Privacy Policy

The purpose of this JCPenney insiders Privacy Policy is to inform you about the practices and procedures of JCP Media, Inc. (“JCPenney”) and Bellomy Research, Inc. (collectively, as follows, “we” or “us”) in handling Personal Information and to inform you about the Personal Information we collect or receive about you from your participation in the JCPenney insiders Community (the “Community”). It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information. Note that this Privacy Policy applies only to Personal Information we collect or receive about you from your participation in the Community and your use of the Community website. Other websites provided by JCPenney and/or its affiliates, including www.jcpenney.com, have different privacy policies that apply to the use of those websites.

If you are a resident of the United States of America or Canada and have any questions or comments regarding this statement, you should first contact our Social Research Group at Bellomy Research, Inc.  175 Sunnynoll Court, Social Research Group, Winston-Salem, NC 2706 or by email at info@JCPenneyinsiders.com.

From time to time, we may make changes to this Privacy Policy. The Privacy Policy is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with this Privacy Policy, unless we have your consent to treat it differently.

What is Personal Information?

Personal Information is any information that is identifiable with you. This information may include but is not limited to your name, mailing address, phone numbers, email address, identification numbers and, in certain circumstances, your opinions and individual preferences. Personal Information, however, does not include (i) your business title or business address and business telephone number and fax in your capacity as an employee of an organization; and (ii) depending on the jurisdiction, publicly available information.

We may collect personal information about other members of your household. This information may include but is not limited to the age and gender of the other household members. We use this information to determine if certain surveys are relevant to you based on the composition of your household.

We may offer you the opportunity to refer-a-friend, which allows you to invite one or more friends to join the Community and, after joining, participating in any type of event on the Community or in surveys. This process will not ask you to provide the email address or any other personally identifiable information about the individuals you wish to refer. An email message with a registration link may be sent to you, and you may be asked to pass on a link to the membership survey to one or more of your friends. Alternatively we may encourage you to forward a link to the membership survey to one or more of your friends by using the friend feature on the Community homepage.

How do we collect your Personal Information?

We will collect your Personal Information by fair and lawful means (for example, when you respond to one of our surveys or participate in discussion forums or polls within the Community, participate in a live chat or phone interview and by uploading pictures or videos to the Community). We collect your Personal Information where we have obtained your consent to do so or as otherwise permitted by law.

We may use a third party agent to host surveys or Community events to collect Personal Information, including email address. That information is delivered to us directly.

We do not knowingly collect Personal Information from individuals under the age of 18 on the Community website.

How do we use your Personal Information?

We use the Personal Information we collect for various purposes. One of the primary purposes for which we collect your Personal Information is to conduct marketing and social research through your participation in the Community. We may also use your Personal Information to send you email communications, to administer the Community, to administer sweepstakes, contests, and similar promotions, to invite you to participate in surveys, to invite you to participate in wear tests, to invite you to participate in online message boards, chat rooms, blogs, or other interactive forums, and to obtain your insight about JCPenney, its parents, subsidiaries, and affiliates and their products and services. We may also use your Personal Information as otherwise permitted by law. We will not ask you for sensitive personal information such as health or financial information.

How do we use your email address?

We will use your email address to send you several different types of messages related to your participation in the Community. Primarily we will invite you to participate in any type of exercise or event on the Community, whether it is participating in a live chat, bulletin board discussion or other type of exercise or send you an email invitation to participate in online surveys. Once you have joined you can also participate by posting comments, providing feedback and voting on responses anywhere on the Community. We will contact you by inviting you to participate in events on the Community or a survey. When you register to participate in the Community we will send an email message to the email address you provide us to confirm that we have received your registration information.

If you use the “I forgot my password” link on Community Login Page to inquire about your login information, you will receive an automated email message sending you the information requested to the email address you provided. An individual from the Social Research Group may also contact you using the email address you provided to respond to your questions.

How can you opt-out of receiving our email messages?

All of our email messages clearly explain how you can opt-out of receiving future email communications and unsubscribe from the Community. All emails include an unsubscribe link that allows you to unsubscribe yourself from the Community right away or an email address that you can contact to unsubscribe. We will always process your opt-out request within 10 business days of receiving it. Note that you can only opt out of emails by unsubscribing from the Community.

To whom do we provide your Personal Information?

We share your Personal Information that we collect in the Community with affiliated companies, service providers, and promotion sponsors. If we desire to share your Personal Information with any other parties, we will obtain your express consent to such disclosure.

We reserve the right to disclose your Personal Information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable law, or when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website.

When and how do we obtain your consent?

At the time you register for the Community we will obtain your electronic consent to collect, use and disclose your Personal Information as described in this Privacy Policy when you accept the Terms and Conditions. In addition, in connection with your participation in certain events on the Community we may obtain your consent prior to collecting, using or disclosing your Personal Information. You may provide your consent to us either electronically, in writing or orally. Oral consent will be required only for purposes of recording information either over the phone or in-person. Oral consent will be recorded. From time to time, we may collect, use or disclose your Personal Information based on your consent and as permitted by law. We will not ask you for sensitive Personal Information such as health or financial information. Consent may be withdrawn either electronically via email or by completing the Opt Out survey, in writing or orally.

