LTK Privacy Statement

 

Last updated: February 1, 2024

Shopping is a uniquely personal experience. What we search for and purchase says a great deal about each of us as individuals. Whether you’re shopping or sharing your recommendations with others, we appreciate you trusting LTK with your personal information. With this Privacy Statement, we intend to provide clear, detailed, and easy-to-read information about how we use the personal information you’ve given us and how we process personal information in general.

It’s true, a lot of people don’t read privacy statements. We hope you’ll read through this one, because the ways in which we use or share your personal information will vary depending on your relationship with us. Regardless, be aware that no matter where you are in the world or where you reside, we offer the same high standards of privacy protection.

First, we provide an outline of our Privacy Statement to easily navigate to the sections you’re most interested in.

First things first: definitions	Let’s start with a basic understanding of what we’re talking about — what we mean by “Shopper,” “Creator”, and other terms like “personal information.” We can only earn your trust by being responsible stewards of your personal information, and that starts with everyone being on the same page.
Shoppers’ Personal Information	Shoppers come to LTK, or use LTK links, for the purpose of browsing product recommendations from their favorite Creators for a variety of lifestyle items to consider purchasing and we rely on these browsing preferences to identify the best recommendations for each shopper. We collect personal information from Shoppers with LTK accounts and from Shoppers who are following LTK links on other online sites, but we use that information to provide the service you’ve asked us to provide — the ability to easily shop the products recommended by your favorite Creators. We generate some personal information automatically, such as inferences based on your shopping trends, and we use that to recommend Creators or products to you. When you click an LTK-owned link on LTK or on another site, we will see that link take you to the Brand you’re shopping from. This allows us to give credit to our Creators when you buy an item from their posts.
Creators’ Personal Information	Creators use LTK to share their product recommendations, some of which are sponsored by the Brand partners we work with. Our Creators entrust us to share their personal information responsibly with Shoppers, Brands, and affiliate networks. We track Creators’ posts both on LTK and via the LTK links they share on other online sites. This allows us to connect your content on other sites with your LTK Shop and to attribute traffic from your links, so you can make a commission on the products Shoppers purchase.
Data protection considerations for Brands	For our brand partners, we provide a very basic overview of how data flows from LTK to Brands in this section. In short, Brands don’t provide their users’ personal information to LTK; Brands receive information about Creators.
Making choices about your personal information	Whether you are a Shopper or a Creator, you have rights with respect to your personal information, and you can make choices about how to share, access, update, or even delete your personal information in your account settings in the LTK Shopping App and LTK Creator App or by contacting us. You can also manage your communication preferences there.
Cookies and tracking technologies	We use cookies, web pixels, and other tracking technologies on LTK’s website. However, you can manage your cookie preferences using our cookie tool. We respond to Global Privacy Control preferences and Do Not Track.
Security information	We have implemented appropriate technical controls to protect the confidentiality, integrity, and availability of your personal information on LTK and to protect the resilience of our systems. We encourage Shoppers and Creators to take steps to protect your account, such as using a strong and unique password and keeping your device updated.
Global privacy compliance and international transfers	LTK is based in the United States, but we are committed to complying with applicable data protection laws in regions where we do business. When we do transfer personal data across borders, we use appropriate cross-border data transfer mechanisms, depending on the region. This section also provides specific notices for U.S. state laws, including the CCPA.
Resolving disputes	In the unlikely event that we are unable to resolve a privacy concern quickly and thoroughly, we provide a path of dispute resolution.
Other information you may find useful	If you need to contact us, our contact information can be found here, including a physical address. We don’t expect to modify this policy often, but if we do change it in a way that impacts you, we’ll give you notice.

LTK Privacy Statement

First things first: definitions

First, and most importantly, if there are any capitalized or defined terms in this Privacy Statement that are not defined here, then those terms will have the same definition used in the LTK Terms of Service. If you have a different agreement with us, such as the Creator Terms of Service, we’ll use that agreement’s definitions. For example, when we refer to LTK throughout this document, or to “we” or “us,” we’re referring to rewardStyle, doing business as LTK. When we talk about our Services, we mean our Services as they’re defined there. This Privacy Statement applies to our processing of personal information on our Services.

