivate your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, resolve disputes, enforce our Terms of Use, Terms of Service, or other policies, or take actions we deem necessary due to technical and legal requirements and constraints related to the security, integrity, and operation of our Site. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties' policies.

IV. SECURITY

Security. It is our intent to protect against the loss, misuse, or alteration of information that we have collected from you or received from a partner. We use a variety of current technologies and processes intended to protect our customer data. We limit the information we provide to outside companies with whom we contract to only what they need to carry out their responsibilities. It is our practice to use encryption whenever we receive or transmit sensitive data.

We protect the personal information within our custody or control with appropriate organizational, technological and physical safeguards. We store personal information in electronic and physical files that are secure, and our security measures include secure on- and off-site storage, restricted access to records and data processing equipment, password protocols, and encryption and security software. We conduct audits and monitor compliance with our privacy practices. For example, when you enter credit card information on our registration or order forms, we encrypt that information using Secure Sockets Layer technology (SSL). You can easily determine when you're sending data securely by looking at the Web address (URL) in your browser window: The first few letters will change from "http" to "https" when you are transmitting information protected by SSL encryption (the "s" in "https" stands for "secure").

However, despite our efforts, no system can completely guarantee that there will never be unauthorized access to your personal information, and your use of the Site indicates that you are willing to assume this risk.

V. CHOICE AND OPT OUT

Where applicable, we will seek your express consent to contact you, including by way of a commercial electronic message such as email or a text message. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions in the message, for example by clicking “Unsubscribe”. You can also remove your information from our database so as not to receive future promotional communications or to close your account by emailing us at [email protected] or sending mail to the following address:

FreeShipping.com
PO Box 290728
Wethersfield, CT 06129-0728

Please note that changes may not be effective immediately. In each event, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personal information removed from our database. We will endeavor to comply with your request as soon as reasonably possible.

Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the products or services we provide to you, or if you contact us with an inquiry.

VI. IMPORTANT DISCLOSURES, PRACTICES, AND CONTACT INFORMATION

Links to other sites. To the extent that hyperlinks may be utilized to access external or third-party sites, or if you come to our Site through a link from any such third-party sites, you should be aware that these external or third-party sites are not controlled by us and, therefore, are not subject to this Privacy Policy. We recommend that you check the privacy policies of these sites to determine how your personal information will be utilized by the proprietors of those third-party sites.

A Note To International Users. The Site is hosted in the United States. If you are accessing the Site from outside the United States, by providing your information to the Site, you are consenting to the transfer of your information to the United States for processing and maintenance in accordance with this Privacy Policy and our Terms and Conditions. You are also consenting to the application of United States law in all matters concerning the Site.

Children's Privacy. The Site is not directed or intended for children under 13 years of age. We do not knowingly collect Personal Information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide Personal Information on the Site.

Changes to the Privacy Policy. We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the Site, with the "Effective Date" posted at the top of the Privacy Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make any material changes to our Privacy Policy or how we handle your personal information, you will know because the Effective Date of the Privacy Policy will change. If we are going to use any personal information in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will give you a reasonable opportunity to consent to the change. If you do not consent, your personal information will be used as agreed to under the terms of the Privacy Policy in effect at the time we obtained that information. By accessing our Site or Services after the Effective Date, you are deemed to consent to our then-current Privacy Policy. We will use information previously obtained in accordance with the Privacy Policy in effect when the information was obtained from you.

Applicable Law. If you choose to visit the Site, your visit and any dispute over privacy is subject to this Privacy Policy, our Terms of Service, our Terms of Use, including limitations on damages, and governing law. By visiting the Site, you agree that the laws of the State of Connecticut, without regard to its conflict-of-laws principles, govern this Privacy Policy and any dispute of any sort that might arise between us or our affiliates. We participate in the Better Business Bureau's BBBOnLine Program. This means that we have committed to cooperating with BBB efforts to resolve disputes that may arise from your use of access to the Site or our products or services. Upon your request, we will agree to participate in a BBB dispute resolution process to resolve these disputes. There are limits as to the kinds of claims that the BBB will handle; call the BBB for more information. Other than for those disputes resolved through the BBB dispute resolution process, you consent to exclusive jurisdiction and venue in the courts of Connecticut.

Your California Privacy Rights. Under California Civil Code sections 1798.83-1798.84, California residents are entitled to receive a notice describing what categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. This notice identifies the categories of information shared and includes a list of the third parties and affiliates with which it may be shared, along with their names and addresses. This notice appears below in the section entitled, “FreeShipping.com Personal Data Processing Disclosure”.

A California consumer may make the following requests as relates to their personal data collected on FreeShipping.com under the rules of California Civil Code Section 1798.100 , using our Individual Rights Request process:

• Access: A consumer may request that Freeshipping.com disclose information collected about the consumer by Freeshipping.com
• Data Portability: A consumer may request that FreeShipping.com transfer any data it has collected and maintains about the consumer to the consumer for the purpose of transferring it to another entity.
• Correction: Once a consumer has access to their information, the consumer may request correction of their information maintained by Freeshipping.com
• Deletion: A consumer has a right to request deletion of personal information that Freeshipping.com collected from the consumer

An authorized Agent may make this request on your behalf. For the protection of our members, access to the inbox for to the member’s registered email address will be required to verify the request.

Please see the “Summary of Categories of Personal Information Processed” and “Summary: Categories of Personal Information Shared” tables below for a summary of the Personal Information that we collect in the course of providing you with services.

Click here to submit an Individual Rights Request.

