PRIVACY POLICY AND COOKIES POLICY
SCOPE AND CONSENT
This Privacy Policy applies to information that J Choo USA, Inc. which is located at 11 West 42nd Street, Floor 27, New York, NY 10036 (referred to herein as "Jimmy Choo", "we", "us", or "our") “Jimmy Choo”, “we,” “us” or “our”) collects, uses, shares or otherwise processes that identifies, relates to, describes, or can otherwise be associated with individuals (individually and collectively referred to herein as “you”, “your” and “yours”) (“Personal Information” or “PI”) in connection with the following customer facing operations in the United States and Canada (individually, "Service" and collectively, "Services"):
in one of our stores, at one of our events or otherwise offline;
through interactions with our customer service representatives in store, online or over the phone/mobile;
in connection with our marketing mail or e-mail lists, store communications; or
on or through our websites (usjimmychoo.com (or any subdomain thereof)), native mobile applications or other internet websites, applications or services (including social media, surveys, sweepstakes, contests, product rating submissions or reviews) from which you are accessing this version of the Privacy Policy or which link directly to this version of the Privacy Policy (each referred to herein as a the "Website", the "Site,"and collectively, the "Sites").
This Privacy Policy provides you details about the PI we collect, use, share or otherwise process, the purposes for which we use that PI, to whom and for what purposes we may disclose that PI, how we protect that PI, the rights and choices you have with respect to that PI, and how you can reach us to get answers to your questions.
Importantly, we use service providers to help us operate, administer and provide our various Sites and Services. Thus, where relevant, our service providers collect, use and otherwise process your PI and Site Usage information on our behalf. As such, the use of the terms “we,” “us,” or “our” throughout this Privacy Policy shall be interpreted to include our service providers acting on our behalf.
Where certain states, provinces, geographic regions or territories require additional terms, you will see those additional location-specific or region-specific terms addressed and they shall only apply to customers who are residents of those specific locations.
Additional privacy notices may be provided by us to you in connection with certain activities, programs, offerings, or websites. We may also provide additional notice, prior to or at the time of collection of PI, where new purposes for processing your PI arise or to clarify our practices regarding your PI.
As indicated in the General Terms and Conditions of Sale, Jimmy Choo manages the Website's online store, and Stores, which involves managing activities such as processing orders, delivering products, and processing returns as well as other activities necessary to facilitate the sale of products via the Website and in Store orders. To perform these activities, Jimmy Choo may process users' information (including name, address, and credit card information).
By using the Website, or Store, each user consents to our collection, use, disclosure, retention, storage, and transfer of his/her information as described in this Privacy Policy, the Terms and Conditions of Use and Terms and Conditions of Sale (https://us.jimmychoo.com/en/customer-services/terms-and-conditions-of-sale.html).
The data controller of the Sites is J. Choo Limited, with registered office at 10 Howick Place, London, SW1P 1GW United Kingdom (Company Registered Number: 03185783) ("Jimmy Choo", "we", or "us"). Jimmy Choo is part of Jimmy Choo Group Limited (the “Group”).
OUT OF SCOPE OF THIS PRIVACY POLICY
Children's Privacy
The Sites are not directed or targeted to children under the age of sixteen (16) nor do we knowingly collect any PI from children under sixteen on the Website or in Stores. If you are under sixteen, do not provide your information to us or the Website. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at J Choo USA, Inc., 11 West 42nd Street, Floor 27, New York, NY 10036 or send an email to customercare.usa@jimmychoo.com.
Information Related to Employment or Business Dealings with Jimmy Choo
This Privacy Policy does not apply to information collected in the employment context or in a business context. To the extent required and applicable, such information is processed in accordance with a separate privacy policy/notice, which may be obtained either on the applicable portal or by contacting us to request a copy of the applicable policy/notice.
Third-Party Websites/Content
The Website may contain links (which may take the form of hyperlinks, widgets, clickable logos, plug-ins, images or banners) to, or content and other information from, websites or services operated by entities other than us (e.g., social media platforms). This Privacy Policy does not apply to such other websites or services, even those belonging to the Group which have their own Privacy Policies. Jimmy Choo does not own or control such content or information practices, and we recommend that you review their posted privacy policies so that you understand their relevant information collection, use, disclosure and processing practices.
