Effective Date: DEC 7th, 2017. Prior policy available here.
Introduction
This Privacy Policy describes how SECRET DOLLS collects, uses, and shares information about you through websites ｏｒ mobile apps operated by us from which you are accessing this Privacy Policy (the "Websites"), through our social media pages (our "Social Media Pages") as well as through email messages that we may send to you that link to this Privacy Policy (collectively, including the Websites and our Social Media Pages, the "Services").
This Privacy Policy does not apply to our data collection activities offline ｏｒ otherwise outside of our Services (unless otherwise stated below ｏｒ at the time of collection). By using our Services, you agree to our Terms of Use. By consenting to this Privacy Policy you consent to our collection, use and disclosure practices, and other activities described in this Privacy Policy. If you do not agree and consent, discontinue use of the Services, and uninstall Service downloads and applications.
“Personal Information” is information, whether true ｏｒ not, that can be used to identify you (whether alone ｏｒ in combination), which may include:
Name
E-mail address
Postal Address (including billing and shipping address)
Geolocation information
Telephone number
Fax number
Bank information and credit references (if applicable)
Arrow Account Number
Credit ｏｒ debit card number.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Subject to applicable law, your continued use of our Services indicates your consent to the privacy policy posted. If the changes are material, we may provide you additional notice, to your e-mail address.
HOW WE COLLECT INFORMATION
Information You Give Us
We may collect Personal Information you provide directly to us via the Services. For example, Personal Information may be collected when you use ｏｒ register for our Services, subscribe to our notifications, post on our Services, participate in promotional activities, apply for a job, communicate with us through the Services, ｏｒ use an app installed on a device. You may choose to voluntarily submit certain other information to us through the Services, including Personal Information, but you are solely responsible for your own Personal Information in instances where we have not collected such information ｏｒ requested that you submit such information to us. De-Identified Data Personal Information once “de-identified” may not be subject to this Privacy Policy and we and our Service Providers (defined below) may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.
Information We Collect Automatically From Your Use of Our Services
We and our Service Providers collect information about the Services that you use and how you use them. Certain information is collected automatically through your device, such as your IP address; device identifier, Ad ID, browser type; operating system characteristics; information about your use of our Services; and data regarding network connected hardware (e.g., computer ｏｒ mobile device) (“Usage Information”). To the extent that Usage Information is Personal Information under applicable law ｏｒ is combined with Personal Information, we will treat that information as Personal Information under this Privacy Policy.
The methods that we and our Service Providers may use to collect Usage Information include:
Log Information: We collect information about your use of our Services, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, cookies that may uniquely identify your browser ｏｒ your account, and related data, and store it in log files.
Information Collected by Cookies and Other Tracking Technologies: We and our Service Providers may use cookies ｏｒ other tracking technologies (“Tracking Technologies”) to collect and store information about interactions with our Services, including information about your browsing and purchasing behavior. Further information about how we use cookies and tracking technologies, and how you can refuse them, is set out in our Cookie Policy.
We are giving you notice of the Tracking Technologies and your choices regarding them explained in Section 13 so that your consent to encountering them is meaningfully informed.
Personal Information Collected from Other Sources
We may receive your Personal Information from other sources, such as public databases, joint marketing partners, and social media platforms, and combine that with information we collect about you. To the extent we combine such third party sourced information with Personal Information we collect directly from you, we will treat the combined information as Personal Information. We are not responsible for the accuracy of the information obtained from third parties ｏｒ third party practices.
HOW WE USE INFORMATION WE COLLECT
We and our Service Providers may use information about you for the following purposes:
To provide, maintain, protect and improve our Services, develop new services, and protect SECRET DOLLS and our users;
To facilitate, manage, personalize and improve your online experience;
To respond to your inquiries and fulfill your requests, such as to send you newsletters, brochures, catalogs and e-mails;
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving, ｏｒ modifying our Services, identifying usage trends, and operating and expanding our business activities; and
To send you advertisements and communicate with you about products, services, offers, promotions, rewards and events we believe may be of interest to you (for information about how to manage these communications, see Section 13).
Marketing Purposes
If you are a user from the United States, we may use your Personal Information for direct marketing purposes. If you are a user from outside the U.S., we will not use your Personal Information for direct marketing purposes unless we have received your express consent. As a Non-U.S. User, you have the right to opt-out from direct marketing and can require us to cease using the data at any time for direct marketing purpose at no cost to you
HOW WE SHARE INFORMATION
Our agents, vendors, consultants, marketing service providers, and other service providers (collectively “Service Providers”) may receive, ｏｒ be given access to your information, including Personal Information and Usage Information, in connection with their work on our behalf. These Service Providers may be located in countries other than your country of residence. These Service Providers are prohibited from using your Personal Information for any purpose other than to provide this assistance, although we may permit them to use de-identified data ｏｒ aggregate information which does not personally identify you ｏｒ any other user of the Services (for example, we may aggregated Personal Information to calculate the percentage of our users who have a particular telephone area code).We may also share information about you as follows:
As necessary, for the following purposes: (a) to comply with legal process; (b) to respond to requests from public and government authorities, including public and government authorities outside your country of residence to meet national security ｏｒ law enforcement requirements; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety ｏｒ property, and/ｏｒ that of you ｏｒ others; and (e) to allow us to pursue available remedies ｏｒ limit the damages that we may sustain;
With our affiliates for internal business purposes. For example, processing your orders, fulfilling your requests, providing customer service, and improving our products;
With our subsidiaries, affiliates, business partners, and other third parties for their own business purposes. For example, improving their products and services; and
To a third party in connection with ｏｒ during negotiations of any reorganization, merger, sale, joint venture, assignment, transfer ｏｒ other disposition of all ｏｒ any portion of our business, assets ｏｒ stock (including in connection with any bankruptcy ｏｒ similar proceedings).
When Arrow engages third-party service providers and when disclosure of Personal Information to such providers is necessary for the provision of such service, Arrow ensures that such providers protect Personal Information in a manner consistent with this Privacy Policy and, where applicable, is responsible for ensuring that such third parties process EU Personal Information in a manner consistent with the Privacy Shield Principles discussed below (see Section 15).
Aggregated Information
Without limiting the forgoing, in our sole discretion, we may share aggregated information which does not identify you ｏｒ de-identified information about you with third parties ｏｒ affiliates for any purpose.
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