Privacy Policy

Last Updated: June 20, 2023

Purchasing Power, LLC (“Purchasing Power,” “we,” “our”) is committed to protecting your privacy because our business is based on the trust you place in us. The information we collect about you is gathered to ensure secure ordering and to provide a more personalized shopping experience. This policy applies to our collection of consumer information online through www.purchasingpower.com as well as our collection of Personal Information offline to the extent applicable. Our site may include links to third party websites for your convenience, but please note that this privacy policy does not apply to those websites, and we recommend that you review the privacy policy of any website you visit.

What information does Purchasing Power collect about me and how do they collect it?

Purchasing Power may collect a range of information and identifiers about you, and we may have collected such information in the preceding twelve (12) months. The collected information or identifiers may include:

Personal Information - “Personal Information” means information that identifies, relates to, or could reasonably be linked to a consumer or their household (e.g., name, address, phone number, social security number, email address, products purchased, browsing history, or IP address).

Sensitive Personal Information - “Sensitive Personal Information” means any Personal Information that reveals certain information about a consumer (e.g., social security number; driver’s license, state identification card, or passport number; a consumer’s account log-in; financial account, debit card, or credit card number).

Commercial Information - Information about products or services you purchased or obtained through Purchasing Power or other purchase or consumption histories or tendencies.

Electronic Network Activity Information – IP address, browsing history, search history, and information regarding your interaction with an Internet website, application, or advertisement.

Professional and Employment-Related Information - Employment status, income, and hire date.

Identifiers - Name, social security number, address, telephone number(s), bank account number, credit card number, debit card number, user ID, password, etc. Identifiers may be disclosed for business purposes with our vendors, service providers, fulfillment partners, payment processors, lenders/investors, professional service firms, and with the customer’s employer or sponsor.

Purchasing Power may collect the identifiers and information described above about our customers as described and for the purposes below.

Eligibility Determination – To determine eligibility to purchase goods and services through Purchasing Power, which is generally limited to employees or members of our partner organizations. We obtain certain eligibility information from employers or other partners (and sometimes from you), which may include, but is not limited to, professional or employment-related information such as employment status, income, and hire date.

Customer Account Setup - If you seek to establish a Purchasing Power account, we ask you to identify the employer or partner organization through which you are eligible to join Purchasing Power. We may request identifiers, Personal Information, or Sensitive Personal Information, such as your Social Security Number, credit or debit card information, or other payment information from you when you sign up for a Purchasing Power account.

Payroll Allotment - If you seek to authorize payroll allotment for your Purchasing Power purchases by using an automated payroll allotment option that we may offer to federal government employees, you will be asked to provide the user ID and password necessary to access your employer’s payroll portal on your behalf. As part of this process, in addition to initiating the payroll change you request, we may also collect, and update additional information, about you from your employer’s payroll system.

Bank Account Payment - If your primary method of payment is from your bank account (via ACH), or if you decide to provide your bank account for backup payment purposes, you will be asked to provide the user ID and password necessary to verify your bank account.

Internet/Network Activity and Sensory Data - When you visit Purchasing Power’s website, we collect internet and network activity information from you by monitoring your interaction with our website. We collect commercial and internet activity information, including your IP address, which we may use to measure our site traffic and to help provide a relevant shopping experience and prevent fraud; browser type, which is captured to optimize our website to ensure compatibility with the latest technologies; and website activity, which we use to track the pages you visit to provide a more personalized and relevant shopping experience. Additionally, we collect sensory data, which refers to audio or electronic information, when we make audio recordings of call center phone calls. As further discussed below, we use technologies including cookies and web beacons, which may use JavaScript code, and third-party analytics such as Adobe Analytics.

Marketing – We may provide information from your purchase and browsing history to third-party marketing support firms who use the information to draw inferences about you to enhance your shopping experience and suggest other items that may be of interest to you. For example, this may include information about you and your household such as occupation, estimated income, children, and purchasing preferences. We may contract with third-party vendors to work on our behalf to provide ads to our customers via the Internet or to send direct mail to customers who may be interested in our products or services. In order to do so, these third parties may collect information concerning visitors to our websites using JavaScript software code and “cookies” (see “What Are Cookies” below for more information). Our vendors may connect the information they collect from our website using “cookies” to other sources of information, which may include your name and mailing address, for the purpose of sending you direct mail or other offline promotions and marketing. By using this site, you consent to these activities, including information collection by our vendors unless you opt-out (see “How do I opt-out of receiving marketing communication from Purchasing Power?” below).