When we use the term “personal information” in this Privacy Statement, we’re talking about a broad range of information. Data protection laws around the world define this concept in different ways, but in general, we mean information that relates to an identifiable, living individual person or their household. It does not include aggregated or deidentified data that is maintained in a form that is not reasonably capable of being associated with or linked to you. If we use deidentified data, we will maintain it in deidentified form, and will not attempt to reidentify it. For example, your username on LTK is personal information, but a Brand’s company name and store information is not, because it does not relate to an individual person.

Throughout this Privacy Statement, we’ll talk about our Shoppers and our Creators. Our Creators are individuals and entities with websites, blogs, social media presence, agents or agencies, digital publishers and other content platforms, who use our Services to share content or links. Our Shoppers are individuals who use our Services, including our website, our Apps, or an LTK link, to shop from or browse the content they like from our Creators. When we say “you” in this Statement, we mean both Shoppers and Creators.

Brands are merchants that sell products in collaboration with Creators. Our relationship with Brands is a little different, because Brands do not provide us personal information.

Remember, some of the posts on LTK are ads, for instance, because they’re sponsored by our Brands. When we’re providing customized content like recommendations based on your favorites, we’re targeting ads to you. However, we don’t sell our Shoppers’ personal information to Brands based on how you browse LTK.

LTK is responsible for making decisions about how the personal information we collect is processed. This makes us a controller (or equivalent) of the data we process.

The personal information we collect depends on how you interact with us and the services we provide to you. Because the information we collect will vary significantly depending on your relationship with us, we’ll discuss our collection in terms of that relationship.

Shoppers’ Personal Information

Shoppers may interact with LTK in a variety of ways. You may have an account with us, you may be on our website or our app, or you may click on an LTK-owned link posted on another online site. We collect, process, and share personal information for Shoppers in essentially the same ways regardless of how you’re initially interacting with us, but if you don’t have an account yet, some of this collection will be more limited.

How we collect and use Shoppers’ personal information

In short, we collect your personal information to provide our Services or to answer your questions. We collect information about you from different sources and in various ways when you use the LTK Services, including information you provide directly, information we collect automatically when you interact with our Services, and data we infer or generate from other data. Sometimes we might also collect personal information about you from other sources and third parties. You can scroll down to learn more details about each of these categories of collection. In general, we only use your personal information to provide our service to you, and we only retain your personal information for as long as is necessary for those legitimate business purposes. We also use your personal information to provide support and improvements and manage our business operations, secure our systems, detect fraudulent or illegal activity, and meet our legal obligations.

Information Shoppers share directly

Contact and account information. When you register for an account with LTK, we collect information like a username, your email address, and profile information. If you’re using our app through a mobile device, we’ll also see your device ID. If you use your real name as your username, we’ll have your real name, but we don’t require it. If you choose to provide your location in your profile, we’ll have that, but again, we don’t require it. We collect this information so we know who you are — this helps us communicate with you if you need support, identify your account, make recommendations to you, connect your account with stores when you make a purchase, and provide other services. We’ll also use your email address to communicate with you via our mailing lists, which you can opt into or out of. If you choose to apply to become a Creator, we’ll communicate with you via your email address or your preferred method of contact.

Inquiry and support information. If you send us messages through the forms or contact information provided on our Services, or send an email to us, we collect personal information and use it to communicate with you for the reasons you expect. This may be to resolve your concerns, to keep track of the inquiries we’ve received from you and from our customers generally, to manage our ongoing relationships with our customers, and for performance improvements.

Comments and content. If you interact with other users on our service in the form of content, messages, and other uploaded content, this content may include your personal information if you choose to share it. We will collect and retain your interactions as a record of messages between users on our Service. You also may have the ability to add information to your profile such as an avatar image, a name, a biography, or other information. We will use your profile information to help identify you.

Screenshots and camera roll data. With your permission, we may access images you select in your camera roll or saved images, such as your screenshots taken of products with an LTK link. If you choose to use this functionality, we will access these images to more quickly connect you with a Creator’s shop on LTK.

Event information. If you attend one of our events, we will collect registration information. This will generally include badge information like your name, as well as other contact information. We’ll use this information to identify you during the event and to manage our relationship with our attendees. We’ll also share your information with our event sponsors.