COLLECTION OF DATA
We collect the following types of information (collectively "Data") in order to provide users with the use of and access to the Website and/or the services and features offered through the Website and in Stores as well as to help us personalize and improve users' experiences on the Website
Information we collect automatically: the computer systems and processing programs used to operate the Website automatically log certain data during their normal operation. This data includes, but is not limited to, device ID or unique identifier, device type, computer and connection information, statistics on page views, traffic to and from the Website, referring URL, Internet Protocol ("IP") address, standard web log information, and anonymous information collected through our use cookies and web beacons (collectively, "Surfing Data"). Some Surfing Data may allow us to identify users if the Surfing Data is associated with other data owned by third parties. Jimmy Choo collects Surfing Data in anonymous form exclusively for statistical purposes and for purposes of monitoring and enhancing the functioning of the Website and its content.
Information provided voluntarily by users:users may provide PI to us voluntarily, such as when contacting us (e.g., via email), interacting with the Website's features, making requests for services offered through the Website, or in Stores, completing forms to access protected sections of the Website, and purchasing products through the online store or in Stores. The PI voluntarily provided by users may include, but is not limited to, name, gender, email address, phone number, address, financial information (such as credit card and/or bank account numbers), as well as shipping, billing, and other information that users provide to purchase products through the Website and in Stores and any other PI that we may ask users to provide to use our services.
Users may be required to provide certain Data to us to create an account on the Website and to access the services and features offered through the Website, including the online store and the relevant e-commerce services and in Stores. Failure to provide Data to us may prevent a user from accessing and using the services and features offered through the Website, Sites or Stores.
The provision of Data to us for marketing purposes is always voluntary and optional. In the event a user elects to not provide Data to us for marketing purposes, that choice will have no effect on the user's ability to use the services and features offered through the Website, Sites or Stores.
COOKIES AND AUTOMATIC DATA COLLECTION TOOLS
The Website uses certain tools, such as cookies, to automatically collect Data. A cookie is a small text file that is used to store information on a user's Internet browser or a user's computer's hard drive when the user visits a website, such as the Website. A cookie does not contain information that identifies a person, but it allows for the linking of a user's computer to the information provided by the user on the Website (such as, for example, linking a user's IP address and other information about the user's experience on the Website to his/her preferences expressed while choosing services and purchasing products offered through the Website). Cookies are disseminated by servers and no one may gain access to information contained therein. The information stored in cookies is gathered directly and automatically by the Website and is processed in an aggregate and anonymous manner.
The use of cookies and other automatic data collection tools is necessary for the proper functioning of the Sites and their Services. In the event a user disables cookies, Jimmy Choo cannot ensure that all web pages of the Website will be displayed and/or that certain services will be supplied.
JIMMY CHOO uses the following types of cookies:
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 site will
FUNCTIONAL COOKIES These cookies enable the website to provide enhanced functionality and personalization. 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 services may not function properly.
PERFORMANCECOOKIES These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. 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 site, and will not be able to monitor its performance.
TARGETING COOKIES These cookies may be set through our site 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 information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
• Do Not Track signals. We do not currently respond to web browser "do not track" signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy. For more information about do not track, visit www.allaboutdnt.org.
• Third Party Cookies and Social Media Access Cookies and other tracking technologies are used by us or other third parties for the purpose of Targeted Advertising (please see the section on Targeted Advertising and Interest-Based Ads as well as our Cookie Notice, for further information). Additionally, please note that if you share content from the Site through third parties’ websites (i.e., social networking websites) you may be sent cookies from these websites, and your activity on our Website becomes subject to the privacy policies of those other websites/services. JIMMY CHOO does not control the setting of such cookies and encourage you to refer to the relevant third parties website for more information about their cookies and how to manage them, as well as their privacy policies and how they handle information to which they gain access as a result of your decision to log into our Website using your social media credentials.
You can, at any time, disable cookies or delete cookies already on your device by selecting the appropriate setting on your internet browser. Information on deleting or controlling cookies are available at www.AboutCookies.org. You can also revisit your consent choices, by clicking on the manage cookie button below. Please note that by deleting the Site cookies or disabling future cookies you may impede some functionalities of the Site or your possibility to interact with the Site.
Manage Settings
To learn more about Targeted Advertising in general, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org and the Digital Advertising Alliance (DAA) at www.aboutads.info. Additionally, the NAI and the DAA each offer consumers choices with respect to their privacy in the context of Targeted Advertising; please visit the NAI Consumer Opt Out page or the DAA’s Consumer Choice Tool for more information and resources. In Canada, please visit the DAAC’s Choice Tools.
DATA TYPES COLLECTED
Information we collect about you:
when you sign up to our newsletter or updates;
when you enter competitions and prize draws;
when you register with the Website, by phone or by email, or provide personal information;
which you complete, or which we complete at your request in-store via a store card;
when you place an order on our Website;
if you ask us to keep in touch with you;
if you ask us to receive personalized online content such as targeted advertising;
if you complete a survey or send us feedback about our products, Websites or Stores; or;
if you contact or correspond with us (for example, by phone, email or otherwise) to find out more about a product or our after sale care and support services, to report a problem with the Website or a product or for any other reason.
