Privacy Policy
E-COMMERCE PRIVACY POLICY
1. Introduction
This Privacy Notice (together with our terms and conditions and any other documents referred to herein) describes the type of data that we collect from you (“you/your”) when you purchase a product or service from us (“Products”) and when you use our website: fashionshow-us.com or local versions of this website (the “Website”), when and why we collect it, how that data may be used or disclosed by us, the choices you have regarding the use of your data, and the safeguards we use to protect it. When used in this Privacy Notice, “we”, “our” and similar terms means the company identified in this Privacy Notice.
This Privacy Notice includes terms specific to individuals residing in or located in certain jurisdictions, in the section “Additional information for individuals located in certain jurisdictions”. In particular:
· If you are located in the European Union or the United Kingdom, please refer to the “Specific information for individuals located in the European Union and the United Kingdom” section of this Privacy Notice for additional information.
· If you are located in Canada, please refer to the “Specific information for individuals located in Canada” section of this Privacy Notice for additional information.
· If you reside in the United States, please refer to the “Specific information for US residents” section of this Privacy Notice for additional information.
Please also note that:
· This Privacy Notice does not apply to Personal Data provided to us or more generally through physical stores. Please however note that personnel in physical stores may have access to your account and hence to your Personal Data, and this Privacy Notice therefore applies to such access and to the use of your Personal Data by in-store personnel. For US residents, please refer to the “Specific information for US residents” section below for a complete description of our privacy practices regarding your Personal Data, including data collected in-store.
· You must be of legal age or older to use this Website, including to register with us to receive communications or to purchase a Product. We do not knowingly collect or use Personal Data from persons under the legal age. If you are the parent or guardian of a minor and believe that they have disclosed Personal Data to us, please contact us so that we may delete the minor’s Personal Data. In addition, if we become aware that we have inadvertently received Personal Data from a person under the legal age, we will delete such Personal Data from our records.
· It is important that the Personal Data we hold about you is complete, accurate and current. Please contact us in accordance with this Privacy Notice if you would like to complete, update or correct your Personal Data during our relationship.
If you have any requests or questions about this Privacy Notice or the collection and use of your Personal Data, please contact us as indicated in this Privacy Notice.
Additionally, we recommend that you familiarize yourself with the other terms and conditions of our Website, accessible through the link “Terms and Conditions” displayed on each page of our Website, as they oversee the usage of our Website and in particular establish applicable disclaimers and limitations of liability.
2. Definitions
· “Personal Data” refers to all kinds of information recorded electronically or otherwise that can be used to, independently or by the combination with other information, identify an individual’s identity, recognize an individual’s activities, or otherwise be linked or related to an individual or household. This can include name, date of birth, mailing address, email address, financial information, IP addresses, location data, aliases, preferences and profiles, amongst other things.
· The term “process” or “processing” means any activity relating to Personal Data, including, by way of example, collection, storage, use, consultation, disclosure, destruction and/or transmission.
3. Who we are
The entity responsible for the collection, use, and disclosure of your Personal Data under this Privacy Policy is as described in our corporate information. Under some applicable laws, this entity qualifies as a “controller” of your Personal Data, which means that it makes decisions about how and why it is processing your Personal Data and, because of this, it is responsible for making sure it is used in accordance with the applicable data protection laws.
If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact our representative responsible for overseeing questions in relation to this Privacy Notice or protection of Personal Data.
4. The data we collect and process about you
We may collect and process the following different kinds of Personal Data about you:
· Identity data: first name, last name, title, gender, date of birth, passport number, username or similar identifier, password for your account;
· Contact data: email address, postal address (including as applicable billing address and mailing address), telephone number;
· Financial data: credit/debit card number and expiration date through our payment service provider, alternative or additional billing information, and other information we may need to collect to process payment;
· Commercial and transaction data: details about Products you have purchased from us including for example sizes and measurements and Products you have returned to us including reason for return when applicable, message for and information on recipients of gift cards, details about the Products you view on our Website;
· Data relating to virtual try on for eyewear: when you use our eyewear virtual try-on services, images of your face are processed for facial mapping to facilitate the virtual try-on. Such images are derived from or stored exclusively on your device, and no biometric data is stored by us or our provider offering this virtual try-on service;
· Marketing and communications data: consents to receiving marketing information and any preferences you have indicated in receiving marketing from us and our third parties and your communications preferences;
· Technical, usage and cookie data: we may collect technical information about our use of our Website and details about how you access and use our Website and Products, including through cookies and other tracers.
