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The policy discloses that SHEIN collects Social Security Numbers from participants in referral and partner programs for commission accounting, tax reporting, and internal audit purposes, alongside location data, transaction records, and account information.
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 establishes that participants in SHEIN's referral and partner programs are required to provide government-issued tax identification numbers including Social Security Numbers, which are sensitive identifiers subject to heightened data security and breach notification obligations under applicable federal and state law.
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 →Under this provision, individuals participating in SHEIN's referral or partner programs are subject to collection of their Social Security Number, location data, commission details, and full transaction records for tax and audit purposes. The agreement designates this data as used for commission accounting, tax reporting, and internal audit functions.
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"To administer our partner Programs (e.g., Refer-A-Friend) Basic Personal Identifiers and contact information (such as email address and password), for profile creation, program onboarding, program promotions and incentives, and communication with program participants about rights, benefits, and services offered by SHEIN. Location data, for profile creation and program onboarding. Commercial Information (Order information of Referral, including transaction details and records) and Payment Card and Financial Information, including Tax ID (e.g., SSN), of Referrer for commission accounting and payment, tax reporting and compliance, and internal audit purposes.Excerpt from Shein's Terms and Conditions
1. REGULATORY LANDSCAPE: Collection of Social Security Numbers and tax identification data engages IRS Form 1099 reporting requirements for commission payments, as well as state data security statutes that impose heightened protection and breach notification obligations for SSN data. The FTC Safeguards Rule and state equivalents impose security requirements on entities that collect financial account and government identifier data. 2. GOVERNANCE EXPOSURE: High. Social Security Numbers are among the most sensitive categories of personal identifiers under US law, triggering specific data security, retention, and breach notification requirements across all fifty states. The policy's disclosure of SSN collection for tax reporting is operationally standard for commission-based programs, but requires robust security controls and a documented data minimization and retention policy for this category. 3. JURISDICTION FLAGS: All US states impose breach notification obligations for unauthorized access to SSN data, with varying timelines and notification requirements. California, New York, and Texas impose particularly detailed breach notification requirements. The collection of SSN data from program participants in states with data minimization requirements should be assessed for compliance with minimum necessary standards. 4. CONTRACT AND VENDOR IMPLICATIONS: Any third-party payment or tax processing vendors that receive SSN data from SHEIN's partner program must be assessed under vendor due diligence protocols for IRS data security standards and applicable state safeguards requirements. Data processing agreements should specify security controls, retention limits, and breach notification obligations for SSN data. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that SSN data collected from referral program participants is stored using encryption and access controls consistent with applicable state data security statutes, that retention is limited to the period required for tax reporting obligations, and that breach notification procedures address the specific timelines and content requirements of each state in which program participants reside.
This provision establishes that participants in SHEIN's referral and partner programs are required to provide government-issued tax identification numbers including Social Security Numbers, which are sensitive identifiers subject to heightened data security and breach notification obligations under applicable federal and state law.
Under this provision, individuals participating in SHEIN's referral or partner programs are subject to collection of their Social Security Number, location data, commission details, and full transaction records for tax and audit purposes. The agreement designates this data as used for commission accounting, tax reporting, and internal audit functions.
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