See below for the metrics required by Section 1798.185 of the California Civil Code (CCPA)

Consumer Requests - Freeshipping.com
Reporting Period	Type	Number of Requests	Fulfuilled (%)*	Denied(%)**	Avg.Number of Days to Fulfill Requests
2022	Request to Know	0	N/A	N/A	N/A
	Request to Opt-out †	0	N/A	N/A	N/A
	Request to Delete	10	10 (100%)	0 (0%)	27
† : This site does not sell consumer data; this metric is included in this table as required by law.
* : This site fulfills deletion requests through anonymization.
** :Requests may be denied for any of the reasons outlined in the CCPA, including but not limited to fraud prevention.
These metrics are provided as required under Section 1798.185 of the California Civil Code.

 

Your Colorado Privacy Choices. Colorado residents are entitled to certain rights as relates to their personally identifiable information.

Using our Individual Rights Request process, a Colorado consumer may make the following requests as relates to their personal data collected on FreeShipping.com:

• Access: A consumer may request to know what personal data FreeShipping.com has collected about them.
• Data Portability: A consumer may request that FreeShipping.com provide a copy of any data it has collected and maintains about the consumer to the consumer
• Correction: Once a consumer has access to their information, the consumer may request correction of their information maintained by Freeshipping.com
• Deletion: A consumer has a right to request deletion of personal information that Freeshipping.com has collected from or about the consumer
• Opt Out: A consumer may request that FreeShipping.com not process the consumer’s personal data for (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling that may impact the opportunities the site provides to you.

An authorized Agent may make this request on your behalf. For the protection of our members, access to the inbox for to the member’s registered email address will be required to verify the request.

Please see the “Summary of Categories of Personal Information Processed” and “Summary: Categories of Personal Information Shared” tables below for a summary of the Personal Information that we collect in the course of providing you with services.

Click here to submit an Individual Rights Request.

 

Your Connecticut Privacy Choices. Connecticut residents are entitled to certain rights as relates to their personally identifiable information.

Using our Individual Rights Request process, a Connecticut consumer may make the following requests as relates to their personal data collected on FreeShipping.com:

A Connecticut consumer may make the following requests as relates to their personal data collected on FreeShipping.com under the rules of the Connecticut Data Privacy Act, using our Individual Rights Request process:

• Access: A consumer may request to know what personal data FreeShipping.com has collected about them.
• Data Portability: A consumer may request that FreeShipping.com provide a copy of any data it has collected and maintains about the consumer to the consumer
• Correction: Once a consumer has access to their information, the consumer may request correction of their information maintained by Freeshipping.com
• Deletion: A consumer has a right to request deletion of personal information that Freeshipping.com has collected from or about the consumer
• Opt Out: A consumer may request that FreeShipping.com not process the consumer’s personal data for (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling that may impact the opportunities the site provides to you.

An authorized Agent may make this request on your behalf. For the protection of our members, access to the inbox for to the member’s registered email address will be required to verify the request.

Please see the “Summary of Categories of Personal Information Processed” and “Summary: Categories of Personal Information Shared” tables below for a summary of the Personal Information that we collect in the course of providing you with services.

Click here to submit an Individual Rights Request.

 

Your Virginia Privacy Choices. Virginia residents are entitled to certain rights as relates to their personally identifiable information. Using our Individual Rights Request process, a Virginia consumer may make the following requests as relates to their personal data collected on FreeShipping.com:

• Know: A consumer may request to know if Freeshipping.com is processing their personal data
• Access: A consumer may request that Freeshipping.com disclose information provided by the consumer to Freeshipping.com
• Data Portability: A consumer may request that FreeShipping.com provide a copy of any data it has collected and maintains about the consumer to the consumer.
• Correction: Once a consumer has access to their information, the consumer may request correction of their information maintained by Freeshipping.com
• Deletion: A consumer has a right to request deletion of personal information that Freeshipping.com has collected from or about the consumer
• Opt Out: A consumer may request that FreeShipping.com not process the consumer’s personal data for (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling that may impact the opportunities the site provides to you.

An authorized Agent may make this request on your behalf. For the protection of our members, access to the inbox for to the member’s registered email address will be required to verify the request.

Please see the “Summary of Categories of Personal Information Processed” and “Summary: Categories of Personal Information Shared” tables below for a summary of the Personal Information that we collect in the course of providing you with services.

Click here to submit an Individual Rights Request.

 

Summary of Categories of Personal Information Processed

Below is a summary of the Personal Information that we collected in the course of providing you with services:

Category	Examples	Processed by FreeShipping.com
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license, or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary codes.	No
K. Inferences drawn from other personal information.	Profile a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes
L. Sensitive Personal Information (Cal. Civ. Code § 1798.140(ae)).	Social security number, precise geolocation, racial or ethnic origin, personal information collected and analyzed concerning health.	No

Summary: Categories of Personal Information Shared

We may use or disclose Personal Information in the following categories in the course of providing services (the “Business Purpose Disclosures” in the table below).

Category	Providing the Program Services, Security and Fraud Prevention	Sold	Shared	Used for Targeting Advertising	Used for Regulated Profiling
A. Identifiers.	Yes	No	Yes	No	No
B. Personal information categories listed in the California Customer Records statute	Yes	No	Yes	No	No
C. Protected classification characteristics under California or federal law.	No	No	No	No	No
D. Commercial information.	Yes	No	Yes	No	No
E. Biometric information.	No	No	No	No	No
F. Internet or similar network activity.	Yes	No	Yes	No	No
G. Geolocation data.	Yes	No	Yes	No	No
H. Sensory data.	No	No	No	No	No
I. Professional or employment-related information.	No	No	No	No	No
J. Non-public education information	No	No	No	No	No
K. Inferences drawn from other personal information.	Yes	No	Yes	No	No
L. Sensitive Personal Information (Cal. Civ. Code § 1798.140(ae)).	No	No	No	No	No