Cookies are small text files that websites place on your Internet-connected device to uniquely identify your browser or to store information or settings in your browser. We use cookies (or similar technologies such as pixel tags, web beacons or other tracers, together “cookies”) notably to allow us to remember you when you come back to our Website and provide you with personalised experiences and advertisements (see sections 5 and 9 for detailed information about the purposes for which we use cookies). Third parties may also set cookies through our Website. We do not control the privacy practices of such third parties. Please see section 9 of this Privacy Notice for additional information about cookies on our local version of the Website.
The technical, usage and cookie data we collect may include: internet protocol (IP) address, login information, browser type and version, operating system and platform, time zone, location, and other data on the technology you use to access our Website, how you arrived to our Website (including date and time), the pages you visited, products you viewed or searched for, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from a page, page response times, or download errors. If you use our virtual try-on services, we collect usage data for analytics, including impressions and number of virtual try-ons.
Please note that such data is sometimes not directly associated with your identity or cannot be related back to you. Hence, under some applicable laws, this information may not be considered as Personal Data (and we will then not treat it as Personal Data) unless they are combined with Personal Data.
5. How we may collect and use your data
5.1. Collection of Personal Data
When you use our Website, we collect information about you when you create an account, when you fill a data collection form embedded in our Website, when you place an order for a Product, or when you otherwise engage with our Website, services, products, activities and/or the resources we make accessible to our customers or users, including to the extent permissible under applicable laws when you initiate an order without finishing it. For example, you may wish to contact us through our contact form on our Website, or to subscribe through the Website to receive communications, or to purchase Products available through the Website, or to give us some Feedback, or use our virtual try-on service for eyewear.
We may also collect data regarding your use of the Website through cookies. Please see the “Cookies” section of this Privacy Notice for more information.
We also collect your Personal Data:
· when you contact us; or
· through social media platforms, if you have accepted the communication of some of your data by the social platform.
We may use third-party providers to collect your Personal Data on our behalf, including e-commerce service providers (such as customer service providers, payment service providers and website analytics service providers). Our virtual try-on service providers or size recommendation partners may provide us with data about your use of such services – we will not obtain or store any biometric data relating to you.
The data we obtain from third parties may also include Personal Data about you, including the data we receive from financial institutions in respect of payments or from delivery companies in respect of deliveries, from our fraud detection service providers or from our insurance companies.
The provision of your Personal Data is not mandatory. However, in some situations, the collection of Personal Data may be a statutory or contractual requirement, and failure to provide certain Personal Data may make it is impossible for us to create an account for you or provide you with our Products or other services in such cases. For example, we need certain information from you to register you, authenticate you, and process your purchases and payments.
If you provide personal information to us about another individual, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Notice and for bringing this Privacy Notice to their attention.
5.2. Reasons for the collection and use of your Personal Data
We may collect and process your Personal Data for the following purposes:
· Transactional purposes:
o Processing your orders and delivering to you the Products you have purchased, including processing payments and refunds, managing pre- and post-sale services, and otherwise carrying out the contracts we have with you;
o As applicable, prepare personalised Products for you;
o Allowing you to access any account you have with us and managing and operating such account;
o Sending you communications regarding your purchases or other transactional or informational messages (e.g. about your account);
o With respect to your passport number, only for tax-free purchases or for fraud investigations;
· Commercial, marketing and profiling purposes:
o Studying and analysing your consumption habits, preferences and choices, to offer you Products and other information that best meet your personal tastes and needs, as further detailed below in the section “Specific Information about profiling”;
o Sending you marketing communications, including personalised communications, for example about Products that we think may interest you, questionnaires or promotional offers;
o Sending you and/or administering contests, surveys, questionnaires, or other features of the Website;
o Administering the comments you post on the Website;
o Providing you with access to our virtual try-on service for eyewear;
· Improvement of our Products and processes:
o Managing availability/inventory of our Products;
o Internal marketing and research and development purposes, including for improving our Products based on customers’ preferences;
· Website operation/improvement purposes, including via cookies:
o Remembering when you come back to our Website and presenting the content of our Website in the most effective manner for you and you device;
o As applicable, allowing you to participate in interactive features of our Website and services;
o Personalising your experience on our Website and allowing us to offer the type of Products, other services and content in which you are most interested;
o Administering the Website, keeping it safe and secure and allowing for maintenance and troubleshooting;
o Evaluating and improving the performance of our Website, including through analytics.
