Club Monaco US Privacy Notice
Effective Date: October 28, 2011
Club Monaco respects your privacy. Consistent with our commitment to providing you a satisfying and helpful shopping experience, we have found that collecting information from and about you through ClubMonaco.com, including our mobile website (the “Site”), and our Club Monaco stores (the “Stores”), helps us to better understand the products and services that are the most helpful to you. Our Privacy Notice describes the types of information we gather online and in our Stores and how we use, disclose and otherwise manage this information. Please read this Privacy Notice carefully.
By accessing the Site and providing information to us when shopping in our Stores, you agree to be bound by this Privacy Notice. This Privacy Notice may be updated from time to time. Accordingly, you should check the date of this Notice (which appears at the top of this page) and review any changes since the last version. Your continued use of the Site following any modifications demonstrates your agreement to such changes. If at any time you do not agree to the terms of this Privacy Notice, please do not use this Site or provide us with personal information when shopping in our Stores.
Collection and Use of Information
Club Monaco, or a third-party service provider acting on our behalf (“Service Provider”), may collect and use information from and about you as described below.
Club Monaco may collect personal information from you in various ways, including when you (1) order products, gift cards or services from us; (2) register with us on our Site to shop or participate in our online community; (3) provide your information to us in a Store; (4) sign up for newsletters, email or other communications from Club Monaco; (5) participate in surveys, contests, sweepstakes or promotions; (6) utilize our Email to a Friend feature; or (6) request information from us or otherwise contact us. The personal information we collect may include your name, email address, mailing address, telephone number, mobile telephone number, credit card number, birthday, gender and income.
We use information from and about you: (1) to fulfill orders, provide services and communicate with you; (2) to improve your shopping experience and to communicate with you about our products and services; (3) to respond to your inquiries; (4) to make promotional and marketing offers to you, and help us target specific products and services to you; and (5) to help us develop and improve our Site and Stores and tailor our Site and Stores to your interests.
Additionally, Club Monaco may combine your personal information with personal and nonperson information we receive from and about you from other online and offline sources.
Club Monaco may collect nonpersonal information from you, including—but not limited to—your browser type, operating system, Internet Protocol (IP) address, domain name from which you access the Site, service provider and mobile-device identifier, as well as information about your browsing behavior, such as the date and time you visited the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, the number of times you return to the Site and other Site usage data.
We use this information: (1) to review the usage and operations of our Site and services; (2) to address problems with our Site, our business or our products and services; and (3) to protect the security or integrity of the Site and our business.
For example, we use a service provider to help us measure the effectiveness of our advertising and how visitors use our Site. If you do not want to help us learn how to improve our Site, products, offers or marketing strategy, you can opt out of this Site analysis tool by clicking here.
Cookies and Web Beacons
A cookie is a small data file that sites often store on your hard drive when you visit the Site. Club Monaco may place cookies on your computer to collect information about your visit to the Site and to improve Site functionality. For example, we may place cookies on your computer to understand which pages of the Site you’ve visited, determine which areas and features of our Site are most popular, learn how search engine referral is working effectively, provide unique user identification, preserve the contents of your shopping bag between your visits, and obtain product browsing and purchasing information.
Sharing Information With Third Parties
Club Monaco does not share, sell or trade your personal information gathered online with third parties for their marketing purposes, except with your consent or as described in this Privacy Notice. Further, Club Monaco does not contribute to or participate in cooperative databases, which give third parties access to such personal information.
We may share your information with our service providers that provide internal business, professional or technical support functions for Club Monaco.
Club Monaco may share your personal information if such action is required for Club Monaco or any of our service providers to comply with any valid legal process, such as a subpoena, search warrant, statute or court order, or any valid administrative or investigative request from a law-enforcement agency. In addition, we may share your personal information if we or any of our service providers believes that such disclosure is necessary to address any unlawful acts or acts that may endanger the health or safety of another customer or of the general public.
