- WHAT PERSONAL DATA DO WE PROCESS?
- HOW DO WE USE THE PERSONAL DATA WE PROCESS?
- WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
- HOW LONG DO WE KEEP YOUR PERSONAL DATA?
- WHAT RIGHTS AND CHOICES DO YOU HAVE WITH REGARD TO YOUR PERSONAL DATA?
- WILL PERSONAL DATA BE TRANSFERRED OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)?
- IS DATA COLLECTED FROM CHILDREN?
- HOW IS YOUR PERSONAL DATA SECURED?
- WHAT ARE YOUR CALIFORNIA PRIVACY RIGHTS?
- WHAT ELSE SHOULD YOU KNOW?
- HOW CAN YOU CONTACT US?
- WHAT ARE COOKIES?
- WHAT TYPES OF COOKIES DO WE USE?
- WHAT INFORMATION IS PROCESSED BY COOKIES?
- HOW DO WE DEPLOY COOKIES?
- WHAT IS OUR LEGAL BASIS FOR PROCESSING INFORMATION COLLECTED BY COOKIES?
2. WHAT PERSONAL DATA DO WE PROCESS?
We process personal information or other information about you when you interact with any of our retail stores, visit our IT Sites or otherwise use our Services. The information we may process depends upon your interaction with us. The types of personal data that we may process include the following:
A. Registration and Account Information. In order to access and use certain features, content or functions of the Services, including, for example, purchasing products through our IT Site, signing up to receive special offers or discounts, signing up for loyalty programs, etc., you may need to register an account. When you create an account, we will process personal data as necessary to offer and fulfill the Services you request. Depending on the Services you elect to use and only as necessary to provide such Services, we may ask you to provide your name, mailing address, email address, phone number, Facebook credentials in order to authenticate your account, date of birth, gender or other descriptive information or preferences, and ask you to create login credentials (i.e., a unique user name and password). If you limit our processing of certain information that we obtained from you via consent, you may not be able to use all of the features of the Services.
B. Purchase Information. If you make any purchase on or through the Services, including in our retail stores, your payment information (e.g., credit or debit card type, number and expiration date) and additional information to fulfill the services or deliver the products (e.g. name, date of birth and shipping address) may be processed by us and/or third party payment processors. We also process the details of any purchased services or products, including the date of purchase, item or product description (e.g., item name, size purchased, color), rate or product purchase price, and any wording you ask to be included in a gift card.
C. Images: We may also use closed circuit television and other security measures at our properties that may capture or record images of customers and visitors in public areas of our store(s). We may also use closed-circuit television and other technologies that record sound or video for loss prevention and security purposes, and the protection of our customers and visitors to our store(s) where permitted by law.
D. Location Information: With your permission, we may process the specific geographic location of your Device (e.g. by accessing your Device's GPS) via our IT Sites or IT Apps to provide you with directions to our properties or to determine your proximity to our store(s). If no longer wish to have this location information processed, you can withdraw your consent at any time by disabling the location and/or Bluetooth features in the operating system of your Device and/or in the IT App. If you have any questions about disabling you location and/or Bluetooth features, you can contact us [email protected]
E. Information You Choose to Provide to Us for Marketing or Additional Services. We may process any information that you choose to provide to us when you elect to participate in optional IT Site-features or Services. For example, if you sign up to receive newsletters, marketing emails, promotions or other communications regarding the Services and/or promotions from our preferred third-party products or services, participate in contests, surveys and other promotions relating to the Services, we may process your name, email address, mailing address, gender, interests and phone number in order to provide the additional features or Services. We will make clear what information we may process as a result of your engagement with the optional IT Site-features or Services.
F. Comments, Feedback, Customer Service and Other Inquires: You have the ability to use the Services to contact us with questions you may have, inquire about our products, provide us with comments and or feedback about the Services (e.g., completing a "Contact Us" form on our IT Sites or surveys relating to your purchase) or to communicate with other users of the Services and post comments to or otherwise interact with certain aspects of the Services that are available to the public and/or other users. We will process any information you submit, post or provide in the course of such activities to respond to your comments or feedback. In the event you contact our customer service center, we may process information related to conversations, including recording or monitoring customer service calls for quality assurance and training purposes, and to verify your identity.
