FOREVER 21 PRIVACY POLICY
Last Updated: October 25, 2023
This Privacy Policy describes how F21 OPCO, LLC (“Forever 21,” “we,” or “us”) collects, uses, discloses, and otherwise processes information about you. This Privacy Policy applies to information we collect when you access or use our websites or mobile applications that link to this Privacy Policy (collectively, our “Services”), or when you otherwise interact with us, such as in our stores, through our customer support channels or marketing campaigns, at an event, or on social media. We may provide different or additional notices of our privacy practices for certain products, services, or activities, in which case those notices will supplement or replace the disclosures in this Privacy Policy.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
CONTENTS
COLLECTION OF INFORMATION
The information we collect about you depends on how you interact with us or use our Services. In this section, we describe the categories of information we collect and the sources of this information.
Information You Provide to Us
We collect information you provide directly to us. For example, we collect information directly from you when you create an account, make a purchase, submit or post content through our Services (including product reviews and other user-generated content), communicate with us via third-party platforms, participate in our contests, sweepstakes, or promotions, sign up for rewards or marketing communications from us, participate in a research panel, request customer support, or otherwise communicate with us.
The types of information that we collect include your name, email address, billing address, shipping address, phone number, username and password for a Forever 21 account, gender/gender identity, body measurements and body type, month and day of birth, social media handle, videos, images, information about your lifestyle, shopping habits, interests, and hobbies, and any other information you choose to provide.
If you make a purchase from us, we work with a third-party payment processor to collect and process your payment information.
Information We Collect Automatically
We automatically collect certain information about your interactions with us or our Services, including:
- Transactional Information: When you make a purchase, exchange, or return, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
- Device and Usage Information: We collect information about how you access or use our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services and your interactions with our ads and communications (such as the routes by which you access our Services along with access dates and times), browsing behavior (such as pages viewed, links clicked, information about your activity on a specific page, and items placed in your cart or added to your wish list), and information about your interactions with our emails.
- Precise Geolocation Information: With your consent, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Location Information section below for details).
- Audio and Video Recordings, Photos, and Chat Content: We capture photographs and video recordings in our stores for security and loss prevention purposes. If you contact customer service through our chat feature or by phone, we may monitor and retain those conversations, including for training purposes.
- Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies, pixels, web beacons, APIs, clear GIFs, and SDKs to collect information about your interactions with the Services. These technologies help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. For more information about the cookies and other tracking technologies we use and how to disable them, see the Targeted Advertising and Analytics section and the Cookies and Similar Tracking Technologies section below.
Information We Collect from Other Sources
We are part of the SPARC Group and may receive information about you from other brands in our corporate family. We also obtain information from other sources, such as:
- Your friends or family members who invite you to participate in our referral programs;
- Marketing partners, including joint marketing/co-branding partners, data co-ops, data brokers, and marketing, advertising, and analytics companies;
- Service providers and vendors, including fraud prevention providers, mailing list providers, fulfillment partners, and shipping carriers;
- Social media sites or similar third-party services when you like, follow, or share Forever 21 content on Facebook, Twitter, Instagram or similar sites; and
- Financial institutions and partners that operate Forever 21’s credit card program.
The types of information we collect from other sources include your contact information (such as name, phone number, and postal address), device and usage information (such as IP address and inferred geolocation), demographic information (such as age and gender), information about your occupation and household, and information about previous purchases, product preferences, interests, and shopping habits.
Additionally, if you create or log into your Forever 21 account or interact with us through a third-party platform (such as Facebook, Amazon, or Google), we will have access to certain information from that platform, such as your profile information, profile picture, user ID associated with your third-party platform account, and any other information the third-party platform discloses about you, in accordance with the authorization procedures determined by such platform.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.
USE OF INFORMATION
We use the information we collect to provide, maintain, improve, and develop our products and services and personalize your experience with us. We also use the information we collect to:
- Send you technical notices, security alerts, support messages and other transactional or relationship messages;
- Communicate with you about products, services, promotions, and events offered by Forever 21 and others and provide news and information that we think will interest you (go to our Marketing Opt-Out Form for information about how to opt out of these communications at any time);
- Provide and administer our rewards program;
- Monitor and analyze trends, usage, and activities in connection with our products and services;
- Target advertisements to you on third-party platforms and websites (for more information, see the Targeted Advertising and Analytics section below);
- Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
- Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of Forever 21 and others;
- Comply with our legal and financial obligations.
