Claire’s European Privacy Notice

Effective date: 15/9/2021

Introduction

This Privacy Notice sets out how Claire’s Stores Inc. (“Claire’s,” “we,” “us,” “our”) processes European personal data obtained via our website claires.com (the “Site”) – in our role as a data controller (i.e., when we are responsible for determining the purpose and means of the processing). This Notice also describes your data protection rights, including the right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your rights” section below.

Personal Data We Collect

Personal data collected via the Sites may include:

• Contact data. You may provide us with your contact details, such as your name, phone number, mailing address, and email address. You may provide us this information when you contact us or sign up for newsletters.
• Payment Information. You may provide payment information and related information such as a billing and mailing address when you make purchases on the Sites.
• Feedback Information. You may also provide your personal data when you respond to surveys or provide feedback or other opinions.
• Account Information. Certain features of the Sites allow you to provide a username and password to access specific content. Once logged in, you can adjust wish list and payment information preferences and view account information such as your order history, date of birth, and store preference.
• Authentication Data. To verify the identity of registered users we may collect authentication information.

• Device Information. We may obtain information about devices that access our Sites, including the type of device, its operating system, device settings, unique device identifiers, and error data.
• Location Information. The Sites may also use GPS (global positioning systems) software, geo-filtering, and other location-aware technologies to locate you (sometimes precisely) and send you geo-targeted marketing communications where permitted.       You may be able to toggle on or off location technologies using your internet browser (e.g., Google Chrome). If you disable location technologies, you may not be able to use certain features of the Sites.
• Information About Others. You may submit to us personal data about other individuals. For example, you may submit someone else’s mailing address when you purchase a gift for them through the Sites. When you submit personal data about others, you represent that you have obtained their consent to disclose their personal data to us.
• User Generated Content: Where you give us permission we may collect user generated content from you or from sources such as your social media profile (such as Facebook, Google, Twitter and Instagram).This may include: your name; your social media handle; messages which you have shared publicly on social media; your gender; number of social media followers; social media profile preferences; your age/date of birth; and your home address and email address.
• Other Information You Provide. This includes emails and other communications that you send us or otherwise contribute, such as user support inquiries regarding the Sites.

How and Why We Use Your Personal Data

We process personal data for the following purposes:

To fulfil a contract, or take steps linked to a contract: this is relevant where

• You make a purchase from us;
• We process your account registration and identify you as a user;

• We take payment for your purchases;
• We provide customer services and arrange the delivery or other provision of products or services;
• Managing our loyalty scheme where you are a participating member including administering the benefits of the loyalty program to you.

As required by Claire’s to conduct our business and pursue our legitimate interests, in particular:

• Responding to your comments, questions and requests, providing customer service, sending you informational notices, or to contact you if we need to obtain or provide additional information;
• Verifying your location so that we can redirect you to the correct site based on your country;
• Accessing and using information about your device location (such as based on IP address), or your account information, to suggest appropriate Claire’s locations;
• Facilitating, managing, personalizing, and improving our user and partner relationships. For example we use your online activity on our Sites, as well as your in-store and online purchases to help us better understand you as a customer and provide you with personalized offers and services;
• Providing you with relevant marketing. This may involve showing you online ads on our Sites and those of third parties or on other media channels;
• We process user generated content (as described above) to contact you regarding having your social media content used in a Claire’s campaign and using your social media content for our marketing and promotional purposes including (where needed, with your permission for intellectual property reasons) posting or reusing your content on social media platforms or media;
• Assessing the effectiveness of our marketing and the marketing activities we carry out including the marketing we carry out as part of our loyalty programme;
• Preventing and addressing fraud, breach of policies or terms, and threats or harm. This includes, among other matters, analyzing and improving the safety and security of the Sites together with implementing and enhancing security measures and protections to combat fraud, spam and abuse;
• Ensuring the security and integrity of the personal data we process;
• Complying with applicable legal requirements;
• Maintaining and improving the Site;
• Operating the Site and providing you with certain information and communications tailored to your preferences.

Where you give us consent:

• where consent is required by applicable law, we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners.
• we place cookies and use similar technologies (see How we use tracking technologies below)
• on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.

For purposes which are required by law:

• In response to requests by government or law enforcement authorities conducting an investigation;
• To comply with applicable tax and other government regulations.

