Club Monaco US Privacy Notice

Effective Date: January 6, 2014

Club Monaco respects your privacy. Our Privacy Notice describes the types of information we obtain through ClubMonaco.com and our mobile website (the “Site”), in our Club Monaco stores (the “Stores”) and in connection with other activities and features. We also describe how we use, disclose and otherwise manage this information. 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.

Personal Information

Club Monaco may collect your personal information 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; (6) request information from us or otherwise contact us, or (7) interact with our social media features. 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; (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 nonpersonally identifiable information we receive from and about you from other online and offline sources.

Information We Collect By Automated Means

When you visit our Site, we (and our Service Providers) may collect certain information by automated means, using technologies such as cookies, web server logs, web beacons and JavaScript.

Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies Please note, however, that without cookies you may not be able to use all of the features of our Site.

In conjunction with gathering information through cookies, our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs also may record information such as the address of the web page that referred you to our Site and the IP address of the device you use to connect to the Internet. They also may log information about your interaction with the Site, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons,” which are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the Site. Cookies or web beacons may also be used to let us know if you have opened an email from us. Both we and others (such as our Service Providers or advertising networks) may collect personal information about our visitors’ online activities over time and across third-party websites.

We may use third-party web analytics services on our Site, such as those of Adobe Analytics and Google Analytics. These Service Providers help us analyze how users use the Site. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these Service Providers. To learn more about opting out of these activities, please click here and here.

The providers of third-party plug-ins on our Site, such as a Facebook “Like” button, may use automated means to collect information regarding your use of the Site and your interactions with the plug-ins. This information is subject to the privacy policies or notices of the plug-in providers.

Interest-Based Advertising

On our Site, we may collect information about your online activities for use in providing you with advertising about products and services tailored to your individual interests. This section of our Privacy Notice provides details and explains how to exercise your choices.

You may see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. To learn how to opt out of ad network interest-based advertising, click here.

Using cookies, we utilize Google AdWords remarketing service, Google Display Advertising (such as Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting) and Criteo to (1) show you our ads on other websites based on your prior visits to our Site, and (2) better understand our ad impressions and use of ad services. In connection with the Google Analytics Demographics and Interest Reporting service, we may use data from Google’s interest-based advertising or third-party audience data (such as age, gender and interests) with Google Analytics to understand and improve our marketing campaigns and Site content.

You can opt out of Google AdWords remarketing service and Google Analytics for Display Advertising by clicking here.To opt out of Criteo, click here.Our Site is not designed to respond to “do not track” signals received from browsers.


Sharing Information With Third Parties

Club Monaco does not share, sell or trade your personal information gathered online or in Stores 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 to comply with any valid legal process, such as a subpoena, search warrant, statute or court order, or any administrative or investigative request from a law-enforcement agency. In addition, we may share your personal information if we believe that such disclosure is necessary to address any unlawful acts or acts that may endanger the health or safety of a 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. Information collected through third-party plug-ins and widgets on our websites (such as information relating to your use of a Facebook “Like” button) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and Club Monaco is not responsible for those providers’ information practices.

If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us as specified below.

Club Monaco reserves the right to transfer personal information 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 information in a manner that is consistent with Club Monaco’s privacy policies.


Security

We have taken certain physical, administrative and technical steps to safeguard the personal 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.


Information Removal

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 from the time of receipt to become effective.


Transfer of Personal Information to Other Countries

Club Monaco may transfer the personal information we collect about you to countries other than the country in which you originally provided it. These countries may not have the same data protection laws as the country in which you provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Notice.

Club Monaco is certified under the Safe Harbor privacy framework set forth by the U.S. Department of Commerce regarding the collection, storage, transfer, use and other processing of personal information transferred from the European Economic Area or Switzerland to the United States. Click here to view our Safe Harbor Privacy Policy.


Links to Other Sites

This Site may contain links to third-party websites, which may have privacy policies that differ from our own. These links are provided solely for the convenience of our Site visitors. We are not responsible for the content or privacy practices of such websites. We encourage you to review the privacy policies and terms of use of any third-party websites or services.


Club Monaco: Safe Harbor Privacy Policy

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.

Notice

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.

Choice

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.

Access

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.

Security

Club Monaco takes reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity

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 JAMS in accordance with the JAMS Safe Harbor Program, which is described on the JAMS website at http://www.jamsadr.com/safeharbor/, 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

To contact Club Monaco about questions or concerns about this Safe Harbor Privacy Policy or Club Monaco’s practices concerning Personal Data, please write to:

Club Monaco US, LLC
c/o Ralph Lauren Corporation
Attention: Chief Privacy Officer
625 Madison Avenue
7th Floor
New York, New York 10022

or

Club Monaco US, LLC
c/o Ralph Lauren Europe SARL
Attention: Marco Kerschen
8 Chemin de Blandonnet
1214 Vernier
Switzerland