Changes to this Privacy Policy

We may change this Privacy Policy from time to time to address changes in applicable laws or our business operations. If we make changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy. We also will inform you in advance of significant changes that may be applicable to you (such as adding a statement to the homepages of our websites or sending you an email notification). If your prior consent is required by applicable laws, we will request your consent to such changes before the revised Privacy Policy becomes applicable to you. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our personal information practices and the choices available to you.


Transaction Information: When you purchase or return a product, we collect information about the transaction, such as product details and the date and location of the purchase/return.

Security Camera Video Data: We collect video data via security cameras that we deploy in some of our retail stores. We provide notice about our use of security cameras as required by law.

Information Collected by Cookies and Similar Tracking Technologies: We (and our vendors) use cookies, web beacons (also known as “tracking pixels”) and similar tracking technologies to collect information about you when you interact with our online Services, customer service chat or emails, such as information about your browsing and purchasing behavior, your device, and your geolocation. We may combine this information with other information we collect about you and use it for various purposes, such as improving our websites and your online experience, understanding which areas and features of our websites are popular, counting unique visits, understanding effectiveness of promotions and other marketing campaigns, personalizing our advertising and communications with you, determining whether J.Crew emails that you receive are opened and whether links within an email have been clicked, and for other similar business purposes. For more information about cookies and how to exercise your cookie preferences.
Personal information we collect from our partners and other sources
We may receive personal information about you from other sources and combine it with information we collect about you. For example, we collect personal information from the local postal services’ national change of address databases to verify and update mailing addresses. If you are a United States customer who applies for a Credit Card, we receive personal information about you, such as your name and address, from the partners that manage our private label credit card program. If you interact with us on social media, we also collect personal information about you from those interactions, such as your username and any other information you choose to provide us as permitted by your social media account settings.

Personal information that we create
We use personal information to draw inferences about you based on personal information that we collect from or about you. For example, we may infer your general location (city, state) based on your IP address when you visit one of our websites, or that you are interested in purchasing a certain type of based on your browsing behavior on our websites or App.


We use personal information about you for various purposes, including to:

Provide, maintain and improve our Services, such as improving your in-store and online shopping experiences;Deliver the products and Services you request, or that are reasonably anticipated within the context of our ongoing business relationship, complete transactions you initiate, perform our contractual obligations and send you related information, such as purchase or delivery confirmations and email receipts or notifications about your order;Process your orders, payments and account adjustments and initiate, render, bill and collect payment for our products and Services;Conduct internal research and development and make business decisions about current and future product and service offerings;Respond to your comments, questions and requests and provide customer service;Communicate with you about products, offers, promotions, rewards and events, and provide news and other information that we think will interest you (for information about how to manage these communications, please see “Your Privacy Choices” here);Manage your online account(s) and send you technical notices, updates, security alerts and support and administrative messages;Personalize your online experience and provide advertisements, content or features that match your profile and interests, including when inferred from your online activity;Monitor and analyze trends, usage and activities;Administer contests, sweepstakes and other promotions, such as processing entries and delivering rewards;Debug and repair errors in our Services and other activities to maintain and improve the quality and safety of our Services;Protect users of our Services from fraudulent, malicious, deceptive, abusive or unlawful activities of others;Debug and repair errors in our products and Services and other activities to maintain and improve the quality and safety of our products and Services;Detect, protect against and prevent security incidents and suspicious activities that may be illegal or unauthorized, investigate complaints and claims and provide other security measures such as identity verification;Protect users of our Services from fraudulent, malicious, deceptive, abusive or unlawful activities of others;Protect the rights, interests, safety or property of J.Crew or our customers, service providers and other third parties;Comply with our legal and regulatory obligations, such as cooperating with law enforcement and responding to governmental requests;Enforce our policies, terms and conditions or other agreements;Defend against or pursue claims, disputes or litigation—in court or elsewhere;Create de-identified data, which is data that cannot reasonably be used to identify you or your browser or device, as permitted by law (once personal information is de-identified as required under applicable privacy laws, it is no longer subject to this Privacy Policy);Provide you the benefits of our loyalty program if you are a member of our loyalty program;Carry out any other purpose described to you at the time the personal information is collected based on the context of our interaction with you; andCarry out any other use as permitted by your consent.


