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Privacy Policy

Last updated: August 27, 2024

YOUR PRIVACY: OVERVIEW

If you are a consumer in the United States, this privacy policy ("Privacy Policy") explains how lululemon Studio d/b/a MIRROR, (collectively, "lululemon Studio," "we," or "us,") collect, use, process, disclose, and retain your personal data when you access or use our websites, mobile applications, lululemon Studio, and any other applications, products, or services that display this Privacy Policy (collectively, the “Services”).

Please read this Privacy Policy to make sure you understand how we process your personal data and the choices you have with respect to such processing. Please note we provide different or additional privacy notices in connection with certain activities, programs, offerings to clarify or supplement our privacy practices in greater detail. For example, this privacy policy is limited to customers within the U.S. Our privacy practices are subject to applicable laws in the places in which we operate, which means we engage in the practices described in this notice in a particular country or region only as permitted under the laws of such jurisdictions. For more information about our privacy practices in other jurisdictions, please refer to the privacy policy for the jurisdiction, available in our stores or posted on website for that jurisdiction.

REVISIONS TO THIS PRIVACY POLICY

lululemon Studio reserves the right to change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we will provide you with additional notice, such as adding a statement to our websites’ homepages or sending you a notification.


CONTENTS


COLLECTION OF PERSONAL DATA

In this Privacy Policy, "personal data" means any information that is related to a reasonably identifiable natural person or as otherwise defined under applicable law. The types of personal data we collect about you depend on your interactions with us and are described in more detail below.

PERSONAL DATA YOU PROVIDE DIRECTLY TO US

We collect personal data directly from you when you purchase our products, use our services, or otherwise interact with us, including:

Profile Data. We collect information or content you provide to us in connection with an account or profile, such as when you register for an account, create a profile, participate in our membership programs, fill out a form, or use lululemon Studio. Examples of profile data we may collect include your name, email address, phone number, mailing address, account login name and password, ID, height, weight, equipment you own, activity preference, lululemon Studio followers, injuries, physical limitations, clothing and shoe size, hobbies, interests, studio or business name, preferred language, dietary restrictions, allergies, birthday, social media handles, and classes you teach or attend in connection with our membership programs.

Demographic Data. We may collect demographic data when you fill out forms or surveys or sign up for and participate in events, contests, sweepstakes, promotions, and special programs that we provide. Examples of such information include age and gender.

Transaction Data. We collect transaction information related to the products and services you purchase from us. Examples of information collected include the type of products or services requested or provided, order details, delivery information, amount charged, payment method, billing or shipping information, government-issued identification card (for returns only), and information about any products or services you returned or exchanged with us. If you make a purchase, we work with third-party payment processors to collect and process your payment information.

Communications Data. We collect information when you communicate with us or others on our Services, such as when you request additional information about products or services, interact with our customer service team or store associates, contact others through lululemon Studio, or sign up to receive our email newsletters or marketing messages. We also collect communications data when you interact with us on social media, such as by tagging us and/or our products or permitting us to follow your social media profile. Examples of such data may include your contact information, the date and time of your communications, online identifiers, social media profile, and the content of your communications.

User Content. We collect any other information or content you provide to us, such as when you rate workouts, provide design or product feedback, make other submissions to us, participate in any of our experiential offerings in our stores or at other locations sponsored by us, or use other features of our Services that may be offered from time to time, which may require the collection of certain personal data in order to utilize the features. Examples of user content may include information about your size, fit, goals, opinions, feedback, preferences, text, images, and any other personal data you choose to provide in your interactions with us.

PERSONAL DATA WE COLLECT AUTOMATICALLY

We automatically collect certain personal data when you access and use our Services or shop in our stores. The types of information we collect may include:

Device and Network Data. We collect certain information about the device you use to access our Services. Examples of such data include your device’s hardware model, browser type, IP address, operating system version, language settings, unique device identifiers, advertising identifiers, serial numbers, device motion data, screen resolution, usage and traffic data, how your device interacts with the Services, network information, and mobile network data.

Usage Data. We collect information about your activity on our Services via log files, cookies, web beacons, and other tracking technologies. Examples of such data include your access dates and times, pages or screens viewed, how long you spent on a page or screen, the routes by which you access our Services, searches you conduct on the Services, information about your activity on a page or screen, app crashes and other system activity, your use of any hyperlinks available within our Services, information about your interactions with our emails, your Internet service provider (ISP), Mobile Advertising ID, media access control (MAC) address, and identifiers associated with browser cookies, web beacons, and similar technologies we deploy on our Services (for more information about cookies and how to disable them, see the “COOKIES AND SIMILAR TRACKING TECHNOLOGIES” section below).

