OOFOS Privacy Policy

Effective Date: 09/30/2023

Oofos, Inc. (“Oofos” “we” or “us”) is a recovery footwear company. This Oofos Privacy Policy (the “Policy”) describes how Oofos collects, uses, discloses and otherwise processes the personal data described in this Policy, as well as the rights and choices individuals have regarding such personal data. We take your privacy and the security of your information very seriously, and we encourage you to read this Policy carefully to understand how we collect and handle your personal data and the choices and rights you have regarding your personal data.

For information about the privacy choices you have regarding your personal data, review Section 7. Your Privacy Choices below, as well as Section 13. Additional Information for Certain Jurisdictions. If you are a resident of California, please also refer to Section 13.B., “Additional Information for California Residents”, for information about the categories of personal data we collect and your rights under California privacy laws.

Your use of our Services, and any dispute over privacy, is subject to this Policy, our Terms and Conditions, available at https://www.oofos.com/pages/terms-and-conditions and our Mobile Terms of Service, available at https://www.oofos.com/pages/mobile-terms-of-service

Scope

Except as otherwise noted below, this Policy applies to the personal data we process related to:

users of our website oofos.com (the “Site”) and the services we provide through the Site (collectively, the “Services”).
current, former and prospective customers and purchasers of Oofos products and rewards program members;
individuals who are subscribed to receive news, information and marketing communications from us, including via SMS text messaging where you have opted in to receive such messaging;
individuals who register for or participate in events, contests, sweepstakes, surveys and research sponsored or conducted by Oofos;
individual vendors, partners and business contacts; and
individuals who communicate with us or otherwise engage with us related to our Services, including through social media and other third party platforms.

This Policy does not apply to the personal data that we collect and process about our employees and personnel or job applicants and candidates, or information that is exempt under applicable privacy laws.

Additional Notices. In some cases, additional or supplemental privacy notices (each an “Additional Notice”) may be provided and will apply to certain personal data collected and processed by us. For example, in order to provide more specific information about our use and disclosure of personal data if you choose to participate in a particular partner promotion. The Additional Notice will control to the extent there is a conflict with this Policy, with respect to your personal data that is subject to that Additional Notice.

Personal Data Collected

As further described below, we collect personal data directly from individuals, as well as from third parties and automatically related to the use of our Services or other interactions with us.

Personal Data Collected Directly. The personal data we collect from you depends upon how you use our Services or otherwise interact or engage with us and includes:

Identifiers/contact information. When you register for an account with us, register to receive information, news, and offers from us, or join our rewards program, or enter our contests, promotions, sweepstakes, or events, we may collect certain personal data, including your name, email address, password, phone number, and communications preferences, as well as other information you choose to submit or store to your account, such as billing and shipping details, other contact information, birthday, interests or preferences. When you purchase a gift card, we collect information about gift recipients so that we can fulfill the gift purchase.
Purchase Information. When you place an order, make a purchase or initiate a return, we will collect payment information and any other information used to process your order, payment or return. When you register for an account with us, we may collect payment details that you choose to store in your account. We also maintain records about your past purchases, as well as items that you view or add to your cart.
Communications and Correspondence. When you submit an inquiry to our Customer Care Team, or otherwise contact us (by chat, email, mail, phone or otherwise), we collect and maintain a record of your contact details, the communications and information you provide, and our responses. We also maintain records of communications and information that you post in chat sessions, forums and in other areas of the Services, as well as on our social media channels.
Photos and Videos. When you enter a contest or sweepstakes, we may collect photos and videos from you in connection with such contest or sweepstakes.

Personal Data from Third Parties. We may collect personal data about you from third party sources, such as public databases, joint marketing partners, social media platforms or other third parties, as described in this section.

Social media pages and platforms. If you post information about us or engage with us on third party platforms, we may collect personal data about you from that third party platform or account. The third-party platforms and services control the information they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.
Other sources. We may engage with third parties to enhance or update our customer information and obtain information about prospective customers that may be interested in our Services. For example, we may engage third parties to assist with our direct mailing campaigns, in order to help us better reach existing customers as well as prospective customers who may be interested in Oofos and our Services.