Information we generate or collect automatically

Browsing and email metadata. When you visit and interact with our website or use our apps, click on an LTK-owned link on our website or another website, read an email from LTK, or otherwise interact with us, we and our service providers acting on our behalf automatically collect some minimal metadata about you. We collect this both through normal interaction with the Service and through technologies like cookies and web beacons. This information includes your IP address, the pages you view, your referring address, the device and kind of browser you’re using, the date and time of your visit, and any errors that may occur during your visit. We use this information to help us understand how visitors use our website, to track performance, and to maintain security. In addition, we use tracking and session replay technologies to provide support, help improve the navigation experience on LTK’s Services, and reduce errors.

Please see our section on Cookies for more information.

Preference information and other inferences. If you’re logged in, we keep track of your interactions with the Service, such as posts you’ve liked, Creators you’ve followed, and products you’ve favorited. We use this information to generate information about your likely preferences so we can recommend new Creators to you, help you discover products you might like, and to make other inferences about you (in other words, to create a profile about you). For example, we remember whether or not you want us to set cookies on your computer, and we infer your general, non-precise geographic location (such as city, state, and country) based on your IP address. We don’t collect precise geolocation information.

Purchase history. When you shop using our Services, we collect information on what you purchased. When you follow an LTK-owned link, we collect the destination of that link. If you make a purchase, we collect some basic information about your order, like the value of it. We use this information to manage our relationship with our Creators and our Brands and to pay commissions to our Creators. We also use your purchase history information to make better recommendations.

Information we collect from third parties

In some circumstances, we collect personal information from third parties. When we do, we often combine it with information we’ve already collected directly from you. For example:

Your Contacts. Someone who is already a Customer or Creator on LTK might send you an invitation to join our Services or share an image with a friend via email or text message, and we may receive your information from that individual.

Creators. Creators you interact with on other social media platforms may refer you to us, such as by using an LTK-owned link to an item or by linking directly to their LTK shop.

Service Providers. Our service providers that perform services solely on our behalf, such as payment processors, may collect personal information and share some or all of this information with us. Our payment processors process payments on our behalf; we do not accept or process payment directly through our Services and we will not see or collect your credit card or banking information. In addition, we may from time to time use information providers (such as data licensors or marketing partners) to correct or supplement personal information we collect, for example to provide demographic or interest information.

Publicly Available Sources. We collect personal information about individuals that we do not otherwise have, such as contact information, employment-related information, demographic information, and interest-in-services information, from publicly available sources. We may combine this information with the information we collect from an individual directly. We use this information to contact individuals, to send advertising or promotional materials, or to personalize our Services and to better understand the demographics of the individuals with whom we interact.

How we share Shoppers’ personal information with others

We do need to share personal information to provide services to you, such as when you follow a link to a Brand Partner in order to purchase an item. We share, and in the last twelve months have shared, the categories of personal information above with third parties in the following scenarios:

Service providers. We share your personal information with service providers who process the information on our behalf to provide or improve our Service. These include service providers we have engaged for payment processing, customer service and support ticketing, marketing communications and survey offerings (including suppression lists), network data transmission, website hosting, infrastructure provisioning, IT services, analytics services, and administrative services. These also include service providers that enable direct purchases from Brands through the LTK platform. These also include information providers described above.

Our service providers also include certain social media providers. We connect with social media services and share aggregate information about our users. This allows us to advertise LTK events and services to you on other social media sites. In addition, we may share certain personal information with other social media sites for the purpose of targeting similar (or “lookalike”) audiences. This form of outreach enables us to find Shoppers and Creators similar to you. You can learn more about this kind of outreach on Facebook and Tiktok. If you would like to opt out of this use of your personal information, please reach out to Creator Support.

Brand Partners and Affiliate Networks. When you click on an LTK-owned link, whether it’s on our website, on our application, or a link LTK owns on a third party website, we’ll take you from LTK to a Brand’s website where you can learn more about, and buy, the product you’re interested in. Sometimes, those links take you through an affiliate network — a platform for retailers — before you reach the Brand’s website. When you click on these links, we do pass along the typical metadata that gets passed along whenever you click on any link on the internet. That way, the Brand knows your destination (the product), your source (LTK), and some information about which of our Creators referred you. Aside from this, we don’t share any of your personal information with the Brand; you may choose to log in to their site and give them your information. If you do, please remember that their sites are governed by their own Terms of Service and Privacy Statements which may differ from ours. Any data you share with them will be shared under their terms.