We disclose personal information about you as follows:

With vendors, agents, consultants, contractors and other third parties requiring access to personal information to carry out work on our behalf and improve the products and services they provide to us, such as providers of web hosting, shipping and delivery, payment processing, fraud prevention, analytics, marketing, advertising and customer service;If you are a U.S. customer with a Credit Card, with our banking partner Comenity Bank, the issuer of the Credit Card. Comenity Bank is independent of and has its own privacy and security policies. We encourage you to review those policies carefully;In response to a request or demand for personal information if we believe disclosure is required or otherwise in accordance with any applicable law, regulation or legal process;If we believe your actions are inconsistent, or if disclosure is necessary to enforce compliance, with our user agreements or policies or to protect the rights, property and safety of us or any third party;In connection with, or during negotiations of, any merger, sale of company assets, financing, or transfer of all or a portion of our business to another company;With our current and future parents, affiliates, subsidiaries and other companies under common control and ownership;With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests;By publicly posting, at our discretion, your product review or other user content if you provide one; andWith your consent or at your direction.
We allow our e-commerce partner, U.S. Direct E-Commerce Limited (trading as “ESW”) (based in County Dublin, Ireland), to directly collect personal information from you for the purposes of facilitating ordering and shipping internationally. The information collected by ESW is treated in accordance with ESW’s privacy notice and practices, not this Privacy Policy.

We may use your personal information to send you marketing communications. Except as described in this Privacy Policy, we will not share your Personal Information with third parties for their own direct marketing purposes.

We may also share aggregated or de-identified information which cannot reasonably be used to identify you. Before we share de-identified information with any third party, we require that each recipient of such information agree not to reidentify or allow reidentification of the de-identified data.


We may offer sweepstakes, contests and other promotions, including promotions jointly sponsored or offered by third parties. If you voluntarily choose to enter a sweepstake, contest or other promotion, we collect your information and may disclose it to co-sponsors and other business partners, such as for posting a winners list. By participating in a promotion, you agree to the official rules or terms and conditions that govern that promotion (“Promotion Terms”). Promotion Terms may include personal information handling practices that are different from what is described in this Privacy Policy. If the practices described in Promotion Terms differ from the practices in this Privacy Policy, the Promotion Terms govern but solely to the extent of the differences between the Privacy Policy and Promotion Terms. Please review the relevant Promotion Terms carefully before you participate in any promotion. You can find our Notice of Financial Incentives here.


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 purposes described above. We also retain personal information as long as necessary to comply with legal obligations, resolve disputes and enforce our agreements. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired.


We engage third parties to serve advertisements on our behalf across the Internet and to provide analytics services. These third parties may use cookies, web beacons and other technologies to collect personal information about your use of our websites, such as your IP address, web browser, pages viewed, time spent on pages, links clicked, conversion information, and use of our App. This personal information may be used by us and others to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our websites and other websites and better understand your online activity and similar data analytics among other things.

We may use Google Analytics, Adobe Analytics, or other vendors for analytics services. These vendors use cookies and other tracking technologies to help us analyze how the Services are used. Information generated by these vendors, such as IP address and usage information, is transmitted to and stored by these vendors in the U.S. or elsewhere. These vendors use this information to compile reports for us on use of the Services and related analytics.
We also may work with third parties (such as Facebook and Instagram) to serve ads to you as part of a customized campaign on their platforms. If you prefer not to see customized ads from us, you can usually opt out by changing your account settings or preferences on those platforms.


uses technical, physical and administrative safeguards intended to protect you and your personal information. gndnw takes reasonable security measures appropriate to the level of information we maintain. You are responsible for maintaining the security of your account credentials.


The Services are intended for a general audience and not directed to children under age 13. We do not, in providing the Services, knowingly collect personal information from children. We do not knowingly Sell or Share the Personal Information of Consumers under age 16.

If you think we may have unknowingly collected Personal Information of a customer under age 16 or if you have reason to believe that a child under age 13 has provided personal information to us via our Services, please contact us immediately at and we will endeavor to delete the child’s personal information as required by applicable law.


