Last Updated: December 5, 2016
PERSONAL INFORMATION WE COLLECT
In every aspect of our business, we may collect personal information or data. Some of this personal information you may provide to us directly, and some may be passively collected from you as you access and use our Service.
INFORMATION YOU PROVIDE TO US
Examples of personal information that you may provide to us include: your contact information (including your name, physical address, fax number, telephone number, and email address); your date of birth; details about your preferences, product interests, orders and transactions with us; whether you participate or have participated in a membership or loyalty program; whether you participate or have participated in a sweepstakes or marketing program; details about your personal characteristics, nationality, and income; and your reviews and opinions of our products or services.
The term "sensitive information" refers to information related to your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership. We do not generally collect sensitive information unless it is specifically volunteered to us by you.
The following are examples of features on our service where you may provide us with your personal information:
- Membership and Rewards Programs: When you enroll in a membership or rewards program through our Service, such as our Charm Club Program, we may ask you for certain personal information, including your name, e-mail address, mailing and billing address, phone number, and date of birth. You may also create and share with us login information that we will store in connection with your account, including a user ID and password. When you manage your membership or rewards program profile online, you may have the opportunity to provide additional information about your language preferences, payment information, and email subscription preferences. In addition, when you use our Service while logged in to your membership or rewards program account, you may have the opportunity to share your product preferences with us by "favoriting" items.
- Purchases: When you make purchases through our Service we may request certain personal information, including your name, your mailing and billing address, your telephone number, and your payment information. For more information about collection and use of your payment information, please read the section above labeled "Payment Information."
- Surveys: If you choose to participate in a customer survey, we may request demographic data or other personal information.
- Social Media: If you choose to participate in our sponsored social media activities or offerings, you may choose to give us access to certain information from your social media account consistent with your settings within the social media service, such as your location, check-ins, activities, interests, demographics, photos, status updates and friends list. You should understand that you are subject to the terms and conditions and any privacy policies of the social media site when using and sharing information on that site, and Charming Charlie is not responsible for the use and collection of your information on any third-party website.
- Information You Post: All information you share about yourself in a public, open forum, whether it can personally identify you or not, will be considered public information for the purposes of this policy.
- Refer-a-Friend: From time to time, we may offer a feature that allows you to send an electronic postcard or otherwise share a message with a friend. If you choose to do so, we may ask you for the recipient's name and email address, along with the text of any message you choose to include, and we may identify you when we reach out to your friend. [While the information you provide about your friend may be used to facilitate the communication, it will not be used for other marketing purposes unless your friend consents to such use.] By using this feature, you represent that you are entitled to use and provide us with the recipient's name and email address for this purpose.
AUTOMATICALLY COLLECTED INFORMATION
In addition to personal information you provide to us directly, we may gather and store information about you automatically when you access and use our Service using tracking technologies, such as cookies, web beacons, embedded scripts, browser fingerprinting, entity tag, recognition technologies, and GPS or other location-identifying technologies. Examples of information that may be collected and stored automatically include: certain details about your browser, operating system, and hardware; your location; the URL that referred you to our Service; your activities on our Service; your mobile service provider (if accessing our service with a mobile device, like a smart phone); and the date and time of your visit to our Service. This browsing information is linked to your anonymous IP address (or another unique device identifier) and not to you personally. If for any reason your browsing information is linked to information that can personally identify you, we treat it as personal information.
THIRD-PARTY TRACKING AND DO NOT TRACK
PERSONAL INFORMATION WE COLLECT FROM THIRD PARTIES
In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from information we receive using third-party analytics services, as described below under "Analytics Services and Targeted Ads." We may also collect information about you from our partners, from social media sites, and from other third-party sources. For instance, we may receive your telephone number or mailing addresses from our partners or from other sources, which we may use for telemarketing purposes. We may append this information to the information we have on file for you and share it with others consistent with this Policy.
ANALYTICS SERVICES AND TARGETED ADS
We may use third-party analytics services, which track details about your online activities over time and across different sites. These services help us to improve our site and the products and services that we offer you. These services may also allow us and others to provide you with targeted advertisements or other content that you may be interested in based on your online activities. If you would like to learn more about targeted ads that may be based on your online activities, and the choices that you may exercise for certain sites and advertisers, you may wish to visit the Network Advertising Initiative or the Digital Advertising Alliance.
