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United States Privacy Notice
EFFECTIVE AS OF January 24, 2024
This Privacy Notice (this "Notice") explains how information about you is collected, used and disclosed by Todd Snyder, a company incorporated under the laws of Delaware, and our affiliates and subsidiaries in the United States (collectively, “Todd Snyder”, “we”, “us”, or “our”) with its principal business office located at 27 West 20th Street Suite 600, New York, NY 10011. This Notice applies to information we collect when you access or use our technology platforms (including, without limitation, our websites and other Todd Snyder-controlled properties that link to this Notice) (collectively, the "Platforms"), shop in our stores, engage with us via social media, or when we otherwise interact (by email, telephone or otherwise). By providing us with your Personal Information (as defined below) or otherwise interacting with us, you consent to the collection, use and disclosure of such information in accordance with this Notice. We may supply different or additional notices of our information practices specific to certain programs or activities. We may also provide different notices of our information practices with respect to certain subsidiaries or affiliates, in which case this Notice will not apply.
California, Colorado, Connecticut, Utah and Virginia Residents – Please see the respective sections below for information about your additional privacy rights.
1. COLLECTION & USE OF PERSONAL INFORMATION
"Personal Information" is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, e-mail address, telephone number, home address, or payment information (e.g., account information or credit card number).
We may collect Personal Information when you interact with Todd Snyder, such as when you:
Purchasing, returning, reserving or trying-on merchandise. When you purchase or return merchandise through one of our stores or through our Platforms, we collect and use the Personal Information that you provide, such as your personal identifiers (such as name, address, email address and telephone number), commercial transaction information (such as order details) and financial information (such as payment card information), for the purposes of fulfilling your order, processing your return or exchange, improving our service and merchandise offerings, security and anti-fraud efforts, tailoring our marketing efforts, auditing, updating you on the status of your order/return and reporting internally. When you reserve or try-on merchandise in-store, we may collect Personal Information such as your personal identifiers (contact information), store location and commercial transaction information (the items you wish to reserve or try-on) for the purposes of fulfilling your request.
We receive personal characteristics (such as size information and locale) when you provide the information to us. We use size information to provide you with the products you order and save your preferences.
In certain circumstances, we may also collect Personal Information that you provide to us regarding other people. For example, you may provide us with personal identifiers (such as the name and address) for a gift recipient. When you provide us with this Personal Information, we use it for the purposes of processing the shipment and, in some cases, to communicate with the intended recipient. We rely on you to obtain any necessary consent from the intended recipient to our use of their Personal Information for these purposes.
Promotional email, SMS/text messages, job postings or other communications. When you consent to receive information from us such as promotional emails, SMS/text messages, job postings or other information, we collect and use your personal identifiers (such as contact information) for the purposes of fulfilling your request. You can unsubscribe from promotional communications by following the instructions in the message, or for SMS/text messages, replying with ‘STOP’. If you have any questions about unsubscribing from our messages, please contact us as outlined below.
Visit or register through our Platforms. If you choose to visit and register with one of our Platforms, we will collect the registration information that you provide, such as your personal identifiers (including your name, email address, telephone number, password, shipping addresses), financial information and combined commercial transaction information (such as your purchase history with Todd Snyder) for the purposes of administering and securing your account on our Platforms. Additionally, when you shop with us through our Platforms, we store your browsing history, what you searched for, including when you use our style personalization tools, what you have saved for later, and when you ask us to notify you about items that go on sale or come back in stock and what you bought (if you make a purchase).
We also collect certain information through our Platforms automatically, such as:
We collect this information automatically through our Platforms for security and anti-fraud purposes (including protecting the integrity of the Platforms and our stores), to better understand and enhance user navigation on our Platforms, for marketing and analytics purposes (including allowing the selection of personalized ads or offers believed to appeal to you, based on your interests, preferences, location, or demographic information), and for internal operations and auditing. Additionally, Automated Technologies may be used to associate you with social networking sites (e.g., Facebook, Twitter and Snapchat), and, if you so choose, enable interaction between your activities on the Platforms and your activities on such social networking sites.
Visiting our stores. To help protect you and others, we monitor and record video and take photographs of the public areas of stores for security, anti-fraud, loss prevention, incident reporting and other operational purposes. We may also collect personal identifiers (such as IP Address and other unique device identifiers) and geo-location information of visitors’ devices in and around our stores to monitor foot traffic to help us understand how shoppers move around our stores, identify what shoppers seem interested in and improve the shopping experience.