Your online gndnw account
You may update, correct or delete certain information stored with in your online gndnw and/or Madewell accounts at any time by logging into your account and navigating to the “My Account” page. To delete your online account(s), please write to If you request account deletion, we may retain certain personal information (such as transaction information) as permitted or required by law. We may also retain cached or archived copies of personal information about you for a certain period of time.

Opting out of promotional communications
You can opt out of receiving promotional communications from us at any time.

To opt out of direct mail (such as catalogs and postcards), please contact us at opt out of promotional emails and text messages, please follow the instructions provided in those communications or contact us at
Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails related to your account or an ongoing transaction you made with us.

You can stop all collection of data generated by your use of our App by uninstalling it. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features by adjusting the permissions in your mobile device and/or the App’s settings. To learn more about how you can control permissions using your mobile device’s operating system settings, please review the mobile device’s support pages.

Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser settings to remove or reject cookies. (Each browser offers different options and settings, so you may need to set them separately if you use different browsers or devices to access our Services.) Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our websites.

Some of the advertisers and vendors that perform advertising-related services for gndnw and third parties participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. Others are members of the Network Advertising Initiative (“NAI”).

Please note that opting out through the mechanisms above means that those businesses agree not to deliver certain interest-based advertising to you. You may continue to receive non-targeted digital advertisements.

In addition, we may serve digital advertisements on other online services that are targeted to reach people on those services that are also identified on one of more of our databases (“Matched List Ads”). This is done by using tracking technologies or by matching common factors between our databases and the databases of the other online services. For example, we may use targeted advertising services offered by Facebook, Pinterest and other third-party services. You control these advertisements through your account on those services, not our Services.


We process and store the personal information that we handle in the U.S. We may transfer personal information across borders to any of the places where we and our vendors and partners do business. These other places may have data protection laws that are different from (and, in some cases, less protective) than the laws where you reside.

If you are based outside the U.S., we transfer your personal information to, and process your personal information on, servers located in the U.S., a jurisdiction that may not provide equivalent levels of data protection as your home jurisdiction. These transfers and processing of your personal information are necessary to provide our Services.


Data controller

We process your personal information described above:

As necessary to fulfill our responsibilities under our contract with you (e.g., processing payments for and providing the products you have ordered);As necessary for our legitimate interests, including our interest in providing relevant and secure Services and improving our Services and products;As necessary to comply with our legal obligations; orAs consistent with your consent, which you may revoke at any time.
gndnw legal bases for processing
The legal bases for our processing of your personal information depend on the context in which the personal information is collected and processed. Generally, we only process personal information:

As necessary to perform our contract with you (e.g., processing payments for and providing the products you have ordered);When the processing is in our legitimate interests and not overridden by the privacy or other fundamental rights and freedoms of users, including our interest in securing the Services and improving our Services and products. If we process personal information in reliance on our legitimate interests (or those of any third party), this interest is to provide our Services and communicate with you about our Services and for responding to queries, improving the Services, advising users about new features or products, maintenance, undertaking marketing activities and similar commercial interests to make the Services available for you. We may have other legitimate interests and if appropriate we will make clear our legitimate interests at the relevant time;When we have your consent, which you may revoke at any time.; orWhen we have a legal obligation to collect personal information from you. If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you of the possible consequences if you do not provide your personal information.

Please contact us at if you have questions about or need further information concerning the legal bases on which we collect and use your personal information or to request a copy of the Standard Contractual Clauses that we use to facilitate the lawful transfer of data outside the EEA or U.K.

How to exercise your data subject rights
To the extent provided under EEA / U.K. law, you have the following rights with respect to personal information concerning you:

Right of access to your personal informationRight to rectification (i.e., correction, update)Right to erasureRight to restrict processingRight to data portability (i.e., receive an electronic copy of your personal information for purposes of transmitting it to another organization)Right to withdraw consent at any timeRight to express your point of view and to contest a decision made based solely on automated processing that produces legal or similarly significantly effects
. For your protection, we verify your identity before fulfilling your request. We will comply with your request as soon as reasonably practicable and within the time periods required by applicable law.