Audio, Video, or Sensory Data. We collect audio, video, or sensory information from you. Examples of such data include video recordings when you visit our stores, sensory data when you participate in a product test requiring sensory data, or audio or video recordings when you call our Guest Education Centre.

Location Data. We collect information about your precise or approximate location information in accordance with your device permissions. You may use our Services without enabling us to collect location data from your device, however, this may affect some functionality available in the Services. For example, you may need to manually enter an address to find a store near you if you have not enabled location data collection. For more details, please see “YOUR PRIVACY RIGHTS AND CHOICES” section below.

Activity Data. When you use lululemon Studio, we may collect activity data, such as information about how your body moves, including audio and video recordings of your workout and how you position and move your head, arms, hands, feet, legs, and torso. We may also collect workout history and metrics data, including your heart rate, fitness performance history, and lululemon Studio achievements.

PERSONAL DATA WE COLLECT FROM OTHER SOURCES

We may collect personal data about you from other sources. For example, we may collect personal data about you from:

Fitness studios and providers of online booking tools when you sign up for and participate in classes offered or sponsored by us;

Our other guests, including when they bring you as a guest to one of our events, in connection with refer-a-friend programs, or if they list you as an emergency contact;

Third parties hosting events, including those sponsored by lululemon Studio, when they provide event attendance or participation information to us;

Publicly available sources;

Other guests or third parties, including when they provide information in connection with a dispute;

Carriers or other third parties when they provide your updated delivery and address information to us, which we use to correct our records and deliver your next purchase or communication;

Our holding company, subsidiaries, and affiliates;

Third-party platforms, such as Facebook, Twitter, Google, Spotify, Apple Health, and Instagram, that you use to interact with our Services (e.g., to create an account) or that allow you to provide information to us (e.g., via plugins, widgets, or other tools), but always in accordance with the authorization procedures and privacy settings you establish with such services; and

Unaffiliated parties, such as our service providers, analytics companies, marketing or advertising service providers, fraud prevention service providers, consumer data resellers, and other third parties that provide us with information so we can better understand you and provide you with information and offers that may be of interest to you.

PERSONAL DATA WE DERIVE

We may derive information or draw inferences about you based on the other types of personal data we collect. For example, we may infer your location based on your IP address, or your purchasing habits based on your browsing behavior on our Services.

USE OF PERSONAL DATA

We collect and use personal data for various purposes, including to:

Provide Products and Services. Provide, administer, deliver, customize, support, maintain, and improve our products, events, services, and membership programs;

Complete Transactions. Complete the transactions you request, perform our contractual obligations, including processing payments through third-party vendors, and as otherwise anticipated within the context of our ongoing business relationship;

Manage Accounts. Create and manage your online accounts, profiles, and membership programs;

Service Communications. Send communications related to your account, participation in membership programs, purchases, exchanges, and returns;

Respond to You. Respond to your requests and any other communications from you, including to provide customer service;

Advertising and Marketing. Send advertising or marketing communications about products, services, offers, promotions, rewards, and events offered by lululemon Studio and others, and provide news and information that we believe may be of interest to you (for information about managing your marketing preferences, see the "Your Privacy Rights and Choices" section below);

Events and Offers. Offer, conduct, and administer events, classes, contests, prize draws, sweepstakes, and other promotions;

Research and Development. Conduct research and development;

Personalize Your Experience. Monitor, analyze, and audit your engagement with our brand and your interactions with our Services and online ads to better understand your interests and behaviors and customize your experience;

Safety and Security. Detect and protect against malicious, deceptive, or illegal activity, including fraudulent transactions, error, negligence, and breach of contract, security incidents, and harm to the rights, property or safety of lululemon Studio and our users, customers, employees, or others;

Troubleshooting. Debug, identify, and repair errors that impair existing intended functionality of our Services;

Corporate Transactions. We may process personal data in the context of corporate acquisitions, mergers, or other corporate transactions;

Your Consent. We may process your personal data in accordance with your consent, or when you intentionally direct or instruct us to do so;

Comply with Legal Obligations. Comply with our legal or regulatory obligations, including our tax obligations and those related to the prevention of fraud and money laundering, and those required for you to benefit from rights recognized by law, or any regulatory requirements or provisions; and

Reasonable Other Purposes. As permitted by applicable law, carry out certain short-term activities and other reasonable purposes related to the products or services you purchase from us or your ongoing relationship with us. Where required by applicable law, lululemon Studio will provide a notice of such data processing prior to using your personal data for such purposes.

