Privacy Policy

THOM BROWNE Inc. 

Website Privacy and Cookies Policy 

Introduction 

This is the privacy and cookies policy for [http://www.thombrowne.com], being the e-commerce website of Thom Browne Inc. (hereinafter TBI) (we, us and our) for the sale and purchase of our products (Site). For the purposes of European data protection legislation (Data Protection Law), we are the data controller in relation to the personal data processed in accordance with this policy. 

We are aware of the importance of your personal data. Therefore, before using your personal data, we will provide you with complete information about the processing of your data and ask for your necessary consent. 
  

By using the Site, you acknowledge that you have read the terms of this privacy and cookies policy. 

The data processing is held by Thom Browne Inc. 3484679, Tax-ID number 90-0009098 whose registered office is at 240 W. 35th St. Fl. 16th New York, New York 1000, (hereinafter referred to as "Thom Browne"). For any information regarding the processing of your personal data, you can contact us by email at privacy@thombrowne.com. 
 

Your personal data (hereinafter referred to as "Data") will be processed for the following purposes.  

(i) Contractual purposes - purposes closely related to the sale (payment, order, delivery), including pre- and after-sales services provided by Thom Browne (cutting, dispatch, repair, customisation) and purposes related to the contractual guarantee provided by Thom Browne (in the case of Thom Browne's own sales registration, the contractual guarantee is in fact recognised even without the appropriate tax documentation).   

(ii) Legal purposes - for any legally relevant purposes arising from the contract of sale (e.g. accounting, taxation and legal obligations, e.g., legal warranties)   

(iii) Customer service purposes - for the specific needs of the customer, in relation to the assistance services to be provided to the customer during the product evaluation and selection process, as well as in relation to the relationship with the customer in the boutique, the reception of the customer, the image consultation, the Style Suggestions ("style wear advice") provided by the dressing consultant, and any other activities related to the Customer Experience ("Customer Experience") in the Boutique.  

and, with your prior consent, for the following purposes.   

(iv) Marketing purposes - for commercial and marketing purposes, such as sending promotional offers, commercial activities and advertising information relating to products and services offered by Thom Browne by automated electronic delivery (including via SMS, instant message, e-mail, etc.) as well as by traditional means (paper letters and telephone calls).   

(v) Purpose of the analysis - for research and analysis of your consumption habits, preferences and choices in order to provide products and services that better meet your personal style and needs. This need is described in more detail in section 3 below.   

Data will be processed mainly electronically and by traditional means; indeed, some processing may take place on paper. At the same time, specific security measures will be observed to prevent data loss, illegal or incorrect use, and unauthorised access.  
 

Study of customers' consumption habits and choices  

With your explicit consent, Thom Browne will be able to study your consumption habits and choices in order to offer products and activities that best meet your personal style and needs, as described in section 2, clause (v) above.  
 

With the help of automated tools, Thom Browne will be able to process data relating to: the value and frequency of purchases (including purchases during the discount season) and the types of products purchased during a given time period (e.g. accessories, clothes, etc.). Thom Browne will be able to obtain more data directly from you about your preferences, hobbies, habits, lifestyle and favourite sports. Such data may also be obtained indirectly (and therefore not from you) through certain social media platforms or through the use of cookies on the Thom Browne website. In any case, this will only happen if you accept in advance with use of third-party login registration functions, by which the transmission of certain data about you from that social platform can authorize the use of analytics and marketing cookies in the manner provided on the platform's website. In addition, Thom Browne may integrate, or correct and update your personal data of a public nature, subject to the relevant restrictions and to the extent that you have consented and for the purposes described above.   

In any case, the sole purpose of this research is to provide products, services and activities to customers according to their style and needs. The manner in which it is carried out is non-intrusive. In any case, you may at any time request that your personal data be analysed and updated or amended as necessary.  

1. Legal basis for data processing and data retention period  

The legal basis for the processing carried out in accordance with the purposes described in section 2 above is as follows.  

• Contractual purposes - performance of the contract and obligations before and after the contract, as well as specific legal obligations arising from the performance of the contract (contractual guarantees).  
• Legal purposes - the fulfilment of legal and tax obligations relating to the sale.  
• Customer service purposes - to guarantee to its customers a level of service and assistance consistent with the relevant industry and brand reputation, where it is in Thom Browne's legitimate interests to do so.  
• Marketing purposes - subject to your specific consent.   
• Analytical purposes - subject to your specific consent.  

Data is kept for different periods of time depending on the specific purpose for which it was collected, for the following periods:   

• Contractual purposes - to comply with civil law provisions and to be kept for a period not exceeding 10 years  

• Legal purposes - to comply with tax regulations and to be kept for a period not exceeding 10 years  

• Customer Service purposes - to be kept for a period appropriate to the needs of the service, the needs of the customer relationship and the needs related to the expression of the customer  

• Marketing purposes - for a period not exceeding 5 years from the date of data collection, except where consent for continued retention has been requested from the client prior to the cut-off date   

• Analytical purposes - no more than 5 years from the date of data collection.  