We have completed out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out in the “How to contact us”, section below.

How We May Share Your Personal Data

We may share your personal data:

• With our affiliates, partner organizations, or suppliers when it is reasonably necessary or desirable, such as to help provide products and services to you or analyze and improve the Sites.
• With our staff, agents, vendors, consultants, and other service providers who perform functions on our behalf. This might include, but is not necessarily limited to the companies that handle our order dispatch service, pay our delivery company, business entities that provide e-mail address management and communication contact services, network equipment and application management providers and hosting entities, credit and debit card payment gateways and processors and the issuing and acquiring banks involved in the funds settlement procedures necessary to charge your cards or financial accounts, entities which obtain information such as demographic information which might be aggregated with information we have about you, judicial, administrative and/or legal or financial accounting providers in the event that information must be reviewed or released in response to civil and/or criminal investigations, claims, lawsuits, or if we are subject to judicial or administrative process (such as an injunction) to release your information or to prosecute or defend legal actions, and other service providers which may be involved in the other types of services and activities otherwise discussed in this Privacy Notice.
• To abide by applicable law or protect rights and interests.       For example, we may disclose your personal data if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property, or interests, or prevent fraud or abuse.
• Social Media networks (see Links to Third-Party Online Services below).

• In the event we sell or transfer all or a portion of our business assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction), including negotiations of such transactions.

 

How We Use Tracking Technologies

We may utilize online identification tools—such as cookies, web beacons, pixels or similar tracking technologies—in accordance with applicable law and requirements. “Cookies” are small text files placed on your device when you visit a website; they store information which is sent back to our servers or those of third parties. As described in more detail below, we use such technologies to:

• Recognize new or past users;
• Store your profile or authentication credentials if you are registered on the Sites;
• Improve the Sites and to better understand your use of the Sites;
• Integrate with third-party social media websites;
• Serve you with interest-based or targeted advertising;
• Observe your behaviors and browsing activities over time across multiple websites or other platforms; and
• Better understand the interests of our Sites users.

Some cookies are required for certain uses of the Sites. For example, if you choose to register an account through the Sites, we will use cookies to facilitate your registration and remember your preferences.

Cookies are either “session” cookies, which are deleted when you end your browser session, or “persistent” cookies, which remain until you delete them or the party who served the cookie removes it.

 

Different types of cookies may be used for specific purposes, for example:

 

Cookie categories

Required cookies These cookies are required to enable core functionality and must be accepted for some Sites to work. They can be used for authentication, security or localisation purposes. Without these cookies, services you have asked for, like adding items to your shopping basket, cannot be provided. If you disable these cookies certain parts of the Sites will not function for you, for example, adding items to your basket, proceeding to checkout.

Functional and performance cookies These cookies help us improve or optimise the experience we provide. They allow us to measure Site usage and improve performance. These cookies help us understand how visitors interact with Claire’s Sites and we use this information to improve user experience and performance.

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. They remember the websites you visit and that information is shared with other parties such as advertisers. We may share this information with other parties, including our partners.

Social media cookies These cookies are used when you share information using a social media sharing button on a Site or other interactions you take on our Sites. The social network will record that you have done this. This information may be linked to targeting/advertising activities.

 

You may also use your device or browser settings to disable certain tracking technologies. For example, you may turn off location tracking through your device’s or browser’s settings to disable the Sites’ location tracking technologies, or set your browser settings either to receive our cookies or to use our Sites without cookie functionality. Please note that if you restrict the use of tracking technologies, some functions of the Sites may be unavailable, and we may not be able to present you with personally-tailored content.

We may link the information collected by tracking technologies with other information we collect from you pursuant to this Privacy Notice. Similarly, the third parties who serve tracking technologies on our Sites may link personal data we collect from you to other information they collect.

For more information on how Google Analytics uses data collected through the Sites, visit: www.google.com/policies/privacy/partners/. To opt out of Google Analytics cookies, visit: http://www.google.com/settings/ads and https://tools.google.com/dlpage/gaoptout/.

To opt out of Adobe cookies, visit: https://www.adobe.com/privacy/opt-out.html.

You may opt out of Facebook Custom Audience by logging into your Facebook account and changing your privacy or advertising settings as per Facebook’s opt-out instructions. You may also use your Facebook account settings to unlink your Facebook account from the Sites.

