Online Privacy Policy

This Policy was last updated April 19, 2022 


Happy Nation Brand Management, LLC (“Happy Nation”) respects your concerns about privacy. This Online Privacy Policy ("Policy") explains what personal information we collect through our websites and online services when you visit, how we use that information, to whom we disclose it, and how we safeguard personal information. Unless indicated otherwise, this Policy applies only to personal information collected through the websites, microsites, mobile applications, and other online services of Happy Nation that expressly adopt, display, or link to this Policy, and then only to the extent indicated (collectively, the “Services”).

California Residents: See the Supplemental Privacy Notice for California Consumers section below.

Collecting and Using Personal Information

1.    Information You Provide

When you visit our Services, you may provide us with certain personal information, such as your name, address, phone number, email address, personal preferences, payment card number, purchase and ordering information, demographic information, responses to survey questions, sizing information and any other information you choose to provide. Our Services may also give you the option to upload product reviews.


We collect this information at various places on our Services, such as when you check out with your online order, subscribe to email offers, and mobile messaging offers; participate in surveys; enter contests or sweepstakes; or interact with special-event or program offers.


We may also collect information that you provide on our Services about people you know. For example, we collect your gift recipient's contact information to process your gift orders. We may also collect contact information about your friends and family members when you participate in one of our refer-a-friend programs. In these instances, we may send a message to your friend or family member on your behalf (so please only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the message from you).


2. Information Your Devices Provide Automatically
When you interact with our Services, we obtain certain information by automated means, including the following:


A. Location Information
We may obtain information about your location when you access or use our Services: for example, via your browser information and other similar device or browser attributes (like IP address), or our mobile applications. For more details, please see the Your Choices section below.

B. Navigational Information

When you access our Services, your computer, phone, or other device may provide navigational information, such as browser type and version, service-provider identification, IP address, the site or online service from which you came, and the site or online service to which you navigate.

C. Device Information 

We also may obtain information about the computer or mobile device you use to access our Services, such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network information, and website or app usage behavior.

D. Cookies, Clear Gifs and Similar Technologies

To better understand how you interact with our Services, we may collect information using cookies, clear-gifs (also known as web beacons or web bugs) and similar technologies.

o A cookie is a small amount of data that's stored by your browser on your device. It's used to do things like see how you navigate our Services, what you click on, remember you and your online purchases when you return, and recognize you and honor a special deal for you, when you redeem one of our offers from a third party's site. This helps us improve and deliver our Services, provide better customer service, tailor and improve your online experience, and tailor offers to you based on your unique tastes and a combination of your online interactions and purchase history.


o A clear gif is a nearly invisible pixel-sized graphic image on a web page, web-based document or email message. It helps us do things like view the URL of the page on which the clear gif appears and the time the site, document or email in question is viewed; and recognize you and honor a special deal for you, when you navigate from a third party's site to redeem one of our offers that may have appeared there. Clear gifs in emails help us confirm the receipt of, and response to, our emails, including those that you forward to friends and family; and they help deliver a more personalized or better online experience.


o In addition to cookies and clear gifs, we may also use device identifiers, web storage, and other technologies to collect information about your interactions with our content and Services.


These technologies, illustrated above, may be used to help us see which of our interactive experiences online users like most. Cookies, clear gifs, and similar technologies also allow us to associate your online navigational information and purchases and interactions with personal information you provide (such as name, address, phone number, survey responses, and email address). We associate this information to deliver products and services to you; improve our business; transact business; and market our products and services on this and other online services, and through a variety of media like email, mobile advertising, and direct mail.

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

For information about your options with respect to cookies, see Your Choices About Use of Your Personal Information below.
We use the following cookies on our Services.


Cookies Necessary for the Functioning of the Services


Name

Function

_ab

Used in connection with access to admin.

_secure_session_idUsed in connection with navigation through our Services.

cart

Used in connection with shopping cart

cart_sig
Used in connection with checkout.
cart_ts
Used in connection with checkout.
checkout_token
Used in connection with checkout.
secretUsed in connection with checkout.
secure_customer_sigUsed in connection with customer login.
storefront_digestUsed in connection with customer login.
_shopify_uUsed to facilitate updating customer account information


Reporting and Analytics


Name

Function

_landing_page

Track landing pages

_orig_referrer

Track landing pages

_s

Shopify analytics.

