PRIVACY POLICY
LAST UPDATED: September 2023
The protection of your personal data is a key value of SMCP USA Inc. (“SMCP”, “us”, “our” or “we”) including its Sandro brand. By accessing or using this Website, you also agree to this Privacy Policy. If you do not agree with our Privacy Policy, your choice is not to use our Website. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
This Privacy Policy describes the types of personal information we may collect from you when you visit our Website or our stores, how we use and protect this information, and when we share it with third parties or affiliates, among other things. Our Privacy Policy also describes the choices you can make about how we collect and use your personal data.
This Privacy Policy does not apply to information collected on any other website or application, such as those operated by a third party or, except as otherwise disclosed herein, any affiliate or subsidiary of the Company, that may link to, or be accessible from, the Website. See “Links to other websites” below.
Note to Residents of California: Further information for your specific region is outlined in the “California” section below.
1. Who are we?
2. What information do we collect?
3. Who are the intended users?
4. How do we use this information?
5. How can you access your information?
6. How do we protect your information?
7. Do we disclose your information to others?
8. Can I unsubscribe?
9. How do we protect a child’s privacy?
10. Links to other websites
11. Text Messages
12. Changes to our Privacy Policy
13. Contact us
1. Who are we?
We are Sandro (“Sandro”) brand operated by SMCP located in the United States at 44 Wall St, 12th Fl, New York, NY 10005.
2. What information do we collect?
We collect data that you voluntarily provide on the Website through transactions, user registration on the Website, surveys, sweepstakes, or contests; that you provide to our sales associates in our Company-owned or affiliated stores; or through phone, e-mail, mail and fax interactions or paper registrations that you submit to us. In the event we conduct surveys or run a contest or sweepstakes, a set of rules or terms governing the survey, contest or sweepstakes will be provided – please read such rules carefully before participating in or entering any survey, contest or sweepstakes relating to this Website.
We may collect and store two types of information: "personal information" and "automatic information".
"Personal information” is information by which you may be personally identified including, but not limited to, your name, gender, billing address, shipping address, email address, telephone number, date of birth or age, any personal preferences you choose to provide, transaction details such as style, size, price, discount, date, store, and an assigned password to protect your privacy.
"Automatic information” is information that we collect through automatic data collection technologies whenever you interact with or navigate through the Website, such as your IP address, the type of computer you use, its operating system, and the web browser you use. An IP address is a number assigned to your computer when you connect to the Internet. Each time you visit this Website, our web server may automatically recognize and collect this information.
Automatic information also includes "cookies" and "web beacons." A "cookie" is a small amount of data that is sent to your browser from a web server and stored on your computer's hard drive. Among other things, cookies provide a means for us to keep track of your online patterns and preferences. By understanding which areas of the website you visit, cookies allow us to present information, products and services that are of personal interest. A cookie will not allow us to learn any personal information (such as your real name and address) that you have not otherwise disclosed. Most browsers are initially set up to accept cookies. You can change your browser so that it will not automatically accept cookies. However, if you do so, it is possible that some portions of the Website may not function as intended. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. "Web beacons", also known as clear GIFs or single-pixel GIFs, are small image files that we may place on web pages within this Website and within web-based email newsletters that we send. Working in conjunction with cookies, web beacons allow us to accurately count the number of unique users who have visited a specific web page and the number of times those web pages are displayed. We can also use web beacons to let us know how many people opened a web-based email newsletter.
We do not collect personal information automatically, however, we may associate automatic information with your personal information. In the event of such association, such automatic information will be considered personal information.
Some content or applications, including some advertisements on the Website are provided by third-party advertisers. Please note that our advertisers may also use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about our users when they use the Website. We do not have control over third-party advertisers' tracking technologies or practices or how they may be used. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. If you have any questions about an advertisement or other targeted content, you should contact the responsible advertiser directly.
By accessing or using the Website, you acknowledge, understand and agree to be bound by the terms of this Privacy Policy and you consent to the collection and use by us of the information about you as described herein. Please do not submit your personal information if you do not want it to be collected, used, and disclosed as described in the Privacy Policy.