G. Application Information: If you apply for a job or internship via the IT Site, we collect information that you voluntarily provide to us, including, for example, your name, employment history and other information you provide on your application or contained in a resume.
H. Third Party Platform Information. If you access the Services via your Third Party Platform account (e.g., by logging in to the Services using your Third Party Platform account credentials) and/or integrate your Ivanka Trump account with your Third Party Platform account, post content from our IT Sites or IT Apps to a social network, or use various social media features (e.g., "Like" button), we may process certain information from the Third Party Platform, such as your username, "likes", location, birthday, check-ins, comments and reviews, direct messages you may send to us, interests, photos, friends, status updates and other information you provided to the Third Party Platform in connection with your account. Depending on your account and privacy settings, we may also be able to see information that you post when using these Third Party Platforms whether or not you are using our Services. The information you post or provide to Third Party Platforms, as well as the controls surrounding these disclosures are governed by the respective policies of these third parties.
J. Browsing Information, Logs, Usage Data and Other Device Information: When you visit our IT Sites and use our IT Apps, we may process information about your activities on our IT Sites and IT Apps through the use of technology such as cookies, web beacons and other tracking technologies, as further explained in Sections 13 - 17 below. Providing this information is not mandatory and cookies can be disabled by clicking here Embed this code However, please note that our IT Sites and IT Apps may not offer the same functionalities when certain cookies are disabled.
3. HOW DO WE USE THE PERSONAL DATA WE PROCESS?
- To fulfill our contractual obligations under an existing agreement with you to provide you with products and services you requested, or in anticipation of entering into such an agreement with you, including, without limitation:
- To complete, fulfill and process your orders and provide you with products and services you have requested and/or paid for, including for our accounting, auditing or other internal functions, and to offer you an overview of your transactional history;
- To complete and fulfill your purchases, including processing your payment, providing you with information relating to your purchase, sending you shipping confirmations, cancellations, modifications, and providing you with other information about the products;
- To manage and administer your accounts, including sending you transaction-related emails for such things as account verification, purchase and billing confirmation, shipping tracking and confirmation;
- To communicate with you about your account, transactions, applications, the IT Sites and the Services;
- To respond to requests for information and services, including services from a third party (such as shipping providers);
- To administer our loyalty program, including sending you information about your account status and provide you with the benefits of the loyalty program;
- To manage, evaluate and administer applications you have submitted to us for employment or an internship;
- To enforce your legal rights under an agreement; and
- To provide you with an estimate for our products or services.
- To pursue our legitimate business interests, including, without limitation:
- To provide you with a more personalized level of service, including information and services related to the products and services you purchase from us;
- To manage our business needs, such as monitoring, analyzing, modifying and improving our Services', including the IT Sites', functionality and performance, including changes/updates to features of the IT Sites/IT Apps, technical and security notices;
- For the security and safety of our customers and visitors, and for purposes of fraud prevention, including preventing fraud and abuse on and unauthorized access to the Services and IT Sites;
- To provide you with information about products and services you have purchased or indicated your interest in;
- To determine which features and functionality of the Services users like best to help us operate, enhance and improve the Services, including by asking you to participate in a survey or review relating your use of the Services;
- To respond to any customer service requests, such as resolving your problems or responding to your questions, managing any complaints or feedback you provide;
- For statistical analysis of aggregated data to help us segmenting our offering and develop our Services;
- To better understand the way in which our IT Sites and IT Apps are working and offer you a better IT Site and/or IT App user experience, to create statistics in relation to the use of our IT Sites, IT Apps and our Services generally;
- To help us diagnose technical issues and problems related to our Services;
- To grow our business, including our portfolio of Ivanka Trump-branded products and services;
- To get to know our potential and existing customers and users; and
- To identify relevant content shared with potential and current users.
- To comply with our regulatory and legal obligations or to enforce our legal rights, including, without limitation:
- To meet reporting requirements (e.g. filing tax forms);
- To retain documents and information related to a legal action;
- To enforce the Terms & Conditions; and
- To report data breaches or unauthorized access to the Services.
