We offer our customers a rewards program (My Place Rewards) that provides certain benefits to members, such as points based on dollars spent, cash back rewards, birthday club offers, easy ways to earn extra points, and other benefits. Membership is free of charge. We may also provide other special offers and benefits to customers who sign-up to receive communications from us via email, text messages, or social media, or who participate in certain promotional campaigns (collectively, the “Programs”). When a customer signs up for one of these Programs, we typically ask the customer to provide their name, email address, and/or telephone number. Because we collect personal information, this may be interpreted as a “financial incentive” program under California law.
The value of customer personal information that we collect is reasonably related to the expenses of providing special offers and benefits to participants in the Programs (which may vary depending on the specific offer or benefit or the amount purchased by the customer using the special offer).