For information on how Microsoft collects or receives personal information through tracking technologies to provide Microsoft Advertising, see the Microsoft Privacy Statements: https://privacy.microsoft.com/en-us/privacystatement.

To opt out of Mouseflow, visit: http://mouseflow.com/opt-out.

For more information on our use of tracking technologies and cookies, contact us at [email protected].

How Long We Retain Your Personal Data

We will store your personal data for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove personal data from our systems and records or take appropriate steps to properly anonymize it.

Social Media and Links to Third-Party Online Services

The Sites may contain links to, or features facilitated by, other websites or online services. We are not responsible for the privacy practices, advertising, products, or content of websites or online services that we do not control. Please note that other online services have their own privacy policies and we are not responsible or liable for these policies.

The Sites may permit you to interact with another website or online service, such as enabling you to “like” Claire’s on another site or “share” content from the Sites with other sites (a “Social Features”). If you choose to “like” or “share” content or post information using Social Feature, that information may be publicly displayed, and the other party may have access to certain information about you and your use of the Sites. Similarly, if you interact with us through Social Features, we may have access to information about you (for example, if you “like” or “follow” our page on another website). Please note that if you mention or comment about Claire’s or the Sites in your post to another platform, that platform may, where legally permissible, allow us to publish your post on the Sites. You may also choose to use Social Features on the Sites, such as by posting a review or logging into the Sites with your username and password for another website (for example, using “Facebook Connect”). Use of such a feature may allow us to collect (or the other party to share) information about you, including your personal information.

Claire’s may share with Facebook actions that you take on our Site such as your visits to our Sites, your interactions on our Sites, information collected from cookies or similar technologies including the Facebook pixel data collected from logging into our Site using Facebook Connect and the ads you see. This allows us to measure the effectiveness of our advertising, improve our marketing practices, and helps us deliver more relevant advertising to you and people like you (including on social media such as Facebook). Claire’s are Joint Data Controllers with Facebook Ireland for this processing. This arrangement means that Claire’s has to provide you this notice, but you should contact Facebook if you wish to exercise your data protection rights. Further information, including how Facebook enables you to exercise your data protection rights, and subsequently processes your information as independent data controller can be found in Facebook Ireland's Data Policy. If you would like to know more, please contact us at the details outlined below (see Who can I contact with questions or concerns)

In addition, we may receive information about you if a user of another website gives us access to their profile and you are one of their “connections”, or information about you is otherwise accessible through that other user. We may also use your personal information to tailor and deliver communications to you and other people like you, including on social media. If you do not want your data used in this way, feel free to contact us at the details outlined below.

 

 

Personal Data Transfers

As Claire’s operates globally, we do need to transfer your personal information internationally. In particular, your personal information will be transferred to and processed in the United States.

Where information is transferred outside the UK, the European Economic Area or Switzerland, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission or the UK Government, data is adequately protected by EU Commission approved standard contractual clauses or a vendor's Processor Binding Corporate Rules. For further information on the specific mechanism used to transfer your personal data, please contact us at [email protected].

Your Rights and Choices

Subject to certain conditions, where the rights apply under applicable law, you may ask us to take the following actions in relation to your personal data:

• Provide you with information about our processing of your personal data and give you access to your personal data.
• Update or correct inaccuracies in your personal data.
• Delete your personal data.
• Transfer a machine-readable copy of your personal data to you or a third party of your choice.
• Restrict the processing of your personal data.
• Object to our processing of your personal data for direct marketing purposes.
• Object to reliance on our legitimate interests as the basis for processing of your personal data.
• Where consent is the lawful basis, withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in the GDPR, UK GDPR, its local implementing legislation and the UK Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.

You may exercise some of these rights and choices through Site features such as editing your account settings when you are logged in. Additionally, you can submit these requests by email to [email protected] or our postal address provided below. We may request specific information from you to help us confirm your identity prior to processing your request. If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction. You can find information about your data protection regulator here.

How to Contact Us

To make a query, raise a concern, or exercise your data protection rights, please contact us at [email protected].

The data controller for your personal data is Claire’s Stores Inc., which you may contact by via email at [email protected] or at the following address:

Claire’s Stores, Inc.

2400 West Central Road

Hoffman Estates, IL 60192

USA