Participating in our contests, sweepstakes, promotions, surveys or customer research. We collect the Personal Information (such as personal identifiers and responses) that you provide if you choose to participate in one of our contests, sweepstakes, promotions, surveys or other customer research, for the purposes of administering them. We will also use the Personal Information you provide to analyze and better understand how customers interact with our brands.
Product ratings and reviews. We collect the Personal Information through purchase and product review forms on the Platforms, such as personal identifiers (including your nickname and email address), your personal characteristics (including your height and weight) and commercial transaction information (including information about the product you purchased and your rating and review information). We use this information to display publicly on the Platforms and other locations (such as in stores, on television, and on social media pages). We also use the information to better understand your needs and preferences, enhance and personalize our product offerings to you and improve the Platforms and our service and merchandise offerings.
Contacting customer service. We use the Personal Information (including personal identifiers, commercial transaction information and financial information) you provide to us when you contact our Customer Service Department for the purposes of reviewing any questions you raise and responding to you. Depending upon the nature of your query, we may request additional Personal Information for the purposes of verifying your identity. We may record the audio information in customer service telephone calls, and may save and store written customer service interactions such as chat and email, for quality and training purposes and to meet our legal obligations.
Information we receive from others. We may obtain Personal Information from other sources and combine that with information we collect directly from you. For example, we may collect personal identifiers, commercial transaction information, and personal characteristics (such as gender and birth date) from our Vendors to ensure we have up-to-date contact information for you, to detect fraud or theft, to facilitate your use of a third-party application or feature (such as one of our Facebook, Twitter or Snapchat applications or a similar application or feature on a third-party website), or from third-party analytics and advertising providers as further described below. We apply the applicable provisions of this Notice to such combined information, so long as it is combined.
Inferences from the information listed above. We will use the information listed above to draw inferences about your preferences (such as your preferred brands and styles) to help us provide you with personalized content and offers and help us develop and provide better merchandise and services.
De-identified or aggregated information. We de-identify and/or aggregate data we receive and may use and disclose it for any business purpose.
2. SHARING OF INFORMATION
Except as described in this Notice, we will not provide your Personal Information to third parties without your consent. We may, however, share aggregated, non-personal or de-identified information, which cannot reasonably be used to identify you, with third parties. We may also share any of your Personal Information (listed above) for our business and commercial purposes and as more specifically described below:
Service Providers Providing Services on Behalf. We may share your Personal Information with service providers that perform functions on our behalf or assist with our business operations, such as those that host or operate our Platforms, analyze data, fulfill, ship, and deliver orders, and provide customer service; advertisers; or other service providers that participate in or administer our promotions, contests, sweepstakes, surveys or provide marketing or promotional assistance; and “powered by” partners who power product reviews on our products or services. These service providers may use the Personal Information only for the purposes of providing the services to you and us.
Third Parties/Trusted Partners Providing Services on Our Behalf. We may share your Personal Information with trusted partners that provide you and us with services, such as those that process transactions and payments, process gift card orders and use, facilitate and publish product ratings and reviews, perform anti-fraud services, and fulfill, ship, and deliver orders. In these situations, you are using and directing us to intentionally disclose Personal Information (including personal identifiers and financial information) so our merchandise and services can be provided to you.
Publicly. If you choose to participate in a product review or rating or rate a review as helpful or not helpful, the submissions may be published on the Platforms, in emails, on television, and on social media platforms. Published ratings and reviews may identify the author’s personal identifiers (such as nickname), personal characteristics, locale and the content of the submissions. You consent to making this information available to the public.
Your Consent to Have Your Personal Information Shared. While utilizing our Platforms, you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the disclosure of your information with other Vendors. If you agree to have your Personal Information disclosed, your Personal Information will be disclosed to such Vendors and the Personal Information you disclose may be subject to the privacy notice and business practices of such Vendors.
Business Transfers. We may disclose your Personal Information with other entities and their advisors in connection with an actual or potential bankruptcy, merger, acquisition, financing, reorganization or sale of company assets, or negotiation thereof.
