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Last Revised: March 2022
This Privacy Policy describes how Bread Financial Holdings, Inc. family of companies, including Comenity Bank, Comenity Capital Bank, and Lon Operations LLC (d/b/a Bread and Bread Operations) (collectively referred to as “Bread Financial”, “we”, the “Bank”), collects, uses, shares, and retains data collected from its websites, including the websites located at www.breadfinancial.com and direct.comenity.com, from when you interact with us (for example on our Social Media Pages), and from the Services we offer to our customers.
If you are visiting us from a location outside of the United States, please keep in mind that we are U.S.-based. This Policy governs the information collected by or on behalf of our sites irrespective of where you are located when you access, browse, or interact with it. If you are a California resident, please see the “California Residents Only” section below which supplements this Privacy Policy.
1. Personal Information We Collect
“Personal Information” refers to information that identifies you directly or can reasonably be associated with you using other information. Such personal information may include your name, Social Security number, date of birth, email address, postal address, or telephone number. Generally, you may provide us with two types of personal information when you interact with our Sites:
Information You Provide Directly To Us
We collect personal information from you online whenever you provide it directly to us. This includes when you send us an email, fill out an application, complete a “Contact Us” form, enter your zip code to find a store, and submit a resume.
We do not knowingly collect, use, or maintain personal information from users under 16.
Information Automatically Collected About Your Device
We, and other parties, such as our analytics and advertising service providers, will automatically collect personal information about your online activities over time and across different websites when you use our Sites. This includes navigational and/or other device-specific information like IP address, browser type, hardware model, and Unique Device Identifier.
Please refer to the “Online Tracking” and “Online Behavioral Advertising” sections of the Policy for additional details.
2. How We Use and Share Your Personal Information
How We Use Your Personal Information
We may use personal information collected at our Sites for servicing, marketing, security, fraud prevention, other internal business purposes, or for any other purpose permitted by law.
How We Share Your Personal Information
We may share your personal information with third party service providers to perform services on our behalf. In addition, we will also share your information throughout our family of companies and with unaffiliated third parties: (i) as required for legal or regulatory compliance, (ii) to protect our rights and property or the rights and property of other parties, (iii) in the event we sell or transfer all or a portion of our business assets, your information may be one of the business assets that are transferred as part of the transaction, (iv) during a bankruptcy proceeding, (v) for servicing, (vi) for internal business purposes, (vii) for fraud prevention, (viii) for marketing and/or to promote additional products, services, and special offers, as permitted by law, (ix) for any purpose you may request, or (x) for any other purpose that may be required or permitted by law.
3. Online Tracking
We, and certain service providers operating on our behalf, may collect information using tracking technologies, including:
Browser Cookies
Cookies are small text files that are stored directly on your device web browser. We use browser cookies to personalize your visit and improve our Sites and other services. Depending on your browser version, you may be able to block or erase browser cookies. Please be aware that some features of our Sites may be unavailable to you if your browser cookies are blocked or erased.
Pixel Tags
Pixel tags (also known as web beacons, web bugs, or clear GIFs) are nearly invisible pixel-sized graphic images in an email message or on a web page. Pixel tags in emails help us confirm the receipt of and response to our emails, the time our email is viewed, and “click-through” information such as where you click email links. Pixel tags on web pages operate similarly to pixel tags in emails in that they help us understand how you interact with our Sites. Please note that pixel tags are often used in conjunction with browser cookies, which are described above.
“Do Not Track” Browser Signals
Our Sites will continue to operate as described in this Policy, whether or not a “Do Not Track” signal or other similar mechanism is received from your web browser.
Location Based Services
Your IP address is a number assigned to your device by your Internet Service Provider and is captured automatically in our server files. If you consent, we may also collect your actual physical coordinates when a location-based service is used, such as GPS signals sent to us when you are searching for a nearby store on a mobile device. We use location information to improve our Sites and service offerings and administration of our Sites.
Retail Application: Location Based Services
For those customers that choose to utilize our retail applications, Bread Financial may collect, use, and share precise location data, including the real-time geographic location of your device. This location data is collected anonymously in a form that does not personally identify you and is used by Bread Financial to provide and improve location-based products and services. For example, we may share geographic location with application providers when you opt in to their location services.
4. Online Behavioral Advertising
Online behavioral advertising (“OBA” or “interest-based advertising”) involves the tracking of your online activities in order to deliver tailored advertising of goods and services that are likely to be of interest to you. We permit third party advertising companies to serve advertisements on our behalf on our Sites and those websites and mobile apps not affiliated with us. This Policy does not cover the privacy practices of the third party sites on which we may have advertisements. Please review their privacy policies and terms of service if you have any questions about their privacy practices.