3. Who are the intended users?
This Website is hosted and operated in the United States, pursuant to the applicable laws in the United States, and is only intended for users who are located in the United States of America. By providing personal information through the use of this Website, you understand and consent to the collection, maintenance, processing and transfer of such information in and to the United States and waive any claims that may arise under applicable foreign laws.
4. How do we use this information?
We use this information to provide the products and services that you have ordered or requested, to confirm, process and ship sales transactions, to send order and shipping confirmations, to contact you with questions or communications about your order, or to respond to your customer service inquiries.
We also use this information to enhance and personalize your shopping experience, both online and in our stores, to communicate with you for marketing and promotional purposes (including via targeted postal pieces, phone messages, newsletters, or emails); to gauge the effectiveness of such promotional communications; to administer, analyze, and improve the effectiveness of our Website; to document our business activities; for archival and record retention purposes. We also use this information to carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
We may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with website or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links:
https://rakutenadvertising.com/legal-notices/services-privacy-policy/
https://rakutenadvertising.com/legal-notices/subject-requests/
Under no circumstances do we want to receive confidential or proprietary information or trade secrets through this Website. Any such information, materials, suggestions, ideas or comments sent to us will be deemed non-confidential, and by submitting it, you are granting us an irrevocable and unrestricted license to use, modify, reproduce, transmit, display and distribute it for any purpose whatsoever, with no payment or other compensation to you.
5. How can you access your information?
You may access and edit the personal information that is stored in your user account on this Website by signing or logging in on the Website. Simply click on "Login" or "My Account" from the home page and enter your email address and password to access your information. You can request password help at any time by clicking on the "Forgot your password?" link, at which time we will email your password to the associated email address. Currently, we do not provide online access to information that you provided to us offline, for example at stores. You may also request to access, correct or delete personal information that you have provided to us at any time from our customer service representatives or by contacting us using the contact information below.
California residents may have additional personal information rights and choices. Please see “Privacy Notice for California Residents” for more information.
6. How do we protect your information?
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. When you place an order on the Website, Secure Socket Layer Technology ("SSL") encryption technology is utilized to protect your personal information during data transport. Please note that e-mail is not encrypted and is not considered to be a secure means of transmitting credit card information. While we strive to protect your personal information, we cannot guarantee or warrant that such information, during transmission through the Internet or while stored on our system or otherwise in our care, as the case may be, will be completely secure. Therefore, any transmission of personal information is at your own risk. We shall have no liability for disclosure of your personal information due to errors, omissions or unauthorized acts of third parties during or after transmission.
When you create an online account on the Website and become a registered user, you will be asked to provide an accurate email address and create a password. You are responsible for keeping this password confidential and are urged (i) not to share your password or account information with others, (ii) to use a secure web browser, and (iii) to change your password from time to time. If you wish to cancel a password, or if you become aware of any loss, theft, or unauthorized use of a password, please contact us as set forth below.
7. Do we disclose your information to others?
All of the information that we collect may be shared among our subsidiaries and affiliates. We maintain a central database of customer information collected via online and offline sources. When you establish or update your customer profile information with us, whether through a purchase, becoming a registered user of the Website, modifying your online account, or signing-up for promotional materials at the Website, our stores, through a customer service representative, or in any other communication you may have with us, we will update your customer profile information on the database.
Except as otherwise described in this Privacy Policy, we do not sell, rent or trade with third parties any personal information you provide to us online or at our stores, nor do we share such information with third parties. We may disclose personal information about you to third party service providers that act on our behalf and who agree to maintain the confidentiality of such information in accordance with this Privacy Policy and use the information only in connection with the services they provide. These third parties may provide a variety of services to us including, without limitation, processing credit card payments, providing website hosting and services related to storage and/or analysis of data, fraud protection and credit risk reduction, assisting us in fulfilling your transactions and customer service inquiries, updating your customer profile information in the database, marketing and promotional material distribution, assisting in data collection, or fulfilling your request to unsubscribe from our emails, newsletters and/or other promotional materials. We do not authorize such third party service providers to make any other use of your information.
We may use and/or disclose to others aggregate information about your demographics and use of our Website in a manner that does not reveal your identity.
We may disclose personal information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may have breached our Terms of Use or who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, or those of other users of our Website, or anyone else who could be harmed by such activities. We may also disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request.