Legal and Additional Disclosure. We may transfer and disclose your information to law enforcement, the courts, our advisors, attorneys, and others who participate in the legal process to comply with a legal obligation; when we believe in good faith that the law or a governmental authority requires it; to verify or enforce applicable policies; to detect and address fraud, security or technical issues; to respond to an emergency; otherwise to protect the rights, property or security of Todd Snyder or third parties, or as otherwise required or permitted by law.
3. CHOICE AND ACCESS
Accessing/Updating/Deleting Your Personal Information. If you wish to access, modify, correct or delete any of your Personal Information collected through the Platforms, you may contact us through ourPrivacy Portal or call us at 1-(866)-897-0333. Alternatively, you may access, modify, verify, correct or delete your registered user information through our Platforms. We may refuse requests that are unreasonably repetitive, require disproportionate technical efforts, risk the privacy of others, or are impractical.
In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Platforms or we have otherwise received. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. It may not always be possible to completely remove or delete all of your information from our databases without some residual data remaining due to backups and other reasons. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and obligations.
Promotional Communications. You may opt out of receiving promotional communications from us at any time by: (i) logging into your online account and updating your preferences; (ii) contacting us by phone, email or postal mail, or (iii) following the removal instructions in the communication that you receive.
For Our Users With Disabilities. Todd Snyder seeks to provide an environment in which every individual has an opportunity to be a part of our community and where full inclusion and respect for all people encourages creativity and authenticity. When our Platforms are not accessible, we recognize the significance of the impact it can have on people with disabilities. If you use assistive technology (such as a Braille reader, a screen reader, or TTY) and the format of any material on this site interferes with your ability to access information or perform any functions, please contact Beth Henke, Chief Compliance Officer, atcompliance@toddsnyder.com or contact our customer service team at 1-(866)-897-0333. To enable us to respond in a way most helpful to you, please describe the nature of your accessibility problem, the preferred format in which to receive the material, the specific Web address of the requested material, and your contact information.
Selling under Nevada Privacy Law. We do not currently and will not sell your Personal Information (as selling is defined under Nevada Privacy Law) for monetary payments without your consent. If we ever do, we will let you know in this Notice and you will have the right to opt out of selling of certain Personal Information for monetary payments by contacting us atprivacy@toddsnyder.com to make this request (include your state of residence when making such request).
4. TARGETED ADVERTISING/ANALYTICS
We use analytic tools (such as Google Analytics) and ad network providers to help analyze the usage of and present ads on the Platforms, third-party mobile applications, or other sites, as well as other service providers to provide analytics services. You can find out how Google Analytics uses data here and how to opt out of Google Analytics here. For more information on how Google uses data when you use our websites, click here.
These entities may use cookies, web beacons and other technologies to collect information about your use of our Platforms, such as personal identifiers (your IP address), device characteristics (web browser, mobile network information) and usage activity (such as pages viewed, time spent on pages, links clicked and conversion information). This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content personalized to your interests and better understand your online or offline activity. For example, you may see advertisements for Todd Snyder on third party sites after you have visited Todd Snyder’s website.
Many advertising and analytics providers are members of associations, which provide a simple way to opt out of analytics and ad targeting, which you can access at:
Do Not Track. Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites may not respond to all browser DNT signals.
5. SECURITY OF YOUR INFORMATION
We implement and maintain reasonable security practices and procedures appropriate to the nature of the information we maintain, including appropriate technical, administrative, and physical procedures to prevent loss, misuse, or alteration of your information on and offline. It is your responsibility to select a strong password, not reuse or share your password, and alert us if you have any concerns about unauthorized use of your account. We encourage you to use complex passwords and to change them regularly.
6. PRIVACY OF CHILDREN
We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Platforms is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at privacy@toddsnyder.com. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.
7. PROCESSING AND TRANSFER OF INFORMATION
We are based in the United States, and the information we collect is governed by U.S. law. If you are accessing our Platform from outside of the U.S., please be aware that information collected through our Platform may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of our Platform or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including PII, in the U.S. as set forth in this Notice.
8. INFORMATION RETENTIONWhere Personal Information is used for more than one purpose, we may retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
9. LINKS TO THIRD PARTY WEBSITES
The Platforms may contain links to third party websites and online services. This Notice does not apply to the practices of other websites and online services, and we are not responsible for the actions and privacy policies of the third parties that operate or interact with those other websites.
10. CHANGES
We may update this Notice from time to time. If we make changes, we will notify you by revising the date at the top of the Notice. We encourage you to review this Notice whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.