Opting Out of OBA
Behavioral advertisements will feature an AdChoices Icon (also known as the “Advertising Option Icon”), that when clicked, provides more information about how the advertisement was delivered to you and also provides the ability to opt-out from future OBA by the third parties listed. To opt-out of OBA from all Digital Advertising Alliance (“DAA”) participating companies, please visit http://www.aboutads.info/choices/.
Please note that if you opt-out of OBA, you may still receive online advertising from us on third party sites. Opting out from third party advertising companies means that the advertisements you receive will not be based on your preferences or behavior. Further, opting out does not prevent other parties from tracking your online activity for other uses as described in this Policy.
5. Social Media Pages
From time to time, we may create and manage social media pages that include, but are not limited to, a Twitter or Instagram account or a Facebook page (“Social Media Pages”). With your consent, personal information like your name, profile picture, gender, networks, user ID, list of friends, birthday, likes, education history, work history, current city, hometown, interests, relationship status, and any other information you have shared on a social media site may be collected by us. This Policy does not cover the privacy practices of the social media sites on which we may have Social Media Pages. Please review their privacy policies and terms of service if you have any questions about their privacy practices.
6. International Users
If you are visiting us from a location outside of the United States, please keep in mind that we are U.S.-based. This Policy governs the information collected by or on behalf of our Sites irrespective of where you are located when you access it, browse it, or interact with it.
With respect to personal information, you provide to us on the Social Media Pages, once received from the social media sites, it is maintained and processed by us on servers and internal systems located in the United States. This means your personal information may be stored outside of the province, state, and/or country in which you reside, and processed by us or a third party as described in this Policy. Moreover, governmental bodies that have jurisdiction over us in the United States (e.g., courts and law enforcement agencies) may be entitled to access your personal information.
7. How Your Personal Information is Protected
Your privacy is important to us. We have implemented physical, technical, and administrative security measures to safeguard the personal information that we maintain.
8. Accuracy of Your Personal Information
We strive to maintain accurate personal information about you. If you are a Bread Financial cardholder and believe that our records contain inaccurate or incomplete information about you, please contact the Customer Care phone number listed on your billing statement or on the back of your credit card. Customers with a registered online account may review their personal information by logging in to our secure account management service. For more information, please locate your card on the Card Search page.
9. Links to Other Sites
We may provide links on our Sites to external websites not owned or operated by us as a convenience to you. This Policy does not apply to the data collection, use, and protection practices of these websites. Please read and understand a linked website's privacy policy before using such a website.
10. Changes to this Policy
From time to time, we may modify this Policy. Should there be a material change to our information collection, use, or disclosure practices, it will be applied only to personal information collected on a going forward basis, and we will update this Policy accordingly.
11. Contact Us
If you have additional questions about this Policy, please contact us at privacy@comenity.net.
12. California Residents Only
The California Consumer Privacy Act (CCPA) defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
A California resident has the following rights:
1. The right to request what personal information we collect, use, disclose and sell including:
In the past 12 months, we collected the following categories of personal information:
The above data was collected from you and data resellers for the marketing or servicing of a financial product. We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected We share the above data with the retailer listed on your card, services providers, vendors, advertising partners and data analytics providers.
In the past 12 months, we sold internet or other electronic network activity for business purposes. However, we did not sell personal information of minors under 16 years of age.
2. The right to request that we delete your personal information if we do not need it or are entitled by law to retain it.
3. The right to request information that we have sold or disclosed to our business partners, including:
4. The right to direct us not to sell your personal information.
5. The right to not be discriminated against because you exercised any of the rights described above.
6. The right to designate an authorized agent to make a request under CCPA on your behalf.
In order to exercise your right(s) please go to https://calprivacy.comenity.com or dial 1-877-655-5391 (TDD/TTY: 1-800-695-1788). In order to verify your identity you will be required to provide: your first name, last name, address, phone number, date of birth and email address. Once you have provided your data you will be asked a series of questions to confirm your identity.
Contact for More Information: 1-877-655-5391 (TDD/TTY: 1-800-695-1788)
7. CCPA Requests Handled July 1, 2020 through June 30, 2021
*Requests are passed to our service providers.