TARGETED ADVERTISING AND ANALYTICS
We engage others to provide analytics, serve advertisements, and perform related services across the web and in mobile apps. These entities may use cookies, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of our Services and other websites and mobile apps, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information is used to deliver advertisements targeted to your interests on other companies’ sites or mobile apps and to analyze and track data, determine the popularity of certain content, and better understand your online activity. You can opt out of cookie-based ad targeting on our website by following the prompts here and on our mobile app by navigating to the app’s settings and adjusting your preferences. Your opt-out choice will be linked to your browser only; therefore you will need to renew your opt-out choice if you visit our website from a new device or browser, or if you clear your browser’s cookies. You can also learn more about interest-based ads or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance by visiting www.aboutads.info/choices if you reside in the United States, https://youronlinechoices.eu/ if you reside in Europe, or https://youradchoices.ca/ if you reside in Canada.
In addition to cookie-based ad targeting, we may disclose your identifiers, such as your email address(es) and phone number(s), to some of our advertising partners. These advertising partners translate that information into a unique identifier that can then be used to show ads that are more relevant to you across the web and in mobile apps. Depending on where you reside, you may opt out of these disclosures by filling out our web form.
DISCLOSURES OF INFORMATION
We disclose (or permit others to directly collect) information about you. We disclose personal information as described in this Privacy Policy and in the following ways:
- We disclose personal information to vendors, service providers, contractors, and consultants that need this information to provide services to us, such as companies that assist us with web hosting, shipping and delivery, payment processing, financing, fraud prevention, customer service, marketing, advertising, and analytics.
- We may disclose personal information to data co-ops and data brokers to expand the reach and effectiveness of our marketing campaigns and other third parties for their own marketing purposes. Depending on where you reside, you may opt out of these disclosures by filling out our web form.
- We are part of the SPARC Group and may disclose information about you to other brands in our corporate family, including for their marketing and advertising purposes. Depending on where you reside, you may opt out of these disclosures by filling out our web form.
- We disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- We disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Forever 21, our users, the public, or others.
- We disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- We disclose personal information in connection with, or during negotiations of certain corporate transactions, including the merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- We disclose personal information when we have your consent or if you direct us to do so.
We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. Forever 21 processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.
CHILDREN'S PRIVACY
Our Services are not designed for children under the age of 13. If you are a parent or legal guardian and you believe that a child has provided personal information to us without your consent, please contact us at [email protected].
YOUR PRIVACY CHOICES
Account Information
You can access, modify, and delete certain information stored within your online account by logging into your account at any time.
Communications Preferences
You may opt out of receiving text messages and promotional emails from Forever 21 by following the instructions in our Marketing Opt-Out Form or in those communications, or by logging in to your account and navigating to the “My Preferences” tab. If you opt out of such communications, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Location Information
When you first launch any of our mobile apps that collect precise location information, you will be asked to consent to the app’s collection of this information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device.
Cookies and Similar Tracking Technologies
Forever 21 uses cookies and similar tracking technologies to analyze visits to our websites and interactions with our communications to help us improve our website, services, and marketing campaigns. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies or click here to disable targeting cookies. Note that removing or rejecting certain cookies could affect the availability and functionality of our Services.
Mobile Push Notifications
With your permission, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
ADDITIONAL INFORMATION FOR CUSTOMERS RESIDING IN CERTAIN U.S. STATES
California, Colorado, Connecticut, Utah, and Virginia have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Laws”). If you are a resident of one of these states, this section applies to you.
Additional Disclosures
Our Privacy Policy explains how we collect, use, and disclose information about you, as well as our targeted advertising and analytics practices. Below, we use two different tables to explain this same information in accordance with the State Laws. The tables describe our data practices now and over the past 12 months.
