Multi-State Notice at Collection and Privacy Policy
Effective Date: January 1, 2023
Last Revised/Reviewed on: 11/03/2025
This Multi-State Notice at Collection and Privacy Policy (“State Privacy Disclosure”) explains how CITITRENDS, Inc. and its subsidiaries and affiliates (“CITITRENDS”, “Company”, “us”, “our”, or “we”) collect, use, disclose, sell, share, and/or retain personal information (“Information Practices”) subject to applicable U.S. state privacy laws.
Certain states provide specific rights to their residents as listed below. While we will attempt to respond to a request from any U.S. resident, we reserve the right to deny requests if allowed under applicable laws.
Unless you are a California resident, any rights that may be available in your state are not afforded to you under this State Privacy Disclosure while you are operating in your commercial or employment capacity. Please refer to our Workforce CCPA Disclosure.
The terms used in this State Privacy Disclosure shall have the same or similar meaning as those terms in each of the applicable laws, or the closest approximation of such terms.
Notice at Collection
The following notice identifies the categories of personal information or personal data (collectively, “personal information”) to be collected from you and the purposes for which the personal information will be used, including whether that information is sold to anyone or shared with third parties who are not our vendors or service providers (“Non-Service Providers”).
General Personal Information
Categories of Personal Information | Purposes for Collection and Use | Sold or Shared with Non-Service Providers |
| Identifiers: For example, a name, address, online identifier, Internet Protocol address, email address, or other similar identifiers. |
| Yes, with lead generators and Non-Service Provider adtech trackers on our website. |
| (Pursuant to California Law) Personal Information Categories from Cal. Civ. Code § 1798.80(e): For example, a name, signature, physical characteristics or description, address, telephone number, or financial information. |
| No |
| (Pursuant to California Law) Characteristics of CA or Federal Protected Classifications: For example, age (40 and over), gender, and ethnicity. |
| No |
| Commercial Information: For example, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
| No |
| Internet or Other Similar Network Activity: For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. |
| Yes, with Non-Service Provider adtech trackers on our website. |
| Sensory or Surveillance Data: For example, security footage. |
| No |
| Profile Data: For example, inferences drawn from personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes. |
| No |
Sensitive Personal Information
Unless otherwise allowed by applicable state law, we will only collect certain types of sensitive personal information with your consent. We do not use or disclose the below sensitive personal information for purposes other than those business purposes specifically enumerated under applicable state law, including California. As a result, we do not offer a right to limit our use or disclosure of these categories of sensitive personal information.
Category | Business or Commercial Purpose for Collection & Disclosure | Categories of third parties to whom the information was disclosed |
| Race or ethnicity, collected through voluntary surveys |
|
|
| Biometric data collected by facial recognition cameras in all stores |
|
Retention Periods
The period of time for which we retain information depends on the purposes for which we collect or use that information. We will delete or de-identify information when it is no longer needed to fulfill the purposes listed for each category above, unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.
Notice of Sale and/or Share
Our use of tracking technologies may be considered a sale or sharing with third parties for cross-context behavioral advertising (e.g., targeted advertising) under applicable state law. You can opt-out of being tracked by these third parties by clicking the “Your Privacy Choices” link at the bottom of our website. Please note that this link provides opt-out rights under all applicable state laws, also known as “opt-out rights” or “personal data use opt-out”.
Please review our Multi-State Privacy Policy below.
PRIVACY POLICY
The purpose of this privacy policy is to provide you with a comprehensive description of our online and offline practices regarding our Information Practices. You have certain rights to control the use of your personal information. This privacy policy describes your rights as it relates to our Information Practices as to your personal information and how you can exercise those rights.
The following table includes disclosures for the preceding 12 months of: categories of personal information we have collected about consumers, the categories we have disclosed for a business purpose, and categories of third parties with whom we shared the personal information during that period.
General Personal Information
Category | In the preceding 12 months this category was: | Business or Commercial Purpose for Collection & Disclosure | Categories of third parties to whom the information was disclosed | |
Collected | Disclosed | |||
| Identifiers | ☒ | ☒ |
|
|
| (Pursuant to California Law) Personal Information Categories from Cal. Civ. Code § 1798.80(e) | ☒ | ☒ |
|
|
| (Pursuant to California Law) Characteristics of CA or Federal Protected Classifications | ☒ | ☒ | This information may be collected from you through voluntary surveys. You are not required to provide us with this information. We use this information to improve our customer service. | None |
| Commercial Information | ☒ | ☒ |
|
|
| Internet or Other Similar Network Activity | ☒ | ☒ |
|
|
| Sensory or Surveillance Data | ☒ | ☒ |
|
|
| Profile Data | ☒ | ☐ |
| None |
Sensitive Personal Information
Category | In the preceding 12 months this category was: | Business or Commercial Purpose for Collection & Disclosure | Categories of third parties to whom the information was disclosed | |
Collected | Disclosed | |||
| Race or Ethnicity | ☒ | ☒ |
| None |
| Biometric data | ☒ | ☒ |
| Security Vendors |
The categories identified as collected in the tables above were collected from the following categories of sources:
- You directly
- Advertising networks
- Internet service providers
- Data analytics providers
- Government entities
- Operating systems and platforms
- Social networks
What We Sell to or Share with Non-Service Providers and Right to Opt-Out
We have sold to or shared with Non-Service Providers personal information in the preceding 12 months as disclosed in the table below.
