Privacy Policy
THOM BROWNE Inc. - Privacy Policy
Effective Date: November 28 2025
Last Updated: November 28 2025
Thom Browne Inc., together with its brands and subsidiaries (“Thom Browne,” “we,” “our,” or “us”), values your privacy. This Privacy Policy (“Policy”) describes how Thom Browne collects, uses, discloses, and otherwise processes personal information described in this Policy, as well as the rights and choices individuals have regarding such personal information.
For additional information about the privacy choices you have regarding your personal information, please review Section 5. Your Privacy Choices, as well as Section 11. Additional Privacy Information for Certain U.S. Residents, which includes additional information about privacy rights for residents of certain U.S. states. If you are a resident of California, please refer to Section 12. California Notice at Collection and Privacy Rights for information about the categories of personal information we may collect and your rights under California privacy laws. Furthermore, please review Section 13. Additional Privacy Information Notice for EU citizens for additional information for EU citizens on the basis of the EU Regulation 2016/679 (“GDPR”).
By using our Services (as defined below), you agree that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy, is subject to this Policy and our Terms and Conditions, available at Terms & Conditions, including their applicable terms governing limitations on damages and the resolution of disputes.
Table of Contents
1. Scope
2. Personal Information Collected
3. Purposes for Collecting and Processing Personal Information
4. Disclosures of Personal Information
5. Your Privacy Choices
6. External Links and Features
7. Children’s Privacy
8. Security
9. Changes to this Policy
10. Contact Us
11. Additional Privacy Information for Certain U.S. Residents
12. California Notice at Collection and Privacy Rights
13. Additional Privacy Information Notice for EU citizens
1. Scope
Except as otherwise described below, this Policy applies to our personal information processing activities including, but not limited to: visitors of our website where this Policy is posted, including Thom Browne Official Website (the “Site”); individuals who sign up for, or create an account with us to access and use certain features of our services; individuals who register for or participate in our events, surveys, and research conducted by us; individuals who subscribe to receive news, information, and marketing communications and other materials from us; current, former, and prospective business partners, and service providers; and individuals who communicate or otherwise interact or engage with us or the services available through our Site, or other online or in-store services (collectively referred to as the “Services”).
Additional Notices. Depending on how you interact or engage with us, we may provide you with additional or supplemental privacy notices with additional details about our privacy practices. These additional notices will control to the extent there is a conflict with this Policy, with respect to your personal information that is subject to that additional notice. For example, this Policy does not apply to the personal information we collect and process about job applicants and candidates for employment with us, or to employees or contractors in the context of our working relationship with them.
2. Personal Information Collected
We collect personal information directly from you, from third-party sources, and automatically through your use of the Services. To the extent permitted by applicable law, we may combine the personal information we collect from publicly available or third-party sources. The personal information we may collect varies depending upon your use of our Services and our interactions with you.
Personal Information Collected Directly. We may collect the following personal information directly from you:
- Contact Information. We may collect certain contact details and other personal identifiers such as your name, email address, phone number, address, or other similar identifiers, as well as any other information you choose to provide.
- Account and Profile Information. When you sign in or create an account in connection with our Services, you are required to provide certain information, including your name, email address, and password. You may also choose to provide additional details through your account, such as your phone number, date of birth, gender, and address.
- Purchases and Payments. When you make a purchase or payment through our Services, we may collect information such as payment type, billing information, shipping address, purchasing information, such as details of SKUs and products purchased, and any other financial or commercial-related information necessary for facilitating our Services. We do not collect or store payment card details.
- Communications and Interactions. When you email, call, or otherwise communicate or interact with us, including if you sign up for our mailing lists, complete forms on our Site, interact with our social media pages, submit content to the Services, or otherwise engage with us or our sponsored content, we may collect and maintain records of your contact details, communications and interactions, your posts or submissions, and our responses, if applicable. We may also collect information you submit through the live chat feature on our website; however, we do not retain information provided through chat after the session ends.
- Promotional Information. If you agree to receive marketing communications from us, we may collect your contact details, preferences, and if relevant, information about your account and profile, including the Services and features you use.