Collection, Use, and Disclosure of Personal Information for Business Purposes
| Categories of Personal Information | Categories of Recipients | Use of Personal Information |
|---|---|---|
| Identifiers (such as your name, email, and IP address) | Advertising and marketing partners, other brands in our corporate family, Internet service providers, research and data analytics providers, providers of Forever 21’s sweepstakes and other programs, operating systems and platforms, payment processors, fulfilment partners, customer support partners, event partners, fraud prevention partners, cloud service providers |
|
| Characteristics of protected classifications under California or U.S. federal law (such as your age and gender) | Advertising and marketing partners, other brands in our corporate family, Internet service providers, research and data analytics providers, providers of Forever 21’s sweepstakes and other programs, operating systems and platforms, payment processors, fulfilment partners, customer support partners, event partners, fraud prevention partners, cloud service providers | |
| Commercial information (such as records of products you purchased) | Advertising and marketing partners, other brands in our corporate family, Internet service providers, research and data analytics providers, operating systems and platforms, payment processors, fulfilment partners, customer support partners, event partners, fraud prevention partners, cloud service providers | |
| Internet and electronic network activity (such as information about your activity on our websites) | Advertising and marketing partners, other brands in our corporate family, Internet service providers, research and data analytics providers, operating systems and platforms, providers of Forever 21’s sweepstakes and other programs, payment processors, fulfilment partners, customer support partners, event partners, fraud prevention partners, cloud service providers | |
| Approximate geolocation data (such as your city of residence) | Advertising and marketing partners, other brands in our corporate family, Internet service providers, research and data analytics providers, payment processors, fraud prevention partners, operating systems and platforms, cloud service providers | |
| Audio or visual data (such as call recordings when you contact customer service and CCTV footage from our stores) | Internet service providers, other brands in our corporate family, operating systems and platforms, providers of Forever 21’s sweepstakes and other programs, customer support partners, fraud prevention partners, cloud service providers | |
| Inferences (such as inferred information about your shopping preferences) | Advertising and marketing partners, other brands in our corporate family, research and data analytics providers, customer support partners, Internet service providers, operating systems and platforms, fraud prevention partners, cloud service providers | |
| Sensitive personal information (such as your precise geolocation data) | Research and data analytics partners |
Personal Information that we “Share,” “Sell,” or Use for “Targeted Advertising”
We disclose the following categories of personal information to third parties to engage in targeted advertising and other marketing activities, including to expand the reach and effectiveness of our own marketing campaigns and for third parties’ own marketing purposes. These disclosures may be considered “sales” or “sharing” or use of personal information for “targeted advertising” under certain State Laws.
| Categories of Personal Information | Categories of Third Parties |
|---|---|
| Identifiers (such as a hashed version of your email address or cookie IDs) | Joint marketing campaign partners, advertising and marketing networks, other brands in our corporate family, data co-ops, data brokers |
| Characteristics of protected classifications under California or U.S. federal law (such as your age and gender) | Advertising and marketing networks, other brands in our corporate family |
| Commercial information (such as records of products you purchased) | Joint marketing campaign partners, advertising and marketing networks, other brands in our corporate family, data co-ops, data brokers |
| Internet and electronic network activity (such as information about your activity on our websites) | Joint marketing campaign partners, advertising and marketing networks, other brands in our corporate family |
| Inferences drawn from your personal information to create a profile (such as inferred information about your shopping preferences) | Joint marketing campaign partners, advertising and marketing networks, other brands in our corporate family |
Other Details About our Information Practices
- We collect personal information directly from you (for example, when you place an order from our website or make a purchase at one of our stores), automatically when you access or use our Services or shop in our stores, and from third-party sources such as joint marketing partners, each described in more detail in the Collection of Personal Information section above.
- We do not knowingly collect, sell, or share personal information about consumers under the age of 16.
- We generally do not collect information that is considered “sensitive” under State Laws. In the limited circumstances that we do, such as precise geolocation data, we do not use or disclose such sensitive personal information for the purpose of inferring characteristics about you.
- Our retention periods for personal information are based on business needs and legal requirements. We retain personal information for as long as is necessary for the processing purpose(s) for which we originally collected it and for other business purposes explained in this Privacy Policy. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired. In addition, we retain your email address and information about your marketing preferences to ensure that we can honor those preferences.
Your Privacy Rights
Opt Out of Sales, Sharing, and Targeted Advertising
Some of the activities described in the Targeted Advertising and Analytics section above may be considered “sales” or “sharing” of your personal information or use of your information for “targeted advertising” under the law that applies to you. You can opt out of cookie-based ad targeting on our website by following the prompts here and on our mobile app by navigating to the app’s settings and adjusting your preferences. You will need to renew your opt-out choice if you visit our website from a new device or browser or if you clear your cookies because your opt-out choice will be linked to your browser only. If you reside in California, you can also opt out of web-based ad targeting by visiting our website with a legally-recognized opt-out preference signal enabled, such as the Global Privacy Control.
In addition to cookie-based ad targeting, we may disclose information about your purchases and contact information (such as email and mailing address) to our affiliates, advertising partners, and other third parties for marketing and advertising purposes, which may constitute “sales” or “sharing” of your personal information or use of your information for “targeted advertising.” You can opt out of having your information disclosed to these third parties by filling out our web form.
Access, Correction, and Deletion
You have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information. To request access, correction, or deletion of your personal information, please fill out this form or call our toll-free number at 1-888-494-3837. We will verify your request by asking you to provide certain information, such as your name, email address, mailing address, and phone number. You can also access, modify, and delete certain information stored within your online account by logging into your account at any time.
Appeals
If we deny your request, you may appeal our decision by contacting us at [email protected]. If you have concerns about the results of an appeal, you may contact the attorney general in the state where you reside.
Nondiscrimination
We will not discriminate against you for exercising your privacy rights.
Authorized Agents
If you reside in California, you can designate an authorized agent to submit a privacy rights request on your behalf. We may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may be required to contact the individual who is the subject of the request to verify his or her own identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a California resident, please fill out our web form.