Club Monaco may also share nonpersonally identifiable or anonymous information about you, such as age, gender, types of products viewed, frequency of Store visits, Site pages you access most frequently or search terms you enter with third parties. For example, Club Monaco may provide a third party with such information as the number of people who shopped at our Site during a specific time period or the number of people who shopped at our Stores and meet certain demographics (e.g., age or gender) during a specific time period. This nonpersonally identifiable or anonymous information does not personally identify a specific visitor to our Site or Stores.
During the normal course of our business, Club Monaco may sell or purchase assets. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties.
Protecting your order information is a priority for us. We have taken certain physical, administrative and technical steps to safeguard the information we collect from and about our customers and Site visitors. For example, we use Secure Sockets Layer (SSL) technology to protect the security of your online order information. While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.
If you prefer not to receive marketing emails from Club Monaco, please click on the unsubscribe link within any marketing email you receive from us. If you prefer not to receive marketing mail via the mail carrier, please let us know by sending a request to:
Senior Director, Database Marketing
625 Madison Avenue, 7th Floor
New York, NY 10022
Please be sure to include in any email or postal mail your full name, email address, postal address and any message. Please note that such requests may take up to ten (10) days to become effective.
Children and Privacy
Club Monaco is concerned about protecting children’s privacy. We encourage parents and guardians to spend time with their children online and to be familiar with the sites their children visit. Our Site is not directed to children under the age of 13, and we do not knowingly collect any personal information from children under the age of 13. If we become aware that a customer is under the age of 13 and has registered without prior verifiable parental consent, we will remove his or her personal information from our files.
Links to Other Sites
Club Monaco US, LLC (“Club Monaco”) respects your concerns about privacy. Club Monaco has certified that it abides by the Safe Harbor privacy principles as set forth by the U.S. Department of Commerce regarding the collection, storage, use, transfer and other processing of Personal Data transferred from the European Economic Area (“EEA”) or Switzerland to the United States. This Policy outlines Club Monaco’s general policy and practices for implementing the Safe Harbor privacy principles for Consumer Personal Data.
For purposes of this policy:
“Consumer” means any natural person located in the EEA or Switzerland who provides Personal Data to Club Monaco on or through the Site.
“Personal Data” means any information that (i) is transferred to Club Monaco in the U.S. from the EEA or Switzerland, (ii) is recorded in any form, (iii) relates to an identified or identifiable Consumer, and (iv) can be linked to that individual.
“Site” means www.clubmonaco.com.
Club Monaco's Safe Harbor certification can be found at https://safeharbor.export.gov/list.aspx. For more information about the Safe Harbor principles, please visit http://www.export.gov/safeharbor. For more information about Club Monaco’s processing of Personal Data collected from Consumers on www.clubmonaco.com, please visit Club Monaco's U.S. Privacy Notice.
How Club Monaco Obtains Personal Data
Club Monaco collects Personal Data from Consumers who visit Club Monaco’s Site and provide Personal Data on or through the Site. Consumers may provide Club Monaco with payment card and other information related to purchases made on or through the Site. In addition, to subscribe for Club Monaco email updates, Consumers may supply Personal Data such as name, email address, mailing address, telephone number, gender and date of birth.
Club Monaco uses this Personal Data to (1) fulfill orders, provide services and communicate with Consumers; (2) improve Consumers’ shopping experience and communicate with them about Club Monaco’s products and services; (3) respond to Consumers’ inquiries; (4) make promotional and marketing offers to Consumers, and help target specific products and services to Consumers; and (5) help develop and improve the Site and tailor the Site to Consumers’ interests.
Club Monaco also may collect Personal Data about Consumers through automated technologies (such as cookies) used in connection with the Site. Club Monaco uses information collected through automated technologies as described in the U.S. Privacy Notice.
Club Monaco’s practices regarding the collection, storage, use, transfer, and other processing of Personal Data comply, as appropriate, with the Safe Harbor principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight.