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Last Revised: July 2023
This privacy policy ("Privacy Policy") describes how Bread Financial Holdings, Inc. family of companies, including Comenity Bank, Comenity Capital Bank, and Lon Operations LLC (d/b/a Bread) (collectively referred to as "Bread Financial", "we", "us", or "our"), collects, uses, discloses, processes, and retains Personal Information collected from you—or that you provide to us—in connection with your use of our "online services." Online services includes our websites, such as www.breadfinancial.com, www.savings.breadfinancial.com, and www.payments.breadfinancial.com, Social Media Pages (as defined below), mobile apps, and from the Services (as defined below) we offer to our customers. By accessing our online services, you signify your understanding of the terms set out in this Privacy Policy.
If you are visiting us from a location outside of the United States, please keep in mind that we are U.S.-based. This Policy governs the information collected by or on behalf of our websites irrespective of where you are located when you access, browse, or interact with it. If you are a California resident, please see the "Privacy Notice for California Residents" section below, which supplements this Privacy Policy.
Our online services and Services are not intended for use by minors under 16, and we do not knowingly collect, use, or maintain Personal Information from users under 16. If you are under the age of 16, please do not use our online services.
We may modify this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will update the last revised date, post the updated version on our website(s) and take any other steps necessary to comply with applicable law. Please check the date at the top of this Privacy Policy to see when it was last updated.
The following details the categories of Personal Information we collect and have collected over the past 12 months. Throughout this Privacy Policy, we will refer back to the categories listed in this chart.
Information You Directly Provide Us: When you visit our online services or use our Services, we will collect information that you directly provide us. This information may include:
You may provide information in writing, through our online services (e.g., online forms), using other customer service tools, or over the phone with our customer service representatives. As noted on our calls, all calls are recorded and retained in order to provide the best assistance to you, improve our level of customer experience and service, and to meet any legal and regulatory requirements.
Information We Collect Automatically or Generate About You: We also collect information automatically when you visit our websites. This information may include:
Information from Third Parties: We also collect information about you from third parties such as credit information (e.g., credit reports).
To help us further identify you to protect against fraud and identity theft, and for other purposes (including to improve our product or Services, or for us, or third parties, to market to you), our technology may gather further information about you, which information may include the following:
Cookies: Like many online services, we use Cookies or other anonymous identifiers to collect information about you. We may also gather and store "clickstream information," including information regarding your use of our site directly, or through service providers, including Cookies, web beacons, page tags, pixels or similar tools (collectively, "Cookies") and information about your device, the type of browser you are using, your internet service provider, your page views, pathways to and from the site, referral URL, data from third party analytics or marketing companies regarding the interaction with any web-based advertising, and your operating system.
We use Cookies for a variety of different reasons. Certain Cookies are essential to our online services, including to provide you with features or Services that you have requested. We also use Cookies to record your choices and settings regarding the Services, collect analytical and performance data, and for the purposes of retargeting and advertising, in order to identify your interests and providing advertising that we believe is relevant to you. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).
Your Choices Regarding Cookies: You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit a website and some of our websites' functionalities may not work. To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu.
Additionally, behavioral advertisements will feature an AdChoices Icon (also known as the "Advertising Option Icon"), that when clicked, provides more information about how the advertisement was delivered to you and also provides the ability to opt-out from future Online Behavioral Advertisements by the third parties listed. To opt-out of Online Behavioral Advertising (OBA) from all Digital Advertising Alliance (DAA)-participating companies, please visit http://www.aboutads.info/choices/. Please note that if you opt-out of OBA, you may still receive online advertising from us on third party websites. Opting out from third party advertising companies means that the advertisements you receive will not be based on your preferences or behavior. Further, opting out does not prevent other parties from tracking your online activity for other uses as described in this Privacy Policy.
We may use various analytics services, including Google Analytics, a web analytics service provided by Google, Inc., on our online services. These analytics services use Cookies or other tracking technologies to help us analyze how users interact with and use the websites, compile reports on activity, identify and address technical issues, and provide other services related to activity and usage. These technologies may collect information such as your IP address, time of visit, whether you are a return visitor and any referring website.
Our online services do not use analytics services to gather information that personally identifies you. The information generated by analytics services will be transmitted to and stored by the individual analytics service provider and will be subject to the providers' privacy policies. You can control the information provided to Google and opt out of certain ads provided by Google by using the methods set forth in http://www.google.com/policies/privacy/partners/ or use the Google Analytics opt out browser add-on at http://tools.google.com/dlpage/gaoptout?hl=en.