We may transfer or disclose personal information in the event that we and/or our subsidiaries or affiliates engages in a business transition, such as a merger, acquisition by another company, divestiture, restructuring, the sale of a business unit or assets, or other “change of control” transaction. In such transactions, personal information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing privacy policy.
8. Can I unsubscribe?
Yes. We honor requests to unsubscribe or “opt-out” from receipt of emails, newsletters and/or other promotional materials (including for emails that we permit other companies to send to their own list of customers or subscribers). There are several ways in which you can tell us whether or not you want to unsubscribe or “opt-out” from receiving promotional communications from us or from certain uses of your personal information. For example, (1) in emails you receive from us, you will have the opportunity to unsubscribe or “opt-out” from receiving future promotional emails from us, or (2) when you become a registered user of the Website or when you access your online account thereafter, you may have the opportunity to make or change your selections in this regard. Please note that you may continue to receive emails, newsletters and/or other promotional materials from us and/or our subsidiaries or affiliates until such requests become effective – we will endeavor to respond to such requests as soon as practicable. In the event you unsubscribe or “opt-out” from receiving promotional correspondence from us, we may still contact you in connection with your relationship with us, Website-related orders or transactions, and related communications with us.
9. How do we protect a child’s privacy?
This Website is a general audience site. We do not knowingly or intentionally collect or maintain personally identifiable information from children under the age of thirteen and no part of this Website is targeted to attract anyone under the age of thirteen. If we become aware that we have collected personally identifiable information from a user of the Website who is under the age of thirteen, we will remove that child's personal information from our files.
10. Links to other websites
While you are using this Website, you may be linked or directed to websites not operated by us, including separate websites operated by our affiliates or by unaffiliated third parties. For example, you might click on a link or banner ad that will take you from the Website to the website(s) of social networks (such as Facebook or Twitter), advertisers, sponsors or co-branding partners. We do not control websites that are operated by these persons and are not responsible for the information practices of such websites or the acts or omissions of such website’s operators. Please review the privacy policies of such websites and be advised that the practices described in this Privacy Policy do not reflect the practices regarding information collection, use and disclosure of linked websites or the owners or operators of those linked websites. For more information, please read our Terms of Use.
11. Text Messages
You may elect to receive text messages from us. When you sign up to receive text messages, we will send you information about promotional offers and more These messages may use information automatically collected based on your actions while on our sites and may prompt messaging such as cart abandon messages (IE Cookies). To the extent you voluntarily opt to have Text notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number or when you read a text message. You may opt out of receiving text messages at any time by texting “STOP” to our text messages. For more information about text messages, see our Terms and Conditions here.
12. Changes to our Privacy Policy
In the event of any changes to these terms for the processing of your Data, we will update our Privacy Policy. You will be notified of any material changes to our Privacy Policy on this page under “Last Update”, below. Your continued use of the Website on or after the date of any such changes or update(s) shall constitute your agreement to any such updated Privacy Policy. We therefore encourage you to refer to this policy on an ongoing basis so that you understand our current Privacy Policy.
13. Contact us
We welcome your comments regarding this Privacy Policy. Please send any concerns by email to customercare@cs-us.sandro-paris.com or by mail to: SMCP Customer Relations Privacy Policy 44 Wall St, 12th Fl, New York, NY 10005.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
This addendum supplements information contained in our Privacy Policy and applies solely to the processing of California residents' personal information. This addendum is intended to address certain relevant notice requirements of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA"). Certain terms used below have the meaning given in the CCPA.
1. Personal Information We Collect about You, Why We Collected It, and Source of Collection
Under the CPRA:
- “Collects,” “collected,” or “collection” means buying, renting, gathering, obtaining, receiving, or accessing any personal information pertaining to a consumer by any means. This includes receiving information from the consumer, either actively or passively, or by observing the consumer’s behavior.