- Responses and Feedback. If you participate in surveys, questionnaires, or research activities or initiatives conducted by us, such as for market research, user satisfaction, or other similar purposes, we may collect your responses and feedback, and any other information you choose to provide.
- Events and Registration Details. We also may collect personal information related to your participation in our events, as well as other requests that you submit to us related to such events and our Services. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event.
- Preferences and Other Requests. We also may collect information about your preferences, including communications preferences, preferences related to your use of our Services, and any other preferences or requests you provide when interacting with us.
- Business Development Information. To assess and pursue potential business opportunities, we may collect and receive personal information about current, former, and prospective business partners, and vendors and service providers, including contact information and other similar identifiers, company and professional-related information, and communications records.
Personal Information Collected from Third Parties. We may also collect and receive certain personal information about you from third party sources, such as business partners, data analytics and marketing providers, operating systems, public databases, customers, and service providers or other third parties who provide services or perform functions on our behalf. For example, we may collect your name, contact details, and other similar information from business partners and service providers for purposes of facilitating shipments and providing our Services. In addition, we may collect the following information from third-party sources:
- Social Media Information. While using our Services, you may choose to enable sharing information or content through various social media platforms or social networking websites. If you choose to share content or interact with our Services using your social media accounts, we may collect or receive personal information about you that you have provided to that social media platform and/or social networking website. For example, we may collect information related to your account and profile, such as your name, username, email, profile picture, public postings, and other similar information available on your social media profile. You should check your privacy settings on each social media platform to better understand how your personal information may be used, disclosed, or otherwise processed by these platforms.
- Integrated Service Information. We may make available the ability for you to access, register for, place orders, or otherwise interact, engage, or connect with the Services through certain third-party features or integrated services. By accessing our Services via these third-party connections or integrated services, we may collect or obtain certain personal information about you related to your use of such third-party connections or integrated services. You should check your privacy settings on each integrated service to better understand how your personal information may be used, disclosed, or otherwise processed by these parties.
Personal Information Collected Automatically. We and our third-party providers may also automatically collect or derive personal information about you related to your use of our Services, including through the use of cookies, pixel tags, and other similar technologies. The personal information automatically collected may include:
- Device and Browsing Information. When you use our Services, we may collect browser type, domain name, page views, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, and other similar device and browsing information.
- Activities and Usage. We also may collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, your interactions with us within the Services, and other similar activities and usage information.
- Location Information. We do not generally collect location information through your IP address. However, if you choose to use features such as “Use My Location” to find a nearby store, the Site may use your IP address to provide approximate location information.
For more information about our use of cookies and other similar technologies, please see our Cookie Policy available here.
3. Purposes for Collecting and Processing Personal Information
Generally, we may collect, use, disclose and otherwise process the personal information we collect for the following purposes:
- Services and Support. To provide and operate our Services, manage your account, communicate with you about your use of the Services, provide troubleshooting and technical support, and for similar support purposes, and to otherwise run our day-to-day operations, including sales.
- Analytics and Improvement. To better understand how users access and use the Services, and for other research and analytical purposes, such as to evaluate and improve the Site, our Services, and business operations, including to develop our Services and its features, and for internal quality control and training purposes.
- Communication. To respond to your questions and inquiries, fulfill your requests, send you requested materials and newsletters, as well as information and materials regarding our Services and our offerings. We may also use this information to send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
- Customization and Personalization. To analyze your preferences and choices and then to tailor content we may send or display on the Services, including to offer location customization and to otherwise personalize your experiences and offerings.
- Marketing and Advertising. For marketing, advertising, and promotional purposes. For example, to send you promotional information about our Services, including information about sales, discounts, and new offerings, as well any other information that you sign up to receive.
- Research and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes.
- Insight Development and Data Enhancement. We may combine personal information collected through the Services with other information that we or third parties collect about you in other contexts for insight development and data enhancement purposes.
- Planning and Managing Events. For event planning and other management-related purposes, such as event registration and attendance, connecting you with other event attendees and users, and contacting you about relevant events and presentations.