Personal Information
Categories sold to or shared with Non-Service Providers over the last 12 months | Categories of Non-Service Providers to whom this category of personal information has been sold or shared |
| Identifiers |
|
| Internet or Other Similar Network Activity |
|
We do not sell or share: other personal information, including sensitive information, as described in the tables above.
The purpose of the notice of Right to Opt-Out is to inform you that you have the right to direct us to stop selling or sharing your personal information, which is called the “Right to Opt-Out.”
You may exercise your Right to Opt-Out by: by: (1) Clicking “Your Privacy Choices (2) submitting your request through an opt-out preference signal (described further below in the section titled “Opt-Out Preference Signals”.
We do not have actual knowledge that we sell the personal information of minors under 16 years of age.
Your Right to Know
Certain states provide the right to request our disclosure of any of the following:
- the categories of personal information we have collected about you
- the categories of sources from which the personal information is collected
- the business or commercial purpose for collecting, selling, or sharing with third parties for cross context behavioral advertising (e.g., targeted advertising)
- the categories of third parties to whom we disclose personal information
- the specific pieces of personal information we have collected about you
You can do this through a verified consumer request. That process is described below in the section, “How to Exercise Your Rights.”
Your Right to Request Correction of Inaccurate Personal Information
Certain states provide you the right to request correction of inaccurate personal information maintained by us. We may request documentation from you to determine the accuracy of the information. If you provide us documentation either upon our request or through your own initiative, that documentation will only be used for the purpose of correcting your personal information and complying with our recordkeeping requirements.
As an alternative to correction, we may delete the inaccurate information if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny this request if allowed under applicable law, or if we determine that the contested information is more likely than not accurate, based on the totality of circumstances. You can submit a correction request through a verified consumer request. That process is described below in the section, ” How to Exercise Your Rights.”
Your Right to Request Deletion of Your Personal Information
Certain states provide the right to request that we delete any of your personal information, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the section, “How to Exercise Your Rights.”
There may be scenarios where we deny your deletion request. If that occurs, we will provide you with an explanation as to why we could not delete all or some of your personal information.
Your Right to Withdraw Consent
Where we are required or otherwise have received your consent to collect, use, disclose, sell, or otherwise process your personal information or sensitive personal information, you can withdraw your consent at any time, subject to certain limitations and exceptions under applicable law. You may withdraw your consent or limit our use by contacting us at privacy@cititrends.com or submit a Do Not Sell / Share request. Where we have collected or used your information without your consent, the process for submitting certain requests (e.g., an access or deletion request), please see the section, “How to Exercise Your Rights” below.
How to Exercise Your Rights
You may exercise your rights, as applicable, by submitting a verified consumer request to know information (and to receive your personal information in a portable format), to correct information, or for deletion.
The response to a request to know will provide the personal information we have collected and maintained about you, in a portable format, unless an exception under applicable state law applies. Please note that, depending on the applicable state law, we may not be required to provide personal information to you if you make multiple requests in a certain time period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You can submit requests by submitting a request through our online webform, contacting us at privacy@cititrends.com, or by mailing us at: CitiTrends Inc. 17 Park of Commerce Boulevard, Suite 200, Savannah, Georgia 31405. Your request will be verified using the information you provide. If you email us or mail us, you must provide the same information that is requested on the online webform. Your request will be verified by matching the information you provide to us with information that we have collected about you.
If you submit a request that is not through one of the above designated methods or is deficient in some manner unrelated to verification, we will provide you with information on how to submit the request or remedy any deficiencies with your request.
Once we receive your verifiable consumer request, we will confirm receipt of the request within 10 business days, or as allowed under applicable law, describing our verification process. We will respond to your request within 45 calendar days, or as allowed under applicable law, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.
Requests to Know or Delete for Child Under the Age of 13: We do not knowingly collect information of minors under the age of 13.