Does Purchasing Power collect geolocation data through the website?

Yes. Purchasing Power collects your device IP address and it gives an approximate geolocation, which is not personally identifiable without other data.

For what purpose is my information collected?

The purpose for collecting the information we collect about you is to confirm your eligibility for a Purchasing Power account; to process, service and deliver your order; to service and/or collect your payments; and to communicate with you about your transactions. If you become a Purchasing Power customer, we may also use this information, and inferences drawn from such information, to provide you with recommendations, mailings, or other communication based on your interactions with us. Additionally, we may analyze such information as part of our standard business practices to improve our products and services, provide reports with aggregate information for your employer and other partner organizations, and to aid our efforts to safeguard the accounts of our customers and prevent fraud.

Will my information be disclosed to third parties?

Yes. Some of the information and identifiers provided in the policy above may be disclosed to third parties for the purpose of processing your order and transacting business with you and as otherwise described in this policy. This may include, but is not limited to, disclosure to vendors and shipping companies for order fulfillment, and with your employer or sponsoring organization or their authorized service providers. For example, if you make a purchase, such as purchasing a laptop, information will be disclosed with the Purchasing Power partners engaged to fulfill your order and ship it to you, and the payments will be processed by authorized service providers. If you seek to authorize payroll allotment to pay for your Purchasing Power purchases by using an automated payroll allotment option that we may offer to federal government employees, a third-party service provider will facilitate this service on our behalf. If your primary method of payment is from your bank account (via ACH) or if you decide to utilize your bank account information for backup payment purposes, a third-party service provider will authenticate your bank account and process payments for us. Your information, including email address, may be disclosed with your employer or other sponsoring organizations under certain limited circumstances. We also reserve the right to disclose identifiers and information to third parties to comply with the law, legal processes, and requirements by government authorities. For instance, Personal Information may be disclosed in connection with an investigation of fraudulent activities, violations of our terms of service, or in the event a transaction occurs that involves the sale or potential sale of all or part of our assets.

Will purchasing Power sell my information to third parties?

No. Purchasing Power does not sell your information to third parties.

How do I participate in the Purchasing Power program?

Generally, to participate in our program, you must be employed by a company or the federal government or belong to an organization with whom Purchasing Power has a contractual agreement to offer products for purchase pursuant to a payroll deduction schedule or payroll allotment. For employer partners, there may be a minimum employment tenure or salary level requirement.

Why do I receive communication regarding survey and research participation?

Purchasing Power is committed to providing an excellent customer experience. To measure how well we are doing, and better understand how we can continue to improve our product offerings, we may contact you by phone or e-mail and solicit your participation in surveys or research. Your participation is voluntary, and if you do not wish to receive such communication, you can simply let us know (See “How do I opt-out of receiving marketing communications from Purchasing Power” below). You may also unsubscribe by updating your communication preferences in your Purchasing Power account.

How do I opt-out of receiving marketing communication from Purchasing Power?

Customers may opt-out of receiving marketing communication using the options below. The processing of opt-out requests may take up to thirty (30) days. Customers who opt-out of marketing communication will continue to receive transactional messages related to active orders and/or account status as applicable.

My Account - Registered users can control their marketing communication preferences by visiting https://www.purchasingpower.com/store/my-account and, using the toggles, make choices regarding receipt of email, direct mail, and SMS messaging.

Telephone - If you do not have an account with us, you may contact customer service by phone at (888) 923-6236 to request to be added to our Do Not Mail list.

Mail – You can send your request via mail to: Purchasing Power Attn: Customer Service 2727 Paces Ferry Rd SE, Building #2 Suite 1200, Atlanta, GA 30339.

Opt-Out Link (E-mail) - In the case of e-mail messages, recipients may also opt-out by using the opt-out link included in the message.

SMS Opt-Out – In the case of SMS text messages, recipients may opt-out of receiving text messages by replying to the text message as instructed in the text message to stop receiving text messages or to unsubscribe (e.g., reply ‘STOP” to unsubscribe).

How does Purchasing Power protect my information?

Purchasing Power protects your information by employing technology in areas where your information is collected and stored and where your transaction information is processed, such as encryption technology. For your protection, our site is certified by a security certificate. This is your assurance that our site is authentic. You can check this security protection setting within your browser. To view our security certificate, click on the image of the closed lock on your browser’s search/address bar or the solid key at the bottom of your browser. Our site security information will appear. For more information, contact your browser's publisher. For additional protection, your account information and order history are kept behind a firewall on separate servers. All transaction information is processed under encrypted channels. To ensure you have the most protection available, be sure to download the latest version of your internet browser. In addition, access to your information is restricted within our company to those with a need to access the information to carry out their job responsibilities.