- Security and Protection of Rights. To protect the Services and our business operations, our rights and those of our stakeholders and investors, to prevent and detect fraud, unauthorized activities and access, and other misuse of our Site and Services, including where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms and Conditions.
- Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, to respond to a subpoena, warrant, court order, or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
- Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits, audits and assessments of our operations, including our privacy, security and financial controls, as well as for risk and compliance purposes. We may also use personal information to maintain appropriate business records and enforce our policies and procedures.
- General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financing, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.
4. Disclosures of Personal Information
We may disclose the personal information we collect for the purposes described above with the following recipients and in the following circumstances:
- Subsidiaries. We may disclose the personal information we collect to our subsidiaries (i.e., our parent company and other companies under common ownership, control or management with us).
- Vendors and Services Providers. We may disclose the personal information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting providers, payment processors, product shipment and order fulfillment facilitators, marketing and marketing research providers, customer support, data storage, data analytics providers, auditors, consultants, and legal counsel.
- Business Partners. In some circumstances, we may partner with other businesses to offer our Services, including to facilitate certain programs, and we may disclose personal information to those business partners.
- Third Party Marketing and Analytics Providers. We may also disclose certain personal information, such as device and browsing, and activities and usage information, and other similar information, to third party marketing and data analytics providers, and other companies who provide marketing, advertising, campaign management, or analytics services on our behalf. We do not disclose data to third parties for their own marketing and analytics purposes.
- In Support of Business Transfers. If we may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company in accordance with applicable laws. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transactions such as financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
- Compliance and Legal Obligations. We may also disclose personal information to third parties to the extent required by applicable law and legal obligations. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators, government entities, and law enforcement, including responding to national security or law enforcement disclosure requirements, or as otherwise required by law or legal process.
- Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and take action in response to violations of our Terms and Conditions. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
- Aggregate and/or Deidentified Data. Notwithstanding anything else described in this Policy, we may use and disclose aggregate, deidentified, and other non-identifiable data related to our business and the Services with third parties for quality control, analytics, research, development, and other purposes. Where we use, disclose or process deidentified data, we will maintain and use the information in deidentified form and not attempt to reidentify the information, except in order to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws. The use of aggregate and/or deidentified data is limited to internal business purposes.
- Other Disclosures. We may disclose personal information in other ways not described above that we notify you of or that we obtain your consent for, or that are otherwise authorized or required by law.
5. Your Privacy Choices
We make available several ways that you can manage your preferences and privacy choices related to your personal information. Some of these choices are browser and device specific, which means that you may need to set the preference for each browser and device you use to access our Services. In addition, if you delete or block cookies, you may need to reapply these preferences to each browser and/or device used to access our Services. The preferences and privacy choices we make available include:
- Account and Profile Information. You may access, update, and delete certain of your personal information by accessing and adjusting your account information or settings directly within our Services.
- Marketing Communications. We may send periodic promotional emails or other similar communications to you, in accordance with applicable law. You may opt-out of these communications by following the instructions provided to you in the communication. If you opt-out of receiving promotional content from us, we may still send you communications about your account or any services you have requested or received from us. Additionally, you can manage your communication preferences in your account settings.
- Cookie Preference Manager. You can review or change your preferences for certain cookies on our Site, other than those that are necessary, by adjusting your cookie settings through our cookie manager available here.
- Cookie Settings. To prevent cookies from tracking your activity on our Site or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set. You can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.
- Browser Signals. Our Site currently does not respond to “Do Not Track” signals. However, our Site may respond to other opt-out preference signals as may be required by law.
- Privacy email: You can send an email to privacy@thombrowne.com to ask us information about the processing of your personal information or to ask for deletion, transfer and/or modification of your personal information.
6. External Links and Features
Our Services may contain links to third-party websites or features or provide certain third-party connections or integrated services. Any access to and use of such linked websites, features, or third-party services is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including their collection, use, and disclosure of your personal information. You should review the privacy policies and terms for any third party before proceeding to those websites or using those third-party features or services.