Compliance with legal obligations. We may disclose personal information to third parties, such as legal advisors and law enforcement, in limited circumstances: (i) if we reasonably believe that disclosure is compelled by applicable law, regulation, legal process, or a valid government request, (ii) to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; (iii) in connection with the establishment, exercise, or defense of legal claims; (iv) to protect the security or integrity of our services and products; or (v) to protect the health and safety of ourselves, our other customers, and the public at large. Where possible, we object to legal requests for personal information that we do not believe were issued properly, and where possible, we will notify you if we are required by law to disclose your personal information in response to a legal demand.

Business transfers. If we are involved in a merger, sale, or acquisition of corporate entities or business units, personal information we have collected from you may be part of the assets shared in connection with the due diligence process or the change of ownership. This situation might constitute a sale of personal information under applicable law.

Aggregated or deidentified information. We might also share information about our Shoppers with third parties if the data has been deidentified or aggregated in a way so it cannot reasonably be used to identify individuals. For example, we might share how many Shoppers liked a product or how popular certain trends are on our site. With respect to deidentified data, we will maintain data in deidentified form, and will not attempt to reidentify it.

Sale of personal information. We have some common website tools on our website like Google Analytics, Facebook pixels, and social media cookies. These cookies receive your IP address, device type, and other metadata. Because we can’t control that data once it leaves our service, some U.S. laws define the use of analytics and tracking pixels to be a “sale” of personal information. This is the only way in which we sell personal information, and you can opt out of this sale using our website’s cookie tool. We provide more information on our sale and sharing of personal information on our Do Not Sell page. See below for more information about our use of cookies.

LTK Affiliates. We share personal information across our subsidiaries, affiliates, and related companies, particularly when we collaborate in providing the Services or where access is needed to operate the Services. Our affiliates will only use your personal information as described in this Privacy Statement.

Otherwise With Consent or Direction. We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with your consent, we may post a testimonial on our Services, or if you direct us to connect your account with another social media service, we may receive some information from that connection.

Creators’ Personal Information

Creators have a more complex relationship with LTK. As a Creator, you expect us to provide a service to you that includes link tracking, paying you commissions when Shoppers purchase the applicable products you recommend, and providing an online shop where you can connect with Brands and post personal information about yourself, and in order to provide that service, we need to process your personal information. In addition, Creators must go through an application process that sometimes includes a recruitment process and a vetting process. We get to know you a little better and, as such, we need to collect a good bit more information from you.

How we collect and use Creators’ personal information

We start by collecting the same personal information for Creators as we collect for Shoppers. It’s important to start by reading the section on How we collect and use Shoppers’ personal information. In addition, because of the very specialized service we provide to our Creators, we collect and use a good deal more personal information from our Creators.

Information Creators share directly

Application information. When you apply to become a Creator on LTK, we need to collect some personal information about you. Some of this is contact and account information, including your full name and email address. We also collect your phone number for the purpose of providing support and response, and for security and account verification. We also collect your profiles on other online media so we can evaluate your fitness for LTK.

Contact and account information. In addition to our collection of account personal information described in the Shopper section, we collect a good deal of Creator account information. Because we need to contact you and pay you, we will collect your full name, email address, phone number, and general location.

Sensitive information. When you create an LTK Creator profile, you may choose to share demographic information, including your race or ethnicity, your gender, or even your style or body type. You may also share your areas of interest and expertise and your general location. These fields are optional.

Some sensitive information, such as government ID, may be required for identity verification purposes. If we do require that you share an identification document, we will only use it for identity verification and not for any other purpose.

Payment, collaboration, and marketing campaign information. As you use your account, we’ll see your LTK account balances, agency contact (if any), and payment and commission history. We will see your collaboration data, including Brand, fulfillment, and earnings information if you engage in sponsored collaborations. If you engage in marketing campaigns, we will see title, date, rate and clicks information. Our payment processors process payments on our behalf; we do not accept or process payment directly through our Services and we will not see or collect your credit card or banking information.

Content such as photos and videos. As a Creator, you are able to upload content to your LTK Shop in various media including photos, videos, recordings, and sounds. These might include images or other insignia of yourself or of others. You may only upload content of others if you have the right to do so (i.e., if you have obtained all necessary permissions and consents). With your permission, we may also access your camera roll or saved images, such as your screenshots taken of products on our Services.

Information we generate or collect automatically

The data we generate or collect automatically is the same for both Creators and Shoppers. Please see the section above on Information we generate or collect automatically.

