THOM BROWNE Inc.
Website Privacy and Cookies Policy
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 committed to protecting your privacy online when visiting the Site or communicating electronically with us. We appreciate that you do not want the personal information you provide to us distributed indiscriminately and here we explain how and why we collect and process personal data, what we do with it and what controls you have.
By using the Site, you acknowledge that you have read the terms of this privacy and cookies policy.
We will treat all your personal information as confidential (although we may disclose this information in the circumstances set out below). We will keep it on secure servers (as further detailed below) and we will fully comply with all applicable Data Protection Law and consumer legislation.
Whose personal data do we process?
- You are a user of the Site.
- You are a customer of us.
- You use our products.
- You are someone to whom we want to advertise or market our products.
Information we may collect from you through your use of the Site, we may collect and process the following information about you:
- information (such as but not limited to your name, email address, billing address, delivery address, telephone number, product selections, payment type, and card expiry number or log in and password details) that you provide by completing forms on the Site, including if you register as a user of the Site, purchase any goods from the Site, upload or submit any material via the Site, request any information, or enter into any competition or promotion we may sponsor;
- Information relating to transactions with us involving details of goods that we have supplied to you.
- Information provided to us when you communicate with us, for example by email or phone. This includes communications you send to us, for example, to report a problem or to submit queries, concerns or comments regarding the Site or its content.
- information from surveys that we may, from time to time, run on the Site for research purposes, if you choose to respond to, or participate in, them.
- Internet pages you have visited immediately before coming to the Site or pages you visit immediately after leaving the Site.
You are under no obligation to provide any such information. However, if you should choose to withhold requested information (e.g. your address or payment details), we may not be able to provide you with certain services.
We may, from time to time, run referral programmes or similar initiatives, such as a "Tell a Friend" programme, that invite you to provide us with the [name and email address] of someone who is known to you who may find our products or services to be of interest. We will only use those contact details for the purpose of the relevant initiative (and not for general marketing purposes). By providing us with their details, you confirm that you have their permission to do so and must not provide us with the details of anyone from whom you do not have such permission. We reserve the right to identify you as the person who has made the referral in the message that is sent to them.
What are Cookies
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.
Cookies are not programs and therefore cannot contain viruses or other malicious software.
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 purpose:
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.
- 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.
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.
Uses made of your information
We will use the information you provide only for the following purposes:
Information you give to us, we will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you, with information about goods or services we feel may interest you, if you have ticked the relevant box situated on the form on which we collect your data (the order form or registration form to create an account with the Site) indicating your consent to receiving marketing material from us;
- verify and carry out financial transactions in relation to payments you make online
- to notify you about changes to our service provided by the Site;
- to ensure in our legitimate interests that content from our Site is presented in the most effective manner for you and for your computer.
Information we collect about you
We will use this information:
- to administer our Site and your account with us under our terms and for internal operations, including identifying visitors to the Site, troubleshooting, and, in our legitimate interests, auditing the downloading of data, data analysis (demographic and sales data), testing, research, statistical and survey purposes;
- to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
- to identify visitors to the Site;
- to allow you to participate in interactive features of our Site, when you choose to do so;
- as part of our legitimate efforts to keep our Site safe and secure;
- for our legitimate interest of measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them in our legitimate interests and subject to your stated preferences where relevant.
- send you information we think you may find useful or which you have requested from us, including information about our products and services, provided you have indicated that you do not object to being contacted for these purposes;
- [allow, with your consent, [carefully selected third parties] to send you information directly which you may find useful regarding their products and services.]
Legal grounds for our processing of your personal data
The basis on which we process your personal data is as follows:
- Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned.
- Otherwise, we will process your personal data only where the processing is necessary:
- for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
- for compliance with a legal obligation to which we are a subject; or
- for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data.
We may disclose aggregate statistics about visitors to the Site, customers and sales in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.
We may disclose your personal information to any of our affiliates, including Thom Browne Inc.,Thom Browne Trading (T.B.T.) SA, Thom Browne UK Ltd, Thom Browne Retail Srl, Thom Browne Japan Inc. or to our agents or contractors who assist us in providing the services we offer through the Site, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks, from time to time.
We have subcontracted the operation of certain aspects of the Site to Farfetch Black & White Limited, a trading division of Farfetch UK Limited (company number 06400760, VAT number GB 204 0769 35) (Farfetch). Services provided or procured by Farfetch include, but are not limited to, payment processing, customer service, hosting and delivery logistics. Our agents and contractors will only use your information to the extent necessary to perform their functions, and always subject to appropriate security and contractual safeguards.
We may share your information with other companies and organisations for identity verification and fraud protection purposes to the extent permitted by applicable laws. In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.
You should be aware that we may be under a duty to disclose or share your personal information and/or user information in order to comply with any legal obligation. We may also disclose your personal information if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Site or the rights, property or personal safety of any person.
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.
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.
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.
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.
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
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 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 [email protected]
- 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 [email protected]
- 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.
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
Date of this policy
This policy was last updated on 25/05/2018.