7. Children’s Privacy
Our Services are not designed for children, and we do not knowingly collect personal information from children under the age of eighteen (18). If we learn that personal information has been collected on the Services from persons under the age of 18, then we will take the appropriate steps to delete this information. If you are a parent or legal guardian and you believe we have collected your child’s information in violation of applicable law, please contact us using the contact information in Section 10. Contact Us below.
8. Security
We have implemented safeguards aimed to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security. There are also certain steps you can take to better protect against unauthorized access to your personal information. For example, when registering for an account, you should choose a strong password that is unique to the Services. You should not reuse passwords across multiple websites or services, and you should never share your password with others.
9. Changes to this Policy
This Policy is current as of the effective date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy on this page. If we make material changes to how we collect, use, or disclose the personal information we have previously collected about you, we will endeavor to provide you with prior notice, such as by emailing you or posting prominent notice on our website or within the Services.
10. Contact Us
If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at privacy@thombrowne.com.
11. Additional Privacy Information for Certain U.S. Residents
This section of the Policy provides additional information for certain U.S. residents under applicable state privacy laws.
Consumer Rights. Residents of certain U.S. states, including Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:
- Access. To confirm whether we are processing their personal information and to obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format.
- Deletion. To delete their personal information provided to or obtained by us.
- Correction. The right to correct inaccuracies in their personal information, taking into account the nature and purposes of the processing of personal information.
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Opt-Out. To opt out of certain types of processing, including:
- to opt out of the “sale” of their personal information;
- to opt out of targeted advertising by us; and
- to opt out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.
- Revoke Consent. If you have provided your consent in order for us to process your personal information, you may revoke such consent.
You may submit a request to exercise most of your privacy rights under U.S. state privacy laws online using our webform, emailing us at privacy@thombrowne.com or calling us at +1 844 938 6703. To opt out of the use of your online browsing information for purposes of “sales” or targeted advertising by us, you can adjust your cookies settings here. Please see Section 5. Your Privacy Choices and our Cookie Policy – available here – for more information.
We will respond to your request as required under applicable U.S. privacy law(s). When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
To the extent required under applicable U.S. privacy laws, if we deny your request, you may appeal our decision in accordance with the instructions we provide in our response.
To the extent permitted under applicable U.S. privacy laws, you may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization, and we may also require the relevant consumer to directly verify the identity and authority of the authorized agent.
If you are a resident of Delaware, Minnesota, or Maryland, you may contact us at privacy@thombrowne.com to request a list of the third parties with whom we have disclosed your personal information. Please note, the categories of third parties that we generally disclose personal information to are listed in Section 4. Disclosures of Personal Information above.
Sale of Personal Information. While we do not disclose personal information to third parties in exchange for monetary compensation, our use of third-party analytics and advertising cookies may be considered “selling” under applicable U.S. privacy laws. We may “sell” the following categories of personal information: identifiers; commercial information; location information; and Internet and network activity information. We may disclose these categories to third-party advertising networks and analytics providers for our own purposes of marketing and advertising and to improve and measure our ad campaigns. You may opt out of the sale of your personal information as further described above.
12. California Notice at Collection and Privacy Rights
This section of the Policy provides additional information for California residents and describes our information practices pursuant to applicable California privacy laws, including the California Consumer Privacy Act (the “CCPA”). This section applies to “personal information” as defined in the CCPA, whether collected online or offline. This section does not address or apply to our handling of personal information that is exempt under the CCPA, such as publicly available information or de-identified or aggregated information.