Club Monaco provides information in its U.S. Privacy Notice available at http://www.ClubMonaco.com/helpdesk/index.jsp?display=safety&subdisplay=restrictions#restrictions and in this Policy regarding its practices related to Personal Data collected on the Site, including the purposes for which Club Monaco collects and uses such information. Relevant details also may be found in privacy notices pertaining to specific data processing activities.
Club Monaco offers Consumers the opportunity to choose whether Club Monaco may (i) disclose their Personal Data to certain third parties or (ii) use their Personal Data for purposes incompatible with the purposes for which the information was originally collected or subsequently authorized by the individual. Consumers may contact Club Monaco as indicated below regarding the company’s use or disclosure of their Personal Data.
Club Monaco may disclose Personal Data without offering an opportunity to opt out (i) to service providers the company has retained to perform services on its behalf, (ii) if it is required to do so by law or legal process, (iii) to law enforcement or other government authorities, or (iv) when Club Monaco believes disclosure is necessary to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity. Club Monaco also reserves the right to transfer Personal Data in the event it sells or transfers all or a portion of its business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a sale or transfer occur, Club Monaco will use reasonable efforts to direct the transferee to use the Personal Data in a manner that is consistent with Club Monaco’s privacy policies. Club Monaco uses Personal Data only for the purposes indicated in its U.S. Privacy Notice or this Policy unless it has a legal basis, such as consent, to use it for other purposes. To the extent required by law, Club Monaco obtains prior opt-in consent at the time of collection for the processing of Personal Data for marketing purposes.
Onward Transfer of Personal Data
Club Monaco may share Consumer Personal Data with third parties as indicated in the “Choice” section above. Except as permitted or required by applicable law, Club Monaco requires third parties to whom it discloses Personal Data and who are not subject to the European Union Data Protection Directive 95/46 or an adequacy finding to either (i) subscribe to the relevant Safe Harbor principles or (ii) contractually agree to provide at least the same level of protection for Personal Data as is required by the relevant Safe Harbor principles.
Where appropriate, Club Monaco provides Consumers with reasonable access to the Personal Data Club Monaco maintains about them. Club Monaco also provides a reasonable opportunity for Consumers to correct, amend or delete that information where it is inaccurate, as appropriate. Club Monaco may limit or deny access to Personal Data where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Safe Harbor principles. The right to access Personal Data also may be limited in some circumstances by local law requirements. Consumers may request access to their Personal Data by contacting Club Monaco as indicated below.
Club Monaco takes reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Club Monaco takes reasonable steps to ensure that the Personal Data the company processes are (i) relevant for the purposes for which they are to be used, (ii) reliable for their intended use, and (iii) accurate, complete and current. In this regard, Club Monaco depends on its Consumers to update and correct Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized by the individuals. Consumers may contact Club Monaco as indicated below to request that Club Monaco update or correct relevant Personal Data.
Enforcement and Oversight
Club Monaco has established procedures for periodically verifying implementation of and compliance with the Safe Harbor principles. Club Monaco conducts an annual self-assessment of its Personal Data practices to verify that the attestations and assertions the company makes about its privacy practices are true and that the company’s privacy practices have been implemented as represented.
Consumers may file a complaint with Club Monaco in connection with the processing of their Personal Information under the Safe Harbor principles. Club Monaco will cooperate with the American Arbitration Association in accordance with its applicable commercial rules to address individuals' complaints regarding privacy issues. Club Monaco will take steps to remedy any issues arising out of a failure to comply with the Safe Harbor principles. Please contact Club Monaco as specified below to address any complaints regarding the company’s Personal Data practices.
How to Contact Club Monaco
Club Monaco US, LLC
c/o Ralph Lauren Corporation
Attention: Chief Privacy Officer
625 Madison Avenue
New York, New York 10022
Club Monaco US, LLC
c/o Ralph Lauren Europe SARL
Attention: Marco Kerschen
8 Chemin de Blandonnet