Information we collect from third parties

Contacts, Shoppers, and references. When an individual chooses to invite you to join LTK, refers you to our Services, or shares an image with you via email or text message, we may receive your information from that individual. We also collect your information from Shoppers who engage with your content on other social media sites via LTK Links so we can track sales and facilitate commissions.

Business Partners. We may receive your information from our business partners who provide our Services by way of a co-branded or private-labeled website or companies that offer their products or services on our Services.

Service Providers. Service providers that perform services on our behalf, such as survey and marketing providers, may collect personal information and often share some or all of this information with us. In addition, we may from time to time obtain information from third-party information providers. These information providers may correct or supplement personal information we collect, such as by helping us obtain updated contact information to reconnect with a Creator. They may also provide contact information for individuals who may be interested in using our Services. If you have been contacted by LTK, we will be glad to share information about the third party service provider that shared your information with us.

Social Media sites. When you connect to or interact with LTK through various social media sites, we may receive some information about you that you permit the social media site to share with us. This information may include name, gender, date of birth, geolocation and interests. We also collect data when you interact with and use LTK through other social media, such as data on traffic, impressions, views, clicks, and similar information. The data we receive is dependent upon your privacy settings with the social media site. You should always review and, if necessary, adjust your privacy settings on third-party websites and apps and social media services before sharing information, linking, or connecting them to other services.

In addition, when you initially apply to become an LTK Creator, we will pull certain information from your social media sites, such as your follower count.

Publicly Available Sources. We collect personal information about individuals that we do not otherwise have, such as contact information, employment-related information, demographic information, and interest-in-services information, from publicly available sources. We may combine this information with the information we collect from an individual directly. We use this information to contact individuals, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.

How we share Creators’ personal information with others

We do need to share personal information to provide services to you, such as when you instruct us to pass your information to a Brand in order to collaborate on a campaign. We share, and in the last twelve months have shared, the categories of personal information above with third parties in the following scenarios:

Brand Partners, Affiliate Networks, and sale of personal information. When a Shopper clicks on an LTK shopping link, whether it’s on our website, on our application, or a link LTK owns on a third party website, the link takes them to one of our third-party Brands to get more information about the item they clicked on. Generally, the Shopper’s information will pass through one of our affiliate networks before they reach the Brand. That link includes a number that helps us identify you, the Creator, so we can pay you your commission on the sale if they make a valid purchase on a link you recommend.

In some states, this is called a “sale” or “sharing” of personal information, because LTK doesn’t retain control of your information when we share it with Brands or affiliate networks. Our Do Not Sell page provides more detail, including information about opting out of the sale of personal information.

In addition, we share your personal information with Brands in other ways. When you choose to feature a Brand’s products on your LTK Shop or use an LTK link on your external social media site, the Brand will see your referral. In some cases, Brands will receive information about the Creators who have referred their products, such as a list of the top referrers. If you participate in campaigns with Brands on LTK, then LTK will provide the Brand with certain information about you and the campaign performance.

Creators and API Developers. We may provide information about you to third party sites, networks, platforms or apps and third-party applications, which interface with LTK application programming interfaces. We share anonymized geo-location data, purchased items, and amount of sale with Partners and Creators. We may combine information internally across different Services so that we may provide better and more customized services. We contract with companies who help with parts of our operations and to enhance our Services.

Social Media sites, Ad Networks and Advertising Partners. We share your personal information with social media sites, ad networks, and advertising partners in several ways. First, we may connect with you or reach out to you on social media. We may also advertise LTK’s services to you on the social media sites you use or on other platforms.

You may opt in to programs in which we share your personal information with other social media sites, ad networks, and advertising partners on your behalf, such as by boosting your posts. These programs will also share your personal information with third party ad networks and advertising partners to deliver advertising and personalized content on other sites and services.

Creators’ own disclosure and privacy obligations

As a Creator, you have certain privacy obligations of your own.

When you begin using LTK links, scripts, and other technology we provide on your own website, blog, or social media site, we will collect and store information about you and your readers. You’re responsible for ensuring that your own website or blog complies with applicable laws regarding collection and use of personal information and consumer data.

You’re also responsible for including any required disclosures with respect to marketing to consumers, as described in the Creator Terms of Service.

Data protection considerations for Brands

Brands do not provide their users’ personal information to LTK.