Categories of Personal Information Collected and Disclosed. The following table identifies the categories of personal information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories of third parties to whom we may disclose this personal information for a business or commercial purpose:
| Categories of Personal Information | Third-Party Disclosures for Business or Commercial Purposes |
|---|---|
| Identifiers. Includes direct identifiers such as first/last name, email address, phone number, and IP address. |
|
| Customer Records. Includes information such as name, user ID, account name, contact information, and financial or payment information (i.e., payment type, billing and shipping address) that individuals provide us in order to purchase or obtain our products and services. |
|
| Commercial Information. Includes records of products or services purchased, obtained, or considered, or other purchasing or usage histories or tendencies. |
|
| Internet or Other Electronic Network Activity Information. Includes, but is not limited to, browsing history, clickstream data, search history, and information regarding interactions with our Site, advertisements, or emails, including other usage data related to your use of any of our Services or other similar online services. |
|
| Audio, Electronic, Visual, or Similar Information. Includes videos, photographs, and profile images. |
|
| Protected Classifications. Limited to gender (male/female), age (date of birth). |
|
| Inferences. Such as inferences drawn from any of the information described in this section about a consumer including inferences reflecting the consumer’s preferences, characteristics, behaviors, attitudes, abilities, and aptitudes. |
|
Sources of Personal Information. We generally collect personal information from the following categories of sources: directly or indirectly from you; subsidiaries; business partners; vendors and service providers; Internet service providers; operating systems and platforms; social networks; and marketing and data analytics providers.
Purposes of Collection, Use, and Disclosure. As described in Section 3. Purposes for Collecting and Processing Personal Information above, in general, we collect and otherwise process personal information for the following business or commercial purposes, or as otherwise directed or consented to by you:
- Services and support;
- Analytics and improvement;
- Communication;
- Customization and personalization;
- Marketing and advertising;
- Research and surveys;
- Insight development and data enhancement;
- Planning and managing events;
- Security and protection of rights
- Compliance and legal process;
- Auditing, reporting, and other internal operations; and
- General business and operational support.
Retention of Personal Information. We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. When deciding how long to keep your personal information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). Rather than deleting your data, we may also deidentify it by removing identifying details. Where we have committed to maintaining and using personal information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.
Sales and Sharing of Personal Information. The CCPA defines “sale” as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third-party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” the following categories of personal information: identifiers, commercial information, and Internet and network activity information. We may disclose these categories to third-party advertising networks, analytics providers, and social networks for our own purposes of marketing and advertising and to improve and measure our ad campaigns. We do not sell or share personal information about individuals we know are under age eighteen (18).
California Privacy Rights. The CCPA provides California residents with specific rights regarding personal information. Subject to certain conditions and exceptions, California residents have the following rights with respect to their personal information:
- Right to Know/Access. You have the right to request: (i) the categories or personal information we collected about you; (ii) the categories of sources from which the personal information is collected; (iii) our business or commercial purposes for collecting, selling, or sharing personal information; (iv) the categories of third parties to whom we have disclosed personal information; and (v) a copy of the specific pieces of personal information we have collected about you.
- Right to Delete. You have the right to request we delete personal information we have collected from you.
- Right to Correct. You have the right to request that we correct inaccuracies in your personal information.
- Right to Opt-Out. You have the right to opt-out of “sales” and “sharing” of your personal information, as those terms are defined under the CCPA.
- Right to Limit Use and Disclosure. Pursuant to the CCPA, you have the right to request that a business limit the use and disclosure of your sensitive personal information. However, because we do not use or disclose sensitive personal information about you, this right is not applicable in our case.
- Right to Non-Discrimination. You have the right not to be subjected to discriminatory treatment for exercising any of the rights described in this section.
Exercising Your Privacy Rights. California residents may exercise their CCPA privacy rights as set forth below:
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Right to Know/Access, Delete, and Correct. California residents may submit CCPA requests to know/access, delete, and correct their personal information by using our webform, available at https://www.thombrowne.com/pages/contact, emailing us at privacy@thombrowne.com, or calling +1 844 938 6703.
When you submit a request, we will take steps to verify your identity and request by matching the information provided by you with the information we have in our records. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
You may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
- Right to Opt-Out of Sales and Sharing. To exercise your right to opt-out of the “sale” or “sharing” of your personal information, you may do so via our cookie preference manager available here.
13. Additional Privacy Information Notice for EU citizens
This Section of the Policy provides additional information for European Union residents and describes our information practices pursuant to applicable European privacy laws, including the EU Regulation 2016/678 (the General Data Protection Regulation, “GDPR”). This section applies to “personal data” as defined in the GDPR.