· Verifying your identity when necessary, including for security reasons;
· Fraud prevention purposes;
· Responding to the requests you send us;
· Complying with, or evidencing our compliance with, our legal and regulatory obligations;
· Exercising, establishing or defending legal rights.
As regards our communications, we may contact you by electronic and traditional means. We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.
Specific information about profiling: In order to offer you products and initiatives that more accurately reflect your tastes and needs, we will also analyse your Personal Data to create a profile reflecting your preferences, with your consent when required under applicable law. By using automated tools, we may process data on the value and frequency of your purchases and the type of products purchased over a specific period of time. We may also collect and process data about you regarding your preferences, hobbies, habits, lifestyle and favourite sports, directly from you, e.g., through online forms embedded on the Website, or indirectly through certain social media platforms or through the use of cookies placed on the Website if you authorise such collection. In addition, we may supplement, correct and update some of your data with information of a public nature, to the extent permitted by applicable law and in all cases within the limits of relevance. The sole purpose of this analysis, which will be carried out in a non-invasive manner, is to offer you products, services and initiatives that are in line with your tastes and needs. At any time, you may request to analyse your profile and update or amend it as you see fit.
6. With whom will your data be shared
6.1. Sharing of your Personal Data within our Group
The Personal Data that we collect about you may, when necessary in order to fulfil the purposes listed above, shared with other companies globally.
In particular, if you decide to opt-in to receiving promotional information, your Personal Data will be disclosed to the relevant affiliated entity, and the use of your Personal Data will be governed by this Privacy Notice. Please keep in mind that you can revoke your opt-in request.
6.2. Sharing of your Personal Data outside the Group
We may provide access to or share your Personal Data with third-party service providers, when necessary in order to fulfil the purposes listed above, and in particular providers that assist us in making our Website available to you and providing you with our Products and additional features and services. These providers include e-commerce service providers that provide order fulfilment services, customer service, other sales-related services, marketing communications services, e-commerce platform hosting, virtual try-on services, analytics services, payment services and fraud prevention services, and suppliers of delivery/shipping services or IT services (including providers that maintain the functioning and security of our Website).
We share your Personal Data with these providers only under strict conditions of confidentiality and similar security levels as those we apply internally, and will request that these providers handle your Personal Data in accordance with the terms outlined in this Privacy Notice.
We may also share your Personal Data with some of our partners who will process your Personal Data for their own purposes, notably to enable them to provide you with the services you request from them. In particular, we may share your Personal Data in a pseudonymised format with our partner for size recommendations services. You may access these size recommendations services via the dedicated links on our Website, which will give you access to a dedicated pop-up window in which you will be able to access these services and review the terms applicable to the processing of Personal Data by this service provider.
We also share your Personal Data with third-parties for targeted advertising purposes, including through the use of cookies and other online trackers on our websites. Please see section 9 “Usage data and cookies” below for more information.
We may also disclose your Personal Data with banks and public authorities, when necessary in order to fulfil the purposes listed above or permitted or required by applicable law or regulation.
We may also disclose Personal Data we have about you: (i) if we determine that such disclosure is necessary in connection with any investigation or complaint regarding your use of the Website, or (ii) to the extent permitted under applicable law, to identify, contact, or bring legal action against someone who may be causing injury to or interference with our rights or property, or the rights or property of visitors to or users of the Website.
We reserve the right at all times to disclose any information that we deem necessary to comply with any applicable law, regulation, legal process or governmental or law enforcement request. We also may disclose your information when we determine that applicable law or regulation requires or permits such disclosure, including exchanging information with other companies and organizations for fraud protection purposes.
We also reserve the right to transfer Personal Data we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use Personal Data you have provided to us in a manner that is consistent with this Privacy Notice.