Instead, when working with LTK, Brands typically receive personal information of our Creators. A Brand receives the personal information of a Creator in a few ways. First, in some circumstances, a Brand may receive a Creator’s personal information in the form of a unique identifier when a Shopper clicks on an LTK link and purchases a product from the Brand. This identifier notifies the Brand that a product has been purchased via a Creator’s recommendation and allows LTK to pay commission to the Creator. A Brand seeking to collaborate with Creators on a project also receives a Creator’s personal information when shown Creator profiles. Brands are responsible for maintaining adequate privacy protections for Creator personal information. We provide a supplemental agreement to our Brands and those terms will control our relationship. Please refer to that agreement.

LTK does not provide Shopper personal information to Brands, except as described above in our section on How we share Shoppers’ personal information with others.

If you are a representative of a Brand, you will have an account with us that allows you to log in to our Brand Portal. We collect ​​the same personal information for Brand representatives as we collect for Shoppers. Please see our section on Shoppers’ Personal Information to understand what information we collect, use, and share, and what your choices are with respect to that personal information.

Making choices about your personal information

Your account information. You have rights with respect to your personal information, including the right to access the information we have about you, to correct inaccurate information, to download a copy of your data, to restrict the use of your data, and to delete your data. We provide you with a lot of options to access, correct, control, or delete your personal information within your LTK account settings. If you are a Creator, you can delete or change any of the optional data settings in the same place you added them. If you are unable to access or change any part of your account and you would like to, please contact us and we’ll help. Please be aware that there may be data elements that we cannot change or delete for security or legal reasons.

If you have connected your account to a third party service like Facebook, Google, or Apple, you can change your settings and unlink from that service in your account settings.

You are responsible for keeping your personal information up to date.

Communications. We use your email — and, if you’ve given us permission, your phone number or third party app ID — to communicate with you. For example, if you’ve told us you’re interested in becoming a Creator, we’ll communicate with you about that process. If you’re interested in our events, we’ll send you information about events in your area. You can opt out of marketing email or text communications by clicking the unsubscribe link in an email or replying STOP to a text message, or by contacting our Customer Support team.

You will not be able to opt out of service emails from us, such as password reset emails or notifications of updates to our terms, unless you deactivate your account.

We may also send push or local notifications to your device to provide updates and relevant messages. You will be able to manage notifications from your account settings in the App or through your device.

Closing your account. You may close your account at any time, either through the deletion process in your account settings in the App or by contacting our Customer Support team. When you delete your account, you will lose access to it and all the content in it. If you are a Creator, we will need to resolve any applicable unpaid commissions before we can close your account.

Data retention. We retain personal information for as long as necessary to provide the Services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and carry out other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable you to delete data within your account settings, and our legal or contractual obligations. For example, most of your deletion requests, such as deleting specific data elements within your account, will be processed immediately, but we will retain security logs for a longer period.

However, if you have closed your account and resolved any outstanding concerns, barring legal or reporting requirements, we will delete your full profile within 30 days of your request. During that 30 day period, we will continue to protect and use your information as described in this Privacy Statement.

After you close your account, we may retain some data associated with your account for legal or security purposes, such as our records of commissions we have paid you.

Cookies and tracking technologies

LTK uses common information-gathering tools such as cookies, web beacons, pixels, and other similar tracking technologies to automatically collect information as you navigate our app, our website, your account, or when you interact with emails we sent to you.

A cookie is a small piece of data, which often includes an anonymous unique identifier, that is sent from a website and stored on your computer’s hard drive. Cookies allow LTK to identify your device as you navigate our website or your account, to keep you logged in, to remember your preferences, to identify your device for security purposes, and to maintain statistical reports. They make navigating and interacting with our websites or your account more efficient, easy, and meaningful for you.

The cookies on our website fall into four categories:

• necessary cookies that are required to use our website, like a login session cookie;
• functional cookies that make our website easier to use, like a preferences cookie;
• social media cookies that are used for connecting to other social media sites, like a TikTok cookie or Facebook pixel, and may share information about your use of LTK with those sites; and
• advertising or tracking cookies. These cookies may be set by other social media sites and used when we send LTK’s ads to you on those sites based on the things you’ve liked here on LTK, like a Facebook cookie, or they may be used to do some basic analytics on our site, like a Google Analytics cookie.

