Privacy Policy

We may collect personal information ("— 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 personal information from you—either directly or via one of our vendors—in other ways, including, without limitation, if you choose to subscribe to our emails; participate in sweepstakes, contests, surveys, and polls; post content or suggestions on this Site; or use any of the 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.

We may use the information we collect 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 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.

We may also use the personal information we collect 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.

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.

We use session replay technology to observe your mouse movements, scrolling, and clicks on our Sites. We use these tracking tools for support and analytics purposes, and to better understand how people engage with our Sites. This information is often collected and processed by our service providers who we have engaged to analyze this information on our behalf. By using our Sites, you consent to our (or our service provider's) collection, use, and retention of this information using session replay technology.

We may engage vendors to provide certain interactive features on our Site. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on the Site to assist you and for other customer service purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the personal information obtained through the feature to provide the service on our behalf.

Generative AI Services - We use generative AI services, including through our phone services and website chatbot functionality which collect certain information you provide when you use these services as well as information about your visit to our Site and use of our services. In addition to the information you may provide through your use of these services, the following information may also be collected, IP address, device ID, or other unique identifiers; details about your use of our site; and general information about Site traffic data, performance, and related statistics, etc.

• All information you submit through our AI services may be used for a variety of purposes, including automated processing, including improving our products or services; quality improvement; or training, including continuous training of generative AI services. Note that submission of confidential or proprietary information could be compromised if submitted to our AI services and should not be submitted. In addition, please note that records of these communications will be maintained.

Other personal information may be collected from you by means of cookies, pixel tags (also called web beacons or clear gifs), local shared objects and other tracking technologies (collectively "Cookies"). 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, advertising and marketing, 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 share your personal information 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 personal information to identify you to anyone to whom you send messages through this Site. You may disclose your own personal information 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 personal information 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 personal information, 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 personal information 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 personal information 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.

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.

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 personal information in a manner that is not permitted by Children's Online Privacy Protection Act ("COPPA"). If you are under 13, do not provide any personal information to us. If we obtain actual knowledge that we have collected children's personal information 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 personal information, you can contact us at 1-866-441-2964 and we will delete their personal information to the extent required by law.

We are committed to providing you with the means to manage your information when you are a minor. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, you may request and obtain removal of content or information you have publicly posted. If you are under 18 and would like to remove content you posted to one of our Sites, you can contact us at (888) 527-6415. Please note that fulfillment of the request may not ensure complete or comprehensive removal (for example, if the content or information has been reposted by another user). Additionally, please note that we are not required to erase or otherwise eliminate content or information if: (a) other state or federal laws require us or a third party to maintain the content or information; (b) the content or information was posed, stored, or republished by another user; (c) the content or information is anonymized so that the minor cannot be individually identified; (d) the minor does not follow our instructions posted in this policy for requesting removal; or (e) the minor has received compensation or other consideration for providing the content. Further, nothing in this policy is intended to limit the authority of a law enforcement agency to obtain the applicable content or information.

This Site may contain links to other sites that are not under our control. These websites have their own policies regarding privacy. You should review those policies when visiting the websites. We are not responsible for the content or policies of those sites.

Some of our Sites participate in online advertising networks that display advertising based on your visits to this Site and other websites. This practice is generally known as "interest-based advertising," and it allows companies to tailor advertising to your interests. When you visit one of our Sites, technology from our advertising partners may place anonymous cookies on your computer to enable customized advertising when you visit other participating websites. You can opt out of interest-based advertising by visiting the Digital Advertising Alliance (DAA) opt-out page or the Network Advertising Initiative (NAI) opt-out page. If you are in the European Union, you can opt out at the European Digital Advertising Alliance (EDAA) site. Please note that opting out will only prevent targeted ads, so you may continue to see generic (non-targeted) ads.

We use reasonable security measures to protect the personal information collected by this Site. However, we cannot guarantee that personal information will not be subject to unauthorized disclosure. You are solely responsible for maintaining the secrecy of any password and/or account information. Please be careful and responsible whenever you're online.

If you are a Registered User, you can access and change your account information, including contact information, payment information, and communication preferences by logging into your account and visiting your profile page.

You can choose not to receive promotional emails from this Site by following the "unsubscribe" instructions in promotional email communications from us. Please note that you may still receive certain email communications such as account statements and other informational emails.