7. Confidentiality and security of your data
Data security is of great importance to us, and we will do what we reasonably can to keep your data secure.
Your Personal Data will be accessed by our employees, consultants and service providers only when they have a need to know your Personal Data, and they will be processing your Personal Data on our instructions and subject to a duty of confidentiality.
We, or our third-party service providers, maintain appropriate administrative, technical, and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of your Personal Data in accordance with local legislation where applicable.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Any electronic payment made by you will be encrypted, and we will not have access to the full information about the cards used to make such a payment. This information will be retained by the payment provider.
When we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure and we cannot guarantee that such transmissions will be free from delay, interruption, interception, or error. Although we will do our best to protect your Personal Data, including using encryption for communications conducted through this Website, we cannot guarantee the security of your Personal Data transmitted and any transmission is at your own risk. Once we have received your Personal Data, we will use strict security procedures and features as set out above.
8. Retention periods of your data
We will retain your Personal Data for as long as we require it in order to fulfil the purpose for which it was collected or provided to us. This period will vary depending on your interactions with us. It will generally be the duration of our relationship and a defined period after our relationship has ended, unless shorter retention periods apply for certain types of Personal Data pursuant to applicable laws or regulations, including regulations from data protection authorities. For any biometric data used by our service provider offering virtual try-on services for eyewear, any such data is derived from or stored only on your device and is inaccessible to us or our service provider after you finish using the virtual try-on service. Other data related to the virtual try-on service is subject to the other retention periods described in this paragraph. You may contact us in accordance with this Privacy Notice to request additional information on applicable retention periods for your Personal Data.
We may however be required to retain Personal Data for a longer period of time to ensure we comply with our legal and regulatory obligations or if we have other valid legal grounds for doing so, for example in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
9. Usage data and cookies
We (or third parties) use different types of cookies on our Website:
- Strictly necessary cookies: these cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Website will not work if these cookies are blocked.
- Performance (including analytics) cookies: these cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the Website and use the services offered through our Website, in order to help us improve our Website and services. All information these cookies collect is aggregated and therefore becomes anonymous. These cookies are set only with your consent. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
- Functional and profiling cookies: these cookies enable the Website to provide enhanced functionality and personalisation, and more generally for profiling purposes. They for example allow us to remind your favourite language or the region in which you are, to know which pages or Products you have seen and which links you click on, and more generally to know about your navigation behaviour. They may be set by us or by third party providers whose services we have added to our pages. These cookies are set only with your consent. If you do not allow these cookies, then some or all of the services may not function properly.
- Targeting cookies: these cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly Personal Data but are based on uniquely identifying your browser and internet device. These cookies are set only with your consent. If you do not allow these cookies, you will experience less targeted advertising.
You can find the full list of cookies placed in our Website here.
We will retain the data collected through cookies for the maximum duration permitted by applicable laws. You may contact us to request additional information on applicable retention periods.
You may accept or refuse performance, functional and profiling and/or targeting cookies on the banner that appears on the Website when you first access it. If you access all or part of those cookies, we will rely on such consent for the duration permitted by applicable laws (unless you withdraw your consent or modify your cookie preferences).
You can edit your cookie preferences at any time by editing your browser settings or by accessing the “Manage Cookies” link at the bottom of our Website. Through this link, you can find a list of cookies used in connection with our Website websites and modify your previous choices. When editing your cookie preferences, please note that your settings only apply to the browser you use to submit your opt-out request, so if you use multiple browsers or devices, you must opt-out on each browser or on each device. Your opt-out is enabled using cookies, so once you opt-out, if you delete your browser’s saved cookies on a device, you will need to opt-out again on that browser on that device.
More generally, you have the right to withdraw your consent to cookies, including by contacting us.
Our Website is not designed to respond to “do not track” signals from browsers.
10. Links to other sites
Our Website may contain links to or otherwise redirect to third party websites or applications, that are not covered by this Privacy Notice. These third-party services accessible via our Website have their own privacy policies and practices related to collection, use and disclosure of your Personal Data. When you click on a hyperlink, a new browser window or frame containing a third party’s website may appear in the foreground, while our site remains in the background. Whenever you navigate away from our Website, including to a new window or frame, neither this Privacy Notice nor our other terms will be applicable. We cannot be and are not responsible for the protection or processing of the Personal Data you provide to other websites or applications. We therefore ask you to review the privacy statements of these websites and applications to understand how and why they collect and process any of your Personal Data.