The personal information you give us may include your first and surname, title, gender, birthdate (day and month), email address, phone number, address, financial information (such as credit or debit card details), as well as shipping address, billing address, and any other information that you consider necessary to provide us with.
The information collected from you via our Website will be matched with PI you may have given us in our Stores. This is to help us ensure that the data we hold about you is kept accurate and up to date.
Categories of Personal Information
The PI we collect, use, share, or otherwise process about you depends on the Service(s) or the circumstances of your interaction with us.
The following are the categories of PI that we may collect or otherwise process:
Basic Identifiers including your name, home address, mailing address, billing address, shipping address, telephone numbers, email address, month and date of birth, gender,* signature, social media handle(s), or other similar identifiers.
Pseudonymous Identifiers or Device Information including IP Address, unique personal identifier, online identifier, hashed email, device identifier or other similar identifiers.
Commercial information including transactional information (including payment information, products or services purchased, obtained, returned, exchanged), virtual shopping cart details, clothing or footwear sizing, activity related to your Jimmy Choo account (including account log-in credentials*), contests, sweepstakes, other purchasing or consumer histories, or other similar preferences or tendencies.
Internet or Other Electronic Network Activity Information including browsing and search history on our Sites, social media activity, activity obtained in the course of providing you the products or Services, activity related to your interactions with our advertisements, emails or Sites.
Geolocation Data** including information to allow us to direct you to the appropriate website.
*Categories denoted with a (*) may be considered a Characteristics of Protected Classifications under California or Federal law or Sensitive Personal Information.
** Most mobile devices (and mobile apps) allow you to turn off location services if you do not want your location information collected.
Site Usage Information
“Site Usage Information” includes, but is not limited to: (i) your browser type, device type, carrier (if applicable), device address, operating system, IP address, domain name from which you accessed a Site, etc.; (ii) general location information, including region, continent, country, city, zip code and time zone; (iii) information about your browsing activities on and through a Site, such as (a) the date and time you visit one of the Sites, (b) the areas or pages of a Site that you visit, (c) the amount of time you spend viewing a Site or specific areas of a Site, (d) the number of times you return to a Site or a specific area of a Site, (e) the web sites or pages you visited prior to visiting a Site, (f) the websites or pages you visit after you leave a Site; (g) searches you have performed on the Site and on other websites that led you to our Site; (h) social plug-ins with which you have interacted on our Site; and (j) other similar Site usage data.
As part of the standard operation of the Sites, we collect certain Site Usage Information automatically or passively (see Cookies above) during your visit to our Sites. We consider Site Usage Information, on its own, to be non-personal information in nature, unless otherwise specified under applicable law. However, where we combine Site Usage Information with personal information about you in a manner that allows you to be reasonably identified, we would consider the combined information to be personal information and will treat that information accordingly.
Information other Jimmy Choo Group members collect about you
This is information we receive about you when you make a purchase in one of our Stores or concession Stores if you have completed a Store Personal Information card. These Stores will also provide us with a record of your transaction.
Information we receive from other sources about you
We work closely with third parties, for example, business partners, sub-contractors for technical, payment and delivery services, advertising networks, analytics providers and search information providers. If we receive information about you from them, we will always seek assurances that they are providing information to us in accordance with data protection laws and that they are transparent with you that they may share your data with us. We may use this information to update our records about you to keep them accurate.
