Home Privacy Policy Legal Information Privacy Policy Terms of Use Legal Notices Privacy Policy CA Privacy Rights Product Safety and Recall Accessibility Effective Date: July 30, 2020 Last Updated: October 7, 2020 OUR COMMITMENT TO PRIVACY Thank you for visiting this website (this “Site”), which is owned by Vera Bradley Designs, Inc. ("Vera Bradley"). Your privacy is important to us. To keep you informed, we provide this Privacy Notice (this “Notice”) explaining our online information practices and the choices you can make about the way your information is collected and used. To make this Notice easy to find, we make links available to it on our homepage and at points where Personal Information may be requested. Vera Bradley reserves the right to change, modify, add to or remove portions of this Notice at any time. Please check this page periodically for any changes. If material changes are made to this Notice, Vera Bradley will post a statement to that effect on the first page of this Privacy Notice. Privacy Notice changes will apply to the Personal Information collected from the Effective Date of the revised Privacy Notice to Vera Bradley's Site. Vera Bradley will always apply the version of the Privacy Notice under which your information was collected, unless we obtain your prior consent. SCOPE OF THIS NOTICE This Notice applies only to information collected through this Site. This Notice does not apply to information collected through other channels, such as in person, on paper, or by phone. YOUR CONSENT By using this Site, you are consenting to the collection, use, disclosure, and transfer of your information as described in this Notice. If you do not consent to the collection, use, disclosure and transfer of your information as described in this Notice, you may not use this Site. INFORMATION WE MAY COLLECT Personal Information Vera Bradley collects Personal Information that our visitors manually provide using their mouse, keyboard, mobile touch screen, or otherwise. We also collect information you provide when you register with this Site, log on to your account, or enhance your profile on this Site by choosing to automatically populate the requested data fields with information you previously provided to a third-party social media platform (such as Facebook or Twitter). "Personal Information" may include (but is not necessarily limited to) your name, billing address, shipping address, email address, phone number, mobile device number, birth date, credit card account data and other purchasing information. You may also provide us with photographs or other video/media content which may contain Personal Information. Unless specifically stated, we do not require this information to obtain access to our Site. The Personal information we collect is used by Vera Bradley and our third-party partners for the purposes enumerated below and on our Site: Consumer Purchases: We use your Personal Information to process your orders and administer your account. You may always refuse to provide your Personal Information, but this may lead to our inability to provide you with certain products or services. When you make a purchase with Vera Bradley online, you are automatically registered for our email marketing program but have the right to opt out, described below. Customer Service: On some pages our visitors can submit comments or ask questions. We also collect Personal Information when you send us emails containing questions or requests. While we retain information in our customer service database in order to provide better service to our customers, we only save Personal Information associated with questions, comments, and requests in this database in order to respond to those questions and requests, and to better serve you when responding to any questions or requests you may have in the future. Catalog Requests: The names and mailing addresses submitted by visitors who request a printed catalog are used to mail the catalog and may also be shared with your Favorite Store, or with our marketing partners to provide you with additional information or products we think may be of interest to you. If you would like to remove your name and address from our catalog mailing list, please send an email to customercare@verabradley.com. Please include your full name, email address and phone number in case we have questions. Please allow a reasonable period of time for your request to be processed. Email: Some of our pages allow visitors to register to receive periodic emails from us. Any promotional email you receive from Vera Bradley will provide a link that will allow you to "unsubscribe" from this informational service at any time. If you would like to change your subscription status now, you may do so by visiting Email Preferences. Note: You may not unsubscribe from transactional emails, such as emails confirming your purchase. Accounts: When you register with us, Vera Bradley collects Personal Information in order to save preferences and Wish List information. This provides you with a personal experience when you use our Site. You may review and edit your Personal Information at any time by logging in to your account or may request changes by contacting us at customercare@verabradley.com. Email a Friend: There are some features on our Site that may require visitors to enter another person's Personal Information and/or email address in order to use the feature. Visitors are responsible for obtaining the consent of any third party prior to entering the Personal Information of such third party. We only use this information to allow visitors to share certain Site content with friends. Discussion/Social Networking Forums: Our Site may offer discussion forums, message boards, social networking opportunities, chat pages and other public forums or features in which you may provide Personal Information, materials and related content. If you submit Personal Information when using these public features, please note that such Personal Information may be publicly posted and otherwise disclosed and used without limitation or restriction, even after you have deleted or