11. ADDITIONAL RIGHTS AND PROVISIONS FOR CALIFORNIA RESIDENTS
The following provisions are applicable to residents of California and supersede the prior general statements made above. Unless otherwise noted, the disclosures contained within this section cover our activities in the prior 12 months from the effective date, as well as our current practices.
CALIFORNIA CONSUMER PRIVACY NOTICE AND RIGHTSUnder the California Consumer Privacy Act found at California Civil Code § 1798.100 et seq. and its implementing regulations (the “CCPA”), California Consumers have the right to request:
California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed above. When you make a request, we may require that you provide information and follow procedures to verify the request before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your identity, we will begin to process it. If we cannot verify your identity, we may ask you for additional information to help us verify your request. If we still cannot verify your identity, we will notify you with further explanation.
We will respond to your request within the 45-day time period required by applicable law. We reserve the right to extend that time to 90 days in order to complete your request. However, we may not always be able to fully comply with your request, and we will notify you in that event. To make requests, California consumers may contact us through our Privacy Portal or call us at 1-(866)-897-0333. Consumers will be required to submit their name, email address, and request-related information. We may also ask you to confirm information such as your order history or account settings so that we may verify the request. Please provide as much of the requested information as possible to help us verify your identity. We will use information received in a request only for the purposes of responding to your request.
The CCPA permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a signed document addressing this topic or a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agency must follow the process described above to make a request, and we will additionally require you and your authorized agent to verify his/her own identity. Additionally, we may confirm the agent’s authority with the California consumer about whom the request was made.
California consumers have the right to opt out of the “selling” and “sharing” of their Personal Information, and can do so by contacting us through the Do Not Sell or Share option in our Privacy Portal. Additionally, sharing and selling occurs via cookies and tracking technologies (“Cookies”). You may opt-out of Cookies by visiting our Cookie Preferences Center in the footer of our website. Opting-out of “sales” and “sharing” will not stop marketing and advertising, but it may be less tailored and useful for you. Even after you opt-out, we will continue to disclose your Personal Information with our service providers.
GLOBAL PRIVACY CONTROL
You may opt out of the sharing of your Personal Information through an opt-out preference signal setting in your browser. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use.
12. CALIFORNIA, COLORADO, CONNECTICUT, UTAH, VIRGINIA INFORMATION COLLECTION
HOW AND WHY WE COLLECT PERSONAL INFORMATION
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CATEGORIES OF PERSONAL INFORMATION |
BUSINESS PURPOSES FOR COLLECTION, USE, AND DISCLOSURE |
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Identifiers (e.g., name, email address, phone number, device identifier, IP address, etc.) |
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Personal Records (the identifiers disclosed above as well as financial information) |
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Commercial Information (e.g., account information, purchase history, etc.) |
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Characteristics of protected classifications under California or federal law. (e.g., gender, age, etc.) |
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Internet or other electronic network activity (e.g., browsing history, search history,“cookies” or other tracking tags, etc.) |
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Inferences drawn from the Information above (e.g., preferences or characteristics) |
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CATEGORIES OF SOURCES FROM WHICH Todd Snyder HAS COLLECTED PERSONAL INFORMATION
CATEGORIES OF RECIPIENTS TO WHOM PERSONAL INFORMATION IS DISCLOSED FOR BUSINESS PURPOSES
Todd Snyder shares personal information with service providers and governmental authorities and permits our service providers to collect personal information directly from visitors and customers when providing services to Todd Snyder. We do not disclose personal information to service providers that do not agree to acceptable data protection agreement terms.
We provide the categories of personal information listed above to service providers for the following purposes: payment processing, gift card processing, customer service, advertising and marketing, email services, mobile messaging services, mail services, data analytics, shipping, warehousing, anti-fraud services, legal and advisory, computer and data infrastructure, telecommunications, auditing, and building products and services for us.
CATEGORIES OF PERSONAL INFORMATION “SOLD” or “SHARED”
Categories of Personal Information Sold or Shared
Categories of Third Parties to Whom Personal Information was Sold or Shared
The purpose of selling or sharing this Personal Information is forproviders of advertising insights to help us tailor and target our marketing and advertising efforts.
To learn more about your cookie preferences and how you can opt-out, please visit our Cookie Preferences Center in the footer of our website.