Personal Data Collected Automatically. We collect personal data related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies, pixel tags and other technologies, as well as information we derive about you and your use of the Services). Such information includes:

Device and browsing information. We use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. For more information, see Section 6. Cookies, Advertising and Tracking, below.
Activities and usage. We also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, products and items you view and items you add to your cart, and your interactions with us and others within the Services.
Location information. We may collect or derive location information about you, such as through your IP address.

Purposes of Collection and Processing

Generally, we collect, use and otherwise process the categories of personal data described above for the following purposes:

Services and support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes. If you participate in or register for contests, sweepstakes, events or other promotions, we use your personal information to administer that event.
Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, to develop services and features, and for internal quality control and training purposes.
Customization and personalization. To tailor content we may send or display on the Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
Marketing and advertising. For marketing and advertising purposes. For example, to send you information about our Services, such as offers, promotions, newsletters and other marketing content, as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach people with relevant content.
Loyalty/rewards program. If you have a My Oofos account and are a member of our rewards program, we use your personal data in order to administer that program, including to make certain rewards and benefits available to you and send you rewards-related communications.
Research and surveys. To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
Security and protection of rights. To protect the Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms and Conditions or this Policy.
Legal proceedings and obligations. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.
General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions, and related to the administration of our general business, accounting, auditing, compliance, record keeping, and legal functions.

Disclosures of Personal Data

We disclose the categories of personal data we collect in order to provide our Services to you, respond to and fulfill your orders and requests, as otherwise directed or consented to by you, and as follows:

Vendors and service providers. We may disclose personal data we collect with our service providers, processors and others who perform functions on our behalf. These may include, for example, IT service providers, help desk, payment processors, analytics providers, consultants, auditors and legal counsel.
Our affiliates. We may disclose personal data we collect with our affiliates and subsidiaries, who will use and disclose this personal data in accordance with the principles of this Policy.
Third party platforms and services. We may disclose or make available personal data to third party platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also share some of your personal data with third parties, which may include third-party marketing partners, who assist with our direct mailing campaigns. These third parties give us data to help us better market our products and services but may also use your information to facilitate other business’ marketing campaigns. Where you have opted in to receive SMS text messaging from us, SMS opt-in data and your consent will not be shared with third party platforms and providers.
Marketing, advertising and analytics providers. We may disclose certain information that includes personal data to third-party ad network providers, sponsors and/or traffic measurement services, who may use this data to improve and measure the effectiveness of our ads and those of third parties. For more information, see Section 6. Cookies, Advertising and Tracking, below. We may also engage third party analytics companies to collect information about Site usage in order to help us to understand how users access and use the Services, to improve our Services and other products and offerings, and for other research and analytical purposes.
Rewards program purposes. If you are a member of our rewards program, we may disclose your personal data to third parties that help us to administer and operate the rewards program.
In support of business transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. We may also share certain personal data as necessary prior to the completion of such a transfer, such as to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for the transfer.
Compliance, governance and legal requirements. We may disclose personal data in order to comply with law, and to respond to legal process and related to legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. We may also disclose information, including personal data, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, record keeping, and legal functions. In addition, we may disclose the names of sweepstakes and contests winners, in accordance with applicable law.
Security and protection of rights. To protect the Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms and Conditions and other policies and terms.

Aggregate Data

We may also use aggregate, anonymous, and in some cases de-identified, information related to our business and the Services in order to analyze, improve and develop our business and services, and for similar research and analytics purposes. Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in de-identified form and not to attempt to re-identify the information, except in order to determine whether our de-identification processes are reasonable and adequate pursuant to applicable privacy laws.