- With your consent*, including, without limitation:
- To provide location-specific functionality, features, services or offers;
- To market to you by delivering marketing materials about our brand, products and services, as well as the products and services of unaffiliated third party businesses;
- To display online advertising and marketing information based on your use of the Services and other websites services and platforms that you have visited;
- To provide you with tailored advertisements about our brand on third party websites, we may provide your personal information to Third Party Advertising Providers that combine such data with information collected by third-parties to send you advertisements on our Sites and third party websites, about our exclusive offers, brand news and events tailored to you and your interests;
- To provide personalized services offered by us on third-party websites and online services;
- To enable you to connect with others who use our Services; and
- For other purposes for which you may grant consent.
4. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
In connection with our business operations, we may share information we collect from you or about you with some of our licensees, manufacturers, affiliates, and third party service providers as necessary to assist us in providing the Services to you, as set forth in more detail below:
- Our Licensees and Group Entities: We may disclose your personal data to our brand licensees and group entities that are affiliates and/or subsidiaries or parents of IT Operations LLC in order to provide you with tailored products, services and communications.
- Service Providers: We may partner with other companies to help us operate certain aspects of our business, including the hosting of our IT Sites and IT Apps, manufacture of our products, sale of our products, operation of our technology infrastructure, processing of payments, and fulfillment certain of the services or products you request from us. We carefully select such third party operators, merchants, manufactures, website hosts, service providers and participants to your transactions, for the purpose of (1) assisting with facilitating transactions on or through the Services, (2) providing information technology and customer service assistance, and (3) providing, offering, supporting, administering, maintaining and enabling the Services (including providing a full range of products, merchandise, content, activities, services, features and functions offered on or in connection with the Services).
- Advertising Providers: In order to provide you with marketing and exclusive offers, including emails and advertisements tailored to you and your interests on and off the Services, we may provide your information to Third Party Advertising Providers.
- Co-Sponsors of Promotions: From time to time, we may co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies. If you enter one of these sweepstakes or contests, we may share your information with the co-sponsor or third-party sponsor.
- Corporate Transactions or Events: We may disclose your personal data in connection with a merger, sale of substantially all of our assets or stock, joint venture, transfer, corporate reorganization or other disposition of our business.
- To Fulfill Your Requests: If you elect to use certain authentication or sharing features available on the IT Sites or via the IT Services, we may use your personal data to fulfill your request to share content with or provide access to such third parties (e.g. Facebook, LinkedIn, or Twitter).
5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
6. WHAT RIGHTS AND CHOICES DO YOU HAVE WITH REGARD TO YOUR PERSONAL DATA?
If you are an EU citizen or reside in the EU, you may have certain additional rights with respect to the personal data you provided to us. To the extent permitted by applicable data protection laws, under EU laws you may:
- Access or modify your personal data;
- Object, on grounds relating to your particular situation, at any time to the processing of your personal data if the legal ground we are relying on is our legitimate interest or in the public interest;
- Request that your personal data be erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn consent to, or object to, the processing of such personal data and we meet no other legitimate basis for such processing or it has been unlawfully processed;
- Restrict the processing of your personal data if you contest its accuracy or the lawfulness of our processing, we no longer need it but you need it for a legal claim or you have objected to its processing and await verification of our legitimate grounds for processing it;
- Stop receiving our marketing communications. If you opt out of marketing emails, you will continue to receive messages from us about your relationship with us where permitted by law;
- Under certain circumstances, have your personal data transferred to another company; and
- Withdraw any consents that you have previously provided to allow us to process your personal data.
If you wish to exercise any of these rights please contact us at [email protected] [LINK] Although we urge you to contact us to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority. Please note that some requests may require you to verify your identity.
How to Unsubscribe from Our Marketing: If you want to unsubscribe from receiving tailored advertisements on third party sites (as described in "Advertising Data" in Section 2 and/or marketing emails sent by or on behalf of us, you can do so by emailing [email protected] or by following the instructions in any such marketing email you receive from us.
