UPDATED AS OF May 23, 2019
This Privacy Notice (this "Notice") explains how information about you is collected, used and disclosed by Todd Snyder, a company incorporated under the laws of Delaware and our affiliates and subsidiaries in North America (collectively, "Todd Snyder", "we", "us", or "our") with its principal business office located at 27 West 20th St, New York, NY 10011. This Notice applies to information we collect when you access or use our technology platforms (including, without limitation, our websites, mobile applications and other Todd Snyder-controlled properties that link to this Notice) (collectively, the "Platforms"), shop in our stores, engage with us via social media, or when you otherwise interact with us. By providing us with your Personal Information (as defined below) or otherwise interacting with us, you consent to the collection, use and disclosure of such information in accordance with this Notice. We may supply different or additional notices of our information practices specific to certain programs or activities. We may also provide different notices of our information practices with respect to certain subsidiaries or affiliates, in which case this Notice will not apply.
1. COLLECTION & USE OF PERSONAL INFORMATION.
"Personal Information" is information that may be used to identify you as an individual, such as your name, e-mail address, telephone number, home address, or payment information (e.g., account information or credit card number).
We may collect Personal Information when you interact with Todd Snyder or any of our brands, such as when you:
Purchase, return, reserve or try-on merchandise at one of our stores or through our Platforms;
Consent to receive marketing communications, promotional emails, SMS/text messages, job postings or other communications;
Visit or register through our Platforms;
Participate in our contests, sweepstakes or promotions, or participate in one of our surveys or other customer research;
Contact or visit our Customer Service Department, or otherwise contact us or one of our service providers with a comment, question or complaint; or
Enroll in one or more of our loyalty or other reward programs.
Purchasing, returning, reserving merchandise. When you purchase or return merchandise through one of our stores or through our Platforms, we collect and use the Personal Information that you provide, such as your order, contact, shipping and payment information, for the purposes of fulfilling your order, processing your return, and updating you on the status of your order/return.
In certain circumstances, we may also collect Personal Information that you provide to us regarding other people. For example, you may provide us with the name and address for a gift recipient. When you provide us with this Personal Information, we use it for the purposes of processing the shipment and, in some cases, to communicate with the intended recipient. We rely on you to obtain any necessary consent from the intended recipient to our use of their Personal Information for these purposes.
Promotional email, SMS/text messages, job postings or other communications. When you consent to receive information from us such as promotional emails, SMS/text messages, job postings or other information, we collect and use your contact information for the purposes of fulfilling your request. You can unsubscribe from promotional communications by following the instructions in the message. If you have any questions about unsubscribing from our messages, please contact us as outlined below.
Visit or register through our Platforms. If you choose to visit and register with one of our Platforms, we will collect the registration information that you provide, such as your contact and account-related information for the purposes of administering and securing your account on our Platforms.
We also collect certain information through our Platforms automatically, such as:
Usage Information. Whenever you visit or interact with our Platforms, we, as well as our vendors and/or service providers (collectively, "Vendors"), may use a variety of technologies that automatically or passively collect information ("Automated Technologies") about how the Platforms are navigated, accessed and used ("Usage Information"). Usage Information may include browser type, device type and characteristics, Device Identifiers (as defined below), operating system, application version, the pages served, the time/date, your geo-location, the preceding page views, and your use of and pathway through the Platforms.
Device Identifier. We or our Vendors may automatically collect your IP address(es) or other unique identifiers ("Device Identifier") for the "Device" (e.g., computer, mobile phone, tablet or other device) you use to access the Platforms. A Device Identifier is usually a number that is assigned to your Device when you access a Platform or its servers, permitting identification of your Device.
Automated Technologies. The Automated Technologies used on the Platforms to collect Usage Information include, but are not limited to, cookies (data files placed on a Device when it is used to visit the Platforms), mobile analytics software, pixel tags (a transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a Platform to indicate that a page or e-mail has been viewed), and similar technologies. Both session cookies (which expire once you close your web browser) and persistent cookies (which remain on your Device, sometimes until you delete them) may be used. Please remember, some Automated Technologies may tell your browser to get third party content, such as customer reviews, from another server.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your Device browser settings to notify you when your Device receives a cookie, which lets you choose whether or not to accept it; or (ii) set your Device browser to automatically reject any cookie.
However, please be aware that if you disable or reject cookies, some features and services on our Platforms may not work properly, because we may not be able to recognize and associate you with your Todd Snyder account. Please note, even if you choose to restrict or modify your settings, you may still see or receive Todd Snyder advertisements via our Platforms and on other sites, but such advertisements will not be based upon your browsing history.
Todd Snyder does not respond to "do-not-track" settings in user's web browser, and our Platforms may continue to collect information in the manner described in this Notice. You can learn more about cookies by visiting http://www.allaboutcookies.org/, which includes additional useful information on cookies and how to block cookies using different types of browsers.
We collect this information automatically through our Platforms for security purposes (including protecting the integrity of the Platforms and our stores), to better understand and enhance user navigation on our Platforms, and for marketing and analytics purposes (including allowing the selection of personalized ads or offers believed to appeal to you, based on your interests, preferences, location, or demographic information). Additionally, Automated Technologies may be used to associate you with social networking sites (e.g., Facebook, Twitter and Snapchat), and, if you so choose, enable interaction between your activities on the Platforms and your activities on such social networking sites.