edited your Personal Information. Offers, Surveys and Promotions: Vera Bradley or our third-party vendors may use your Personal Information to notify you about special offers, promotions, news and surveys that may be of interest to you. On occasion, we also may send information or offers to you on behalf of other Vera Bradley entities, such as Vera Bradley Retail Stores or the Vera Bradley Foundation for Breast Cancer. These notifications may be sent via email or text messages. Please note that Vera Bradley will not send any text messages to your mobile device without first obtaining your prior, express, written consent to receive such messages. You may opt-out of receiving these notifications at any time by following the instructions set forth below in the Opt-Out section of this Privacy Notice or as set forth in the SMS Terms of Service, or by following the instructions in the notification. Our Marketing Strategies. Vera Bradley may use your Personal Information to better understand your needs and interests and to improve our marketing and promotional efforts or products and services. Security, Credit, or Fraud Prevention: Vera Bradley may use your information to protect its rights or the rights of others, to comply with the law, a court order, or a subpoena, or to protect the security of our Site or its terms of use. If you prefer not to receive the information or offers described above, please 1) follow the instructions in the email to "unsubscribe;" 2) write to us at Vera Bradley Customer Service, 12420 Stonebridge Road, Roanoke, Indiana 46783; or 3) send an email to customercare@verabradley.com, and we will remove your name from our email mailing list. Please include your full name, email address and phone number in case we have questions. It may take several days to process your instructions, and you may receive messages after submitting your instructions. Non-Personal Information Vera Bradley collects a variety of non-personal information, such as information about the operating system on your computer, the type of web browser you are using, your IP address, and the links you followed to enter and leave the Site. This information is not, in and of itself, personally identifiable and is collected automatically via the use of cookies (small computer files saved on your hard drive) and standard web technology by Vera Bradley or a third party. However, we may combine non-personally identifiable information with other information in an attempt to identify you or we may combine it with information that does identify you. Vera Bradley's web servers collect the domain names of visitors to our Site, however, they do not recognize individual email addresses. Aggregate information showing the IP addresses and/or domain names of visitors, the number of visits, average time spent on the Site, pages viewed, etc. is collected and used only for internal review to measure the overall use of our Site and provide direction for its continuous improvement. This information is not sold to or shared with other organizations for commercial purposes. INFORMATION COLLECTED AUTOMATICALLY Vera Bradley, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Site (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Site, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Vera Bradley with Vera Bradley-Collected PI, Vera Bradley does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information or Vera Bradley-Collected PI. The methods that may be used on the Site to collect Usage Information include: Log Information: Log information is data about your use of the Site, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files. Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Site or e-mails, including information about your browsing and purchasing behavior. Cookies: Cookies allow us to tailor the Site to better match your interests and preferences. With most internet browsers or other software, you can erase cookies from your computer hard drive, block all cookies or receive a warning before a cookie is stored. Please refer to your browser instructions to learn more about these functions. If you reject cookies, functionality of the Site may be limited and you may not be able to take advantage of many of our Site's features. In addition to the cookies Vera Bradley delivers to your computer or mobile device through our Site, certain third parties may deliver cookies to you for a variety of reasons. Other third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on our Site or on other websites. The Site may associate some or all of these types of cookies with your devices. Web Beacons ("Tracking Pixels"): Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Site, to monitor how users navigate the Site, and to count content views. Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Site. It is temporarily downloaded onto your computer from Vera Bradley’s web server, or from a third party with which Vera Bradley works, and is active only while you are connected to the Site, and deleted or deactivated thereafter. Location-identifying Technologies: GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting content based on your location. Fingerprinting: Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes of identification and/or tracking Device Recognition Technologies: Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) In-App Tracking Methods: There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps and/or devices. TRACKING TECHNOLOGIES Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. Please be aware that if you disable or remove these technologies, some parts of the Site may not work and that when you revisit the Site your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations. Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. ANALYTICS AND ADVERTISING TRACKING TECHNOLOGIES Vera Bradley uses Google Analytics, a web analytics tool that helps us understand how visitors engage with our Site. To learn more about Google Analytics, click here. In addition, if you would like to opt-out of having interest-based information collected by certain entities during your visits to our Site or other websites, please click here. You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on our Site do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies. Vera Bradley is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. SHARING OF INFORMATION Except as set forth in this Notice, we do not share your Personal Information unless you have given us permission to do so, for example, by checking the box allowing us to share your Personal Information with your Favorite Store, or by checking the box allowing us to share your Personal Information with our marketing partners. We do not share Personal Information collected through our SMS/MMS service. At times, we employ other companies and individuals to perform certain functions on our behalf. Examples include removing repetitive information from customer lists, analyzing data, providing marketing assistance, sending emails and text messages and processing credit card payments. In the scope of providing services on behalf of Vera Bradley, these third parties may have access to your Personal Information. Using contractual or other arrangements, Vera Bradley will ensure that these agents, contractors and third-party service providers, who may receive Personal Information in the course of providing services to Vera Bradley, protect the Personal Information in a manner consistent with the principles set out in this Privacy Notice and as required by law. Vera Bradley may also disclose Personal Information to conform to or comply with the law or where such disclosure is necessary to protect our Site, our company, our employees, our Site visitors, or the general public. If Vera Bradley is involved in a sale or transfer of all or a substantial portion of its business assets, information about you may be among the transferred assets. Any third party to whom we sell or transfer assets will have the right to continue to use your Personal Information in the manner described in this Privacy Notice. PRIVACY OF CHILDREN Pursuant to the Children’s Online Privacy Protection Act, we do not knowingly collect, use or disclose personal information from or about visitors to our Site under 13 years of age. If you are under the age of 13, you can use this Site only in conjunction with your parent’s or guardian’s permission. Only visitors who are 18 years or older may purchase products from, participate in activities offered on, register or create an account or profile, or otherwise use the services on our Site. The Site is intended for a general audience and not directed to children less than 13 years of age. Only visitors who are 18 years or older may purchase products from, participate in activities offered on, register or create an account or profile, or otherwise use the services on our Site. Vera Bradley does not intend to collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA. Any California residents under the age of eighteen (18) who have registered to use the Site, and who posted content or information on the Site, can request removal by contacting Vera Bradley at customercare@verabradley.com, detailing where the content or information is posted and attesting that you posted it. Vera Bradley will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that Vera Bradley does not control. RETENTION OF INFORMATION Vera Bradley retains information collected through our Site for as long as the information is relevant to our business purposes or as permitted by applicable law, unless you request deletion of your Personal Information, in which case we will take reasonable steps to comply with your request. Please keep in mind that Vera Bradley cannot delete information which you have shared with others through discussion/social networking forums. OUR COMMITMENT TO DATA SECURITY Vera Bradley employs physical, electronic, and organizational safeguards to protect the confidentiality and security of our online visitors' Personal Information. Although we use reasonable measures to help protect your information, including against unauthorized use or disclosure, we cannot guarantee the security of information provided over the Internet or stored in our databases and will not be responsible for breaches of security beyond our reasonable control. HOW YOU CAN ACCESS, CORRECT OR DELETE YOUR PERSONAL INFORMATION Visitors may review and modify Personal Information stored by Vera Bradley by accessing their account. Stored Personal Information does not expire and is retained until you request that it be deleted from our database (as permitted by applicable law and subject to any limitations described in this Notice). If you would like to remove your name and Personal Information from our records, please contact us using the information provided below. YOUR CHOICES We respect your right to make choices about the ways we collect, use, and disclose your information. This Notice describes some of your choices, such as your choice to opt out of receiving “cookies.” We may ask you to indicate your choices at the time and on the page where you provide your information. Email preferences: You can opt out of promotional emails we send to you. If you wish to stop receiving promotional emails or would like to change their send frequency, you can either click the “unsubscribe” link located at the bottom of each communication, or visit Email Preferences. Text preferences: You can opt-out from receiving text messages from us by following the instructions on text messages that you receive from us. To opt-out reply STOP to 72276 at any time, and to receive assistance simply reply HELP to 72276. Do Not Track Mechanisms: California law requires this Notice to address how we respond to any “Do-Not-Track (‘DNT’) signal” delivered by your browser. Because of the changing state of technology and indecision within the industry regarding the meaning of DNT signals, we do not make any guarantee that we will honor DNT signals. For more information on Do Not Track, you may visit allaboutdnt.org. Previously Expressed Preferences: You may be able to change through your account previously expressed preferences regarding how we use your information. Otherwise, please contact us using the information provided below. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS The Site may include hyperlinks to, or include on or in connection with, the Site (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you. Certain functionalities on the Site permit interactions that you initiate between the Site and certain Third-Party Services, such as third party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Site and a Third-Party Service; “liking” or “sharing” Vera Bradley’s content; logging in to the Site using your Third Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Site to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Site or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Site (e.g., by using a hashtag associated with Vera Bradley in a tweet or status update), your post may be used on or in connection with the Site or otherwise by Vera Bradley. Also, both Vera Bradley and the third party may have access to certain information about you and your use of the Site and any Third-Party Service. Vera Bradley may engage and work with Service Providers and other third parties to serve advertisements on the Site and/or on third-party services. Some of these ads may be tailored to your interest based on your browsing of the Site and elsewhere on the internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third party service after you have left the Site (i.e., “retargeting”). Vera Bradley uses Google Analytics, and may use other Service Providers as well for analytics services. These analytics services may use cookies and other Tracking Technologies to help Vera Bradley analyze Service users and how they use the Site. Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Site, compiling statistic reports on the Service’s activity, and providing other services relating to Site activity and other Internet usage. Except to the extent Vera Bradley combines information from Service Providers, Third-Party Services, or other third parties with Vera Bradley-Collected Personal Information, in which case Vera Bradley will treat the combined information as Vera Bradley-Collected Personal Information under this Privacy Policy, data obtained by Vera Bradley from a third party, even in association with the Site, is not subject to Vera Bradley’s limitations regarding Vera Bradley-Collected Personal Information under this Privacy Policy, however such data remains subject to any restrictions imposed on Vera Bradley by the third party, if any. Otherwise, the information collected, stored, and shared by third parties remains subject to their privacy policies and practices, including whether they continue to share information with Vera Bradley, the types of information shared, and your choices on what is visible to others on third-party services. Vera Bradley is not responsible for and makes no representations regarding the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Site, and encourages you to familiarize yourself with and consult their privacy policies and terms of use. THIS SITE IS HOSTED ON SERVERS LOCATED IN THE UNITED STATES Vera Bradley is a U.S. corporation. The servers that support this Site are located in the United States. While it is in our possession, your information will generally be stored in Vera Bradley databases or databases maintained by our third-party service providers on servers and data storage devices located in the United States. U.S. data protection laws may not provide as much protection as the data protection laws in force in some other countries, however, we will process your information in accordance with this Notice no matter where our data is stored. If you are located in a country outside the United States, by using our Site you consent to the transfer and storage of your information to the United States. NEVADA PRIVACY RIGHTS Although we do not currently “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, Nevada consumers have the right to instruct us not to sell covered information. You may contact us here to be verified and exercise your opt-out rights under that law. For more information about our data collection and sharing practices, please review this Privacy Policy. We may share your data as explained in this Privacy Policy for different purposes, such as to make your experience and our services better, and those activities are separate from the opt out request. CALIFORNIA PRIVACY RIGHTS Californians have certain additional rights set forth below. The rights derive from different California laws and must be exercised separately. These notices supplement this Privacy Policy and govern in event of a conflict with other sections of this Privacy Policy. CALIFORNIA’S “SHINE THE LIGHT” LAW We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine The Light law”) with non-affiliated third parties for their direct marketing purposes absent your consent and Californians may opt-out of our sharing of personal information with our affiliates for their own direct marketing purposes by exercising their Do Not Sell rights described in the “Right to Opt-Out of Sale of Personal Information” section below. If you are a California resident, you may request information confirming our compliance with the Shine the Light law by sending a letter to the address or email address below: Vera Bradley Customer Service 12420 Stonebridge Road Roanoke, Indiana 46783 or customercare@verabradley.com. Any such request must include “California Privacy Rights Request – Shine the Light” in the first line of the description, your name, street address, city, state, and ZIP code, and an attestation that you are a California resident. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the above e-mail address or mail address. CALIFORNIA CONSUMER PRIVACY ACT (CCPA) This CCPA Notice (“CCPA Notice”) applies to California residents that are “Consumers” as defined by the California Consumer Privacy Act (“CCPA”), California Civil Code Section 1798.100 et seq. Capitalized terms that are used herein shall have the meaning given to them in the remainder of the Privacy Notice unless otherwise noted. This CCPA Notice, and the consumer rights described in it, does not apply to our employees, job applicants and contractors, although they can obtain certain information about our California data practices related to them from our human resources department, nor to persons whose personal information is collected by us in the context of them representing a business (i.e., business-to-business communications). As the CCPA is new and there remain many questions regarding its interpretation, we may from time-to-time update information in this CCPA Notice regarding our data practices and your rights, modify our methods for responding to your requests, or supplement our responses to your requests. We will continue to develop our compliance program to reflect the developments of the law. This CCPA Notice covers our collection, use, and disclosure of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, for the twelve months preceding January 1, 2020 (the effective date of the CCPA), except to the extent such PI is exempt from the notice obligations of the CCPA. It will be updated annually to reflect our practices in the prior calendar year. Our practices in the current calendar year may differ. This CCPA Notice covers our collection, use, and disclosure of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, for the twelve months preceding January 1, 2020 (the effective date of the CCPA), except to the extent such PI is exempt from the notice obligations of the CCPA. It will be updated annually to reflect our practices in the prior calendar year. Our practices in the current calendar year may differ. Collection, Use and Disclosure of PI Generally, we collect, retain, use, and share your PI to provide you the Site and as otherwise related to the operation of our business. In addition, we may collect, use and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this CCPA Notice. The table below describes each category of PI we collect and includes examples of types of PI that may fall into a specific category. We collect the below categories of PI directly from you, your device or browser, our Vendors (defined in the table below) and suppliers, social media platforms, through our “Email a friend” feature, data append services, and our corporate affiliates. We collect, use and share the PI we collect for the CCPA-defined business purposes in the bulleted list below and also for the purposes described in our Privacy Notice (our “Other Operational Purposes”) (collectively, our “Business Purposes”). The categories of third parties with whom we share your PI for our Business Purposes are set forth in the table below. Applicable Business Purposes: Providing the Site and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services Detecting security incidents and protecting against malicious, deceptive, or illegal activity Debugging the Site to identify and repair errors Internal research and development Quality and safety assurance, and improving, upgrading, and enhancing the Site and our products and services Processing and managing interactions and transactions on the Site and our products and services Other Operational Purposes Category of Personal Information Categories of Recipients of Business Purposes Disclosures 1. Identifiers (e.g., name, social media handles, contact information including email, phone, and address, IP addresses, device IDs, account names and numbers) Vendors that assist us in providing the Site and running our internal business operations (“Vendors”); Analytics and advertising partners; Corporate affiliates 2. Personal Records (e.g., payment information) Vendors; Corporate affiliates 3. Personal Characteristics and traits (e.g., age, gender, household information, marital status) Vendors; Corporate affiliates 4. Customer Account Details / Commercial Information (e.g., purchase history) Business Purposes: Vendors; Corporate affiliates 5. Internet Usage Information (e.g., browsing history, referring URLs, search history, interactions with advertising links, mobile application usage, social media information linked to your account with us) Vendors; Analytics and advertising partners; Corporate affiliates 6. Geolocation Data (e.g, your location we infer based on your IP address) Vendors; Analytics and advertising partners; Corporate affiliates 7. Sensory Data (e.g., voice recordings from call centers, photos you upload, or security video footage from our stores) Vendors; Corporate affiliates 8. Professional or Employment Information (e.g., education level, employment status) Vendors; Corporate affiliates 9. Inferences from PI Collected (e.g., customer profiles including shopping preferences, product preferences, customer characteristics and behaviors) Vendors; Analytics and advertising partners; Corporate affiliates In 2019, we did not sell PI to our corporate affiliates, but reserve the right to do so and provide an opt-out as described in the next section. See also the discussion in the next section regarding third party cookies. YOUR CCPA RIGHTS Right to Opt-Out of Sale of Personal Information We may share your PI with one or more of our corporate affiliates in a manner that may be considered to be a “sale” of your PI as defined by the CCPA. The categories of PI (from the above table) that we may share with our corporate affiliates in this manner that may be considered a sale are Identifiers, Personal Characteristics and Traits and Customer Account Details. In order to opt out of such sales, please click here or by calling us at 888-855-8372. Third parties may collect personal information through our online services for advertising, analytics and other purposes. Please visit here to opt-out of the sale of personal information by participating third parties. This is a third-party program and we are not responsible for its effectiveness. You must opt out on every device and browser you use in order to effectuate your “Do Not Sell” requests from these parties. However, opting out does not mean you will stop seeing ads and you may continue to still see interest-based ads. However, you