USE OF DATA
Jimmy Choo may use Data for the following purposes:
PURPOSE WHAT WE MAY USE
To improve your experience in our stores and on the Sites including: to track your activities on the Sites; to track clicks, purchases and conversion; to recognize your computer or device so that you are able to save your preferences and stay logged in to the Site without having to re-enter your online account credentials; to preserve the contents of your shopping cart and remind you if you have left items in it, or to remind you if you left the Sites without adding items to your cart; and to otherwise enhance, monitor and analyze our site usage. Name, email address, postal address (including zip code), telephone number, date of birth, demographic information, order history, transaction information, IP address, preferences, site usage information
To process and fulfil your requests for products and services, and to keep you informed about your requests or orders Name, email address, postal address (including zip code), telephone number, payment information, transaction information
To administer and communicate with you about your account Name, email address, zip code, date of birth, order history, preferences, gender, transaction information, site usage information
To better understand you, including in order to provide: personalized content, tailored offers, personalized messaging, and targeted advertising on and in connection with our Sites, services and products; and a personalized shopping experience Name, email address, postal address (including zip code), telephone number, date of birth, order history, IP address, preferences, transaction information, site usage information
To contact you (via postal mail, email, SMS or any other method you have elected) with promotional materials about Jimmy Choo and our Sites, services, products and select partners Name, email address, postal address (including zip code), telephone number, preferences, demographic information, transaction information, site usage information
To contact you in connection with your relationship with us (such as via email in regards to your rating or review submissions) Name, email address, postal address (including zip code), telephone number, preferences, site usage information
For market research and to review, better understand and improve our advertising and emails, merchandise selections, content, services, programs, customer service, business planning, online and offline operations and overall shopping experiences Name, email address, postal address (including zip code), telephone number, date of birth, order history, IP address, transaction information, site usage information
To enforce our terms and conditions, and to protect the security or integrity of the Sites, our customers and our business in general (such as protecting against illegal or fraudulent activity, or misuse including cyber-attacks) Name, email address, postal address (including zip code), telephone number, date of birth, payment information, order history, transaction information, IP address, site usage information
To set up and manage your online account (including, for example, to send password reminders or notifications to changes to your account details) and to process your communication and privacy preferences Name, email address, postal address (including zip code), telephone number, date of birth, payment information, order history, preferences, site usage information
To process product returns, replacements, repairs and alterations; to resolve product issues (e.g., sending replacement products); and other customer service related issues Name, email address, postal address (including zip code), telephone number, payment information, order history, transaction information
To comply with legal requirements Name, email address, postal address (including zip code), telephone number, date of birth, order history, payment information, site usage information
Furthermore, with a user's freely given consent, Jimmy Choo may also use Data to create individual or group profiles (user profiling) and for marketing purposes, notably to send to users-via newsletters, emails, or text messages-information and updates on Jimmy Choo products or initiatives, offers, exclusive sales, promotional campaigns, and events and shows organized by Jimmy Choo or in which Jimmy Choo takes part, including invitations to those events and shows. To opt-out of receiving marketing messages from us, see the User’s Choice sections below.
We do not share users' Data to third parties for their marketing purposes without users' explicit consent. We may combine users' Data with information we collect from other sources and use it to improve and personalize our advertising and marketing to users. We do not sell users’ data to any third parties.
Targeted Advertising and Interest-Based Ads
Targeted Advertising (sometimes called online behavioral advertising, interest-based advertising or cross-context behavioral advertising) refers to the practice of collecting information about a user’s visits across multiple, unaffiliated websites or applications over time for the purpose of predicting their preferences or inferring their interest in order to show them ads that are more likely to be relevant. Typically, Targeted Advertising does not use information that is personally identifiable in a traditional sense, such as name, home address, etc. Rather, Targeted Advertising uses a combination of Pseudonymous Identifiers or Device Information along with Site Usage Information to match a user’s web browser or device with their online activity or interest categories. To learn more about Targeted Advertising in general, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org and the Digital Advertising Alliance (DAA) at www.aboutads.info. Additionally, the NAI and the DAA each offer consumers choices with respect to their privacy in the context of Targeted Advertising; please visit the NAI NAI Consumer Opt Out page or the DAA’s Consumer Choice Tool for more information and resources.
We use Google Analytics, Google Tag Manager and other technologies to better understand how you use our Sites across the various devices you use. We also utilize popular social network sites such as Meta, (Facebook, Instagram), Google, Tik Tok and Pinterest’s Targeted Advertising programs that match users of their respective platforms with users of our Sites or Services or with individuals that could have an interest in Jimmy Choo, based on their interactions or preferences across various other websites. To learn more about the Targeted Advertising programs of each social network we participate in and how you can manage your preferences for these programs directly with them, please review your account on the individual social network sites.
href="https://optout.networkadvertising.org/?c=1"target="_blank">NAI Consumer Opt Out page or the DAA’s Consumer Choice Tool for more information and resources.
Where specific states or regions provide additional privacy rights for their residents related to Targeted Advertising, we address those in the Your Privacy Rights section.
STORING AND PROTECTING DATA
Data collected will be stored and processed via an electronic system owned and managed by ENTSERV SCHWEIZ GMBH (a DXC Technology company) (“DXC”) with its registered office address at Neue Winterthurerstrasse 99, 8304 Wallisellen, Switzerland, a service company to the Jimmy Choo Group.
We protect users' Data by using technical and administrative security measures to reduce the risk of loss, misuse, and unauthorized access, disclosure, and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access controls. Please understand, however, that no system is perfect or can guarantee that unauthorized access or theft might not occur.
