Your Privacy Choices

You may make certain choices with respect to your personal information. Those choices and how you may exercise them are described below. The fact that you have elected to make these choices will have no adverse effect on the price and quality of our products.

PERSONAL DATA DELETION. You may request that we delete any personal information that we have collected from you. However, we may exempt certain information from deletion. For example, we may keep information necessary for security and fraud detection. We also may keep information needed to provide you goods or services. For example, if you ask us to delete your data but retain your loyalty account, we will keep the information we need to continue providing you loyalty benefits. Please note that we do not consider anonymized or pseudonymized information to be “personal information,” and we may “delete” your information by anonymizing or pseudonymizing it.

HOW TO MAKE A REQUEST. You may make a request to know or delete by emailing DataPrivacyOfficer@urbn.com or by calling our toll-free number at (888) 708-0525. When you make a request, we will take steps to verify your identity before responding. This is to protect your information. We will ask you to provide us your email and physical address. If you maintain an account with us, these must match the addresses connected to your account. We will then send you a physical letter to this address with a one-time code. You must email us this code from the email address you provided. Once you do, we will respond to your request.

CONTACT FOR MORE INFORMATION. If you have questions please contact DataPrivacyOfficer@urbn.com.

CHOICE TO OPT OUT OF “SALE” OF PERSONAL INFORMATION You have the choice to opt out of the “sale” of your personal information to “third parties.”

Sale is defined very broadly. We define “sale” more broadly than you might think. It doesn’t just include the exchange of data for money. Instead, it covers any transfer of personal information to a “third party” in exchange for “other valuable consideration.”

We do not transfer your information to third parties in exchange for money and we will not do so. However, we do transfer personal information to certain third parties in order to operate our business (for example, to market our products and services). It is possible that someone could claim that this transfer was in exchange for “other valuable consideration.” We want to be careful with and respectful of your information. Therefore, if you opt out, we will not transfer your information to any “third party” except as explained below.

Opting out may have impacts you don’t expect. Any transfer of data to a “third party” may be considered a “sale” of data. We consider any other business a “third party” unless that business agrees to specific contractual provisions. We try to get all of the businesses to whom we send information to add this special language to their contracts with us. But not everyone will or can agree to those terms.

As a result, if you opt out of the “sale” of data, we will not be able to send data to some of our business partners. That may mean that, after you opt out, you may not receive all of the marketing and other information you are accustomed to receiving from us. In the extreme, if one of our critical partners cannot agree to the special contract language, and is considered a “third party”, it is possible that some features of our web site or other services may not work for you after you opt out.

Minors. We do not “sell” the data of people under 16, and do not intend to collect data related to people who are under 13.

Exceptions to the opt out. Please be aware of the exceptions below.

We will transfer data to a “service provider” even if you opt out. We do not consider that kind of transfer to be a “sale.” A service provider is a business that agrees not to use your information for any purpose other than providing the services specified in our contract. For example, we transfer data to business partners to provide data security and detect fraud. Those businesses are “service providers.” Even if you opt out, we will continue to transfer data to our service providers.

We will also transfer your data to a third party where you direct the transfer or direct us to interact with the third party. For example, if you direct us to use a specific payment method to pay for your order, even if you have opted out, we will still transfer the data necessary to process your order.

Collecting information and using it ourselves is not a “sale.” Opting out of the “sale” of your data does not prevent us from continuing to collect and process your personal information. You can learn more about how and why we collect personal information at our Notice of Collection.

The “opt out” only applies to “personal information.” This is information that is or is capable of being linked to you. We use anonymization and pseudonymization to protect privacy. That data is not “personal information.” Opting out will not limit our transfer of that data to third parties.

Technical limitations on opt out. Please note that there are technical limits to our ability to identify data related to you and, if you opt out, to prevent the “sale” of that information to other parties. Where we can reasonably determine that information relates to you and you have opted out, we will not “sell” it to “third parties” (note exceptions above). However, we may not be able to determine that information relates to you. In that case, the information may be “sold” to a third party.

Opting out is not unsubscribe. Opting out of the “sale” of personal information will not prevent you from receiving marketing messages from us. If you wish to unsubscribe from our emails, please follow the unsubscribe link in one of our emails. If you wish to unsubscribe from text messages, please follow the unsubscribe process for the program you opted into.

HOW TO OPT OUT. If you would like to opt out of the “sale” of your data, you have several options. You may click the opt out button (located at the bottom of this page), you may email us at DataPrivacyOfficer@urbn.com, or you may call us toll free at (888) 708-0525. You will not be required to create an account in order to opt out.

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