_shopify_s

Shopify analytics.

_shopify_y

Shopify analytics.

_y

Shopify analytics.


3. Information Derived Through or Provided by Others

Affiliated entities and vendors may provide us with, or supplement, information about you. We may use this information for a variety of operational or marketing purposes, such as to correct shipping information, market to you, deliver more relevant offers through customer insights, improve our business, and transact business.


4. How We Use the Information We Obtain
 We use the personal information we obtain through the Services to:

A. deliver our Services
B. process your online orders;
C. facilitate payment and transactions;
D. create and manage your online account;
E. personalize your online experience with content and offers that are tailored to your interests;
F. provide customer service and respond to your inquiries and requests;
G. include you in surveys and contests;
H. enable you to post your content, such as reviews and comments;
I. improve our Services, the manner in which offers are made on our Services, and the interactions and experience visitors have with our Services;
J. enable you to interact with third-party content service providers, whether by linking to their sites, viewing their content within our online environment, or by viewing our content within their online environment;
K. market our products and services that may be of interest to you; and
L. create aggregated, pseudonymized or anonymized information for statistical purposes


5. Third Party Analytics and Personalization Services
We may use third-party analytics and personalization services to analyze Services metrics and performance, analyze our visitors’ preferences, and to serve personalized content to you through the use some or all of the technologies described below, such as cookies and clear gifs.
We use Google Analytics to help us understand how our customers use the Site.

You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.

You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.





Use of Technology to Serve our Advertisements on Other Online Services and Your Choices.

On our Services, we and third parties may collect information about your online activities to provide you with advertising about products and services tailored to your interests.
We contract with third-party advertising companies, which may collect information about your use and interactions with the Services, over time and across third-party websites and online services, for use in delivering tailored online display and banner advertising to you on other websites and online services. To serve this advertising, these third-party companies place, use, or rely on the technologies described above, including cookies, clear gifs, device identifiers and similar technologies to obtain information about customer interactions with us through our Services and interactions with other online services. These companies use the information they collect to serve you ads that are targeted to your interests

You can specify your preferences over the use of some of these technologies by opening Cookie Preferences to view or change your preferences (to address future cookie placement).
You may also specify your preferences through a centralized registry. To learn about how to opt out of interest-based advertising, in general, click the following: NAI Opt Out or, DAA Opt Out. Your mobile device settings may allow you to prohibit mobile app platforms (such as Apple and Google) from sharing certain information obtained by automated means with app developers like us and other businesses.




Sharing Personal Information

We may share information about you with certain third parties, as described below, and as otherwise described in this Policy. We do not sell or otherwise share personal information about you, except as described in this Policy.

1. Our Sister Brands
We may share the information we collect about you, such as your postal and email address, customer preferences and purchase history, with affiliated entities that operate our sister brands so they may market to you. Such sister brands include Victoria’s Secret and Victoria’s Secret Pink. We will obtain your consent to this sharing to the extent required by applicable law. If you don’t want this information shared with our sister brands, follow the instructions below in  Your Choices About Use of Your Personal Information .



2. Service Providers and Contractors

We may share personal information with third-party service providers and contractors whom we engage to provide services to us, such as fulfilling orders; processing payments; providing customer service through chat features; monitoring activity on our Services; delivering surveys and related analysis (which could be combined with Services usage analytics); maintaining databases; hosting and operating our websites, mobile websites and mobile applications; administering, sending and monitoring emails and text messages; serving online advertisements as described above; and providing consulting services.


3. Law Enforcement and Emergency Response

We also may disclose personal information about you (a) if we are required to do so by law or legal process (such as a court order or subpoena); (b) in response to requests by government agencies, such as law enforcement authorities; (c) to establish, exercise, or defend our legal rights; (d) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (e) in connection with an investigation of suspected or actual illegal activity; or (f) otherwise with your consent.


4. Sale or Merger

We reserve the right to transfer your information in the event we sell or transfer all or a portion of our business assets (including, without limitation, in the event of a merger, acquisition, joint venture, reorganization, dissolution, or liquidation).


