Privacy Policy

Effective Date: 10 January 2022

Clarus Direct, LLC, an American company trading as ShoppingSmarter ('ShoppingSmarter', 'we', 'us', 'our', or 'Company'), is the owner of the site (the 'Site') and has developed this Privacy Policy, which details important information regarding the use and disclosure of user information collected on the Site. ShoppingSmarter provides this Privacy Policy to help you make an informed decision about whether to use or continue using the services ('Services') found at the Site or through its third-party affiliates.

This Privacy Policy is incorporated into and subject to the Terms (found at, and the same capitalised definitions set out in the Terms apply to this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you must discontinue using the Site and accessing the Services available on the Site.

If you are located outside the United States and you send us your Personal Information we will treat this Personal Information in accordance with this policy. To ensure that you have additional protections in the US Clarus Direct, LLC, voluntarily complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. The Company has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit

Clarus Direct, LLC, is a Delaware limited liability company, with registered offices at 251 Little Falls Drive, Wilmington, DE 19808, United States of America.


Information Provided by You.

Registration and Membership. We will collect personal information from you when you visit our Site, sign up for our Services, interact with our Site, register with us, or use various features of our Site. Personal information is information relating to an identified or identifiable individual. This includes your name: your username and member ID; email address; address; phone number; and IP address. ('Personal Information'). Personal Information does not include “anonymous information", which is data collected as part of the Services from which we cannot identify an individual or from which individual identities or other personal information has been removed.


Membership Data.This Personal Information is used for enrolment and billing purposes; to verify customer membership; communications (member, marketing); and customer benefits fulfilment. Additionally, if we have trouble processing an order, the information may be used to contact you.

When you provide us with Personal Information in connection with a particular activity or otherwise register for our Services we will process this as necessary to enter into and perform the contract that exists between yourself and Clarus Direct, LLC. We require Personal Information to fulfil our contract with you and if you choose not to provide it you will not be able to become a member or use the Site. As part of this we may communicate with you about our Services (service messages) using the information you provided to us. We may contact you for these purposes, by way of a live phone call, recorded message, email, telephone and/or mobile telephone number (including use of automated dialling equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving. Occasionally we may wish to transfer your Personal Data to third party. Before we do this we will contact you to ask your consent to do this.

We will use other companies to operate our business and the Site in some countries or to administer activities on our behalf, such as process orders, process payments, order fulfilment, send marketing and other emails related to your membership, sending cheques, survey and prize draw administration, and government filings. We may share your information with these companies for this purpose and in compliance with this policy.

We have entered into agreements with third-party-affiliated companies to enable us to provide our Services in connection with purchases you have made with those companies, such as delivery fees charged by those companies. In certain situations, we may provide your information to those companies informing them of your membership or to investigate a claim or inquiry regarding any benefit you may make pertaining to our Services and your interactions with those companies. Since these third parties will use your information in accordance with their own privacy practices, you should check their websites for information regarding their privacy policies.

Other Uses. We may use your Personal Information to contact you about the Services on our Site for which you have expressed an interest; for example, if you have contacted customer service or made an inquiry.

Like most online businesses, we log IP addresses (a unique number assigned to every computer on the Internet) in order to improve security, analyse trends, and administer the Site. We may track your movement within the Site and through our offers on affiliate retailer sites, the pages from which you were referred, access times, and browser types. This information may include the browser you are using, the Internet address from which you linked to our Site, the operating system of your computer, the unique IP address of the computer you used to access our Site, and your usage and browsing habits. We use this information in the aggregate to gauge the effectiveness of our Site, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyse trends, track user movement in the aggregate, and gather broad demographic information.

Survey and prize draws. From time to time, we may request Personal Information from you via surveys sometimes with a prize draw. If you choose to participate in a survey or sweepstake then any Personal Information you provide will be processed in accordance with our legitimate interest in monitoring and improving the use and satisfaction of our Site. Contact information will also be used to notify the winners and award prizes.

Cookies. Please refer to our separate cookie policy for details of how we use cookies.