DISCLOSURE OF PERSONAL DATA

We disclose personal data to the entities and for the purposes described below:

Affiliates and Subsidiaries. We disclose your personal data to our corporate affiliates, including our holding company, sister companies, and subsidiaries for the purposes described in the “USE OF PERSONAL DATA” section above.

Service Providers. We disclose personal data to unaffiliated companies or individuals we hire or work with that perform services on our behalf, including customer support, web hosting, information technology, payment processing, financing, product fulfillment, marketing and database management, direct mail and email distribution, events, contest, sweepstakes and promotion administration, music integration, extended warranty services, and advertising and analytics services. These service providers and contractors have access to personal data in order to perform services for us.

Contractors and Third-Party Partners. We disclose personal data to unaffiliated companies or individuals we partner with to provide certain products, services, or experiences to you. For example, if you decide to pay for a purchase in installments, we disclose personal data to the third party that provides financing for your purchase. We also permit certain third parties, like our fraud prevention partners, to collect personal data in order to detect and prevent fraudulent transactions.

Corporate Transactions. Personal data may be disclosed or transferred as part of, or during negotiations of any purchase, sale, lease, merger, amalgamation, or any other type of acquisition, disposal, securitization or financing involving lululemon Studio.

Professional Advisors. We disclose personal data to our legal, financial, insurance, and other advisors in connection with the kinds of corporate transactions described above or in connection with the management of all or part of lululemon Studio’s business or operations.

Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose personal data when we believe doing so is reasonably necessary to comply with applicable law or legal process (including an enforceable request from authorities), to respond to claims (including inquiries by you in connection with your purchases from lululemon Studio), enforce or apply our TERMS OF USE, or to protect the rights, property, or personal safety of lululemon Studio, our users, employees, or others.

Other Users of the Services or the Public. When you use lululemon Studio, we may display your username so that other users can connect with you. For example, if you choose to add other users as friends or participate in face-offs, your video, profile data, and fitness and performance data may be visible to these users and they may be able to comment on your workouts. Also, if you choose to activate the camera on your lululemon Studio Mirror during a workout, other users may be able to see your video while the workout is occurring or during future, on-demand versions of the workout. We do not control how other users or third parties use any personal data that you make available to them. Please be aware that any information you post publicly can be cached, copied, screen captured, or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.

Your Consent or at Your Direction. We disclose personal data, such as profile data and communications data, to third parties when we have your consent or direction to do so. For example, if you decide to participate in certain interactive areas or features of our Services, such as creating a public profile and posting your goals, you consent to the disclosure of this information to other users of our Services. We may also disclose your personal data to third parties, such as personal trainers, fitness studios, and providers of online booking tools, when you intentionally direct us to do so or when you use our products or services to intentionally interact with third parties.

Aggregated, Anonymized, or De-identified Data. We may also disclose aggregated, anonymized, or de-identified information, which cannot reasonably be used to identify you. lululemon Studio processes, maintains, and uses this data only in a de-identified fashion and will not attempt to re-identify such data, except as permitted by law.

TARGETED ADVERTISING AND ANALYTICS

We engage others to provide analytics services, serve advertisements, and perform related services across the web and in mobile applications. These entities may use cookies, web beacons, SDKs, device identifiers, and other tracking technologies to collect information about your use of the Services, and other websites and applications, including your IP address and other identifiers, web browser and mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information is used to deliver ads targeted to your interests on other companies’ sites or mobile apps, analyze and track data, determine the popularity of certain content, and better understand your online activity. In addition, some of our advertising partners enable us to translate your email address into an identifier that can’t be used to identify you personally. Our advertising partners then use that unique identifier to show ads that are more relevant to you across the web and in mobile apps.

The activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under certain laws. If you prefer to opt out of having your information used for these purposes, please see the “YOUR PRIVACY RIGHTS AND CHOICES” section below. You can also visit WWW.ABOUTADS.INFO/CHOICES for more information about interest-based ads and to opt out of having information about your use of the Services be used by companies that participate in the Digital Advertising Alliance.

CHILDREN’S PRIVACY

lululemon Studio does not target our products and services to children; however, we may allow children 13 and older to use lululemon Studio with the consent and under the supervision of a parent or legal guardian. If you are a parent or legal guardian and you believe that your child has provided us with personal data without your consent, please contact us at PRIVACYOFFICER@LULULEMON.COM.