2. Mandatory or optional nature of the data   

The provision of data for contractual and legal purposes is not compulsory, but failure to provide certain data may prevent Thom Browne from performing sales contracts and/or related services.  

If certain data is not provided for "service purposes", it may not be possible to obtain help and advice from Thom Browne, but this will not affect the sales contract.  

With regard to marketing and analysis, failure to provide data will not in any case affect the sales contract and its related services, but may prevent you from receiving invitations, information and business proposals, or even from responding to your needs, as well as from participating in questionnaires and satisfaction surveys.   

3. Categories of recipients of personal data  

The following parties will be able to know and process the data.  

• Other companies belonging to same group of companies  
• Technical, process and mail service providers, as well as providers of tools for sales purposes  
• Third parties, such as banks, public institutions, payment service management companies.   

The above parties act as data duty holders through Thom Browne's appointment, i.e. as autonomous data holders.  

In addition, your personal data will be made known to Thom Browne's employees and consultants, who will act as authorised parties and process your personal data on behalf of the data holder in accordance with the full instructions of the holder.   

4. Transfer of data outside the EU  

Given the multinational nature of the Group itself and the services offered by Thom Browne in all its boutiques, data may be transferred to companies belonging to the same group also outside the EU. In any case, an adequate level of protection and supervision is guaranteed for each data transfer, in accordance with applicable regulations, through the use of technically secure tools and channels, and in accordance with the provisions of the standard contractual clauses. You can contact the data controller at privacy@thombrowne.com to find out where the data is and to obtain a copy of it.  

5. Your rights 

You have certain rights under the applicable data protection laws regarding your personal data. For example, you may request information from Thom Browne as to what personal data about you is held by Thom Browne 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. To exercise your rights, withdraw your consent, or to make a complaint about our handling of your personal data, please send the relevant request to the following email address: privacy@thombrowne.com. 

We remind you that you may also 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. 

Finally, please note that you may at any time lodge a complaint with the competent supervisory authority. 

Cookies 

What are Cookies 

Most websites you visit will use cookies to improve your user experience by enabling that website to remember you, either for the duration of your visit (using a 'session cookie') or for future visits (using a 'persistent cookie'). 

A cookie is a simple text file that is issued to your computer when you visit a website and which stores and sometimes tracks information about your use of a website. Each cookie is unique to your browser. It will contain some anonymous information such as a unique identifier, the website name and some digits and numbers. It allows a website to remember things like your preferences or what's in your shopping basket. 

Although they do identify a user's computer, cookies do not personally identify users, and passwords and credit card information are not stored in cookies. 

Cookies are not programs and therefore cannot contain viruses or other malicious software. 

How We Use Cookies 

To perform fraud and credit checks and if we can do business with you, we collect your name; email; addresses; credit/debit card details; browsing history; purchase history; date of birth; gender; specific behavioral cookies, device information (such as IP address and device type), any national identifiers (like driver’s license or ID cards) and any publicly available information (like social media profiles or news). The legal basis is the legitimate interests to protect Thom Browne and its customers from fraudulent activities and compliance with a legal obligation. You can find a summary of the various types of cookies we use below. Our cookies are used for 5 types of purposes: 

 We use the following categories of cookies on our Site. 

• CATEGORY 1: STRICTLY NECESSARY COOKIES 

These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided. These cookies will also inform us, by your behaviour on our website, if we can do business with you and protect Thom Browne and its customers from fraudulent activities. cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided. These cookies are passed under HTTPS in an encrypted format. This provides the most security when identifying you as a user. 

• CATEGORY 2: PERFORMANCE COOKIES 

These cookies collect anonymous information on how people use our Site. For example, we use Google Analytics cookies to help us understand how customers arrive at our Site, browse or use our Site and highlight areas where we can improve areas such as navigation, user experience, shopping experience, and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established. 

Google Analytics is a system used by many websites to record information about who visits a website. Google sets five different cookies with expiry dates ranging from 1 day to 2 years. These cookies are used mainly to differentiate between first time visitors to a website and repeat visitors. They do not contain any personally identifiable information. You can find out more about how Google uses cookies at http://www.google.com/intl/en/analytics/privacyoverview.html 

• CATEGORY 3: FUNCTIONALITY COOKIES 

These cookies allow us to: 

• remember choices you make such as the region you visit our Site from, language and search parameters such as size, color or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites. 

• remember that you have visited us before; this means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get. 

• CATEGORY 4: TARGETING COOKIES OR ADVERTISING COOKIES 

These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third-party companies such as Criteo to provide you with more personalised adverts when visiting other websites. 

• CATEGORY 5: SOCIAL MEDIA COOKIES 

These cookies allow you to share what you’ve been doing on the Site on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work. 

Cookies on the Site 

Some of the cookies on the Site are set by us and some are set by third parties who are delivering services on our behalf. 

Controlling or deleting cookies 

Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. 

Information on deleting or controlling cookies is available at www.AboutCookies.org, which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device. 

Please note that by deleting or restricting cookies or by disabling future cookies you may not be able to access certain areas or features of our Site or take full advantage of the Site. 

To opt-out of being tracked by Google Analytics across all websites visit Google Analytics Opt-out Browser Add-on. 

