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The policy discloses that SHEIN collects body measurement data including body shape, height, chest, waist, hip circumference, and weight, as well as behavioral inferences automatically derived from service interactions, and designates this category as used for targeted advertising.
This analysis describes what Shein's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision authorizes the collection and use of body measurement data and automatically generated behavioral inferences for targeted advertising purposes, which may engage sensitive personal information frameworks under state privacy statutes that impose heightened consent or processing restrictions on physical characteristic data.
Interpretive note: Whether body measurement data as described qualifies as sensitive personal information under CPRA or analogous state statutes requires jurisdiction-specific legal evaluation.
Previously, Shein asked users to explicitly agree or disagree with account persistence for future logins. The updated terms remove this choice entirely. Instead of a consent decision, users now see a promotional discount offer in that location. This means users lose direct control over whether Shein maintains their login session across device visits, which affects convenience and privacy preferences around authentication persistence.
View change record →New collection of sensitive biometric data (body measurements) and automated behavioral inferences derived from user interactions.
View full change record →Under this provision, body measurement data voluntarily provided for fit and size recommendations, along with behavioral inferences automatically derived from site or app interactions, are retained for the life of the account and used for targeted advertising. The agreement states this data may also be anonymized or aggregated and retained for analytic purposes.
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"Preferences, Behavior Data, and Inferences, such as your indicated body shape, height, chest/waist/hip circumference, and weight, as well as your preferences for clothing sizes or styles, personalization Source(s) of information: Preferences are manually received directly from you, though inferences may be collected automatically based on your interaction with the Services and subsequently created by us. Purpose(s) of collection/use: All purposes listed in 'How Do We Use Your Personal Information?' section below. Used for Targeted Advertising: YesExcerpt from Shein's Terms and Conditions
1. REGULATORY LANDSCAPE: This provision engages the CPRA's sensitive personal information framework, which may classify physical characteristic data including body measurements as sensitive personal information subject to use limitations and opt-out rights. Colorado, Connecticut, Virginia, and Texas privacy statutes similarly impose heightened obligations on sensitive data categories. The FTC's guidance on sensitive personal information in consumer-facing digital services is also relevant. 2. GOVERNANCE EXPOSURE: Medium. The CPRA designates certain categories of physical characteristic data as sensitive personal information, potentially requiring a separate opt-out mechanism or limiting use to purposes reasonably necessary for the services requested. Whether body measurement data as described in this policy meets the CPRA's sensitive personal information threshold requires legal evaluation specific to the data's granularity and how it is processed. 3. JURISDICTION FLAGS: California creates the highest exposure given the CPRA's sensitive personal information provisions. Illinois BIPA is not directly implicated by body measurement data as described, though the intersection of measurement data with any biometric component would require separate analysis. Texas and Colorado sensitive data frameworks may also apply depending on how body measurement data is classified under each statute. 4. CONTRACT AND VENDOR IMPLICATIONS: Service providers receiving body measurement data for fit prediction or size recommendation services should be assessed to confirm that data processing agreements limit use to the disclosed purposes and prohibit secondary use for independent advertising or profiling. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether body measurement data collected for fit and size services requires separate disclosure or consent under the CPRA's sensitive personal information rules, and whether the current opt-out mechanism for targeted advertising adequately covers the use of this data category for advertising purposes.
This provision authorizes the collection and use of body measurement data and automatically generated behavioral inferences for targeted advertising purposes, which may engage sensitive personal information frameworks under state privacy statutes that impose heightened consent or processing restrictions on physical characteristic data.
Under this provision, body measurement data voluntarily provided for fit and size recommendations, along with behavioral inferences automatically derived from site or app interactions, are retained for the life of the account and used for targeted advertising. The agreement states this data may also be anonymized or aggregated and retained for analytic purposes.
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