How long will Purchasing Power retain my information?

Your information will be retained for business purposes as long as is reasonably necessary and in accordance with applicable laws and regulations.

Will Purchasing Power request my Purchasing Power user ID or password?

No. Purchasing Power will not request this information. Once you have registered with us, we will never ask you for your Purchasing Power user ID, password, or password retrieval information.

Please note Purchasing Power will never ask you to provide any of this information over the telephone, by email, or by text message.

How will I know if Purchasing Power changes its privacy policy or practices?

If Purchasing Power changes its privacy policy or practices, it will update its privacy policy, change the “last updated” date on the policy, and post an updated privacy policy on its website.

What are cookies? How does Purchasing Power use cookies?

Cookies store small amounts of data on your computer about your visits to websites. Purchasing Power uses cookies to assist in tracking which of its features you like best. When you re-visit Purchasing Power’s sites, cookies enable it to recognize that you are a return visitor and to customize its content according to your preferences.

We may also use cookies to:

Accumulate and report anonymous, aggregate, statistical information on website usage.
Deliver content or products specific to your interests.
Facilitate online, offline, and direct mail marketing of offers we believe may be of interest to you.
Save your username so you do not have to re-enter it each time you visit our website.

Our site does not honor “do not track” signals sent by some internet browsers, but, if you do not wish for cookies to be placed on your computer, most web browsers permit you to prevent that from taking place or to delete cookies that have already been placed. However, please keep in mind that cookies and similar technologies are an important part of how the website works. Removing, rejecting, or limiting the use of cookies or other similar technologies might affect the availability and functionality of the website.

Our website uses third parties such as Google Analytics to collect information such as the number of visitors to a site, the webpage that referred visitors, and the pages visitors viewed within the site. You can opt-out of Google Analytics by downloading Google’s Opt-Out browser add-in.

Does Purchasing Power collect information from individuals under the age of 16 years old?

No. We do not knowingly collect or sell Personal Information from children under 16 years old. Purchasing Power’s services and website are not directed at or marketed to children under the age of 16 years old. If we learn we have inadvertently collected Personal Information from a child under the age of 16 years old, we will remove the information from our files.

How do I give my feedback to Purchasing Power?

Click here for information on how to contact customer service.

How can I update my Purchasing Power account information?

You can update your information online to keep your customer information complete, up-to-date, and accurate. Log in to the website and navigate to My Account > Profile Information.

How can I contact Purchasing Power if I have a privacy-related question?

You may contact us with privacy-related questions using the contact options provided below.

Online - You can visit our website and submit a privacy request form if you have a data privacy question, if you would like to request detail information about our information collection and disclosure practices, or if you would like to request a copy of the Personal Information we maintain about you.

Telephone - You may also contact customer service by phone at (888) 923-6236.

What rights do I have with respect to my information? How do I exercise these rights?

You have the right to exercise the rights described below upon receipt of a verifiable request (see definition below). Requests to exercise these rights can be submitted to us through our website privacy request form or by telephone at (888) 923-6236.

A verifiable request is a request made by or on behalf of a consumer which the business can reasonably verify was made by or on behalf of the consumer that is the subject of the request. If the business cannot reasonably verify the request, it is not required to perform the actions described below. You may designate an authorized agent in writing or through a valid power of attorney to submit requests on your behalf. We will put forth good faith efforts to verify such requests and the identity of the requestors before acting on such requests. When you or an agent acting on your behalf make a request, we may ask for Personal Information about you which we will match with Personal Information we maintain about you in our records.

Right to Access - You have the right to access Personal Information we collect about you. You must submit a verifiable request (see the definition above). You also have the right to receive your Personal Information in a structured and commonly used format so that it can be transferred to another entity.

Right to Know - You have the right to request that we disclose the following about your Personal Information. You must submit a verifiable request (see the definition above).

The specific pieces of Personal Information we collected about you.
The categories of Personal Information we collected about you.
The categories of sources from which the Personal Information was collected.
The business purposes for collecting or disclosing that Personal Information.
The categories of Personal Information we may disclose for business purposes.
The categories of third parties with whom we disclosed that Personal Information.