Advertisements for our Products or other services may appear on third party websites around the Internet. Some websites and services deliver these advertisements based upon data that has been previously collected about your past behaviour online. For example, if you have viewed websites about shoes, these websites or services may display to you an advertisement for our shoes. This kind of targeted advertising is sometimes called interest-based or online behavioural advertising. It is generally not based upon your Personal Data, but rather, upon your online activities. We do not control such third-party websites or services on which these advertisements appear. Further, we do not control how they collect and use data about your online activities. However, you may opt-out of being tracked online by certain companies by visiting relevant opt-out pages. If you opt-out, you may still receive advertisements, but they will not be delivered to you upon your behavioral data possessed by the companies from whom you have opted-out. This process relies upon an opt-out cookie, so if you delete your cookies or use a different computer, you will have to repeat this process.
11. Changes to this Privacy Notice
This Privacy Notice may be updated from time to time. The latest version will always be available on this page of our Website, hence please check this page for our current Privacy Notice. We will notify you if we make any substantial changes to this Privacy Notice.
12. Additional information for individuals located in certain jurisdictions
12.1. Specific information for individuals located in the European Union and the United Kingdom
If you are located in the European Union or the United Kingdom, please review this section carefully, as it supplements the rest of the Privacy Notice. In the event of any conflict or inconsistency between the terms set out in sections 1 through 10 of this Privacy Notice and the terms set out in this Section, if you are located in the European Union or the United Kingdom, the terms in this section will take priority to the extent of such conflict or inconsistency.
In addition:
· If you are a resident of France, please also refer to the “Specific information for French residents” section of this Privacy Notice for additional information.
· If you are a resident of Germany, please also refer to the “Specific information for German residents” section of this Privacy Notice for additional information.
· If you are a resident of Italy, please also refer to the “Specific information for Italian residents” section of this Privacy Notice for additional information.
· If you are a resident of Spain, please also refer to the “Specific information for residents of Spain” section of this Privacy Notice for additional information.
· If you are a resident of the United Kingdom, please also refer to the “Specific residents of the United Kingdom ” section of this Privacy Notice for additional information.
12.1.1. Legal basis for the collection and processing of your Personal Data and purpose limitation
Our legal bases for the collection and processing of your Personal Data for the purposes indicated in this Privacy Notice are as follows:
· Performance of our contract with you for contractual and account management purposes and responding to your requests;
· Compliance, or evidencing compliance with, our legal or regulatory obligations;
· As regards marketing, either your express consent, or our legitimate interests in providing you with communications on Products similar to those you have already purchased when we are allowed to rely on this legal basis pursuant to applicable laws;
· Your consent for performance, functional and profiling, and targeting cookies and for the use of our virtual try-on service for eyewear;
· For other processing operations, our legitimate interests in:
o Offering an efficient and personalised customer experience and services to our customers;
o Improving our Products, Website or other services;
o Ensuring the proper functioning and security of our Website and other services;
o Ensuring fraud prevention.
When we collect Personal Data from you, we will only process it as needed for the fulfilment of the purposes set out in this Privacy Notice. We will use your Personal Data for the purpose(s) for which we collected it, and for reasons compatible with the original purpose(s). If you wish to get an explanation as to how the processing for further purposes is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain our purpose and the legal basis which allows us to do so.
12.1.2. Personal Data sent outside of the EEA or the United Kingdom
Your Personal Data may be transferred outside the European Economic Area (the “EEA”) or the United Kingdom (the “UK”) in view of the transnational nature of our activities and services, including to other companies or to our partners or service providers located abroad.
In all cases, transfer of your Personal Data will take place with adequate levels of protection. When your Personal Data is transferred to a country that has not been recognized by the European Commission or the United Kingdom as providing an adequate level of data protection, such transfer will be made subject to appropriate safeguards to ensure the protection of your Personal Data in accordance with applicable laws.
In the absence of an adequacy decision and where appropriate safeguards are unavailable, transfers may take place on the basis of your consent. In such a situation, we will inform you of the possible risks associated with such a transfer. Alternatively, we may transfer your Personal Data where necessary for reasons of public interest, or in connection with a legal claim.