In the preceding 12 months, we have collected the following categories of consumer personal information, for the business purposes indicated, and from the sources listed below:
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CATEGORY OF PERSONAL INFORMATION COLLECTED |
BUSINESS PURPOSE FOR COLLECTING AND USING PERSONAL INFORMATION |
SOURCE OF PERSONAL INFORMATION |
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Identifiers (include information such as name, address, email address, and Social Security number) |
Performing services on |
Directly from you – in person, by |
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Personal Information Classifications (include details like name, signature, address, phone number, education, and employment history) |
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
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Directly from you – in person, by telephone, text or email and/or via our website; Cookies on our website;
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Commercial Information (includes records of Client Services, financial data, and payment information) |
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
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Directly from you – in person, by telephone, text or email and/or via our website; Cookies on our website;
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Internet or Electronic Network Activity Information (includes data such as IP addresses, login information, browsing history, and interactions with websites, applications, or advertisement) |
Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer;
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Cookies on our website
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Geolocation Data (includes information regarding IP addresses and device locations used to determine general geographic location) |
Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer;
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Cookies on our website;
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Audio, Electronic, Visual, and Similar Information (includes call recordings, CCTV footage for safety and security purposes (e.g., office premises), and audio/video recordings of events, conferences, and meetings) |
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
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Directly from you – in person, by
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| Inferences Drawn from Other Personal Information (refers to profiles reflecting preferences, characteristics, psychological trends, behaviours, attitudes, intelligence, abilities, and aptitudes) | Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer; |
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To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services
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Directly from you – in person, by telephone, text or email and/or via our website.
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For short-term, transient use, including, but not limited to, non-personalized advertising.
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Cookies on our website.
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A legitimate interest is present when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
We only use sensitive personal information for the business purposes described above.
2. Categories of personal information we sold or shared, why we sold or shared it, and to/with whom
Under the CPRA:
- “Sell,” “selling,” “sale,” or “sold,’’ means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration.
- “Share,” “shared,” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.
- “Cross-context behavioral advertising” means the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s activity across businesses, distinctly-branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the consumer intentionally interacts.
In the preceding 12 months, we have not sold personal information in exchange for monetary compensation.
In the preceding 12 months, we have shared the following categories of personal information for the business purposes indicated, and to, or with the following categories of third parties:
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CATEGORY OF PERSONAL INFORMATION SHARED |
BUSINESS PURPOSES FOR SHARING PERSONAL INFORMATION |
CATEGORIESOF RECEIVING THIRD PARTIES |
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Identifiers (include information such as name, address, email address, and Social Security number) |
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider; |
Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies; |
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Personal Information Classifications (include details like name, signature, address, phone number, education, and employment history) |
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
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Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies; |
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Commercial Information (includes records of Client Services, financial data, and payment information) |
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
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Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies; |
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Internet or Electronic Network Activity Information (includes data such as IP addresses, login information, browsing history, and interactions with websites, applications, or advertisement) |
Providing advertising and marketing services, except for cross-context behavioural advertising, to the consumer;
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Our affiliates, including companies within the SMCP group; Other third parties we use to help us run our business, such as marketing agencies or website hosts; |
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Geolocation Data (includes information regarding IP addresses and device locations used to determine general geographic location) |
Providing advertising and marketing services, except for cross-context behavioural advertising, to the consumer;
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Other third parties we use to help us run our business, such as marketing agencies or website hosts; |
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Audio, Electronic, Visual, and Similar Information (includes call recordings, CCTV footage for safety and security purposes (e.g., office premises), and audio/video recordings of events, conferences, and meetings. |
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
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Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies;
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| Inferences Drawn from Other Personal Information (refers to profiles reflecting preferences, characteristics, psychological trends, behaviours, attitudes, intelligence, abilities, and aptitudes) | Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer; |
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We do not knowingly provide services to anyone under the age of 16 nor do we have actual knowledge that we sell or share the personal information of consumers under 16 years of age.