A web beacon is a small, single-pixel clear image contained within a website or email. When your browser loads the image, the server hosting that image is able to log information about your device and set and read its own cookies. LTK uses web beacons on some of our pages, and we sometimes use web beacons in emails that we send you. These let us know when you open an email or view a page. LTK also uses embedded scripts and logging technologies.

Managing cookie preferences

You can manage your cookie preferences, and learn more about the cookies we set, using our cookie consent tool. When you visit our website for the first time, a cookie consent banner will pop up and ask you to customize your cookie preferences. You can also manage your cookie preferences in your browser. Please be aware that you cannot opt out of necessary cookies, and if you opt out of functional cookies, your ability to use our site may be impaired. In addition, you can manage cookies in the following ways:

• Global Privacy Control (GPC) is a technical specification that you can use to inform websites of your privacy preferences in regard to ad trackers. To set up GPC, you can visit the Global Privacy Control website. If you do choose to set up GPC, we will automatically turn off all non-required cookies on LTK’s website by default.
• Do Not Track (DNT) is a signal that some browsers can send that requests that a website disable tracking activity. If your browser sends a DNT signal, we will automatically turn off all non-required cookies on LTK’s website by default.
• Certain browser extensions, such as Privacy Badger, will manage or block cookies based on your preferences.
• You may also visit third party opt-out tools such as the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Alliance. These opt-out tools are not provided by LTK and we cannot assist with them.

Security information

We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. These measures vary based on the sensitivity of the personal information we collect, process, and store and the current state of technology. We also take measures to ensure service providers that process personal information on our behalf also have appropriate security controls in place.

To help us protect your account, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts. We encourage you to keep your phone, computer, or any device you use to access LTK updated to the latest version for security purposes. Please be aware that we will never contact you unexpectedly by phone or email requesting your account ID, password, credit or debit card information, or national identification numbers.

Global privacy compliance and international transfers

LTK is proud to be a global company with Creators, Shoppers, and Brands all over the world. As such, our approach to privacy compliance is global. We remain committed to complying with applicable data protection laws and protecting your data whether you’re a Shopper or a Creator on LTK.

Regions requiring a legal basis for processing personal information

If you are from a region that requires a legal basis for processing personal information (such as the EEA or the UK), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person, such as in the case where we request personal information from you in the context of a government audit or in response to a request from law enforcement.

Generally speaking, when we use personal information to further our legitimate interests, it is for these limited purposes:

• to understand who our Shoppers and Creators are and what their interests are;
• to manage our relationships with our Shoppers, Creators, and Brand representatives, and provide support and product improvements;
• to respond to inquiries, concerns, and complaints, and communicate with you when you have a question;
• to carry out core business operations such as accounting, filing taxes, and fulfilling regulatory obligations; and
• to detect, prevent, or investigate security incidents, fraud and financial crime, and other abuse or misuse of our Services.

Cross border data transfers and onward transfers

LTK is based in the United States and we process personal information in the United States. We also use service providers around the world. Therefore, we may transfer, store, and process your personal information outside of the jurisdiction where you reside. When we do transfer your personal information, we maintain the same standard of data protection regardless of where the information originates and where it is processed.

When we transfer personal information from the EEA, from the UK, or from Switzerland, we rely on data transfer mechanisms such as Standard Contractual Clauses and the International Data Transfer Agreement. You may obtain a copy of the Standard Contractual Clauses or the International Data Transfer Agreement by contacting us.

When we transfer personal information from countries other than the EEA, the UK, or Switzerland, we strive to comply with those countries’ data protection and data transfer laws, such as by cooperating with that country’s data protection authority or providing a written agreement.

Privacy compliance for specific individuals

Job applicant and candidate personal information. If you are applying for a position at LTK or are a candidate for a job here, our Candidate Privacy Notice provides up to date information about the personal information we collect about you and how we protect it.

Information from children. We do not knowingly permit children under the age of 16 to sign up for an account on LTK, and we don’t direct our Services to children. If we discover that someone under 16 has signed up for an LTK account, we will take reasonable steps to promptly remove that person’s personal information from our records. If you are a parent or guardian and you believe that a child has signed up for an LTK account, please contact us to request that we remove that personal information. If we obtain actual knowledge that we have received personal information from a child, we will promptly delete that information from our records.