7. WILL PERSONAL DATA BE TRANSFERRED OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)?
Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and some of our subsidiaries and affiliates, servers, vendors and service providers may not be located in your jurisdiction and may also be located outside of the European Economic Area and Switzerland. If you are an EU citizen or resident in the EU, we will transfer your personal data to the United States in accordance with EU data protection law requirements by using model contractual clauses that have been approved by the European Commission or other appropriate means.
Please note that such transfers may also be necessary in order to perform our obligations under a contract with you, to fulfill a request made by you, to meet a legal or regulatory obligation and/or through obtaining you express consent. If you make transactions with parties outside the EEA or Switzerland or connect our Service with platforms, such as Facebook, outside the EEA or Switzerland, we are required to transfer your personal data with those parties in order to provide the requested Service to you. If you wish to gain more information about such transfers, please contact us at [email protected]
8. IS DATA COLLECTED FROM CHILDREN?
Our IT Sites and our IT Apps are not directed to children under the age of majority. We do not knowingly collect personal information from U.S. children under 13 without appropriate parental notice and consent. If we obtain actual knowledge that we have collected personal data from someone under the age of majority, we will promptly delete it, unless we are legally obligated to retain such data. If you believe that we have mistakenly or unintentionally collected information from someone under the age of majority, please contact us at [email protected]. For users in the United States, please also visit ftc.gov for information from the Federal Trade Commission about protecting children's privacy online.
9. HOW IS YOUR PERSONAL DATA SECURED?
While no data transmission over the internet or wireless networks is 100% secure from intrusion, we maintain and have implemented reasonable physical, electronic, technical and procedural security policies and measures to protect the personal data that we process, which are consistent with applicable privacy and security laws. These policies and measures are designed to prevent against loss, misuse, unauthorized access, modification and disclosure and unlawful destruction of your personal data. The security measures can change and be modified over time, but generally include, but are not limited to, firewalls, data encryption, physical access controls to our data centers, servers and hardware and information access authorization controls, regular testing and updating of the systems and training programs.
10. WHAT ARE YOUR CALIFORNIA PRIVACY RIGHTS?
If you are a resident of the State of California, we provide you with information on how to exercise your disclosure choice options such as your right to opt-out (which we may sometimes refer to as "unsubscribe"), as described in Section 6, or opt-in for use of your information by third parties (such as advertisers) for marketing purposes. Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that received your information for marketing purposes during the preceding year. If you are a California resident and you wish to request information about how to exercise your third party disclosure choices, please submit your request at [email protected] or by postal mail to IT Operations LLC, Attn: Privacy Matters, 725 Fifth Avenue, New York, New York 10022. All requests must be labeled "Your California Privacy Rights" on the email subject line or envelope or post card. For all requests, please clearly state that the request is related to "Your California Privacy Rights", include your name, street address, city, state, zip code and e-mail address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. You can always opt-out or unsubscribe by emailing [email protected]
11. WHAT ELSE SHOULD YOU KNOW?
12. HOW CAN YOU CONTACT US?
Email: [email protected]
Mail: IT Operations LLC
Attn: Privacy Matters 725 Fifth Avenue New York, New York 10022
13. What Are Cookies?
14. What Types of Cookies Do We Use?
We do not place cookies until you elect to continue using our IT Site after our cookie banner displays.
Our cookie management tool uses Cookiepedia to, with no input from us, automatically categorize cookies that we deploy on our IT Sites. We use the following types of cookies:
- Strictly Necessary Cookies: These cookies are necessary for the IT Sites 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 Site(s) may not work if you choose to do so.
- Performance Cookies: These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our IT Sites. They help us know which pages are the most and least popular and see how visitors move around the IT Sites. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our IT Site(s).
- Functional Cookies: These cookies allow the provision of enhanced functionality and personalization, such as videos and live chats. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these functionalities may not function properly.
- Targeting Cookies: These cookies are set through our IT Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites. They work by uniquely identifying your browser and Device. If you do not allow these cookies, you will not experience our targeted advertising across different websites.
15. What Information Is Processed By Cookies?
16. How Do We Deploy Cookies?
17. What Is Our Legal Basis For Processing Information Collected By Cookies?
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