THIRD PARTY SITES

Please note that our websites contain links to third-party websites that are not controlled or operated by lululemon Studio. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that lululemon Studio does not accept any responsibility or liability for these policies. Please review these policies before you disclose any personal data when visiting such third-party websites.

YOUR PRIVACY RIGHTS AND CHOICES

Depending on where you reside, you may have the right to (1) request to know more about and access your personal data, (2) request deletion of your personal data, (3) request to transfer your personal data to a designated third-party (“portability”), and (4) request correction of inaccurate personal data.

You can make these requests at any time by visiting our PRIVACY PORTAL or by calling us at 1-877-263-9300. You can also access, correct, or delete certain information stored within your online account at any time by logging into your account and navigating to the “Profile” page. After submitting your request, please monitor your email for a follow-up communication from us. We may be required to verify your request by asking you to provide additional information related to your recent interactions with us, such as your name and email.

If we deny your request, you may appeal our decision by contacting us at PRIVACYOFFICER@LULULEMON.COM. If you have concerns about the results of an appeal, you may contact the attorney general or other regulatory authority in the state where you reside.

OPTING OUT OF TARGETED ADVERTISING, SHARING, AND SALES

As described in the “Targeted Advertising and Analytics” section above, we process personal data to deliver ads targeted to your interests on other companies’ websites and mobile apps. Some of these activities may be considered “sales” or “sharing” of your personal data or “targeted advertising” under certain laws.

In addition, we disclose your information to other entities for marketing purposes as described above, which may constitute “sales” of your personal data under certain laws.

Depending on where you reside, you may have the right to opt out of targeted advertising, sharing, and sales of your personal data. You can do so by following the under "Your Privacy Choices" at the footer of our website or by visiting our Services with a legally-recognized opt-out preference signal enabled, such as the Global Privacy Control (see the opt-out form for details).

We will not discriminate against you if you exercise your privacy rights.

MARKETING COMMUNICATIONS

You may opt out of receiving promotional communications from us by following the instructions in those communications or by logging into your online account and changing your communications preferences. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

LOCATION DATA

When you first launch any of our mobile applications that collect precise location information, you will be asked to consent to the application’s collection of this information. If you initially consent to our collection of this location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. If you do so, our mobile applications, or certain features thereof, may no longer function properly.

MOBILE PUSH NOTIFICATIONS/ALERTS

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

COOKIES AND SIMILAR TRACKING TECHNOLOGIES

Like many websites, lululemon Studio uses cookies to analyze visits to our websites and emails and help us improve our website, services, and marketing campaigns. Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Please follow your browser’s process for doing so. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our websites.

ADDITIONAL STATE-SPECIFIC INFORMATION

Certain states have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures with respect to our collection, use, and disclosure of personal data. If you are a resident in a state with a comprehensive consumer privacy law, including California, Colorado, Connecticut, Virginia, and Utah, this section applies to you.

ADDITIONAL DISCLOSURES

In the preceding 12 months, we have collected the following categories of personal data: identifiers (such as your name, email, or IP address), characteristics of protected classifications under California or U.S. law (such as your age or gender), commercial information (such as records of products or service purchased), internet and electronic network activity (such as information about your activity on our website), geolocation data (such as your city of residence), audio, visual, or other sensory information (such as phone recordings when you call our Guest Education Centre), and inferences drawn from your personal data to create a profile (such as your fitness level, regimen, goals and preferences). If you choose to participate in market research surveys, we may also collect any sensitive personal information you choose to disclose, such as your identified race or ethnicity. For examples of the precise data points we collect and the categories of sources of such collection, please see “COLLECTION OF PERSONAL DATA” section above.

We collect, use, and disclose personal data for the business or commercial purposes described in the “USE OF PERSONAL DATA” section above.

In the preceding 12 months, we have disclosed the following categories of personal data for business or commercial purposes to the following categories of recipients:

CATEGORIES OF PERSONAL DATA: IDENTIFIERS

Categories of Recipients: Advertising networks, Internet service providers, data analytics providers, operating systems and platforms, social networks, payment processors, fulfillment partners, customer support partners, events and promotions partners, and fraud prevention partners

Categories of Personal Data: Internet and electronic network activity information

Categories of Recipients: Advertising partners, Internet service providers, data analytics providers, operating systems and platforms, internet service providers, customer support partners, and fraud prevention partners

Categories of Personal Data: Commercial information

Categories of Recipients: Advertising partners, data analytics providers, payment processors, fulfillment partners, customer support partners, and fraud prevention partners