can exercise some control over browser-based cookies by adjusting the settings on your browser. For additional details about your choices regarding certain kinds of online interest-based advertising, see the section above titled "Analytics and Advertising Tracking Technologies". There is not yet an industry consensus as to whether data collection by third party cookies and tracking devices associated with our Site may constitute a “sale” of your PI by us as defined by the CCPA, but we do not believe that such third party activities are a sale by us, and as such, we do not treat such information as subject to a Do Not Sell request. Accordingly, except for those cookies which participate in the third-party program described in the prior paragraph, opting out of sale will not affect third party cookies operating on our Site. Some browsers have signals that may be characterized as do-not-track signals, but as this is not an actual request from a person, we currently do not recognize these as a do-not-sell request. We understand that various parties are developing do-not-sell signals, and we may recognize certain such signals if we conclude such a program is appropriate. Note that we do not recognize do-not-track signals on a general basis either. The CCPA requires that we state that we do not knowingly sell the PI of Consumers we know are under 16. We may disclose your PI for the following purposes, which are not a sale: (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures to corporate affiliates, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law. Rights to Know and Delete Personal Information California Consumers have the right to exercise certain privacy rights under the CCPA. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. If you are unable to provide us with certain information about yourself or, in some cases, about your transaction history with us, we will be unable to verify your identity to fulfill a request to know or delete. As an initial matter, we will send you a letter to the address we have on file in order to confirm your request and verify your identity. You must provide the information requested in such letter and return the accompanying form to us, otherwise we will not be able to verify your identity or proceed with your request. For your specific pieces of information and/or to delete important data, as required by the CCPA, we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above. If we cannot meet that standard, we will treat your request as a request for categories (explained below), in which case we require verification to a reasonable certainty. If we cannot verify you to a reasonable certainty we will reject your request to know and/or delete, in which case you can still obtain a copy of this CCPA Notice and/or opt-out of sale. Some personal information we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response. We will make commercially reasonable efforts to identify PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. You may use an authorized agent to submit a consumer rights request. If you use an authorized agent to submit a request, we will require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent. The Right to Know Categories You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date: The categories of PI we have collected about you. The categories of sources from which we collected your PI. The business or commercial purposes for our collecting or selling your PI. The categories of third parties to whom we have shared your PI. A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred. A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain: The categories of your PI we have sold. The categories of third parties to which we sold PI, by categories of PI sold for each third party. Specific Pieces You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is twelve months prior to the request date and are maintaining. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back twelve months prior to the request. The Right to Deletion You may request that we delete your PI that we have collected directly from you and are maintaining. Note, however, that we are not required to delete your PI that we did not collect directly from you. In addition, exceptions to your deletion rights do apply, including, without limitation, where we need to retain your personal information for regulatory reasons, to complete a warranty or other contract with you, or other internal uses of the information that are compatible with the context in which you provided it. To exercise the right to know or right to delete, California residents may request disclosure and/or deletion of personal information by visiting our Privacy Request Form or calling 888-855-8372. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so. Vera Bradley will not discriminate against any consumer for exercising these rights, as described further below. Notice of Financial Incentive and Non-Discrimination We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may from time-to-time offer you financial incentives for the collection, sale, and retention and use of your PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly. Limitations and Contact Us Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law. As these rights and your rights under other California laws, such as Shine the Light, are not the same and exist under different laws, you must exercise your rights under each law separately. For more information on your California privacy rights contact us at 888-855-8372 or email us here. QUESTIONS? CONTACT US If you have questions about the Site, the collection of information that occurs on our Site, or this Privacy Notice, please contact us at: Vera Bradley Customer Service 12420 Stonebridge Road Roanoke, Indiana 46783 or customercare@verabradley.com or 888-855-8372. Please include your full name, email address and phone number in case we have questions. Feedback BACK TO TOP CUSTOMER SERVICE THE BRAND #VERABRADLEY Get the latest news and offers before anyone else. 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