Supplemental Information. We may supplement information you give us with information from other sources, such as information to validate or update your address, payment card or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect; to enable us to fulfil our products and services; to target our communications so that we can inform you of products, services, and offers that may be of interest; and for internal business analysis or other business purposes. In the event that additional information is requested from a member to support a claim made under a specific benefit provided, we will use this information to validate the nature of the claim. This may include contacting the relevant retailer on whose Affiliate Retailer Site a purchase was made in order to verify that an item was purchased, the amount paid, if a benefit was utilised, or if an item has been returned.

Announcements. We may send you service-related announcements and emails from time to time relating to your account. These include emails such as order confirmations, renewal/expiry notices, and payment-card problem notifications. We may also send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if any service is temporarily suspended for maintenance, the delivery of a service is delayed, or if there is some service issue with something you might have requested, we might send you a notice. You may not opt out of these communications, which are not promotional in nature, unless you cancel your membership or we are required to remove your details from database.

Legal Matters; Safety. We may access and disclose your information, any communications sent or received by you, and any other information that we may have about you or your account required by law (including but not limited to court orders or subpoenas witness summonses). Additionally, we may disclose your information in situations that we believe to be emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat. We also may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets, or otherwise, or in the event of an insolvency, bankruptcy, or receivership, Personal Information of our visitors and members may be one of the assets sold or merged in connection with that transaction. Information about our visitors may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support, or funding.

Automated Decision Making. As part of the membership sign-up, or the delivery of our services, we do not currently employ any Automated Decision Making technology or processes. If our operations change as to incorporate this technology, applicable policies will be revised and required communications will be made.


You have a choice about how we use your Personal Information, and you may choose to amend how we use your Personal Information at any time by deactivating your account or changing your account preferences. When you deactivate your account, you will not be able to use our Services and your Personal Information will not be capable of being viewed through our Site. However, even after you deactivate your account, your Personal Information including, name and email address, may be retained by us as backup copies for legal and compliance reasons.

You can also contact us to find out if we are processing your Personal Information. If we are, you can ask us what Personal Information of yours we hold and what we do with your Personal Information. If you would like, we can also provide you with a copy of any of your Personal Information that we hold.

If, once you've spoken with us, you find out that the Personal Information that we hold about you is incorrect or incomplete, please let us know and we will correct any mistakes.

If you want us to stop using or to delete your Personal Information, you can contact us and tell us why. In certain circumstances we may be entitled to refuse your request but, if that is the case, we'll let you know and tell you why.

If you wish to speak to us in relation to any of these rights to deactivate your account or to notify us of a profile created without your knowledge or authorization, please contact us at [email protected]

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will keep your Personal Information for the time during which your account is active (or, if you do not have an account, for a reasonable period) or as needed to provide you with our Services and as necessary to comply with our obligations under this Privacy Policy and at law, including to resolve disputes, enforce our agreements, and for backup or compliance purposes. To determine the appropriate retention period for your Personal Information we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. At all times we will comply with our data retention policy. Details of retention periods for different aspects of your Personal Information are available in our retention policy which you can request from us by contacting us by using the contact details at the end of this policy.


If you have an online account with us, you also may choose to resign and deactivate your account at any time. Please visit our Terms and Conditions ( for removal information for your particular product. After you close your account, you will not be able to sign in to our Site. If you deactivate your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, resolve disputes, enforce our Terms or other policies, or take actions we deem necessary due to technical and legal requirements and constraints related to the security, integrity, and operation of our Site. All Personal Information will only be kept for a specific length of time and deleted once this time has elapsed. For details of this please see the "registration and membership" section. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties' policies.


You may wish to opt out of receiving future promotional communications or close your account by emailing us at [email protected]

If you prefer not to receive electronic promotional communications from us, you can also opt out by following the 'Unsubscribe' instructions included in each communication we send to you.

Please note that changes may not be effective immediately. In each event, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your Personal Information removed from our database. We will endeavour to comply with your request as soon as reasonably possible. We will inform any applicable third parties who we have shared your Personal Information with of your request.


Links to Other Sites. To the extent hyperlinks may be utilised to access external or third-party sites, or if you come to our Site through a link from any such third-party sites, you should be aware that these external or third-party sites are not controlled by us and therefore are not subject to this Privacy Policy. We recommend that you check the privacy policies of these sites to determine how your Personal Information will be utilised by the proprietors of those third-party sites.