Using an Authorized Agent to Submit a Request
California: Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized to act on your behalf, may make a verifiable consumer request related to your personal information, to opt-out of sale or sharing, or to limit the use or disclosure of your sensitive personal information. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request, verify your identity directly by submitting a verified consumer request according to the procedures in the section “How to Exercise Your Rights,” and directly confirm with us that you provided the authorized agent permission to submit the request. To submit authorized agent documentation, contact us at Email: privacy@cititrends.com.
Other States: If you use an authorized agent, you may provide a power of attorney executed pursuant to applicable state law. If a power of attorney is not submitted, you may be required to provide commercially reasonable identification of your identity and evidence of your authorized agent’s authority to act on your behalf. For example, you may need to provide the authorized agent signed permission to submit a request, verify your identity directly by submitting a verified consumer request according to the procedures in the section “How to Exercise Your Rights,” and directly confirm with us that you provided the authorized agent permission to submit the request, by contacting us at Email: privacy@cititrends.com.
Opt-Out Preference Signals/Universal Opt-Out Mechanism
Our use of tracking technologies may be considered a sale or share for targeted advertising under applicable state law. You can opt-out of being tracked by these third parties by clicking the “Do Not Sell / Share” link at the bottom of our website and selecting your preferences, or by broadcasting an Opt-Out Preference Signal/Universal Opt-Out Mechanism, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us. Because the signal is browser-specific, you will need to broadcast subsequent signals if you are accessing our website through different online devices (e.g., computers, smartphones, tablets).
Notice of Financial Incentive
The purpose of this notice of financial incentive is to explain to you the material terms of a financial incentive we are offering so that you may make an informed decision on whether to participate.
We currently provide the following financial incentive(s):
Name of Service with Financial Incentive | Customer survey sweepstakes (“Giveaway”) | Sign-Up For Text Promotions (“Text Promotions”)
|
| Categories of Information | Identifiers: Name, e-mail address and phone number (required). Other information: Age, gender and ethnicity (optional). | Identifier: Phone number (required), email address (optional). |
| Summary of Financial Incentive | This financial incentive provides an opportunity to win a prize, such as a $100 gift card for providing information in response to an online survey. | When you sign up using your phone number to receive messages, we will provide you certain discounts on items, such as a coupon for $5 off for every $50 you spend with us. Each promotion is different. |
| Description of the Terms of the Financial Incentive If Applicable | The full terms of the customer survey sweepstakes, Giveaway, are found here: https://cititrends.com/csat-sweepstakes-official-rules/ | Please see our Terms and Conditions to learn about the rules of our Text Promotions. |
| Explanation of how the financial incentive or price or service difference is reasonably related to the value of the consumer’s data | In our good-faith estimation the value of the financial incentive offer reflects the value CITITRENDS receives from obtaining the customer’s information provided in response to the survey. The incentive may fluctuate based on a number of variables such as the time of year, upcoming holidays, and the response to the survey. | In our good-faith estimation the value of the financial incentive offer reflects the value CITITRENDS receives from obtaining the customer’s information provided when a consumer signs up for Text Promotions, such as the number of coupons consumers use over a certain time period. |
| How to Opt-In | After you click on the link above to get to the full terms of the Giveaway, scroll to the section “HOW TO ENTER, DRAWINGS, and PRIZES/ODDS” to learn how to enter into the Giveaway. | Provide your phone number at the bottom of our website. |
| How to Opt-Out of the Giveaway | Consumers have the right to withdraw from the any of our Giveaway at any time. Consumers may exercise that right by contacting us at privacy@cititrends.com or submit a Do Not Sell / Share request | Follow the instructions when you receive text messages from us. |
Your Right to Non-Discrimination for the Exercise of a Privacy Right
We will not discriminate against you for exercising any of your state privacy rights. However, we may still offer you certain financial incentives permitted under applicable state law, such as discounts, rewards, premium features, loyalty accounts, or club card programs that can result in different prices, rates, or quality levels.
Supplemental U.S. State Privacy Rights
In addition to the privacy rights listed above, certain states provide supplemental privacy rights to residents of those states.
Right to Opt-Out of Certain Profiling
You have the right to opt-out of our use of profiling when used to make decisions that produce a legal or similarly significant effect concerning you or your interactions with us. Currently, we do not engage in such profiling.
Right to Appeal
You have the right to appeal our refusal to take action on, or respond to, a verified consumer request. Upon receipt of our denial or refusal to take action on, or to respond to, a verified consumer request, a consumer has 90 days to submit a request to appeal our decision by contacting us at privacy@cititrends.com. We will timely inform you in writing of any action taken or not taken in response. We will also include a written explanation of the reasons for our decision.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Contact for More Information
If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Email: privacy@cititrends.com
Postal Address: CITITRENDS, Inc.,
17 Park of Commerce Boulevard, Suite 200,
Savannah, Georgia 31405
Attn: Privacy