3. Categories of personal information we disclosed for a business purpose, why we disclosed it, and to whom:
In the preceding 12 months, we have disclosed the following categories of personal information for the business purposes indicated, to the following categories of third parties:
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CATEGORY OF PERSONAL INFORMATION DISCLOSED FOR A BUSINESS PURPOSE |
BUSINESS PURPOSES FOR DISCLOSING PERSONAL INFORMATION |
CATEGORIES OF RECEIVING THIRD PARTIES |
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Identifiers (include information such as name, address, email address, and Social Security number) |
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider; |
Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies; |
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Personal Information Classifications (include details like name, signature, address, phone number, education, and employment history) |
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
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Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies;
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Commercial Information (includes records of Client Services, financial data, and payment information) |
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
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Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies;
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Internet or Electronic Network Activity Information (includes data such as IP addresses, login information, browsing history, and interactions with websites, applications, or advertisement) |
Providing advertising and marketing services, except for cross-context behavioural advertising, to the consumer;
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Our affiliates, including companies within the SMCP group; Other third parties we use to help us run our business, such as marketing agencies or website hosts;
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Geolocation Data (includes information regarding IP addresses and device locations used to determine general geographic location) |
Providing advertising and marketing services, except for cross-context behavioural advertising, to the consumer;
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Other third parties we use to help us run our business, such as marketing agencies or website hosts;
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Audio, Electronic, Visual, and Similar Information (includes call recordings, CCTV footage for safety and security purposes (e.g., office premises), and audio/video recordings of events, conferences, and meetings) |
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
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Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies;
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| Inferences Drawn from Other Personal Information (refers to profiles reflecting preferences, characteristics, psychological trends, behaviours, attitudes, intelligence, abilities, and aptitudes) | Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer; |
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4. Your Rights under the CCPA
You have the right under the CCPA, to exercise, free of charge, the following rights:
- Right to Know. You have the right to request information about the personal information we have collected about you, including the categories of personal information, sources of collection, and the business purposes for collecting it.
You have the right to request information about the personal information we sold, shared or disclosed, including the categories of personal information, the categories of third parties to whom the information was sold, shared, or disclosed, and the business purposes for collecting, sharing or disclosing it. Additionally, you have the right to request specific pieces of personal information in a portable and structured format
- Right to Correct. You can request the correction of inaccuracies in your personal information.
- Right to Delete. In certain circumstances, you have the right to request the deletion or de-identification of your personal information. However, please note that this right does not apply in specific situations, such as when the information is necessary to provide services, fulfil a contract, protect security and rights, comply with legal obligations, or engage in research or other lawful uses.
- Right to Opt-Out. You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of cross-context behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.
SMCP processes opt-out preferences signals in a frictionless manner.
- Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to only use your sensitive personal for limited business purposes specified by law (e.g., providing you with services you request or preventing fraud, or for other purposes that don’t involve deriving your attributes, etc.). We only use sensitive personal information for such permitted purposes, so we do not have an opt-out.
5. How to exercise your rights
To exercise your rights, described above, you can:
- Call the toll-free number 1.866.814.1404 (excluding public holidays); or
- Write to Customer Care by selecting the "privacy" topic in the relevant webform in the Contact Us section of the Website; or
- Contact us directly at the address indicated above.
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly by phone or email, you will need to provide us with: (i) enough information to identify you; (ii) proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and (iii) description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
You may designate an authorized agent to exercise a right on your behalf. If you utilize an authorized agent to exercise a CCPA right, the following proof that the agent has been authorized to act on your behalf will need to be provided:
- Your written permission for the authorized agent to act on your behalf and separate verification of your identity; or
- Proof that the authorized agent holds a power of attorney to act on your behalf pursuant to Cal. Probate Code §§ 4121--4130.
6. No discrimination
If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.
7. Security and retention of your personal information
We use reasonable and appropriate measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the personal information we collect.
We will keep your personal information, including sensitive personal information, for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may retain your personal information for a longer period if there are 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.
To determine the appropriate retention period for personal information, we consider many factors, including the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
8. Do not track
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place.
9. Personal, family and household clients
As outlined in our Privacy Policy, California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email message to our email address below customercare@cs-us.sandro-paris.com with "Request for California Privacy Information" in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide you with a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the preceding calendar year, along with the third parties' names and addresses. Please note that not all personal information sharing is covered by Section 1798.83's requirements.]
10. Contact us
If you have any questions regarding this Privacy Notice For California Residents, and/or SMCP’s privacy and information practices, you can direct them to us by:
- Writing to Customer Care by selecting the "privacy" topic in the relevant webform in the "Contact us" section of the Website; or
- Contacting us directly at the address indicated above.
11. Conflicts
This Privacy Notice for California Residents is supplementary to and incorporated into our Privacy Policy. In the event of any conflict between this California Privacy Addendum and the Privacy Policy, the California Privacy Addendum shall prevail solely concerning personal information governed by California Privacy Laws.
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