State-specific privacy information

If you are a U.S. resident, we process your personal information in accordance with applicable U.S. state data privacy laws, including the California Consumer Privacy Act (CCPA), the Colorado Privacy Act (CPA), the Utah Consumer Privacy Act (UCPA), and the Virginia Consumer Data Protection Act (VCDPA). We don’t discriminate or change our practices based on where you live; all our Shoppers and Consumers have the same rights, and we won’t change how we offer our Services if you exercise your rights. However, if you ask us to delete or restrict your personal information, it will impact your ability to use LTK, particularly if you are a Creator. You have the right to request that we (i) provide details about the categories of personal information we collect, use, disclose, share, and sell; (ii) provide access to, and a copy of, the personal information we collect about you; (iii) correct any inaccurate personal information we have about you; (iv) restrict the use and disclosure of your sensitive information; (v) delete your personal information; and (vi) opt you out of future “sharing” of personal information for targeted advertising purposes.

We provide this information here in this Privacy Statement, and our section on Making choices about your personal information offers steps on exercising these rights. You may make these requests yourself or through an authorized agent. If you use an authorized agent, we provide your agent with detailed guidance on how to exercise your privacy rights. However, we will need to take steps to verify that you or your agent are authorized to make the request.

For California residents, we share your personal information as we describe above, for our business purposes. Please contact us if you would like more specific information.

Resolving disputes

We hope that we can resolve any disputes relating to our data protection practices by working with you to understand your concerns and correct any issues. If something isn’t right or if you have questions about our data protection practices, please contact us. We want to help.

You may also send us a physical letter addressed to LTK, attn: Office of the Data Protection Officer, at the address in our section on Contacting LTK.

In the event that you have a dispute relating to your agreement with us, please see that agreement regarding how those disputes will be resolved. For our Shoppers and Creators, most disputes will be resolved according to the provisions of our Terms of Service.

In the event that you have a dispute relating to our data protection practices, we offer a few different options, all offered without charge to you. LTK commits to cooperate with the panel established by the EU data protection authorities (DPAs), as well as the Swiss Federal Data Protection and Information Commissioner and the Information Commissioner’s Office of the United Kingdom, as applicable, and comply with the advice given by them with regard to personal information transferred from the European Union, Switzerland, and United Kingdom. Additionally, you may have the right to lodge a complaint with your local data protection or privacy agency or supervisory authority. We ask that you please contact us before filing your complaint and allow us to attempt to resolve your issue. For your local data protection authority’s contact information, please see the EDPB’s website.

LTK is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Other information you may find useful

Contacting LTK

If you have any questions or requests in connection with this rewardStyle Privacy Policy or other privacy-related matters, please send an email to datarequests@rewardstyle.com. We will respond promptly to your questions.

Alternatively, inquiries may be addressed to:

United States (Headquarters): rewardStyle, Inc. Attn: Office of the Data Protection Officer 3102 Oak Lawn Avenue Suite 900 Dallas, TX 75219 Email: datarequests@rewardstyle.com

United Kingdom: rewardStyle Uk Ltd 2-4 Old Street London EC1V 9AA Email: datarequests@rewardstyle.com

Europe: rewardStyle GmbH c/o Grant Thornton AG Cicerostraße 2, 10709 Berlin Email: datarequests@rewardstyle.com

United States (Headquarters): rewardStyle, Inc. Attn: Office of the Data Protection Officer 3102 Oak Lawn Avenue Suite 900 Dallas, TX 75219 Email: datarequests@rewardstyle.com

United Kingdom: rewardStyle Uk Ltd 2-4 Old Street London EC1V 9AA Email: datarequests@rewardstyle.com

Europe: rewardStyle GmbH c/o Grant Thornton AG Cicerostraße 2, 10709 Berlin Email: datarequests@rewardstyle.com

Changes to our Privacy Statement

LTK may change this Privacy Statement from time to time for a variety of reasons, including to comply with new laws and regulations, to cover new features and functionality, and to increase transparency. If we do, the most recent version will always be available at https://qa-company.qashopltk.com/privacy. These changes might be minor, such as fixing a typo, or they might be changes that affect your rights. If we make a material change — a change that affects your rights — we will provide 30 days’ advance notice of those changes by sending you an email via the address in your account or by posting a notice in the App.

Because we are a global company, we may provide translations of this Privacy Statement in languages other than English. If we do, those translations are provided for your convenience. In the event of any ambiguity or conflict between translations, the English version controls, to the extent permitted by local laws.