If you are an authorized agent seeking to make an opt-out request for a consumer in California, Colorado, or Connecticut, please fill out this web form.
Notice of Financial Incentives
We provide discounts, rewards, or other benefits to customers who download our mobile app or sign up to receive our marketing emails or text messages. These offerings may constitute “financial incentives” or “bona fide loyalty programs” under certain state privacy laws (for simplicity, we refer to these collectively as “financial incentives”). If you participate in a financial incentive, we collect personal information from you, such as identifiers (like your name, email address, and phone number), commercial information (like your purchase history), and inferences drawn from your personal information (like your product preferences and interests). We disclose this information to our service providers, contractors, and consultants who perform services on our behalf, to other brands in our corporate family, and to our marketing and advertising partners, including for the purposes of engaging in targeted advertising and other marketing activities.
You can opt into a financial incentive by following the sign-up or participation instructions provided and you can opt out at any time by following the unsubscribe instructions in the applicable program’s terms and conditions, promotional emails, or text messages, or contacting us at [email protected]. If you request that we delete any of your personal information that is essential to providing you with the financial incentive, we will not be able to provide you with the benefits of that program (e.g., if you ask us to delete your email address, we will no longer be able to provide you with early access to sales or other benefits via email). In some cases, we may provide additional terms and conditions, which we will provide to you when you sign up. The value of your personal information is reasonably related to the value of the offer or discount presented to you.
Shine the Light
California’s Shine the Light law permits residents of California to request certain details about how their information is disclosed to third parties for direct marketing purposes. Under the law, Forever 21 must either provide this information or permit California residents to opt in to, or opt out of, this type of disclosure. Forever 21 qualifies for this alternative option. To opt out of having information about you disclosed to our affiliates or other third parties for direct marketing purposes, please fill out this form.
ADDITIONAL INFORMATION FOR CUSTOMERS RESIDING OUTSIDE THE U.S.
International Customers
If you are making a purchase on our website that will be shipped outside of the United States, such purchase is made through a separate company, Global-e, rather than Forever 21. When you purchase through Global-e, the information you provide and other transaction information is received by both Global-e and Forever 21 (except for payment information, which is processed exclusively by Global-e or its payment processors). Forever 21 will handle this information in accordance with this Privacy Policy. Global-e and its payment processor will handle this information in accordance with Global-e’s (or the payment processor’s) privacy policy. If you have questions about how Global-e collects, uses, and discloses your personal information, please contact Global-e or review its privacy policy.
Cross-Border Data Transfers
Forever 21 is based in the U.S. and we process and store personal information on servers located in the U.S. We also use service providers to process personal information, and they may be located in, or have servers in, the U.S. and other countries. Where required by law, we provide adequate protection for the transfer of personal information in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, executing Standard Contractual Clauses, or complying with another approved data transfer mechanism. Where relevant, you may request a copy of these Standard Contractual Clauses by contacting us at [email protected].
Data Retention
Our retention periods for personal information are based on business needs and legal requirements. We retain personal information for as long as is necessary for the processing purpose(s) for which we originally collected it and for other business purposes explained in this Privacy Policy. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired. In addition, we retain your email address and information about your marketing preferences to ensure that we can honor those preferences.
Additional Disclosures for Canada
If you reside in Canada, this section applies to you. You may exercise your rights to access and correct the personal information we hold about you by emailing us at [email protected]. By submitting personal information to us or our service providers, you consent to the collection, use, disclosure, and transfer of your personal information in accordance with this Privacy Policy and as permitted or required by law. You may withdraw your consent at any time by emailing us at [email protected]. If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that we may not be able to provide you with certain products, services, or information.
Additional Disclosures for Europe
If you reside in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, this section applies to you.
When we process your personal information, we will only do so when:
- We need to use your personal information to perform our responsibilities under our contract with you, for example to deliver products that you ordered from us.
- We have a legitimate interest in processing your personal information. For example, if you are a customer, we may process your personal information to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
- We find such processing is necessary to comply with our legal obligations.
- We have your consent to do so. When your consent is the legal basis for our processing, you may withdraw such consent at any time by emailing us at [email protected].
You have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, (3) request correction of inaccurate personal information, (4) request restriction of processing of your personal information, and (5) object to the processing of your personal information for certain purposes. To exercise any of these rights, please email [email protected]. If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
- For individuals in the EEA, click here.
- For individuals in the UK, click here.
- For individuals in Switzerland, click here.
CONTACT US
If you have any questions about this Privacy Policy, please contact us at:
Forever 21 ATTN: Privacy 110 E. 9th Street #A500 Los Angeles, CA 90079
1-888-494-3837 [email protected]