Your Choices About Use of Your Personal Information

1. Email
You may opt out of the Happy Nation email list by following the instructions located at the bottom of each commercial email. You may also submit your request on our email opt-out form. If you opt out of the Happy Nation email list, we may still send you operational or transactional messages, such as password-reset or account related information.

2. Location Information
You may have the ability to turn location-based services on and off by adjusting the settings of your Internet browser or mobile device or, for some devices, by adjusting the permission settings for our mobile apps to access your location information.

3. Cookies and Clear Gifs
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible. Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

You can also visit Use of Technology to Serve our Advertisements on Other Online Services and Your Choices to learn about how to specify your preferences over our use of cookie and similar technologies in connection with online advertising.

4. Our Sister Brands
If you don't want your information shared with our sister brands for those brands’ own direct marketing purposes, please submit your request here.

Information from Children

Our Services are designed for a general audience and are not directed to children. We do not knowingly collect or solicit personal information from children under the age of thirteen (13) (or other relevant ages, which may apply by virtue of applicable law) through our Services. If we become aware that we have collected personal information from a child under such age, we will promptly delete the information from our records. If you believe a child under such age may have provided us with personal information, please contact us as specified in the Contact section of this Policy.

Retention

We will process and keep your personal information for as long as is necessary for the purposes set out in this Policy, for our legitimate business needs, and for compliance with the law.

Do Not Track

Our Services do not respond to "Do Not Track" signals.

Changes to This Policy

This Policy may be updated periodically to reflect changes in our personal information practices. Changes to the Policy will be posted on this page. For significant changes, we will notify you by posting a prominent notice on our Services indicating at the top of the Policy when it was most recently updated.

Contact

If you have general questions about our Policy, or if you would like to make a complaint, please contact us by e-mail at privacy@happynation.com or by postal mail using the details provided below:


ATTN: Happy Nation Privacy Matter
Victoria’s Secret & Co. Legal Department
4 Limited Parkway
Reynoldsburg, OH 43068
US


Protection of Personal Information

We maintain administrative, technical and physical safeguards designed to protect the personal information we collect through our Services against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Our administrative safeguards include implementing, maintaining, and training employees on company privacy and information security policies and procedures.  Our physical and technical safeguards include maintaining physical security policies and standards to protect company systems and data, and a cybersecurity program overseen by our executive leadership team.


California Supplement

If you are a California consumer, the information below (the “California Supplement") also applies to you, in addition to our Online Privacy Policy. Certain terms used in this section have the meaning given to them in the California Consumer Privacy Act found at California Civil Code § 1798.100 et seq and its implementing regulations (the “CCPA”). For clarity, the information below applies to personal information we collect about California consumers both on our Services and any potential offline collection.  This California Supplement does not apply to Happy Nation personnel or job applicants

Collection and Disclosure

a. We may collect (and may have collected during the 12-month period prior to the effective date of this Policy), the following categories of personal information about you:


1. Identifiers (personal) (including, for example, name, postal address, unique personal identifier, online and device identifier, IP address, email address, account name and number, telephone number, postal address, or other similar identifiers).
2. Commercial Information (including, for example, records of personal property; products or services purchased, obtained, or considered; marketing histories; purchasing histories or tendencies; purchase profiles; shopping and retail browsing channel preferences; online browsing and website interaction histories; and direct marketing histories).
3. Personal characteristics, histories, and associations (including, for example, signature; physical characteristics or description; and characteristics of protected classifications under California or federal law).
4. Computing or mobile-device information and internet or other electronic-network-activity information (including, for example, login credentials; online advertisement engagements; and cookies, tags, and similar device or user identifying information).
5. Education and professional information.
6. Financial information (including, for example, banking details and income level).
7. Geolocation information.
8. Inferences (including, for example, predictive information, purchase profiles, shopping profiles and characteristics (e.g., loyalty shopper, cardholder, or online shopper)).
9. Payment card and transaction information (including, for example, credit card number; debit card number, and other financial information).
10. Household information (including, for example, family size and composition).
11. Incident-related information (including, for example, statements; or insurance, or similar claims).
12. Audio and visual information (including, for example, videos you upload with a review).



b. During the 12-month period prior to the effective date of this Policy, we may have collected personal information about you from the following categories of sources:

1. You (for example, through your use of our Services).
2. Your computing or mobile devices.
3. Our technology (for example, through observed consumer interactions with us and through our Services).
4. Our Services and systems.
5. Our vendors.
6. Public records.
7. Our customers’ associations (e.g., through refer a friend or family programs).
8. Social media networks.
9. Advertising networks.
10. Unaffiliated third parties.


c. We may collect or sell (and may have collected or sold during the 12-month period
prior to the effective date of this Policy) personal information about you for the purposes described in the “How We Use the Information We Obtain” section of the Policy and for the following business or commercial purposes:


1. Facilitate accounting, auditing, and reporting.
2. Deliver analytics (machine generated through computing/mobile devices for performance, monitoring, personalization, and order processing).
3. Deliver advertising through technology (including, for example, to facilitate personalized content, remarketing, online display ads, and interest-based ads).
4. Deliver advertising through direct or mass media (including, for example, via email, SMS, telephone, post, and broadcasts).
5. Facilitate affiliate marketing.Administer claims management, handling, and insurance.
6. Respond to incidents.
7. Deliver customer service.
8. Pursue legal matters.
9. Deliver website, mobile-app, and e-commerce services.
10. Facilitate information security.
11. Facilitate fraud monitoring and prevention.
12. Deliver logistics (including, for example, order management, shipping, and fulfillment).
13. Develop customer information for personalization.
14. Process, fulfill, and ship orders.
15. Deliver shopping and customer engagement (including events and experiences, such as contests, sweepstakes, previews, and shows).
16. Deliver social media engagement.
17. Conduct surveys.
18. Administer technology and ensure technology integrity (including, for example, by maintaining and improving networks; and identifying and fixing problems).
19. Process transactions and payments.
20. Develop, review, and test products and services.
21. Perform miscellaneous services.


d. During the 12-month period prior to the effective date of this Policy, we may have shared your personal information with certain categories of third-parties, as described below.

 

Category of Personal Information Collected

Category of Third-Party, to Whom Information is Disclosed for a Business Purpose (as defined under the CCPA)

Category of Third-Party, to Whom Information is Sold (as defined under the CCPA)

Identifiers (Personal) 

• Analytics insights provider

• Advertising vendor

• Direct marketing (e.g., email, text, telephone, postal) vendor
• Affiliated brands and entities
• Contextual online experience provider
 • Customer service provider

• Customer information provider
• Data center
• Event or experience provider
• Focus group service
• Fraud monitoring and prevention
• Human resources service provider
• Information security service provider
• Logistics provider, e.g., order management and fulfillment
• Payment and transaction processor
• Process, services, or technology development or improvement vendor
• Product review vendor
• Social media platform
• Technology administration and integrity provider (including for maintaining and improving networks; identifying problems; and fixing problems)
• Third party, performing services in their own name through an independent consumer relationship, e.g., via consent
• Vendor (miscellaneous) services
 

• Advertising technology provider (including for online advertising)
affiliated brand or entity
 • Affiliate marketer

• Social media platforms

• Survey company

Identifiers (Government-Issued Identification Information) 

• Fraud monitoring and prevention
• Human resources service provider
 • Third party, performing services in their own name through an independent consumer relationship, e.g., via consent

Not applicable

Commercial Information

 

Personal Characteristics, History, and Associations

Inferences (Predictive Information)

 

• Analytics insights provider

• Advertising vendor

• Direct marketing (e.g., email, text, telephone, postal) vendor
• Affiliated brands and entities
• Contextual online experience provider
• Customer service provider
• Data center
• Event or experience provider
• Focus group service
• Fraud monitoring and prevention
• Human resources service provider
• Information security service provider
• Process, services, or technology development or improvement vendor
 • Product and fit tester

• Social media platform
• Solutions (miscellaneous) provider
• Third party, performing services in their own name through an independent consumer relationship, e.g., via consent
 • Vendor (miscellaneous) services

• Advertising technology provider (including for online advertising)
affiliated brand or entity
 • Affiliate marketer

• Social media platforms

• Survey company

Computing or Mobile Device Information, and Internet or Other Electronic Network Activity Information of End Users 