From time to time, we may create and manage social media pages that include, but are not limited to, a Twitter or Instagram account or a Facebook page ("Social Media Pages"). With your consent, Personal Information like your name, profile picture, gender, networks, user ID, list of friends, birthday, likes, education history, work history, current city, hometown, interests, relationship status, and any other information you have shared on a social media site may be collected by us. This Privacy Policy does not cover the privacy practices of the social media websites on which we may have Social Media Pages. Please review their privacy policies and terms of service if you have any questions about their privacy practices.
Information we receive in connection with our online services or the Services we provide may be used for the following purposes:
We may disclose your Personal Information to third parties in the ways described in this Privacy Policy:
Merchants: By using our Services, you authorize us to disclose Personal Information to Merchants, for managing and servicing your account, Merchants' marketing purposes, including certain information that is a part of or related to your application for your account, including, but not limited to, your name, email address and whether or not you were pre- qualified for our loan products, as permitted by law. You may limit this sharing at any time. See "Your Choices" below.
Service Providers: We disclose information (such as name, account information, demographic information) to our service providers in connection with our everyday business operations, including those that engage in assisting us in underwriting, sending communications on our or our Merchants' behalf, document storage, fraud prevention, collections, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of a service provider.
Marketing and Analytics Companies: We disclose information (such as name, account information, demographic information, and transaction information) to marketing and analytics companies for the purposes of marketing our or our Merchants' products and services to you, as well as the purposes set forth below:
In the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of any or all of our assets, some of the Personal Information that we hold may be among the assets transferred to a buyer or other successor. We may transfer to another business or non-affiliated entity or its affiliates, advisors or service providers some or all information about you in connection with, or during negotiations of, any joint marketing relationship, merger, acquisition, sale of assets or any business unit, change in ownership control or financing transaction. If we do, we may not be able to limit how such other party may use or further transfer your information.
We may disclose information in other ways if you give us consent or direct us to do so.
When it comes to how your Personal Information is collected, stored, used, and disclosed, you have rights and choices. You can control how Personal Information is collected or disclosed, as well as how we communicate with you. Here are some of the ways you can customize your choices.
You may choose to limit the Personal Information you provide when our online services or Services request it. In order to receive our Services, some Personal Information is required. This Privacy Policy is intended to describe to you how your Personal Information is collected, used, and disclosed so you can make the choices that are right for you.
You have choices about how we communicate with you and how it is delivered. Some messages are considered necessary for you to manage your accounts with us (e.g., servicing your account) and some are considered optional (e.g., marketing emails).
Service | How to Change Your Preferences |
---|---|
Bread Financial (Comenity) | Our menu will prompt you through your choices:
If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to disclose your information as described in this notice. However, you can contact us at any time to limit our sharing. |
Bread Savings (Deposits) | Contact us at 1-833-755-4354; dial 7 for a representative. |
Bread Pay | Contact us at support@breadpayments.com or call 1-844-992-7323. |
Emails | Click the unsubscribe button on any marketing emails from us or call us at:
|
California Residents | Refer to “Information for Residents of California” on how to exercise your rights. |
Some browsers have a 'Do Not Track' feature that signals to online services that you do not want your online activities tracked. We recognize browser do not track signals. In order for us to recognize such a signal you will have to enable it in your browser according to your browser's instructions.
Your privacy is important to us. We have implemented and maintain reasonable physical, technical, electronic, and administrative security measures to safeguard the Personal Information that we collect through our websites, your interactions with us, or through our Services.
We strive to maintain accurate Personal Information about you. If you are a Bread Financial cardholder or borrower and believe that our records contain inaccurate or incomplete information about you, please contact the Customer Care phone number listed on your billing statement or on the back of your credit card. Customers with a registered online account may review their Personal Information by logging in to our secure account management service.
This Privacy Notice for California Residents ("Notice") applies to California consumers and households ("you" and "your") whose Personal Information we collect through our online services and the services we offer, and describes your rights and choices with respect to the processing of Personal Information under the California Privacy Rights Act ("CPRA") which amends the California Consumer Privacy Act ("CCPA"). This Notice does not apply to Bread Financial employees or job applicants except to the extent you may utilize our Services. For California residents, this Notice controls to the extent it conflicts with any provision in the main body of the Privacy Policy. Capitalized terms not defined in this Notice are defined in our Privacy Policy.
The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CPRA will vary based on our relationship or interaction with that individual. Most of the information that we collect is collected in connection with your application for, and use of our Services. As such, it was collected in accordance with the terms of the federal Gramm Leach Bliley Act and is exempt from the provisions of the CCPA and CPRA. For your privacy rights related to that information please see our Financial Privacy Policy further described above or found at https://www.breadfinancial.com/en/privacy.html.