Cookies, Advertising and Tracking

We and our third-party service providers use cookies, pixels, java script, log files, and other mechanisms to automatically collect information browsing, activity, device and similar information within our Services. We use this information to, for example, analyze and understand how users access, use and interact with others through our Services, as well to identify and resolve bugs and errors in our Services and to assess secure, protect, optimize and improve the performance of our Services. You have certain choices about our use of cookies within the Services, as described in this section. For more information on the types of personal data we collect via cookies and similar mechanisms, please see Section 2. Personal Data Collected.

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within the Services. For example, we use cookies to help keep track of items you place in your shopping cart, and we use this information to send you cart reminder messages via text message (where you have opted in to receive text messages from OOFOS).

Pixel tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third-Party analytics and tools. We use third party tools, such as Google Analytics, to evaluate usage of our Services and to help us improve performance and user experiences. These third-party tools may use cookies and other tracking technologies, such as pixel tags, to perform their services. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Advertising and targeting. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising on our Site and Services, as well as to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect activity information within our Services (as well as on third-party sites and services), as well as IP address, location information, device ID, cookie and advertising IDs, and other identifiers; this information is used to provide you more relevant ads and content within our Services and on third-party sites and services, and to evaluate the success of such ads and content.

Preferences and Privacy Choices.

Industry ad choice programs. You can control how participating third-party ad companies use the information that they collect about your visits to our Site and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices (https://youradchoices.com/appchoices) tool in order to help control interest-based advertising on apps on your mobile device.
Targeted advertising/cookie preferences. If our website detects that your browser is transmitting a “global privacy control” (or GPC) signal, we will apply that to opt that browser on your device out of targeting cookies on our website. If you come to our website from a different device or from a different browser on the same device, you will need to apply GPC for that browser and/or device as well.
Browser settings and controls. If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse the Site, but some features may not function.

Your Privacy Choices

You have certain choices regarding our processing of your personal data, as set forth in this section. In addition, if you are a California, Virginia, Colorado, Connecticut, or Utah resident, please review Section 13. Additional Information for Certain Jurisdictions below, for specific information about your privacy rights and how to exercise them.

Marketing Communications. You can opt out of receiving marketing emails from us by using the unsubscribe link in the footer of each marketing email we send to you or going to the “Manage Preferences” menu in your account. If you have opted in to receive text messages from OOFOS, you can opt out of receiving marketing text messages from us at any time by replying “STOP”. For more information, please see our Mobile Terms of Service at https://www.oofos.com/pages/mobile-terms-of-service.

Correction and deletion. You can update much of the personal data we maintain about you, by logging into your account and updating your profile information. You can also request to correct/update or delete your personal information by sending us a request as set forth in the Contact Us section below. We may maintain information about an individual sales transaction in order to service that transaction and for record keeping purposes. We may require you to provide certain information to verify it is you making the request.

To submit a request to correct or delete your personal data or for more information about our privacy practices and your privacy choices, you may contact us as set forth in the ‘Contact Us’ section below. You can also opt-out of having your personal information shared with third parties by sending us a request as set forth in the ‘Contact Us’ section below.

Children/Minors

Our Services are not designed for minors and we do not knowingly collect personal data from children under 13. If we discover that a child under 13 has provided us with personal data in violation of applicable law, we will delete such information from our systems. If you’re a parent and you believe we have collected your child’s information in violation of applicable law, please contact us as set forth below, in Section 12. Contact Us.

Security

We have implemented safeguards that are intended to protect the personal data we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security. There are also certain steps you can take to better protect against unauthorized access to your personal data. For example, you should choose a strong password that is unique to the Services (and do not reuse passwords across multiple sites and services or share your password with others). If you believe that your password or account has been compromised, please reset your password through our login page.

Third Party Links

In an attempt to provide you with increased value, we may include third party links on our site. These linked sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these linked sites (including if a specific link does not work).

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. Where the changes to our Policy are material, we will make reasonably efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or we will notify you through a pop-up banner on our website’s homepage.

Contact Us

We welcome your questions, comments, and concerns about privacy. You may send us any feedback pertaining to privacy or the contents of this Policy by emailing us at info@oofos.com.