• Analytics insights provider

• Advertising vendor

• Direct marketing (e.g., email, text, telephone, postal) vendor
• Affiliated brands and entities
• Contextual online experience provider
• Data center
• Fraud monitoring and prevention
• Information security service provider
• Solutions (miscellaneous) provider
• Technology administration and integrity provider (including for maintaining and improving networks; identifying problems; and fixing problems)
 • Third party, performing services in their own name through an independent consumer relationship, e.g., via consent

• Social media platform

• Vendor (miscellaneous) services
 

• Advertising technology provider (including online advertising), or
 affiliated brand or entity

• Affiliate marketer

• Social media platforms
 • Survey company

Financial Related Information

• Customer service provider
 • Payment and transaction processor

Not applicable

Login Credentials 

• Third party, performing services in their own name through an independent consumer relationship, e.g., via consent
 • Vendor (miscellaneous) services

Not applicable

Geolocation 

• Analytics insights provider
• Contextual online experience provider
• Customer service provider
• Data center
• Fraud monitoring and prevention
• Human resources service provider
• Information security service provider
• Logistics provider, e.g., order management and fulfillment
• Third party, performing services in their own name through an independent consumer relationship, e.g., via consent
 

Not applicable

Payment Card and Transaction Information

• Customer service provider
• Fraud monitoring and prevention
• Information security service provider
• Logistics provider, e.g., order management and fulfillment
 • Payment and transaction processor

Not applicable

Household Information

• Analytics insights provider

• Direct marketing (e.g., email, text, telephone, postal) vendor

Not applicable

Incident-Related Information

• Information security service provider

• Fraud monitoring and prevention
 • Third party, performing services in their own name through an independent consumer relationship, e.g., via consent

Not applicable


We do not have actual knowledge that we sell personal information of consumers under the age of 16.


California Consumer Privacy Rights

You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

In addition, you have the right to request that we delete certain personal information we have collected from you.


To submit a request, please visit Your Data Rights. To help protect your privacy and maintain security, we take steps to verify your identity before granting access to information or complying with a request. These steps include first verifying the email address you submit with a request. You will receive an email from us with instructions on completing this step. You will be contacted to provide additional verification information, which may include your phone number, billing or shipping address, order history, a copy of a utility bill, emails showing order/shipping confirmation, and/or a signed declaration.


To submit a request as an authorized agent on behalf of a consumer, please visit Your Data Rights, on the form add your email address and include information about the individual for whom you are submitting the request in the other required fields. Please add your name and phone number in the Request Details field and indicate that you are submitting the request as an authorized agent. We will contact you to request information to verify the individual’s identity and your authority to ask on her or her behalf.


To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.


Do Not Sell My Information: You have the right to opt out of the “sale” of your personal information, as that term is defined under the CCPA. To specify your opt-out preferences, visit Do Not Sell My Personal Information.

Shine the Light Rights: Under California law, we also provide you with a cost-free means to opt-out of our sharing your information with third parties with whom we do not share the same brand name, if that third party will use it for its own direct marketing purposes. Follow the instructions here to make you request.


Right to Non-Discrimination for Exercise of Privacy Rights: Under the CCPA, you have the right to not receive discriminatory treatment if you exercise your privacy rights conferred by the CCPA.

Financial Incentive Notice: We sometimes offer exclusive price discounts, rewards, offers, deals, coupons, services and other perks for (1) customers who enjoy our loyalty and rewards programs; (2) recipients of our mailing lists who were presented with a financial incentive to sign up; (3) app subscribers who were presented with a financial incentive to download the app; and (4) applicants or registrants who were presented with a financial incentive for their application or registration (collectively “programs”). Through these program offerings, consumers may provide us with some personal information (e.g., name, postal address, email address, phone number, birth day and month, and other similar forms of personal information) when they opt-in to our programs. There is no obligation to opt in and consumers may opt out. The details of each program are contained in the program offering. We offer these programs to, among other things, enhance our relationship with customers. The value to our business, in the aggregate, of customers’ personal information depends on specific facts, such as whether and to what extent they take advantage of any offerings. We do not calculate the value of the customers’ information for our accounting statements. To the extent we would, however, such valuation could be directly or reasonably related to the cost associated of acquiring or developing such information.

You may opt-in to our programs by signing up in the manner invited for an individual program. And you can opt out of these programs by contacting us at https://happynation.com/pages/contact-us.