Categories of Personal Data: Audio, visual, and sensory information

Categories of Recipients: Customer support partners, events and promotions partners, and fraud prevention partners

Categories of Personal Data: Geolocation data

Categories of Recipients: Advertising networks, Internet service providers, data analytics providers, and fraud prevention partners

Categories of Personal Data: Characteristics of protected classifications under California or U.S. law

Categories of Recipients: Advertising networks, Internet service providers, data analytics providers, and fraud prevention partners

Categories of Personal Data: Inferences from your personal data to create a profile

Categories of Recipients: Advertising networks, Internet service providers, data analytics providers, and fraud prevention partners

Categories of Personal Data: Sensitive personal information

Categories of Recipients: Market research providers, for customers that voluntarily participate in marketing surveys

We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you. We also do not knowingly “sell” or “share” personal data about consumers under the age of 16.

We “share” and “sell” personal data for the purpose of engaging in advertising and marketing activities. In the preceding 12 months, we have shared and sold the following categories of personal data to the following categories of third parties:

CATEGORIES OF PERSONAL DATA CATEGORIES OF THIRD PARTIES

Categories of Personal Data: Identifiers

Categories of Recipients: Our affiliated companies, joint marketing campaign partners, other retailers, and

advertising and marketing networks

Categories of Personal Data: Commercial information

Categories of Recipients: Advertising and marketing networks

Categories of Personal Data: Internet and electronic network activity information

Categories of Recipients: Advertising and marketing networks

STATE-SPECIFIC PRIVACY RIGHTS

Please see the “YOUR PRIVACY RIGHTS AND CHOICES” section above for more information about your privacy rights , how to exercise these rights, and how we verify the identity of requesters.

You may designate an authorized agent to exercise privacy rights on your behalf by providing the authorized agent signed permission to submit the request on your behalf. If an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal data. If you are an authorized agent seeking to make a rights request, please contact us at PRIVACYOFFICER@LULULEMON.COM.

NOTICE OF FINANCIAL INCENTIVES AND BONA FIDE LOYALTY PROGRAMS

We offer various financial incentives. For example, we may provide discounts, coupons, or other benefits to customers who join membership programs or sign up to receive our marketing emails or text messages. These offerings may constitute “financial incentives” or “bona fide loyalty programs” under certain state privacy laws (for simplicity, we refer to these offerings as financial incentives). If you decide to participate in a financial incentive, we collect personal data from you, such as identifiers (like your email address or phone number), commercial information (like your purchase preferences and interests or purchase history), professional or employment-related information, inferences drawn about your preferences, and other categories of personal data that relate to or are reasonably capable of being associated with you. We disclose this information to our service providers that perform services on our behalf, including payment processing, product fulfillment, and marketing and database management. We also disclose your commercial information to our marketing and advertising partners so we can display ads that are targeted to your interests and preferences. You can opt into a financial incentive by following the sign-up or participation instructions provided. For any ongoing benefits, you can opt out at any time, such as by following the unsubscribe instructions in the applicable program’s terms and conditions, promotional emails, or text messages, or contacting us at PRIVACYOFFICER@LULULEMON.COM. If you request that we delete personal data that is essential to providing you with the financial incentive, we will not be able to provide you with such benefits going forward. For example, if you ask us to delete your email address, we will no longer be able to provide you with early access to sales or other benefits. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your personal data is reasonably related to the value of the offer or discount presented to you.

RETENTION OF PERSONAL DATA

Our retention periods for personal data are based on business needs and legal requirements. We store personal data associated with your account for as long as your account remains active. If you close your account, we will delete your account data within the applicable regulatory timeline. We retain other personal data for as long as is necessary for the processing purpose(s) for which we originally collected it and for other business purposes explained in this Privacy Policy. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired. In addition, we retain your email address and information about your marketing preferences to ensure that we can honor those preferences.

ADDITIONAL INFORMATION FOR AMBASSADORS

If you are a lululemon Studio ambassador, this section also applies to you. We may collect additional identifiers, such as your passport number and social security number, user-generated content such as product reviews, professional or employment-related information, and other information you provide to us. We may also collect information about your activity on our intranet or other collaboration platforms via log files, cookies, web beacons, and other tracking technologies. We may collect and use your personal data to manage the ambassador program, such as to conduct pre-participation checks or references, process payments, and conduct performance reviews. We may disclose your personal data to other users of the services or the public.

CONTACT US

If you have any questions or comments about this Privacy Policy, you may call us at 1-877-263-9300 or email us at PRIVACYOFFICER@LULULEMON.COM.