Below is a summary describing the Personal Information we collected from you in the past 12 months, as classified under the CPRA, the reason we collect your Personal Information, and how we disclose, share, and sell your information. Please see our Privacy Policy for further detail about how we collect, process, and disclose Personal Information about you.
Categories of Information Collected: As described further in our Privacy Policy, when you visit our online services, interact with us, or use our services, we may collect your Personal Information for business or commercial purposes. In the past 12 months we may have collected the following categories of Personal Information directly from you when you communicated with us, indirectly when you visited our online services, through the use of Cookies and other technologies, as well as from third parties, such as Merchants:
Merchant website or our online services, or information collected from Cookies and other similar technologies
Uses of Information: As described further in our Policy, in the past 12 months we may have used the information we receive in connection with our online services or the Services we provide for the following purposes:
Disclosure of Information: As described further in our Policy, in the past 12 months we may have disclosed each of the data categories described above to the following third parties:
Selling or Sharing of Information: In the last 12 months, we have "sold" or "shared" (as defined by the CPRA) identifiers and internet or other electronic network activity information to third party partners for advertising and marketing Bread Financial services to consumers. We did not sell or share personal information of minors under 16 years of age.
We retain your Personal Information as long as it is deemed necessary for providing our Services and in accordance with applicable laws and regulations, which is approximately seven years from the end of our relationship (e.g., seven years after the account is closed and balance is paid in full). Your Personal Information will be destroyed in accordance with applicable requirements at the end of the applicable retention period.
The CPRA provides California residents with certain rights regarding their Personal Information. These rights are not absolute and certain exceptions apply under the CPRA. To exercise any of the rights described below, see the "Exercising Your CPRA Rights" section.
Right to Know: You have the right to know the categories and specific pieces of personal information we have collected about you in the previous 12 months.
The categories of Personal Information include:
As more fully explained above, the data that we collect in the categories listed above is collected from you and data resellers for the marketing or servicing of a financial product. We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected. We disclose the above data to the Merchant listed on your card or who received the proceeds of your loan, services providers, vendors, advertising partners and data analytics providers.
Right to Deletion: You have the right to request that we delete any Personal Information we have collected about you.
Right to Opt-Out of the Sale and Sharing of Information: You have the right to opt-out of the sale and sharing of Personal Information we have collected about you.
Right to Non-Discrimination: You have the right to not receive discriminatory treatment for exercising any of your CPRA Rights. The Company will not treat you differently for exercising any of the rights above.
Right to Correct: You have the right to request that we correct inaccurate Personal Information maintained about you.
How to Submit a Request: If you are a California resident or an authorized agent and wish to make a request, you can make a request by visiting https://calprivacy.comenity.com or dialing 1-877-655-5391 (TDD/TTY: 1-800-695-1788). In order to verify your identity we will require you to provide: your first name, last name, address, phone number, date of birth and email address. Once you have provided your data you will be asked a series of questions to confirm your identity.
If you are an authorized agent, such as Power of Attorney, and submitting a request, please send a letter to Comenity at PO Box 182567, Columbus, OH 43218 with the request type(s) (request to know, delete, do not sell or share, and/or correct my data). Please include proof that the data subject gave you signed permission to make the request.
Under the CPRA, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. For the Company to process the request, you must provide the authorized agent signed written permission. The Company reserves the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.
How to Opt-Out of the Sale and Sharing of My Information: If you are a California resident and wish to opt-out of the sale and sharing of your personal information, please click here: Do Not Sell or Share My Personal Information.
To submit questions about this Notice, or to contact us for more information, please call 1-877- 655-5391 (TDD/TTY: 1-800-695-1788). To exercise your rights under the CPRA, please only do so following the designated methods above.
CPRA Requests Handled July 1, 2022 through June 30, 2023
Request to Know: 1,517 Requests Received, 887 Requests Verified, 887 Verified Requests Answered, 630 Verified Requests Denied
Request to Delete: 342 Requests Received, 207 Requests Verified, 207 Verified Requests Answered, 135 Verified Requests Denied
Request to Opt Out*: 4,143 Requests Received, N/A Requests Verified, 4,143 Verified Requests Answered, 0 Verified Requests Denied
Request to Correct: 250 Requests Received, 126 Requests Verified, 126 Verified Requests Answered, 124 Verified Requests Denied
*Requests are passed to our service providers.
During this period, our median time within which we sent responses was 3.6 days.