Participating in our contests, sweepstakes, promotions, surveys or customer research. We collect the Personal Information that you provide if you choose to participate in one of our contests, sweepstakes, promotions, surveys or other customer research, for the purposes of administering them. We will also use the Personal Information you provide to analyze and better understand how customers interact with our brands.
Contacting Customer Service. We use the Personal Information you provide to us when you contact our Customer Service Department for the purposes of reviewing any issues you raise and responding to you. Depending upon the nature of your query, we may request additional Personal Information for the purposes of verifying your identity.
Loyalty Program. If you choose to enroll or engage in one of our optional loyalty programs, we will use the Personal Information you provide to us, along with information about the products and services you purchase from Todd Snyder, for the purposes of administering the loyalty program, including any points you earn or redeem through the programs.
Information We Receive from Third Parties. We may obtain information from other sources and combine that with information we collect directly from you. For example, we may collect information from third parties to ensure we have up-to-date contact information for you, to detect fraud or theft, to facilitate your use of a third-party application or feature (such as one of our Facebook, Twitter or Snapchat applications or a similar application or feature on a third-party website), or from third-party analytics and advertising providers as further described below.
Information Combined from Sources. If we combine any information about you received from third parties with your Personal Information or other information collected pursuant to this Notice, then we apply the applicable provisions of this Notice to such combined information, so long as it is combined.
2. SHARING OF INFORMATION.
Except as described in this Notice, we will not provide your Personal Information to third parties without your consent. We may, however, share aggregated, non-personal or de-identified information, which cannot reasonably be used to identify you, with third parties. We may also share your Personal Information in the following circumstances:
Third Parties Providing Services on Our Behalf. We may share your Personal Information with Vendors that perform functions on our behalf or assist with our business operations, such as those that host or operate our Platforms, analyze data, process transactions and payments, fulfill orders or provide customer service; advertisers; or other third parties that participate in or administer our promotions, contests, sweepstakes, surveys or provide marketing or promotional assistance; and “powered by” partners who power product reviews on our products or services.
Your Consent to Have Your Personal Information Shared. While utilizing our Platforms, you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the sharing of your information with a third party. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the third party and the Personal Information you disclose will be subject to the privacy notice and business practices of that third party.
Business Transfers. We may share your Personal Information with other entities in connection with a bankruptcy, merger, acquisition, financing, reorganization or sale of company assets, or negotiation thereof.
Legal and Additional Disclosure. We may transfer and disclose your information to third parties to comply with a legal obligation; when we believe in good faith that the law or a governmental authority requires it; to verify or enforce applicable policies; to detect and address fraud, security or technical issues; to respond to an emergency; otherwise to protect the rights, property or security of Todd Snyder or third parties, or as otherwise required or permitted by law.
3. CHOICE AND ACCESS.
Accessing/Updating/Deleting Your Personal Information. If you wish to access, modify, verify, correct or delete any of your Personal Information collected through the Platforms, you may contact us using the contact information provided below. Alternatively, you may access, modify, verify, correct or delete your registered user information through our Platforms. We may refuse requests that are unreasonably repetitive, require disproportionate technical efforts, risk the privacy of others, or are impractical.
In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Platforms or otherwise. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. It may not always be possible to completely remove or delete all of your information from our databases without some residual data remaining due to backups and other reasons. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and obligations.
Promotional Communications. You may opt out of receiving promotional communications from us at any time by: (i) contacting us by phone, email or postal mail, or (ii) following the removal instructions in the communication that you receive.
4. TARGETED ADVERTISING/ANALYTICS.
For more information about interest-based ads, or to opt-out of having your web browsing information used for interest-based advertising purposes, please visit the following link (http://www.aboutads.info/choices/), if you are located in the United States or Mexico. Please visit youradchoices.ca/choices if you are located in Canada. Your Device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt-out of having certain information collected through apps used for interest-based advertising purposes.
We may also work with other websites or platforms (such as Facebook, Twitter or Snapchat) to serve ads to you as part of a customized campaign, unless you notify us that you prefer not to have information about you used in this way. You can opt-out of receiving interest-based ads from Facebook by changing your ads preferences in your Facebook Settings, on Twitter by changing your advertising preferences in your Account Settings, and on Snapchat by changing your privacy settings in the profile screen.
5. SECURITY OF YOUR INFORMATION.
We take industry-standard administrative, technical and physical measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
6. CONSENT TO PROCESSING AND TRANSFER OF INFORMATION.
We are based in the United States, and the information we collect is governed by U.S. law. By accessing or using the Platforms, or otherwise providing information to us, you consent to the collection, processing, transfer and storage of information about you in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen. Please use the contact information below if you have a question or complaint about the policies, practices or manner in which we or our Vendors treat your Personal Information.
We may update this Notice from time to time. If we make changes, we will notify you by revising the date at the top of the Notice and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review this Notice whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.
8. CONTACT US.
As it relates to questions you might have about this Notice or if you have a concern that Todd Snyder may have failed to adhere to this Notice, please contact us as follows:
Please note, the role and department responsible for compliance with the obligations under this Notice is:
Assistant General Counsel, Privacy: Legal Department, firstname.lastname@example.org
c/o Legal Department
77 Hot Metal Street
Pittsburgh, PA 15203
Attention: Assistant General Counsel, Privacy