As noted above, if you have a gndnw and/or Madewell account, you also may review, update and delete certain personal information or adjust your marketing preferences by logging in to your account(s).

Please note that we often need to retain certain personal information for recordkeeping purposes and/or to complete any transaction that you began prior to submitting your request (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of the purchase or promotion). We also may not delete certain personal information for legal reasons.

Please contact us at if you have questions about or need further information concerning the legal bases on which we collect and use your personal information or to request a copy of the Standard Contractual Clauses that we use to facilitate the lawful transfer of data outside the EEA or U.K.

Questions or complaints
If you have a concern about our processing of your 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.


This U.S. State Privacy Rights Notice (“U.S. State Notice”) applies to Consumers under the State Privacy Laws (defined below).

This U.S. State Notice serves as our Notice at Collection for purposes of CCPA.

In this U.S. State Notice:

“Consumer” means individuals acting in an individual or household context. For California residents, a Consumer also includes individuals in a business-to-business context or employment context. This U.S. State Notice does not, however, apply to our current and former job applicants, employees, and independent contractors.

“Process” means any operation or set of operations performed on Personal Information.

“State Privacy Laws” means the California Consumer Privacy Act, including as amended by the California Privacy Rights Act (together, the “CCPA”), the Colorado Privacy Act, the Virginia Consumer Data Protection Act, the Utah Consumer Privacy Act (beginning December 31, 2023), Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring, Chapter 603A of the Nevada Revised Statutes, and all laws implementing, supplementing or amending them..

We may Collect your Personal Information (also known as Personal Data under the State Privacy Laws) directly from you (such as when you register for an account); your devices; our affiliates; service providers; public sources of data; credit reporting agencies; or other businesses or individuals.

We process your Personal Information to provide you services and as otherwise related to the operation of our business, including for one or more of the following Business Purposes: Performing Services; Managing Interactions and Transactions; Security; Debugging; Advertising & Marketing; Quality Assurance; Processing Interactions and Transactions; and Research and Development. We may also use Personal Information for other Business Purposes in a context that is not a Sale or Share under State Privacy Laws, such as disclosing it: (i) to our Service Providers, Contractors, or Processors that perform services for us (“Vendors”); (ii) to the Consumer or to other parties at the Consumer’s direction or through the Consumer’s action; (iii) for the additional purposes explained at the time of collection (such as in the applicable privacy policy or notice); (iv) as required or permitted by applicable law; (v) to the government or private parties to comply with law or legal process or protect or enforce legal rights or obligations or prevent harm; and (vi) to assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business (“Corporate Transaction”) (collectively, (i) – (vi) are “Additional Business Purposes”). Subject to restrictions and obligations under State Privacy Laws, our Vendors also may use your Personal Information for Business Purposes and Additional Business Purposes and may engage their own vendors to enable them to perform services for us.

We may also use and disclose your Personal Information under this U.S. State Notice for Commercial Purposes, which may be considered a Sale or Share under applicable State Privacy Laws, such as when Third-party Digital Businesses (defined below) Collect your Personal Information via third-party cookies, and when we process Personal Information for certain advertising purposes. We provide more detail on our data collection practices in the two charts that follow.

Disclosures for Business Purposes:
Our Vendors;The issuer of the Credit Card;Corporate Group;Governmental entities; and/orOther parties to comply with our legal obligations.
Sale/Share: Not Sold/Shared

4. Customer Account Details/Commercial Information

Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

We may Collect other information that meets the definition of Personal Information under State Privacy Laws but is not reflected by a category above. When this occurs, we will treat the information as Personal Information as required by the State Privacy Laws.

As permitted by applicable law, we do not treat “de-identified information” and “publicly available information” as Personal Information. We reserve the right to convert (or permit others to convert) your Personal Information to de-identified information. We will not attempt to reidentify data that we maintain as de-identified data and if we share it with third parties will use technical and administrative controls to ensure that it is not reidentified.

Retention Period: Our Personal Information retention periods vary for each of the categories of Personal Information described above. The length of time for which we retain each category of Personal Information depends on the purposes for our Collection and use and requirements pursuant to applicable laws. We do not retain your Personal Information for any longer than reasonably necessary to achieve the purposes for which it was Collected or processed, or as required by applicable law.