13. CALIFORNIA SHINE THE LIGHT
California Shine the Light underCalifornia Civil Code §1798.83.California law permits customers in California to request certain details about how their personal information is shared with third parties, and in some cases affiliates, if personal information is shared for those third parties’ or affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us atprivacy@toddsnyder.com. Please allow 30 days for a response.
14. CALIFORNIA PRIVACY RIGHTS - CALIFORNIA MINORS
As stated in our Privacy Notice, our websites, mobile/tablet sites, web pages, social media presence, marketing campaigns, applications, our stores and other Todd Snyder controlled digital properties that link to this Policy (collectively, our “Platforms”) are “general audience” websites and not directed toward children.
Certain areas of our Platforms may contain interactive features that allow registered users to post content or information (the “Interactive Services”). If any of our Interactive Services are either: (1) directed toward California residents under the age of eighteen (18); or (2) if Todd Snyder has actual knowledge that a registered user of the Interactive Services is a California resident under the age of eighteen (18), Todd Snyder will permit such registered user to remove (if applicable) or request that Todd Snyder remove or anonymize such content or information as posted by the registered user, to the extent required byCalifornia Business and Professions Code § 22581.
If you are under the age of eighteen (18) and would like to request the removal or anonymization of content or information you have posted on or to our Interactive Services, please send your request to privacy@toddsnyder.com.
15. ADDITIONAL RIGHTS AND PROVISIONS FOR COLORADO, CONNECTICUT, UTAH, VIRGINIA RESIDENTS
This section applies to Colorado, Connecticut, Utah and Virginia Consumers as defined by the Connecticut Data Privacy Act (“CTDPA”), Colorado Privacy Act (“CPA”), Utah Consumer Privacy Act (“UCPA”) and Virginia Consumer Data Protection Act (“VCDPA”) that use our Platforms. Capitalized terms defined in the CTDPA, CPA, UCPA and VCDPA that are used in this section shall have the same meaning as in the CTDPA, CPA, UCPA and VCDPA.
This section describes our collection, use, and disclosure of Personal Data. You can learn more about the Personal Data we process and the purpose for processing such Personal Data in Section 1. Collection and Use of Personal Information, above. You can also learn more about our disclosure of Personal Data and the categories of third parties we disclose Personal Data to in Section 2. Sharing of Information, above. To view the categories and the purposes of how Todd Snyder processes Personal Data please see Section 12, California, Colorado, Connecticut, Utah, Virginia Information Collection.
Todd Snyder does not use or disclose sensitive personal data of consumers for purposes other than those identified in the CTDPA, CPA, UCPA and VCDPA.We do not currently and will not sell your Personal Information (as selling is defined under the CTDPA, CPA, UCPA, VCDPA) for monetary consideration. We may Process your Personal Data for Targeted Advertising. You have the right to opt-out of the Processing of your Personal Data for Targeted Advertising, as described below.
If you are a Colorado, Connecticut, Utah or Virginia Consumer, subject to certain conditions and restrictions set out in the CTDPA, CPA, UCPA, VCDPA and other applicable laws, you have the following rights with regard to your Personal Data:
Colorado, Connecticut, Utah and Virginia Consumers may submit their CTDPA, CPA, UCPA and VCDPA requests via ourPrivacy Portal. Consumers may also opt-out of Sales and Targeted Advertising via a GPC browser signal. Please note that, depending on the nature of your request, you may be asked to provide information to verify your identity before your request can be processed. We will confirm receipt of your request and respond to your request as soon as we reasonably can and no later than legally required.
You may exercise your privacy rights under the CTDPA, CPA, UCPA and VCDPA no more than twice in a 12-month period. If you choose to exercise any of the privacy rights described above, you will not receive discriminatory treatment from us.
If you make a privacy rights request, we will retain the Personal Data provided to us to fulfill your request for our record keeping purposes.
16. CONTACT US
As it relates to questions you might have about this Notice or if you have a concern that Todd Snyder may have failed to adhere to this Notice, please contact us as follows:
Please note, the role and department responsible for compliance with the obligations under this Notice is: Assistant General Counsel, Privacy: Legal Department, privacy@toddsnyder.com.
Todd Snyder
c/o Legal Department
77 Hot Metal Street
Pittsburgh, PA 15203
Attention: Assistant General Counsel, Privacy
Tel: 1.888.232.4535
E-mail: privacy@toddsnyder.com