Right to Delete – In certain circumstances, you have the right to request that we delete your Personal Information that we collected from you and have us instruct our service providers to do the same, if applicable. In response to your request, Purchasing Power will either delete, de-identify, or aggregate Personal Information. You must submit a verifiable request (see the definition above). Please note we are not required to delete Personal Information if it is necessary that the Personal Information be maintained for certain purposes including, but not limited to:

To complete the transaction for which the Personal Information was collected, provide a good or service you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you, or to otherwise perform a contract you have with us.
To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or to prosecute those responsible for such activities.
To debug products to identify and repair errors that impair existing intended functionality.
For internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
To comply with a legal obligation.

Right to Correct – In certain circumstances, you have the right to request correction of any inaccurate Personal Information. You must submit a verifiable request (see the definition of verifiable consumer request in this section above).

Purchasing Power will use commercially reasonable efforts to correct your Personal Information. In addition to submitting your request provided above, you may individually correct your Personal Information by logging in to your Purchasing Power account and navigating to My Account -> Profile Information.

Do Not Sell, Share, or Disclose My Sensitive Personal Information – You have the right to limit how your Sensitive Personal Information is disclosed or shared with third parties. You must submit a verifiable request (see the definition above). Please note that Purchasing Power does not sell Personal Information to third parties.

Purchasing Power does not discriminate against consumers that exercise the choices described above. Businesses are prohibited under California privacy laws, with limited exceptions, from denying goods or services to the consumer; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to the consumer; or suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services because a consumer exercises these rights.

What is Purchasing Power’s Customer Privacy Statement?

Purchasing Power may collect, use, and process a range of your information and identifiers. We may disclose this information to third parties in accordance with laws and regulations, and as described in this privacy policy.

Why?	Purchasing Power collects, uses, discloses, and processes customers’ information as reasonably necessary to operate its business and to service customers. Below, is a list of the reasons Purchasing Power may disclose its customer’s information; the reason Purchasing Power chooses to disclose this information, and whether you can limit disclosure.

What?	The types of information that Purchasing Power may collect, use, disclose, and process depends on the product or service you have with us. This information may include, but is not limited to, Personal Information or Sensitive Personal Information, identifiers, commercial information, or professional or employment-related information.

How?	Purchasing Power collects customer information from various sources, including employers, partners, customers, electronic network activity, and as further described in this privacy policy.

Reasons we may disclose your Personal Information

Does Purchasing

Power disclose?

Can you limit this disclosure?

For our everyday business purposes - such as to process your transactions

Yes

Please review Do Not Sell, Share, or Disclose My Sensitive Personal Information

For legal or regulatory purposes -

such as fraud investigations or legal processes

Yes

For our marketing purposes-

to offer our products and services to you

Yes

For joint marketing with other financial companies

Yes

For our affiliates' everyday business purposes

We do not disclose

For our affiliates to market to you

We do not disclose

For non-affiliates to market their products to you

Yes

Who we are

Who is providing this notice?

Purchasing Power, LLC

What we do

How does Purchasing Power protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with laws and regulations. These measures include computer safeguards and secured files and buildings.

How does Purchasing Power collect my personal information?

We collect your personal information, for example, when you

§ Complete registration, open an account, or provide your contact information

§ Make payments, set-up your spending limit, or provide account information

§ Make payments using payroll deduction, allotment, credit card or ACH

§ Make a transaction

We also collect your personal information from others, such as affiliates, or other companies.

Once you have registered with us, we will never ask you for your username, password, or password retrieval information.

Why can't I limit all disclosure?

Federal law gives you the right to limit:

§ Disclosure for affiliates' everyday business purposes - information about your creditworthiness

§ Affiliates from using your information to market to you

§ Disclosure for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit disclosure.

What happens when I limit disclosure for an account I hold jointly with someone else?

Your choices will apply to everyone on your account.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Non-affiliates

Companies not related by common ownership or control. They can be financial and non-financial companies.

Purchasing Power does disclose to non-affiliates for purposes of marketing their products to you.

Joint marketing-

to offer our products and services to you

A formal agreement between non-affiliated financial companies that collectively market financial products or services to you.

Our joint marketing partners include financial companies.

Other important information

California Residents Only: Purchasing Power does not disclose your Personal Information or Sensitive Personal Information with affiliates. Purchasing Power does not disclose your Personal Information or Sensitive Personal Information for joint marketing with other financial companies.

Vermont Residents Only: Except with the authorization or consent of the Vermont resident, Purchasing Power will not disclose among its affiliates information we receive from customer application materials, consumer reports and information we receive from others about Vermont residents.

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