How do we ensure the privacy of your Personal Information, including email address, when dealing with our affiliates and other third parties?

We ensure that all our affiliates and other third parties which are engaged to perform services on our behalf and are provided with Personal Information are required by contract to observe the intent of this Privacy Policy or are governed by the same Privacy Policy.

How long will we use, disclose or retain your Personal Information?

We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. We have established minimum of 1 month and maximum of 6 months retention periods and procedures for maintaining and destroying your Personal Information with prior approval from JCPenney. If you have any questions about the Personal Information, including email address, which we have on file for you, you can contact our Social Research Group by sending an email to: info@JCPenneyinsiders.com.

How can you review your Personal Information that we have collected, used or disclosed?

We will make available to you any specific Personal Information on you in our custody or control, that we have collected, used or disclosed, upon your written request, to the extent permitted by law. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes.

How do you know that the Personal Information we have on you is accurate?

We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. When we collect Personal Information from you, we rely on you for its accuracy. You may take the “Profile” survey at any time to update your Personal Information.

What if the Personal Information we have on you is inaccurate?

You can, at any time, question in writing or electronically the accuracy or completeness of the Personal Information we have on you. If you successfully demonstrate that the Personal Information we have on you is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

How fast will we respond to your requests?

We will attempt to respond to each of your requests not later than thirty (30) days after receipt of such requests. We will advise you if we cannot meet your requests within this time limit.

Are there any costs to you for requesting information on your Personal Information or on our Privacy Policy or practices?

We will not assess any costs to you for access to your Personal Information or on our Privacy Policy or practices without first providing you with an estimate of the approximate costs, if any. You may withdraw your requests for access to information by notifying us in writing or electronically within the thirty-day notice period disclosed on the estimate.

How do we know that it is really you requesting your Personal Information?

All comments, questions, concerns or complaints regarding your Personal Information or our Privacy Policy and practices, should be forwarded to our Privacy Officer as set forth below. We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information, including your email address. Any such information shall be used only to validate your identify before releasing personal information.

What safeguards have we implemented to protect your Personal Information?

We have implemented physical, procedural and technological security safeguards to protect your Personal Information, including email address, from loss or theft, unauthorized access, disclosure, copying, use or modification.

We limit the information we provide to outside companies to only information we believe is appropriate to enable them to carry out their responsibilities under our contracts. We contractually require that they have information security safeguards, and that the information provided be used only for the specifically authorized purpose.

How do you contact us regarding access to your Personal Information or our Privacy Policy and practices?

All comments, questions, concerns or complaints regarding your Personal Information or our Privacy Policy and practices, should be forwarded to our Privacy Officer as follows.

USA and Canada Residents:

In writing:

Attn: Privacy Officer

Bellomy Research, Inc. 
175 Sunnynoll Court

Winston-Salem, North Carolina 27106

By emailprivacy@bellomyresearch.comIf you are a resident of the United States of America or Canada you may submit changes to your Name, Mailing Address, Email Address, and Telephone Number by email to info@JCPenneyinsiders.com or mail to our Social Research Group at Bellomy Research, Social Research Group, 175 Sunnynoll Court, Winston-Salem, NC 27106.

When you make an inquiry or lodge challenges or complaints, we will inform you of the relevant procedures.

If you are chosen as a winner in one of our sweepstakes or judged contests you will be given the option to provide a testimonial which we may post on the Community website or include in an email communication to members of the Community. Your testimonial, username, and an electronic picture of yourself, if you provide one, will only be included in the newsletter or communication if you provide us with consent. You can request to have your testimonial and Personal Information removed from the Homepage or future email communication by sending an email to our Social Research Group: info@JCPenneyinsiders.com. You may also submit your request in writing to:

Bellomy Research, Inc.

Social Research Group
175 Sunnynoll Court

Winston-Salem, North Carolina 27106

Notification of Changes

If we decide to change this Privacy Policy, we will post those changes to the Community website and other places we deem appropriate so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

If we are going to use your Personal Information that is collected on the Community, in a manner different from that stated at the time of collection, we will notify you via email. You will have a choice as to whether or not we use your information in this different manner. However, if you have opted out of all communication with the Community, or deleted/deactivated your account, then you will not be contacted, nor will your Personal Information be used in this new manner. In some cases where we post a notice on the Community website we will also email you even if you have opted not to receive communications from us, notifying you of the changes in our privacy practices.

Log Files

As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and click stream data.

The information in this fingerprint, which does not identify individual users, is used to analyze trends, to administer the site, to track your movements around the Community website and to gather demographic information about our user base as a whole.

We do not link this automatically-collected data to Personal Information, including your email address.

Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to any Personal Information, including email address, you submit while on our site. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. This Privacy Policy covers the use of cookies by the Community only and does not cover the use of cookies by any third parties.

Digital Fingerprints

We may use digital fingerprinting technology, also known as “Machine Identification” digital fingerprints, to gather certain information about your computer hardware and software, for example, your IP address, the display settings of your monitor, the type of browser you are using, the type of operating system you are using, etc. We use this information to create a digital “fingerprint” – and determines if it matches previous fingerprints. The data collected in this process and the digital fingerprint created is not tied to any of your Personal Information, is stored on secured servers, and is used only to help prevent you from completing the same survey multiple times and for no other purpose.