13. Additional Information for Certain Jurisdictions

This section includes additional information as required under privacy laws of certain jurisdictions.

A. Additional Information for Virginia, Colorado, Connecticut, and Utah Residents

Residents of Virginia, Colorado, Connecticut, and Utah have additional rights under applicable privacy laws, subject to certain limitations:

Correction. The right to correct inaccuracies in their personal information, taking into account the nature and purposes of the processing of the personal information. You can update much of the personal information we maintain about you by logging into your account and updating your profile information.
Deletion. To delete their personal information provided to or obtained by us.
Access. To confirm whether we are processing their personal information and to obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format.
Opt-out. To opt out of certain types of processing, including:

To opt out of the “sale” of their personal information.
To opt out of targeted advertising by us.
To opt out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by contacting us at info@oofos.com. To opt out of targeted advertising by us, you can enable a “global privacy control” (or GPC) signal, and we will apply that to opt that browser on your device out of targeting cookies on our website. If you come to our website from a different device or from a different browser on the same device, you will need to apply GPC for that browser and/or device as well.

We will respond to your request as required under the applicable privacy law(s). If we deny your request, you may appeal our decision by contacting us at info@oofos.com

B. Additional Information for California Residents

In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.

Categories of Personal Information Under the CCPA

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months.

Categories of Personal Information Collected and Disclosed. The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see Section 3. Purposes of Collection and Processing and Section 4. Disclosures of Personal Data, above.

Category	Description	Third Parties
Identifiers	Includes direct identifiers, such as name, alias, user ID, username, and other unique personal identifiers; email address, phone number, address and other contact information; IP address and other online identifiers.	• service providers • advisors and agents • regulators, government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • social networks • internet service providers, operating systems and platforms • third parties, such as data brokers • others as required by law (such as disclosures of sweepstakes and contests winners)
Customer Records	Includes personal data, such as name, account name, user ID, contact information, and financial or payment information, that individuals provide us in order to purchase or obtain our products and services. For example, this may include information collected when an individual registers for an account, submits and order or request to us, or makes a purchase on our Site.	• service providers • advisors and agents • regulators, government entities and law enforcement • affiliates and subsidiaries • data analytics providers • others as required by law (such as disclosures of sweepstakes and contests winners)
Commercial information	Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. For example, this may include demographic information that we receive from third parties in order to better understand and reach our customers.	• service providers • advisors and agents • regulators, government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • social networks • internet service providers, operating systems and platforms • third parties, such as data brokers • others as required by law (such as disclosures of sweepstakes and contests winners)
Usage data	Including, but not limited to, browsing history, clickstream data, search history, and information regarding interactions with an internet website, application, or advertisement, including other usage data related to your use of any of our Services or other online services.	• service providers • advisors and agents • regulators, government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • social networks • internet service providers, operating systems and platforms • third parties, such as data brokers • others as required by law (such as disclosures of sweepstakes and contests winners)
Location data	Location information about a particular individual or device.	• service providers • advisors and agents • regulators, government entities and law enforcement • affiliates and subsidiaries • internet service providers, operating systems and platforms • others as required by law (such as disclosures of sweepstakes and contests winners)
Audio, visual and other electronic data	Includes audio, electronic, visual, thermal, olfactory, or similar information, such as CCTV footage (e.g., collected from visitors to our offices and retail locations), photographs and images (e.g., that you provide us or post to your profile), and call recordings (e.g., of customer support calls).	• service providers • advisors and agents • regulators, government entities and law enforcement • affiliates and subsidiaries • others as required by law (such as disclosures of sweepstakes and contests winners)
Professional information	Includes professional and employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships).	• service providers • advisors and agents • regulators, government entities and law enforcement • affiliates and subsidiaries • others as required by law (such as disclosures of sweepstakes and contests winners)
Education Information	Information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates).	• service providers • advisors and agents • regulators, government entities and law enforcement • affiliates and subsidiaries • others as required by law (such as disclosures of sweepstakes and contests winners)
Profiles and inferences	Including inferences drawn from any of the information identified above to create a profile reflecting a consumer’s preferences, characteristics, behavior or attitudes.	• service providers • advisors and agents • regulators, government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • third parties, such as data brokers • others as required by law (such as disclosures of sweepstakes and contests winners)
Protected classifications	We collect limited information that is considered a protected classification under California/federal law (e.g., your gender and disability status).	• service providers • advisors and agents • regulators, government entities and law enforcement • affiliates and subsidiaries • others as required by law (such as disclosures of sweepstakes and contests winners)

