OUR PRIVACY COMMITMENTS
PRIVÉ respects the privacy of every person who visits our websites or responds
to our interactive advertisements. This Privacy Statement outlines the information
PRIVÉ will collect and how we will use that information. This Statement will
also tell you how you can verify the accuracy of your personal information
submitted to PRIVÉ through our websites and interactive advertisements and
how you can request that we delete or update your personal information.
We've developed our privacy policy from industry guidelines and standards,
and local, national, and international laws and requirements. All privacy practices
and methods described herein only apply insofar as permitted by the applicable
standards, laws and requirements and as limited by the website or interactive
banner you are visiting.
INFORMATION COLLECTED AND HOW WE USE IT
WHAT WE COLLECT
PRIVÉ Products' primary goal in collecting personal information from you is to give
you a meaningful, enjoyable and customized experience while using our websites
and interactive banner ads, and to allow us to develop new products and services
which are relevant to consumers like you. Personal information also allows
us to provide services and features that most likely meet your needs, and to
customize our service to make your online experience smooth and efficient.
Personal information received from you online will only be used by the brand
to which you submitted your information, PRIVÉ Products, a purchaser of
the brand, and other PRIVÉ Products brands, except as otherwise required by law or as
PRIVÉ discloses to you when the information is collected.
a) Personal Information
When you visit PRIVÉ's websites or interactive advertisements, we will not
collect any personal information about you (including but not limited to your
name, address, telephone number, email address, and credit card number if you
place an order with us) unless you provide it to us voluntarily.
If you opt not to provide us with personal information you can still access
our websites; however you may be unable to participate in certain promotions
or receive product information offered through PRIVÉ's websites or interactive
advertisements
b) Aggregate and Statistical Data
PRIVÉ Products may collect certain aggregate data called web log information (such as
your web browser, operating system, pages visited, etc.) and use cookies when
you visit many of our web pages. For instance, when you visit one of our websites,
our webserver will automatically recognize some non-personal information, including
but not limited to the date and time you visited our site, the pages you visited,
the referrer (the website you came from), the type of browser you are using
(e.g. Netscape, Internet Explorer), the type of operating system you are using
(e.g. Windows '95 or Mac OS), and the domain name and address of your Internet
service provider (e.g. AOL).
Neither our cookies nor web beacons nor web log information collects any personal
information. They do not contain personal information such as your name or
email address. In some cases we may also collect information about you that
you voluntarily submit and which is not personal, such as general statistical
information like age, gender, household size, zip/postal code, preferences
and interests.
INFORMATION WE COLLECT
PRIVÉ Products does not require visitors to our websites to provide personal information
in order to obtain access to any of our sites. PRIVÉ Products collects personal information
(including but not limited to your name, address, telephone number, and email
address) from our visitors only on a voluntary basis.
You are in control of the personal information you provide to PRIVÉ Products online.
You can:
1. Ask for a copy of your personal information
2. Ask for your personal information to be corrected or updated
3. Ask us to remove your personal information from our records
To do this, please contact us using the links provided later in this statement.
PRIVÉ Products will use reasonable efforts to fulfill you request.
At some PRIVÉ Products sites you can order product samples, enter contests, vote in
polls or otherwise express an opinion, subscribe to one of our services such
as newsletters, or participate in one of our online forums or communities.
These programs require you to submit some information in order to participate.
These programs and the types of information required are described in more
detail below.
Registration/Subscriptions/Product Samples Requests: To fully use our websites,
visitors may need to register using our online registration forms, where visitors
will be required to provide us with their personal information. Visitors may
also be asked to select a user ID and password. Further, to register for certain
services or become a member of certain communities, we may ask visitors to
submit their name, email address, home address, and zip/postal code. In addition,
we ask for country of residence and age so that we can comply with all applicable
privacy regulations. You can further make choices about receiving email newsletters
and alerts from PRIVÉ brands. You can always decide not to receive or stop
receiving any email from PRIVÉ Products brands that you do not want.
Contests/Sweepstakes: PRIVÉ Products may run contests, sweepstakes and other promotions
on its Sites or through interactive banner ads. These events which may ask
you to provide personal information which is needed in order to administer
the contest, sweepstakes or promotions and to notify winners.
Referrals: Occasionally, visitors may have the opportunity to forward product
sampling opportunities or other information on the website to friends/relatives
or to send messages from our websites or interactive advertisements to friends/relatives.
This personal referral information you provide to facilitate this communication
is used on a one-time basis or stored only for analysis purposes, and is not
further used by PRIVÉ Products to recontact referred individuals, except in circumstances
where we obtain consent from the people you have referred to receive communications
from us.