You may always contact us to know about the location of your Personal Data and to obtain a copy of the safeguards implemented for transfers of your Personal Data.
12.1.3. Your rights over your Personal Data
You have the right to request to exercise the following legal rights over your Personal Data. Please note that not all these rights are absolute and that, in some situations, we may not be able to comply with a request.
(i) Right of access: You may contact us at any time to request access to the Personal Data we hold about you. We can also provide you with a copy of your personal information on request.
(ii) Right of rectification: You may contact us to correct or complete the Personal Data we hold about you.
(iii) Right to restriction of processing: In certain circumstances, it may be possible to require us to limit the way we process your Personal Data.
(iv) Right of erasure: You may contact us to request the deletion of the Personal Data we hold about you.
(v) Right to receive/transfer your Personal Data (data portability): In certain circumstances, you may ask us to send you your Personal Data in an electronic format, or to send this data to another entity.
(vi) Right to object: Where we are processing your personal information without your consent to pursue our legitimate interests, you may object. In particular, where we are using your Personal Data for marketing purposes, you may object at any time.
(vii) Right to withdraw your consent: Where our processing is based on your consent, you have the right to withdraw your consent at any time.
(viii) How to exercise your rights: If you wish to exercise any of your rights, please contact us as indicated in this Privacy Notice.
Where necessary, we may ask you for additional information to confirm your identity.
Upon receipt of your request, we will seek to respond within a reasonable timeframe. You will not normally have to pay a fee to exercise your rights.
12.1.4. Complaints
You may lodge a complaint regarding the processing of your Personal Data with the data protection authority in your jurisdiction.
12.1.5. Specific information for residents of France
(i) Right to issue post-mortem directives: You are entitled to issue post-mortem directives concerning the processing of your Personal Data after your death. If you wish to exercise this, please contact us.
(ii) Additional information on the exercise of your rights: When you contact us to exercise one of your rights, you must justify your identity. If we have reasonable doubts, we may request any additional information that appears necessary.
12.1.6. Specific information for residents of Germany
(i) Specific information under German law: To the extent that the German Data Protection Act is applicable, specific provisions regarding right of access, right of erasure, and marketing using electronic mail may apply in accordance with local legal requirements.
12.1.7. Specific information for residents of Italy
(i) Right to issue post-mortem directives: You are entitled to issue post-mortem directives concerning the processing of your Personal Data after your death. If you wish to exercise this, please contact us.
(ii) Additional information on the exercise of your rights: When you contact us to exercise one of your rights, if we have reasonable doubts as to your identity, we may request any additional information that appears necessary and proportionate.
12.1.8. Specific information for residents of Spain
(i) Blocking of Personal Data: We will proceed with the “blocking” of your Personal Data when its rectification or deletion is required, in accordance with legal provisions. Blocked Personal Data cannot be processed for any purpose other than those specified by law.
12.1.9. Specific information for residents of the United Kingdom
(i) Specific rights under UK law: Residents of the United Kingdom have specific rights regarding their Personal Data as outlined by the Information Commissioner’s Office.
12.2. Specific information for individuals located in Canada
If you reside in Canada, please review this section carefully. In the event of any conflict between the main Privacy Notice and this section, the terms in this section will take priority.
12.2.1. Consent
In Canada, the only legal basis that we rely upon to process your Personal Data is your implied or express consent, except where permitted or required by law.
12.2.2. Your rights
Subject to certain exemptions, you may have the following rights: (i) Right of access to the Personal Data we hold about you; (ii) Right to rectification of inaccurate or incomplete Personal Data; (iii) Right to withdraw consent to our processing at any time.
12.2.3. Contact information and challenging compliance
You may contact us with any questions, comments or requests regarding our processing of your Personal Data.
12.3. Specific information for US residents
This section contains additional information relevant to residents of certain states. This section serves as our notice at collection for Personal Data collected online or that you submit.
If you are a resident of applicable states, you may have certain rights regarding the use of your Personal Data. While we endeavour to respond to all privacy rights requests, we reserve the right to limit our response or deny your request if permitted by law.