Data Controller and EU Privacy representative. The data controller of personal data related to the Site is Thom Browne Inc. 3484679, Tax-ID number 90-0009098 whose registered office is at 240 W. 35th St. Fl. 16th New York, New York 10001. For any information regarding the processing of your personal data, you may contact us by email at privacy@thombrowne.com. We have also appointed our EU privacy representative, who may be contacted writing to rappresentanteprivacyEU@thombrowne.com.
Legal Basis for the processing of personal data and data retention period. The processing of personal data, as described under Section 3. Purposes for Collecting and Processing Personal Information, is based on the following legal basis and relevant data are retained by the Company for the period indicated below:
| Processing reference | Purpose | Legal basis | Data retention |
|---|---|---|---|
| Services, Support and Sales | Registration, access and use of the user’s personal account on the Site – use of the Services provided on the Site | Contract | 10 years |
| Purchases and payments | Sale and pre-post sale services | Contract | 10 years |
| Analytics and Improvement | Internal analysis | Consent (cookie) | All information is aggregated and therefore anonymous |
| Customer service | To respond to your questions and inquiries. To deliver information about contract and services | Contract | 10 years |
| Customization and Personalization | To analyze your preferences and choices and then to tailor content we may send or display on the Services | Contract | 5 years |
| Marketing and Advertising | For marketing, advertising, and promotional purposes by traditional means (such as post and telephone) and technological ones (such as smart messages, emails, etc.). | Contract | 5 years |
| Research and Surveys | For market research or user satisfaction purposes. | Contract | 5 years |
| Insight Development and Data Enhancement | Combine personal information collected through the Services with other information without identifying consumers | Legitimate interest to improve the Site features | 5 years |
| Planning and Managing Events | For event planning and other management-related purposes, such as event registration and attendance | Legitimate interest of the Company in managing its events | 5 years |
| Security and Protection of Rights | To protect the Services and our business operations, our rights and those of our stakeholders and investors | Legitimate interest of the Company to prevent and detect fraud | 10 years |
| Compliance and Legal Process | To comply with applicable legal or regulatory obligations | Law | As required by applicable law |
| Auditing, Reporting, and Other Internal Operations | To conduct financial, tax and accounting audits, audits and assessments of our operations | Law / Legitimate Interest to properly manage the Company | 10 years |
| Operational Support | To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions | Legitimate Interest of the Company to manage extraordinary and ordinary operations | 10 years |
Mandatory or optional nature of data. The provision of your personal data for contractual and legal purposes is not mandatory, but failure to provide certain data may prevent us from fulfilling sales contracts and/or related Services.
Failure to provide certain personal data for "Service purposes" may prevent you from receiving assistance and advice from us but will not affect the sales contract.
With respect to marketing and analysis, failure to provide data will in no way affect the sales contract and related Services, but may prevent you from receiving invitations, information and customized business proposals, or even from responding to your needs, as well as from participating in questionnaires and satisfaction surveys.
Transfer of personal data outside the EU. We are a US based Company; therefore, we can transfer your personal data to the US. We are a Data Privacy Framework certified Company (EU-U.S. Data Privacy Framework, Swiss-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework, please see https://www.dataprivacyframework.gov/list). For further information regarding the transfer of your personal data and how to obtain a copy, you may contact us at privacy@thombrowne.com.
Your GDPR rights. You have certain rights under the applicable data protection laws regarding your personal data (Articles 15 et seq. of the GDPR). For example, you may request information as to what personal data about you is held by us and how it has been used or disclosed, and you may request access to such personal data in an understandable form. You may also request deletion, correction or updating of your personal data. You may also request to deregister your account (if any) or withdraw your consent to automated decision.
We remind you that you may withdraw your consent at any time, as well as restrict specific contact details. It should be noted that the right to object to the processing of data for marketing purposes is also valid for traditional means if you do so electronically.
You can exercise this right by contacting us at privacy@thombrowne.com.
Please also note that you have the right to file a complaint with the Data Protection Supervisory Authority of the Country in which you reside if you believe that your rights under GDPR have been violated.