California Consumer Privacy Act

This section of our Privacy Policy provides information for California residents in connection with the California Consumer Privacy Act ("CCPA"). Under the CCPA, and for purposes of this section, "Personal Information" generally means information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

The CCPA provides California residents with the following rights:

Information: You have the right to request information about our Personal Information practices, including the categories of Personal Information we collect, the sources of that information, the business purposes for collecting it, and the categories of parties with whom we share Personal Information.

Access: You have the right to request a copy of the Personal Information that we have collected about you in the 12 months before your request.

Deletion: You have the right to request that we delete Personal Information we have collected from you, subject to certain exceptions.

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.

If you are a resident of a Regulated State, subject to certain conditions and restrictions set out in the VCDPA, CPA, CTDPA, MTCDPA, OCPA, TDPSA, UCPA and other applicable laws, you have the following rights with regard to your "Personal Data" (as defined in the VCDPA, CPA, CTDPA, MTCDPA, OCPA, TDPSA, and UCPA):

• 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.
• Right to confirm. You have the right to confirm that we are processing your Personal Data.
• Right to correct. You have the right to request that we correct inaccuracies in your Personal Data.
• Right to delete. You have the right to request that we delete Personal Data that we have collected from or obtained about you.
• Right to opt out of Sales. While we do not Sell your Personal Data for monetary consideration, we do disclose your Personal Data for Targeted Advertising. This disclosure of Personal Data for Targeted Advertising may constitute a Sale in certain Regulated States and residents may opt out by managing cookie preferences. Please see below for more information on how to opt out of Targeted Advertising via cookies.
• Right to opt out of Targeted Advertising. You may request that we stop disclosures of your Personal Data for Targeted Advertising.
• 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.
• Right to appeal. If you are unsatisfied with our actions related to our resolution of your privacy request, you may appeal our decision.
• 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.
• Right to obtain a list of Third Parties. Oregon consumers may also request a list of Third Parties to which we disclosed Personal Data.

We Process Personal Data, including personal identifiers, internet or other electronic network activity information, and geolocation data for Targeted Advertising purposes. You have the right to opt out of our use of your Personal Data for Targeted Advertising. Information on how to exercise your opt-out rights as well as other rights you may have are described below.

We may Sell or share the categories of Personal Data listed below to the following categories of Third Parties: advertising and analytics partners.

• Personal identifiers;
• Internet or other electronic network activity information; and
• Geolocation data

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 visiting. You may exercise your other privacy rights here. 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. 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. Residents of Regulated States may also contact us at dataprivacy@transformco.com.

Additional Disclosures for Colorado Residents

Below is a description of our online and offline information practices and other disclosures required by the Colorado Privacy Act

You can learn more about the categories of Personal Data and Sensitive Data that we have collected about Consumers and the purpose for processing your Personal Data by visiting the What Type of Information Do We Collect and How Do We Use It?

Information about our Bona Fide Loyalty Program

Please see our Shop Your Way Loyalty Program and Financial Incentive Disclosure, which describes our Personal Data collection practices for our Bona Fide Loyalty Program.

We may offer loyalty programs and other financial incentives to customers. The value we provide to you through these programs is reasonably related to the value of your Personal Information to us. The value of your Personal Information to us is based on the additional revenue we generate from the customer engagement, retention, and acquisition facilitated by the additional Personal Information you provide through participation in the program. To calculate this value, we consider factors such as the expense related to the collection, storage, and use of Personal Information, the revenue generated from customers who participate in the financial incentive relative to customers who do not, the revenue attributable to products or services offered as part of the financial incentive, and the anticipated retention rate of customers. To opt-in to our financial incentive program, please follow the sign-up instructions provided at the time the financial incentive is offered. You can opt-out of a financial incentive program at any time by contacting us at the information provided below.

Some states provide their residents with additional rights regarding our use of their personal information. California, Virginia, Colorado, Connecticut, Utah, Montana, Oregon, Texas, and other states provide their residents with rights to:

• Confirm whether we process their personal information
• Access and delete certain personal information
• Data portability
• Opt-out of personal data processing for targeted advertising and sales
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects
• Correct inaccuracies in their personal information

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.

If you have any questions about this Privacy Policy, please contact us at (888) 823-0650. Because voicemail 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 voicemail 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 Team
5407 Trillium Boulevard, Suite B120
Hoffman Estates, Illinois 60192