1. Performing Services

Real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address, email address, and account name.

2. Managing Interactions and Transactions

Auditing: related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with user interaction or transaction specifications and standards (e.g., ecommerce activities).

3. Security

Security/fraud prevention: to protect the security of gndnw, our Services, or its users and to prevent and address fraud.

4. Debugging

Repairs: identify and repair errors that impair existing intended functionality of our Services. Advertising & Marketing (excluding Cross-context Behavioral Advertising and Targeted Advertising) Content and offers customization: to customize your experience on our Services, or to serve you specific content and offers that are relevant to/customized for you (e.g., pricing and discounts based on your profile, location, or shopping history)

5. Advertising & Marketing (excluding Cross-context Behavioral Advertising and Targeted Advertising)

Content and offers customization: to customize your experience on our Services, or to serve you specific content and offers that are relevant to/customized for you (e.g., pricing and discounts based on your profile, location, or shopping history)

Advertising, marketing, and promotions: to assist us in determining relevant advertising and the success of our advertising campaigns; to help us determine where to place our ads, including on other websites; for promotional activities such as running sweepstakes, contests, and other promotions (including third-party and co-promotions).

6. Quality Assurance

Quality and Safety of Service: undertaking activities to verify or maintain the quality or safety of our Services, and to improve, upgrade, or enhance our Services.

7. Processing Interactions and Transactions

Short-term, transient use: including, but not limited to, non-personalized advertising shown as part of a Consumer’s current interaction with gndnw and use of our Services’ features and functionality (e.g., e-commerce transactions).

8. Research and Development

Research and analytics: to better understand how users access and use our Services, both on an aggregated and individualized basis, to improve our Services and respond to user preferences, and for other research and analytical purposes.

Market research and customer satisfaction surveys: to administer surveys and questionnaires, such as for market research or customer satisfaction purposes.

9. Additional Business Purposes

Compliance with legal obligations: to comply with legal obligations, as part of our general business operations, and for other business administration purposes and in response to legal obligations or process.

Prevention of illegal activities, fraud, injury to others, or violation of our terms and policies: to investigate, prevent or act if someone may be using information for illegal activities, fraud, or in ways that may threaten someone’s safety or violate of our terms or this U.S. State Notice.

Purposes disclosed at Personal Information Collection: We may provide additional disclosures at the time of Personal Information Collection, such as on a checkout page.

Related or compatible purposes: for purposes that are related to and/or compatible with any of the foregoing purposes

10. Commercial Purposes

Cross-context Behavioral Advertising and Targeted Advertising (as explained below), which may be treated as a Sale and/or Share under State Privacy Laws. For the specific types of Personal Information Sold or Shared for this purpose and the recipients thereof, see the first chart above.


Subject to certain limitations permitted by applicable laws and meeting the requirements for a Verifiable Consumer Request (defined below), gndnw provides California, Colorado, Connecticut, Nevada, Utah (beginning December 31, 2023), and Virginia Consumers the privacy rights as legally required described in this section. For residents of states without Consumer privacy rights, we will offer you a limited right to delete, but will apply our discretion with respect to if and how we process such requests. Once we receive your request, we will verify it by asking you to provide certain information, such as identifiers like your email address and phone number.

Right to Limit Sensitive Personal Information Processing
We only process Sensitive Personal Information for purposes that are exempt from Consumer choice under the State Privacy Laws.

Right to Know/Access
1. Categories (available for California Residents Only). California Residents have a right to submit a request for any of the following for the period that is 12-months prior to the request date:
The categories of Personal Information we have Collected about you.

The categories of sources from which we Collected your Personal Information.The Business Purposes or Commercial Purposes for our Collecting, Selling, or Sharing your Personal Information.The categories of Third Parties to whom we have disclosed your Personal Information.A list of the categories of Personal Information disclosed for a Business Purpose and, for each, the categories of recipients, or that no disclosure occurred.A list of the categories of Personal Information Sold or Shared about you and, for each, the categories of recipients, or that no Sale or Share occurred.

