Privacy Policy

Last modified: September 18, 2025

Introduction

Its Layered, LLC, a California limited liability company (“Its Layered,” “Company,” “we,” or “us”) respects your privacy and is committed to protecting it through this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit www.itslayered.co or use our web or mobile applications (collectively, the “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy covers the Its Layered iOS and Android mobile apps and any in-app features, notifications, and integrations.

By accessing or using the Services, you agree to this Privacy Policy. If you do not agree, do not use the Services. We may change this policy from time to time (see Changes to Our Privacy Policy). Our Services are not for anyone under sixteen (16) years of age.

Our Role vs. Brand Partners’ Role

In some cases we act as an independent controller (e.g., for your Its Layered account, our Website analytics, security, and marketing). In other cases, we act as a service provider/processor to Brand Partners (e.g., when operating a brand’s community, challenges, or rewards program on that brand’s behalf). When we process personal information on behalf of a Brand Partner, that Brand Partner’s privacy policy governs and you should contact the Brand Partner to exercise your rights for that data. Our Data Processing Addendum is available to Brand Partners upon request.

Information We Collect and How We Collect It

Categories of Information

We may collect:

Identifiers & contact information: name, email, phone, postal address, region/country, account username, and similar identifiers.
Commercial information: records of products/services purchased, brand communities joined, redemptions.
Internet/network activity: browsing history, search history, clickstream, IP address, device/browser type, OS, pages viewed, session data, cookies, pixels, SDKs.
Geolocation data: approximate location from IP; precise location with your device permissions.
User content: posts, images, reviews, challenge entries, messages, and other content you submit.
Inferences drawn from other information (e.g., preferences).
Financial information (if applicable to purchases or for brand contacts): processed by third-party payment processors; we do not store full card numbers.
Employment/role information (brand contacts): company, job title.

Sources of Information

We collect information:

Directly from you (forms, registrations, uploads, communications, survey responses).
Automatically via cookies, pixels, SDKs, web beacons, and similar technologies as you use the Services.
From third parties, such as ecommerce platforms (e.g., Shopify), analytics providers, identity providers, and Brand Partners in connection with programs you join.

Information You Provide

Includes registration information, content you upload, communications with us, survey responses, transaction details, search queries, and User Contributions you choose to post publicly or within communities. User Contributions are posted at your own risk. We cannot control how other users may use, share, or retain your User Contributions.

Information Collected Automatically

We may automatically collect usage details, device and network info, timestamps, pages viewed, referring/exit pages, approximate location, and similar data. These help us operate, secure, and improve the Services, remember preferences, and recognize returning users.

Precise Location (mobile). With your device permissions, we may collect precise geolocation to enable location-based features. You can disable precise location in your device settings; some features may not function.
Mobile Advertising Identifiers. We may use mobile advertising identifiers (e.g., IDFA, GAID) for analytics and advertising where permitted; you can reset/limit these in your device settings.
Caching. We may cache certain data locally to improve performance and user experience. Cached data is retained for limited periods.

Mobile App Permissions

Depending on your settings and device, the app may request access to:

Location (precise/approximate) to enable location-based features;
Camera/Photos to let you upload content to challenges;
Push Notifications for account, reward, and program updates;
Advertising Identifier (IDFA/GAID) for analytics/advertising where permitted.
You can change these permissions in your device settings. Some features may not work without the relevant permission.

Cookies, Pixels, and Similar Technologies

Cookies are small files stored on your device. You may refuse cookies in your browser; some features may not function if disabled.
Web beacons/pixels help track engagement (e.g., email opens, page views).
Local storage/SDKs may store settings and enable features in our web/mobile apps.

Third-Party Tracking & Advertising

Some content or applications, including advertisements, are served by third parties (ad networks, analytics providers, ecommerce, social media, etc.). These parties may set cookies/pixels/SDKs to collect information about your use of the Services and other sites/apps, including for interest-based advertising. Their practices are governed by their privacy policies; we do not control their technologies.

How We Use Your Information

We use information to:

Provide, operate, maintain, and secure the Services.
Present the Website and its contents to you.
Process registrations, authenticate users, and manage accounts.
Provide information, products, or services you request.
Operate brand programs/challenges you join.
Personalize content and experiences and remember preferences.
Perform analytics, research, and product improvement.
Communicate with you, including account notices and marketing (where permitted).
Enforce our terms and policies, collect amounts owed, and prevent fraud/abuse.
Comply with legal obligations and respond to lawful requests.
For any other purpose disclosed at collection or with your consent.

Brand Communications (Email/SMS)

If you join a Brand Partner’s community, you may receive communications from that brand subject to their privacy policy and terms.

Text Messages. By providing your mobile number, you consent to receive recurring automated and non-automated text messages from Its Layered and/or the Brand Partner. Consent is not a condition of purchase. Message & data rates may apply. Reply STOP to opt-out and HELP for help. You can also email hello@itslayered.co to update preferences.

Disclosure of Your Information

We may disclose aggregated or de-identified information without restriction. We may disclose personal information:

To affiliates and subsidiaries.
To service providers/contractors that support our business (hosting, security, analytics, support, email delivery, payments) under agreements limiting their use to providing services to us.
To Brand Partners when you join or interact with their programs, consistent with program operation.
In corporate transactions, such as a merger, sale, restructuring, financing, or acquisition.
For legal reasons, including complying with law, responding to lawful requests, enforcing terms, and protecting rights, property, or safety.
With your consent or as otherwise disclosed at collection.