We take steps to ensure that the Data we collect is accurate and up to date, and we provide users with the opportunity to update their information as specified in this Privacy Policy. To provide use with updated information, contact us at customercare.usa@jimmychoo.com.
DATA COMMUNICATION AND DISCLOSURE
Data will be accessible by Jimmy Choo personnel, including employees and external contractors.
We may also share users' Data with:
RECIPIENT/PURPOSE OF DISCLOSURE WHAT WE MAY SHARE
To our service providers and suppliers who collect or use such information on our behalf (such as website or database hosting companies, address list hosting companies, email service providers, customer service providers, chat service providers, stylists, analytics companies, distribution companies, fulfilment companies, and other similar entities that help us to operate the Sites and Services and/or to provide functionality, content and services) Name, email address, mailing address (including zip code), telephone number, date of birth, demographic information, order history, IP address, payment information, preferences, transaction information, site usage information
As necessary, if we believe that there has been a violation of the Site Terms and Conditions, or any other Site or company policy, or if we have reason to believe that our rights or property, or the rights or property of any third party, may be or have been harmed. Name, email address, mailing address (including zip code), telephone number, date of birth, demographic information, order history, transaction information, IP address, payment information, preferences, site usage information
To provide information to and as required by local law enforcement agencies, other local government authorities, or otherwise required by law or to protect the rights and safety of our property, company and customers. Name, email address, mailing address (including zip code), telephone number, date of birth, demographic information, order history, preferences, transaction information, IP address, payment information
On a case by case basis, in the event that Jimmy Choo or substantially all of its assets are acquired by one or more third parties as a result of an acquisition, merger, sale, consolidation, bankruptcy, liquidation or other similar corporate reorganization, where your information may be one of the transferred assets. Name, email address, mailing address (including zip code), telephone number, date of birth, demographic information, order history, IP address, payment information, preferences, transaction information, site usage information
The aforementioned third parties that may receive users' Data will process that Data for the same purposes as specified above and in accordance with applicable law. Jimmy Choo will retain a list of the third parties with which Data is shared, which will be available upon request.
If users' Data will be used or disclosed for any purpose other than the purposes described in this Privacy Policy, they shall receive prior notification of such use or disclosure. Data will be transferred to Jimmy Choo Group companies located outside the United States or EEA only with a user's freely given consent.
LENGTH OF PROCESSING
Your PI is stored by us and/or our service providers for as long as necessary to fulfil the specific purposes described herein and to the extent permitted by applicable laws. When we no longer have a legitimate business purpose for your PI, or when you request that we delete your PI (except where we need to retain it in order to comply with a legal obligation, are permitted to retain it under applicable law or need to retain it to establish, exercise or defend legal claims), we will remove such information from our systems and records, which includes taking steps to anonymize it so that you can no longer be identified from it.
USERS' CHOICES
Users are entitled to obtain, at any time, a copy of their PI and to have any inaccuracies corrected. Where appropriate, users may have their PI deleted, corrected, amended, or completed. To do so, please or send an email to customercare.usa@jimmychoo.com, or write to us at J Choo USA, Inc., 11 West 42nd Street, Floor 27, New York, NY 10036
Users may revoke, at any time, consent to the delivery of commercial and promotional material via email by clicking the "unsubscribe" link in every commercial communication sent by Jimmy Choo and/or other companies of the Jimmy Choo Group.
YOUR PRIVACY RIGHTS
Residents of California, Colorado, Connecticut, Virginia, Utah and Nevada have the following rights in relation to our processing of your Data:
• Access to Your Personal Information: You have the right to confirm whether or not we have collected or otherwise process personal information about you and to request a copy of the personal information we collect about you, which we will provide back to you in electronic form.
• Data Correction: You have the right to request we correct factually incomplete or inaccurate personal information that we process about you. Note that you can make certain corrections to some of your personal information directly through your online account.
• Deletion of Personal Information: You have the right to request that we delete personal information that we process about you, except under certain circumstances (i.e., if we need to retain such PI in order to fulfil an order or a contract, comply with a legal obligation or to establish, exercise or defend legal claims).
• Process to Submit an Access, Correction or Deletion Request: To make such requests, please contact us at USprivacy@jimmychoo.com or call us at 1-800-913-4393. The Subject Access Request Form is available here.
•Authorized Agent: If you designate an authorized agent to submit a request on your behalf, you must have the authorized agent attach the signed form when they submit a Request Form on your behalf.
• Opt Out of Targeted Advertising/Opt Out of Sale/Share: Residents of the above