Questionnaires, Surveys and Profile Data: PRIVÉ Products may occasionally ask visitors
to complete surveys and opinion polls about their interests, needs, and attitudes.
Surveys help us provide better services and products that meet customer needs.
Participation is completely voluntary and these surveys are optional.
Consumer Services and Contact Information: If you provide our consumer service
representatives with feedback on your experiences with our products/services
or otherwise submit questions to our consumer service representatives or webmasters,
you will be asked to supply personal information for our record keeping and
follow-up.
Employment Information: Personal information you may submit in connection with
employment inquiries will be used only for recruitment and future internal
consideration. It will be accessible solely by persons responsible for recruitment
for PRIVÉ entities. This information will be kept no longer than 2 years.
HOW WE USE YOUR INFORMATION a) Personal Information
We may use your personal information to contact you. For example, we may send
you marketing or promotional materials including emails or other information;
we may respond to your comments or requests for information; or we may contact
you if needed in the course of processing or shipping your order for products
or services offered through our websites. We may also enhance or merge personal
information with data obtained from third parties for the same purposes.
We also use personal information about you to improve our marketing and promotional
efforts; to statistically analyze site usage; to improve our content and product
offerings; and to customize our sites' content, layout and services. We may
also use your information to deliver information to you that, in some cases,
is targeted to your interests, such as targeted banners, new services and promotions.
We believe these uses allow us to improve our site and better tailor it to
meet our visitors' needs. PRIVÉ Products does not collect personal information automatically,
but we may combine non personal information collected automatically (e.g.,
through cookies) with your previously submitted personal information.
PRIVÉ Products occasionally sends visitors who have opted-in emails describing new products,
promotions or events. These services are optional and you may opt-out of these
services completely, at any time. We will only store your personal information
for a reasonable period of time.
b) Aggregate and Statistical Data
PRIVÉ uses web log information (such as your web browser, operating system,
pages visited, etc.) to help us design our website, to identify popular features,
and for other managerial purposes. However, web logs may be used if necessary
to help identify any person attempting to break into or damage our website.
We may share web log information with law enforcement agencies if we believe
that we have evidence of a violation of computer security or related laws.
DATA SHARING AND TRANSFER a) How We May Share Information
We will not share, trade or sell personal information of our visitors for use
by any business, other than the brand to which you submitted your information,
PRIVÉ Products, a purchaser of the brand, and other PRIVÉ Products brands, without
your consent. However, aggregated and statistical data from our visitors may
be shared with our partners. For example, we may let a partner know that
approximately "20,000
people visited a webpage regarding a specific joint promotion." If you
do provide us with consent to share your information with other companies,
we may share your information with companies who offer products and services
that may be of interest to you. These companies may then contact you directly
with product or sample offers, personalized offers and information, or to ask
for your feedback on products and programs that they think may be of interest to you.
Occasionally, we may share personal information from you (such as name, mailing
addresses and email addresses) with vendors, contractors or partners of PRIVÉ Products
in connection with services that these individuals or entities perform for
or with PRIVÉ Products. These vendors, contractors or partners are restricted from using
this data in any way other than to provide services for PRIVÉ, and they may
not share or resell this data. The services they provide for PRIVÉ Products include
mailing product samples, or contacting the winners of PRIVÉ Products contests.
PRIVÉ Products also reserves the right to share the information to respond to duly authorized
information requests of governmental authorities or where required by law.
b) Data Transfers
Your personal information will generally be stored in our PRIVÉ databases,
which are located in various geographies, including the United States and the
European Union. For easier processing of e-mail campaigns or other marketing
purposes, your personal information may however be sent, usually on a temporary
basis, to countries outside the United States or the European Union. PRIVÉ Products
data protection standards are the same, regardless of where your personal information
is stored.
PRIVÉ Products adheres to U.S./EU Safe Harbor principles. If you feel that Safe Harbor
privacy principles may have been violated by PRIVÉ Products, you may contact us with
your complaint.
COOKIES AND WEB BEACONS
When you view one of our websites or interactive advertisements, we may collect
some non personal information about you. The collection of this non-personal
information is done either through the "cookie" technology or with "web
beacons" (also called "single-pixel gif" or "web pings").
Neither our cookies nor web beacons nor web log information collects any personal
information.
a) Cookies
When you view one of our websites or interactive advertisements, we may store
some information on your computer. This information will be in the form of
a small text file, also called a "cookie". Cookies help us in many
ways to make your visit to our website more enjoyable and meaningful to you.