Specific Pieces
You may request to confirm if we are processing your Personal Information and, if we are, to obtain a transportable copy, subject to applicable request limits, of your Personal Information that we have Collected and are maintaining. For your specific pieces of Personal Information, as required by applicable State Privacy Laws, the request must be a Verifiable Consumer Request as described below. We have no obligation to re-identify information or to keep Personal Information longer than we need it or are required to by applicable law to comply with access requests.

Do Not Sell / Share / Target
Under the various State Privacy Laws there are broad and differing concepts of “Selling” Personal Information for which an opt-out is required. California also has an opt-out from “Sharing” for Cross-context Behavioral Advertising (use of Personal Information from different businesses or services to target advertisements). Other states have an opt-out of “Targeted Advertising.” We may Sell or Share your Personal Information and/or use your Personal Information for Targeted Advertising, as these terms are defined and apply under State Privacy Laws. However, we provide Consumers an opt-out of Sale/Sharing/Targeting that is intended to combine all these state opt-outs into a single opt-out.

Third-party digital businesses (“Third-party Digital Businesses”) may associate cookies and other tracking technologies that Collect Personal Information about you on our Services, or otherwise Collect and process Personal Information that we make available about you, including digital activity information. We understand that giving access to Personal Information on our Services, or otherwise, to Third-party Digital Businesses could be deemed a Sale and/or Share under some State Privacy Laws and we will treat such Personal Information (e.g., cookie ID, IP address, and other online IDs and internet or other electronic activity information) collected by Third-party Digital Businesses, where not limited to acting as our Service Provider (or Contractor or Processor), as a Sale and/or Share and subject to a Do Not Sell/Share/Target opt-out request. We will not Sell your Personal Information, Share your Personal Information for Cross-Context Behavioral Advertising, or process your Personal Information for Targeted Advertising if you make a Do Not Sell/Share/Target opt-out request.

Opt-out for Personal Information: If you want to limit our processing of your Personal Information for Targeted Advertising, or opt-out of the Sale/Sharing, you need to exercise your opt-out request .Our consent management tool enables you to exercise such an opt-out request on your device. You must exercise your preferences on each of our websites and Apps you visit, from each browser you use, and on each device that you use. Since your browser opt-out is designated by a cookie, if you clear or block cookies, your preferences will no longer be effective, and you will need to enable them again via our cookie management tool. Please also refer to our cookie policy for other ways to exercise preferences regarding Third-party Digital Businesses. If you use ad-blocking software, our cookie banner may not appear when you visit our website, and you may have to use the link above to access the tool.

We may disclose your Personal Information for the following purposes, which are not a Sale or Share: (i) if you direct us to disclose Personal Information; (ii) to comply with a Consumer rights request you submit to us; (iii) disclosures amongst the entities that constitute gndnw as defined above, or as part of a Corporate Transaction; and (iv) as otherwise required or permitted by applicable law.

Right to Delete
If we have a basis for retention under applicable law, you may request that we delete your Personal Information. Our retention rights include, without limitation:
to complete transactions and services you have requested; for security purposes;for legitimate internal Business Purposes (e.g., maintaining business records);to comply with the law and to cooperate with law enforcement; andto exercise or defend legal claims.

Please also be aware that making a deletion request does not ensure complete or comprehensive removal or deletion of Personal Information or content you may have posted.

Correct Your Personal Information
Consumers may bring inaccuracies they find in their Personal Information that we maintain to our attention and we will act on a request as required by applicable law. You can also make changes to your online account(s) as explained in your online gndnw and/or Madewell account. That will not, however, change your information that exists in other places.

1. Your Request Must be a Verifiable Consumer Request
As permitted or required by applicable State Privacy Laws, any request you submit to us must be a Verifiable Consumer Request, meaning when you make a request, we may ask you to provide verifying information, such as your name, email, phone number and/or account information. We do not verify opt-outs of Sell/Share/Target or Limitation of Sensitive Personal Information requests unless we suspect fraud. To protect Consumers, if we are unable to verify you sufficiently we will be unable to honor your request.