If you'd like to opt-out of other third party cookies relating to behavioral advertising, please go to www.youronlinechoices.eu. Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. 

 We (and other third parties acting on our behalf) may automatically track and collect information about the IP address, domain service, region location, time zone, language, the type of computer and web browser you are using and the pages you visit (including by using web beacons and other similar technology). If you access our Site via your mobile device, we may also collect information about your mobile provider and your mobile device. We use this information so that we can administer and improve our system, analyse trends, track users' movements, gather broad demographic information for aggregate use and detect suspicious or fraudulent transactions. If these automated processes reject your transaction on the basis that it is a suspicious or fraudulent, you may contact us and ask us to reconsider the decision within 21 days of receiving such notification. We are likely to use very similar criteria to review your transaction in person so there is no guarantee that the decision will be different. 

Public forums 

The Site may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to its users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and never disclose your personal information. 

Child safety 

Protecting the safety of children when they use the Internet is very important to us.  We recommend that children receive permission from their parent or guardian before gaining access to the Site or sending personal information to us or anyone else online. 

External links 

The Site may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and processes and that we do not accept any responsibility or liability for these policies and processes. Please check these policies before you submit any personal data to these websites. 

Payment processing 

Payment details you provide will be encrypted using secure sockets layer (SSL) technology before they are submitted to us over the internet. Payments made on the Site are made through our payment gateway provider from time to time, [including PayPal and Adyen]. You will be providing credit or debit card information directly to such payment provider which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to such payment providers is not within our control and will be subject to their own privacy policy and terms and conditions. For more information please contact us. 

We use certain pixels that track your behavior in our website and which can collect certain information regarding your interaction with our website as well as information relating to the devices you are using, like the operating system and browser used. This information is used for fraud prevention purposes and we may share such information with selected third parties which assist us to prevent fraud in our website. 

Security 

We place great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorized personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it. 

You should bear in mind that the submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. 

It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place. 

Data Retention 

We process personal data only for so long as it is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose. 

Storage of your information 

Your personal information may be transferred to, and stored at a destination outside of the European Economic Area including the US and Switzerland, Japan  The US and other non-EEA regions do not have similar data protection laws to the EEA, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from Europe.  Where we transfer your information we will take all reasonable steps to ensure that your data is subject to appropriate safeguards, such as relying on EU approved standard contractual clauses relevant to transfers of personal information and that it is treated securely and in accordance with this privacy policy. 

Information submitted by you may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above (see Information sharing), which may be situated outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA who work for these third parties or for us or one of our suppliers. This includes staff engaged in, among other things, the processing of payment details and the provision of support services. The regions concerned may not have similar data protection laws to the EEA. Where we transfer your information we will take all reasonable steps to ensure that your data is subject to appropriate safeguards, such as relying on EU approved standard contractual clauses relevant to transfers of personal information and that it is treated securely and in accordance with this privacy policy. 
In-Store Clients 

We may collect and process the following information about you: 

• information (such as your name, email address, postal address and telephone number) that you provide by completing customer cards in our stores; 

• information from surveys that we may, from time to time, email you for research purposes, if you choose to respond to, or participate in them; 

• in connection with an account sign-in facility, your log-in and password details; 

• product preferences you express during your store visit or through your interactions with thombrowne.com via the creation of wish-lists linked to your account; 

• details of any transactions made in store; 

We will use the information you provide to 

• track online and in-store sales data; 

• send you information we think you may find useful or which you have requested from us, including information about our products and services [or those of carefully selected third parties], provided you have indicated that you do not object to being contacted for these purposes; 

• carry out research on our clients’ demographics and tracking of sales data; 

• measure and understand data analysis (demographic and sales data) for testing, research, statistical and survey purposes. 

You can tell us not to contact you with information regarding our products either at the time you provide your information in-store (by not checking (as directed) the relevant marketing communications box) or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. You can also exercise the right at any time by contacting us using the Contacting us details at the end of this privacy policy. 

Your rights 

You have the following rights in relation to personal data relating to you that we process: 

• You may request access to the personal data concerned (please see the section on how to access your personal data, below). 

• You may request that any incorrect personal data about you that we are processing be rectified. 

• In certain circumstances (normally where the personal data has been provided by you and it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned. 

• Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time, after which we shall stop the processing concerned. If you do withdraw your consent here, please note that this may affect our ability to provide you with our goods or services. 

• If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a formal complaint with the Information Commissioner. 

How to withdraw your consent to the processing 

You can withdraw your consent to any relevant processing of personal data: 

• By emailing us at privacy@thombrowne.com 

• By contacting us at the telephone number +442037430123 

How to exercise your right of access to your personal data 

You can exercise your right of access to your personal data: 

• By emailing us at privacy@thombrowne.com 

• By contacting us at the telephone number +442037430123. 

Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested. 

Contacting us 

Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to privacy@thombrowne.com, or by telephone on +442037430123 between the hours of 9am to 5pm, Monday to Friday . 

The Information Commissioner 

The ICO is the supervisory authority and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data. 

Changes to this policy 

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy and cookies policy. 

Date of this policy 

This policy was last updated on 26/092022.