For example, cookies avoid you having to log in every time you come back to
one of our websites. They also allow us to tailor a website or advertisement
to better match your interests and preferences. Most browsers can be configured
not to accept cookies or to indicate when a cookie is being sent.
b) Web Beacons
Web beacons are site instrumentation that help us to determine, for instance,
whether a page has been viewed or not and, if so, how many times. When you
ask us to send you information on a promotion or a newsletter, we may use web
beacons to establish how many of the emails are actually opened. In general,
any electronic image viewed as part of a web page, including an ad banner,
can act as a web beacon.
Third party advertising networks that serve ads onto any PRIVÉ Products web site may
use cookies and/or web beacons in their advertisements. PRIVÉ Products retains no control
over such third party cookies and/or web beacons and does not have access to
the information related to third party cookies and/or web beacons.
CHOICE
Our sites allow you to choose to receive or stop receiving communications from
us. If you would like to be removed from PRIVÉ Products programs you enrolled in or
prevent further use of your personal information, please click on the link
below.
To Prevent Further Use of Your Personal Information - You will be asked for
your country of residence, then provided with a way to remove yourself from
PRIVÉ Products' online programs.
CHILDREN'S PRIVACY
PRIVÉ Products believes that it's especially important to protect children's privacy
online and encourages parents and guardians to spend time online with their
children to participate and monitor their Internet activity.
PRIVÉ Products respects all applicable national and international children's privacy
regulations.
PRIVÉ Products generally does not intend to collect personal information from children.
In the event it does, we will collect such information in accordance with local
laws and regulations on children's privacy. If we collect personal information
from children, we ask only for the information necessary to participate in
the program for which the child is registering.
Where appropriate, PRIVÉ Products will specifically instruct children not to submit
such information on our websites and/or will take reasonable steps to ensure
parental consent to such submission. For instance, we may ask for a visitor's
age, birthday, or birth year in order to determine whether or not the visitor
is a child. If the birthday or birth year entry reveals a child is under the
age limit as defined by the applicable local or national law, we will not allow
the child to continue without the guardian's consent. If a child has provided
us with personal information, a parent or guardian of that child may contact
us at the email address or address listed at the bottom of this Privacy Statement
if they would like this information deleted from our records. We will use reasonable
efforts to delete the child's information from our databases. We do not filter
advertisements or other content that children may view through our sites, and
they could receive content and materials from the Internet and/or advertising
that are inappropriate for children.
If you would like to contact us about your or your child's personal information,
or to find out how you can have your child's personal information removed from
our database, please see the Access To Your Information and Complaints section
later in this document.
DATA SECURITY AND RESPONSIBILITY
PRIVÉ is committed to keeping the data you provide us secure and will take
reasonable precautions to protect your personal information from loss, misuse
or alteration. Vendors, contractors, or partners of PRIVÉ Products who have access to
your personal information in connection with providing services for PRIVÉ are
required to keep the information confidential and are not permitted to use
this information for any other purpose than to carry out the services they
are performing for PRIVÉ Products. We use secure connections on our web sites to protect
credit card information during its transmission.
ACCESS TO YOUR INFORMATION AND COMPLAINTS
If you have submitted personal information to PRIVÉ Products through a PRIVÉ website
or interactive advertisement, or if someone else has submitted your personal
information through a PRIVÉ website or interactive advertisement you can:
a) Access, Correct, Update Your Personal Information
By clicking on this link and completing the instructions provided. You will
be asked for your country of residence so that we may direct you to the proper
contact for this service. PRIVÉ Products will use reasonable efforts to supply you with
the information you requested to access and to correct any factual inaccuracies
in this information.
b) Complaints
PRIVÉ Products is committed to working with consumers to obtain a fair and rapid resolution
of any complaints or disputes about privacy. Please send us your questions
or comments regarding our privacy practices by clicking on this
link, or send us a letter to:
PRIVÉ Products Privacy Team
C/o Customer Service
7250 Beverly Blvd., Suite 100
Los Angeles, CA 90036
PRIVÉ will be happy to respond to your questions and comments. Please feel
free to use your native language when contacting us at this address.
LINKS TO OTHER SITES
Some PRIVÉ websites may contain links to other websites. PRIVÉ Products is not responsible
for the privacy practices or the content of such websites. We recommend you
carefully read the privacy policies of each site you visit.
YOUR ACCEPTANCE OF OUR PRIVACY PRACTICES
By using this website or any other PRIVÉ Products website or interactive banner ads,
you signify your acceptance of this Privacy Statement, and you adhere to the
terms and conditions posted on the website. If you do not agree with any of
these terms in, please do not use this site or submit any personal information.
This clause is not enforceable in member states of the European Union.
Please check back for updates to this Privacy Statement or our Executive Summary.