2. Agent Requests
You may use an authorized agent to make a request for you, subject to our verification of the agent, the agent’s authority to submit requests on your behalf, and of you. Once your agent’s authority is confirmed, they may exercise rights on your behalf subject to the agency requirements of applicable State Privacy Laws.

3. Appeals

Residents of California, Colorado, Connecticut, and Virginia may appeal gndnw decision regarding a request by submitting a new Consumer Rights Request and identifying your previous request number.

Our Responses
Some Personal Information that we maintain is insufficiently specific for us to be able to associate it with a verified Consumer (e.g., clickstream data tied only to a pseudonymous browser ID). We do not include that Personal Information in response to those requests. If we deny a request, in whole or in part, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Personal Information that we process to respond to your request(s). We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision.

Consistent with applicable State Privacy Laws and our interest in the security of your Personal Information, we will not deliver to you your more Sensitive Personal Information in response to a Consumer privacy rights request; however, you may be able to access some of this information yourself through your account if you have an active account with us.

Non-discrimination / Non-retaliation
We will not discriminate or retaliate against you in a manner prohibited by applicable State Privacy Laws for your exercise of your privacy rights. We may charge a different price or rate or offer a different level or quality of goods or service, if and when doing so is reasonably related to the value of the Personal Information.


We offer various financial incentives, such as discounts, coupons, and other benefits for customers who sign up to receive our marketing emails or join our loyalty program. When you participate in a financial incentive, we collect Personal Information from you, such as identifiers (like your name and email address) and commercial information (like your purchase history). You can opt in to a financial incentive by following the sign-up or participation instructions provided, and you have the ability to opt-out of the financial incentive, or our subsequent use of your Personal Information in connection with a financial incentive, at any time by contacting us at In some cases, we may provide additional terms and conditions for a financial incentive, which we will present to you when you sign up. We value your Personal Information as the value of the offer or discount provided to you, and the value of your Personal Information is reasonably related to the value of the offer or discount presented to you.

Our Rights and the Rights of Others
Notwithstanding anything to the contrary, we may process your Personal Information as required or permitted by applicable law and this processing may override your rights under State Privacy Laws. We are not required to honor your privacy requests if doing so infringes on our or another party’s rights or conflicts with applicable law.


If you have any questions about this Privacy Policy, please contact us at

Categories of Third PartiesCategories of Personal Information Disclosed for a Business or Commercial Purpose
Vendors, consultants and other service providers who perform services on our behalfIdentifiersInformation subject to Cal. Civ. Code § 1798.80Commercial informationInternet or other electronic network activity informationGeolocation dataInferences
Comenity Bank (in connection with the gndnw Credit Card)IdentifiersInformation subject to Cal. Civ. Code § 1798.80Commercial informationGeolocation data
Other gndnw website visitors (in connection with product reviews submitted through our Services)IdentifiersInformation subject to Cal. Civ. Code § 1798.80Characteristics of protected classifications under California or federal law

Sale of Personal Information: California law requires that we provide transparency about personal information we “sell,” which for the purposes of the gndnw broadly means scenarios in which we have shared personal information with partners in exchange for valuable consideration. While we do not provide personal information about you to other companies for money, we do allow our advertising partners to collect identifiers, commercial information and Internet or other electronic network activity information via our Services to show you ads that are targeted to your interests.

Your Rights: Subject to certain limitations, you have the right to request (1) more information about the categories and specific pieces of personal information we have collected, used, sold and disclosed about you, (2) deletion of your personal information and (3) that we stop selling your personal information. We will not discriminate against you if you exercise your rights under the gndnw.

Once we receive your request, we will verify it by asking you to provide certain information, such as identifiers like your email address and phone number. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests on your behalf.

Notice of Financial Incentives: We offer various financial incentives. For example, we may provide discounts, coupons and other benefits for customers who sign up to receive our marketing emails or join our loyalty program. When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your name and email address) and commercial information (like your purchase history). You can opt into a financial incentive by following the sign-up or participation instructions provided, and you have the ability to opt-out of the financial incentive, or our subsequent use of your personal information in connection with a financial incentive, at any time by contacting us at In some cases, we may provide additional terms and conditions for a financial incentive, which we will present 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.