Your Choices & Controls

Cookies/Tracking & Interest-Based Ads

You can set your browser to refuse cookies or alert you when cookies are set. Disabling cookies may affect functionality. You can also use industry tools: NAI (optout.networkadvertising.org) and DAA (optout.aboutads.info), and manage Google settings at adssettings.google.com or install the Google Analytics Opt-out Browser Add-On. Choices are browser/device-specific.

Global Privacy Control (GPC). Where legally required, we honor GPC signals as an opt-out of “sale”/“share” for that browser.

Marketing Communications

You may opt out of marketing emails via the unsubscribe link or by emailing hello@itslayered.co. We may still send transactional or account-related messages.

Third-Party Marketing

If you do not want us to share your personal information with unaffiliated third parties for their direct marketing, email hello@itslayered.co.

Do Not Track

We do not respond to Do Not Track browser signals at this time.

Accessing, Correcting, and Deleting Your Information

You may request access, correction, or deletion by emailing hello@itslayered.co. We may need to verify your identity. We may decline requests where permitted or required by law (e.g., to complete transactions, detect security incidents, or comply with legal obligations). Deleting personal information may require deleting your account.

Your State Privacy Rights (U.S.)

Residents of certain states (including California, Colorado, Connecticut, Virginia, and Utah) may have rights to:

Know/confirm whether we process personal information;
Access and obtain a copy;
Delete personal information;
Correct inaccuracies;
Data portability;
Opt out of sale, sharing for cross-context behavioral advertising, and certain profiling.

To exercise rights, email hello@itslayered.co with subject “Privacy Request”, describe your request, and provide information we need to verify your identity (or your authority as an authorized agent). We generally respond within timelines required by law (e.g., 45 days under CCPA, extendable as permitted).

Authorized Agents. Where allowed, you may designate an agent to submit requests; we may require proof of authorization and verification of your identity.

Appeals. If we deny your request, you may appeal by replying to our decision or emailing hello@itslayered.co with subject “Privacy Request Appeal.” If your appeal is denied, you may contact your state attorney general.

California Notices (CCPA/CPRA)

Categories collected may include: identifiers; commercial data; internet/network activity; geolocation; user content; inferences; and limited financial info via processors.
Sensitive personal information. We do not knowingly use or disclose sensitive personal information for purposes that require a Right to Limit notice.
Sale/Share of Personal Information. We do not sell personal information for money. We may share identifiers and internet/network activity with advertising partners for cross-context behavioral advertising. You can opt out of such “sharing” by emailing hello@itslayered.co with subject “Do Not Sell or Share”, by adjusting cookie preferences (where available), and/or by using a browser that sends a GPC signal, which we honor where required.
Shine the Light (Cal. Civ. Code § 1798.83). California residents may request information about disclosure of personal information to third parties for their direct marketing by emailing hello@itslayered.co with “Shine the Light” in the subject line.

Nevada

Nevada residents may opt out of the sale of certain personal information by emailing hello@itslayered.co

EU/UK Privacy Information (GDPR/UK GDPR)

Legal Bases. Where the GDPR/UK GDPR applies, we process personal data on the following bases: contract (to provide the Services); legitimate interests (e.g., security, fraud prevention, product improvement, analytics); consent (e.g., certain marketing, cookies, precise location); and legal obligations.

Your Rights. You may have rights to access, rectify, erase, restrict, object, and data portability, and to withdraw consent where processing is based on consent. To exercise rights, email hello@itslayered.co. You also have the right to lodge a complaint with your local supervisory authority.

International Transfers. When transferring personal data outside the EEA/UK, we implement appropriate safeguards such as the EU Standard Contractual Clauses and the UK Addendum/IDTA, as applicable.

Children’s Privacy

The Services are not directed to children under 16. We do not knowingly collect personal information from children under 16. If we learn we have collected personal information from a child under 16 without appropriate consent, we will delete it. Parents/guardians may contact hello@itslayered.co.

Data Security

We implement administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials.

Data Retention

We retain personal information as long as needed to provide the Services and for other legitimate purposes (e.g., security, fraud prevention, legal, and tax). As guidance, we typically retain:

Account data while your account is active and up to 24 months after closure, unless a longer period is required by law or for legitimate business purposes;
Analytics and log data generally for 12–24 months;
Backups/archives for limited periods consistent with our disaster-recovery policies.

International Transfers

We are based in the United States and may process information in the U.S. and other countries with privacy laws that may differ from yours. Where required, we use appropriate safeguards, including Standard Contractual Clauses (and the UK Addendum) to legitimize transfers.

Third-Party Services and Integrations (Including Ecommerce)

The Services may integrate with or link to third-party platforms and services (e.g., Shopify, identity providers, communications, analytics, and advertising tools). Your use of third-party services is subject to their terms and privacy policies. We are not responsible for their privacy or security practices.

Changes to Our Privacy Policy

We post any changes to this policy on this page with an updated “Last modified” date. If we make material changes to how we treat personal information, we will provide additional notice (e.g., email or in-Service notice). You are responsible for ensuring we have a current email address for you and for periodically reviewing this policy.

Contact Information

To ask questions, exercise your rights, or appeal a decision, contact us at:
hello@itslayered.co
Its Layered, LLC
3400 Cottage Way, Suite G2-28544
Sacramento, CA 95825

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