“Sales” and “Sharing” of Personal Information? Under the CCPA, a “sale” includes disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value, and “sharing” broadly as disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may disclose or make available usage data, commercial information, profiles and inferences, and identifiers to third party ad companies and third parties that assist us with our direct mail and marketing campaigns. While we may “sell” or “share” personal information as defined by the CCPA, we do not sell or share sensitive personal information, or any personal information about California consumers who we know are younger than 16 years old.

Sources of Personal Information. In general, we may collect the categories of personal data identified in the table above from the following categories of sources:

Directly from the individual
Advertising networks
Data analytics providers
Social networks
Third party data providers (e.g., direct mail providers)
Internet service providers
Operating systems and platforms
Government entities
Data brokers

Purposes of Collection, Use, and Disclosure

As described in more detail above in Section 3, Purposes of Collection and Processing and 4, Disclosures of Personal Data, we collect, use, disclose, and otherwise process the above personal information for the following business or commercial purposes and as otherwise directed or consented to by you:

Services and support;
Analytics and improvement;
Customization and personalization;
Marketing and advertising;
Loyalty/rewards program;
Research and surveys;
Security and protection of rights;
Legal proceedings and obligations; and
General business and operational support.

Retention

We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection.

California Residents’ Rights

CCPA Rights. In general, California residents have the following rights with respect to their personal information, subject to some exceptions:

Do-not-sell or share (opt-out): to opt-out of the sale and sharing of their personal information by Oofos;

Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge);

Right of Correction: to correct inaccurate personal information that we maintain about them;
Right to Limit the Use and Disclosure of sensitive personal information: the right to limit our use or disclosure of sensitive personal information to those authorized by the CCPA. We do not collect, use, or disclose sensitive personal information, thus this right is not available;
Right to know/access: the right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them;

Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests.

Requests to know/access, correct, or delete

California residents may submit a CCPA requests to know/access, correct, or delete to Oofos by emailing us at info@oofos.com or calling 888.820.7797.

When you submit a request to know or a request to know/access, correct, or delete, we will take steps to verify your identity and request by matching the information provided by you with the information we have in our records. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.

Authorized agents may initiate a request on behalf of another individual by contacting us at the toll-free number above; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

Requests to Opt Out

Our website responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our website. Note that your settings are browser and device specific. If you come back to our website from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. More information about GPC is available at: https://globalprivacycontrol.org/.

Financial Incentives. You can sign-up for a My Oofos account, which gives you access to certain rewards, and we will collect your personal information in order to set up, operate, and administer your My Oofos account, and for purposes of providing members with various membership benefits. You may opt out at any time by contacting us at info@oofos.com.

The financial incentives Oofos offers to participating customers is reasonably related to the value of the customers’ data. As a basis for offering these financial incentives, we have valued the personal information we obtain based on a reasonable and good faith calculation determined by considering expenses related to the programs. In doing so, we value the personal information collected through the programs as the equivalent of the costs and expenses incurred to provide the program, including IT, administration, direct costs, third party costs, discounts, and service development costs. We operate the program and make the benefits available to foster a positive relationship with members, which we consider to be invaluable.

Your Privacy Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at info@oofos.com, and include in your request a current California address and your attestation that you are a California resident.

Contact Us. For more information about our privacy practices, you may contact us as set forth above, in Section 12. Contact Us.