12.3.1. Notice of collection, disclosure, and selling or sharing Personal Data
The following chart identifies the categories of Personal Data that we’ve collected, the sources of that data, the business purposes for its collection, the categories of third parties to whom we’ve disclosed it, and the purposes for such disclosure:
· Category of Personal Data – Identifiers: name, title, postal address, unique personal identifier, internet protocol address, email address, account name
o Source: You
o Business or commercial purposes for collection: Verifying your identity; communicating regarding your order; processing your order; managing your account; website personalization; security; internal research and marketing; direct marketing.
o Categories of third parties with which information is disclosed: Ecommerce service providers; communications service providers; courier services; our affiliates.
o Business or commercial purposes for disclosure: Fulfill orders; customer service; marketing.
· Category of Personal Data – Commercial information: products or services purchased, or other purchasing histories
o Source: You
o Business or commercial purposes for collection: Analyzing customer patterns; managing inventory; marketing; processing made to measure orders; processing purchases and refunds; providing interactive services.
o Categories of third parties with which information is disclosed: Ecommerce service providers; point of sale service providers; our affiliates.
o Business or commercial purposes for disclosure: Fulfill orders; customer service; marketing.
· Category of Personal Data – Internet or other electronic network activity information: IP address; login information; browser type; operating system; clickstream data; page response times; products viewed.
o Source: You
o Business or commercial purposes for collection: Website functionality; interactive features; security; internal research; website administration.
o Categories of third parties with which information is disclosed: Website maintenance providers; analytics service providers; ecommerce service providers.
o Business or commercial purposes for disclosure: Website maintenance; user experience improvement; providing interactive services.
· Category of Personal Data – Geolocation data: general geographic location
o Source: You
o Business or commercial purposes for collection: Website security.
o Categories of third parties with which information is disclosed: Ecommerce service providers.
o Business or commercial purposes for disclosure: Fraud prevention and security.
· Category of Personal Data – Audio information
o Source: You
o Business or commercial purposes for collection: Assisting in telephone inquiries.
o Categories of third parties with which information is disclosed: Customer service providers.
o Business or commercial purposes for disclosure: Provide customer service.
· Category of Personal Data – Video information
o Source: You
o Business or commercial purposes for collection: Security monitoring; interactive features like virtual try-on.
o Categories of third parties with which information is disclosed: Security service providers; ecommerce service providers.
o Business or commercial purposes for disclosure: Security monitoring; providing interactive services.
· Category of Personal Data – Inferences drawn to create a profile about preferences
o Source: You
o Business or commercial purposes for collection: Suggesting new products; responding to inquiries.
o Categories of third parties with which information is disclosed: Our affiliates.
o Business or commercial purposes for disclosure: Direct and affiliate marketing.
· Category of Personal Data – Sensitive personal information (passport number)
o Source: You
o Business or commercial purposes for collection: Verifying identity for tax-free purchases or fraud investigations.
o Categories of third parties with which information is disclosed: Ecommerce service providers.
o Business or commercial purposes for disclosure: Order fulfilment and fraud prevention.
· Category of Personal Data – Sensitive personal information (financial account information)
o Source: You
o Business or commercial purposes for collection: Processing purchases and refunds.
o Categories of third parties with which information is disclosed: Ecommerce service providers.
o Business or commercial purposes for disclosure: Fulfill orders and refunds.
12.3.2. Sales of Personal Data and Targeted Advertising
We may share certain Personal Data, such as online identifiers and internet activity information, with third-party advertising partners for targeted advertising purposes. You may have the right to opt out of this sharing.
12.3.3. Your Privacy Rights
Depending on your state of residence, you may have the following rights: (i) Right to Know/Access your Personal Data; (ii) Right to Delete your Personal Data; (iii) Right to Correct inaccurate Personal Data; (iv) Right to Opt-Out of the “sale” or sharing of your Personal Data for targeted advertising; (v) Right to Non-Discrimination for exercising your rights.
12.3.4. How to Exercise Your Rights
To exercise your rights, please contact us as detailed in this Privacy Notice. To opt out of targeted advertising, please use the “Manage Cookies” link on our Website.
12.3.5. Appeal Process
If we decline to take action on your request, you may appeal our decision by contacting us as outlined in this Privacy Notice.