Data Security. When you enter credit card information on our registration or order forms, we encrypt that information using Secure Sockets Layer technology (SSL). While using the encryption software, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just 'surfing'. We also take precautions offline to protect your information.

Data Integrity. We only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorised by the individual. To the extent necessary for those purposes, We shall take reasonable steps to ensure that Personal Information is accurate, complete, current, and reliable for its intended use.

Location of Hosting and Information Processing. The Site is hosted in the United States. If you are accessing the Site from outside the United States, by providing your information to the Site, you are consenting to the transfer of your information to the United States for processing and maintenance in accordance with this Privacy Policy and our Terms.

Children's Privacy. The Site is not directed or intended for children under 13 years of age. We do not knowingly collect Personal Information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide Personal Information on the Site.

Enforcement. In compliance with the EU-US Privacy Shield Principles, We commit to resolve complaints about your privacy and our collection or use of your Personal Information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Company at: [email protected] or 0800 440 2822 (free from UK landlines). If you are not satisfied with how we deal with your enquiry or complaint you may have additional rights under Privacy Shield. For further information please see the Privacy Shield section of this policy.

Changes to Privacy Policy. This Privacy Policy may be amended from time to time. The most recent version of the Privacy Policy will always be posted on the Site, with the effective date posted at the top of the Privacy Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make major changes in the way we use Personal Information, we will notify you by posting a prominent announcement on our site or sending you an email to the email address you provided when you submitted your Personal Information on the Site prior to the change becoming effective. Users are bound by any changes to the Privacy Policy when they use the Site after such changes have been first posted.

Privacy Shield. Clarus direct voluntarily complies with Privacy Shield. This means that If you are located outside the United States and agree to give us your Personal Information you have additional protections in the US.

Our obligations to you under the Privacy Shield

Clarus Direct has certified that it complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce and approved by the European Commission regarding the collection, use, and retention of Personal Information transferred from the European Union to the United States.

Clarus Direct has certified to the Department of Commerce that that it adheres to the Privacy Shield principles of: (1) Notice; (2) Choice; (3) Accountability for Onward Transfer; (4) Security; (5) Data Integrity and Purpose Limitation; (6) Access; and (7) Recourse, Enforcement and Liability in respect of any Personal Information received from the European Union or Switzerland in reliance on the Privacy Shield (the "Privacy Shield Principles").

Clarus Direct collects Personal Information in accordance with this privacy policy. Please see above for further details of the types of data which Clarus Direct collects from you and the purpose we collect them for.

If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the certification page for Clarus Direct on the Privacy Shield List, please visit

The Federal Trade Commission has jurisdiction over Clarus Direct's compliance with the Privacy Shield.

Accountability and liability to onward transfer. Clarus Direct may be liable in cases of onward transfer of EU individuals' data to third parties received pursuant to the Privacy Shield.

Privacy complaints, recourse, enforcement and liability In compliance with the Privacy Shield Principles, Clarus Direct commits to resolve complaints about your privacy and our collection or use of your Personal Information (without charge to you). European Union individuals with inquiries or complaints regarding this privacy policy should first contact us at: [[email protected]].

Clarus Direct has further committed to refer unresolved privacy policy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint. This service is provided free of charge to you. 

Where you believe that we have not acted in accordance with the Privacy Shield Principles you may, under certain conditions, be able to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. In order to invoke the Privacy Shield arbitration procedure you must have complied with all of the Privacy Shield Pre-Arbitration Requirements. If you believe that you have the right to invoke binding arbitration, you must notify us at [[email protected]], and give a summary of steps taken under the Privacy Shield Pre-Arbitration Requirements to resolve your claim, a description of the alleged violation, and, if you wish, any supporting documents and materials and/or a discussion of law relating to the alleged claim.

Clarus Direct commits to cooperate with the panel established by the EU data protection authorities and comply with the advice given by the panel with regard to data transferred from the EU.

In the EEA, you may also make a complaint to our supervisory body for data protection matters (namely the Information Commissioner's Office) or seek a remedy through local courts if you believe your rights have been breached.

Contacting Us. If you have any questions about this Privacy Policy or the practices of the Site, please visit our 'Contact Us' page.

You can also contact our Data Protection Officer by sending an email to [email protected]

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