USE OF PERSONAL INFORMATION COLLECTED ABOUT YOU
We may use your personal information for a variety of purposes, including to: (1) facilitate your online shopping and provide the products and services you request from Charming Charlie, or which are part of a program you have joined or a purchase you have made, including processing online purchases and e-mailing purchase receipts; (2) provide you with information about marketing, promotions, and meeting and event planning services; (3) improve Charming Charlie's products and services to provide you with the expected level of products and services; (4) ensure our site, products and services are of interest to you; (5) process enrollments and applications; (6)facilitate collections; and (7) provide or offer you newsletters, promotions and featured specials, other marketing communications, product or service awareness marketing, to conduct surveys, sweepstakes, prize draws, and other contests. We may provide these communications online, via email, telephone, mobile/text messaging (including SMS and MMS) and postal mail.
We may also aggregate your personal information, including your date of birth, gender, marital status, and location, with data from third-party sources for purposes of data hygiene and analytics, as described above under the heading "Analytics Services and Targeted Ads." As long as this data is anonymized, it may be used and disclosed in a variety of ways. If any data is tied to personally identifying information about you, such as your name, we will treat it as personal information and it will be protected as such.
HOW WE SHARE YOUR PERSONAL INFORMATION.
Our Service is operated in the United States. If you are located outside of the United States, please be aware that information we collect, including personal information, will be transferred to, and processed, stored, and used in the United States by us as well as by our third-party service providers. As noted above, different countries have different data protection laws, so please be aware that the United States data protection and privacy laws may differ from the laws in your own country. By using our Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including personal information, in the United States.
As a global company, we endeavor to provide you with the same level of service that you have come to expect at Charming Charlie whether you are in Houston, New York City, or LA. To provide this service, we may share your personal information among members of the Charming Charlie companies, franchisees or service providers and business partners that may be located in countries outside your own. Although the data protection laws of these various countries may not be as comprehensive as those in your own country, Charming Charlie takes appropriate steps to ensure that your personal information is handled as described in this Policy.
- Franchises: We may share personal information with owners and operators of Charming Charlie franchises.
- Electronic Receipt Program: If you participate in electronic receipt program, billing information will be shared with the credit card provider and if you use a corporate credit card, possibly, your employer.
- Business Partners: From time to time we may partner with other companies to provide products or services and may share your information with our business partners to provide those products or services to you.
- Co-Sponsors of Promotions: We also may co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies, or we may provide prizes for sweepstakes and contests sponsored by other companies. If you enter one of these sweepstakes or contests, we may share your information with our co-sponsor or the third-party sponsor.
- Service Providers and Business Partners: We rely on service providers to provide certain products and services, such as to facilitate administrative functions and information technology operations, credit card billing, online ordering/return services, fulfillment services, administering our membership and loyalty programs, providing services in connection with our websites, communicating news and delivering promotional and transactional materials via email and via online and mobile advertising; processing credit card transactions, data hygiene and enhancement services; professional services such as accounting, auditing and legal advice; investigating accident reports; processing insurance claims; and administering sweepstakes, prize draws, competitions and customer surveys. Charming Charlie will disclose personal information to service providers and business partners as appropriate.
- Business Transactions: As we develop our business, we might sell, buy, restructure or reorganize businesses or assets. In the event of a merger, consolidation, sale, liquidation or transfer of assets, Charming Charlie may, in its sole and absolute discretion, transfer, sell or assign information collected, including, without limitation, information you have provided to us and information we have automatically collected about you, to one or more affiliated or unaffiliated third parties.
- Telemarketing: If you purchase products from Charming Charlie or its website or are a member of any of our loyalty or membership programs, we may share your telephone number among our Affiliated Companies for purposes of telemarketing.
- Other: In addition, Charming Charlie may disclose personal information in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of Charming Charlie, site visitors, customers, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites' terms and conditions, and (vii) respond to an emergency.
RETAINING PERSONAL INFORMATION
We retain personal information about you for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by applicable law.
PERSONAL INFORMATION FROM CHILDREN
We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission. In accordance with the Child Online Privacy Protection Act, in the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any personal information from or about a child, please contact us immediately by writing to Charming Charlie Customer Privacy Department, Attn. to Legal, 6001 Savoy Drive, Houston, Texas 77036, USA.
LINKS TO THIRD-PARTY WEBSITES
Our Service may contain links to third-party websites, and may allow you to use your account from other online services, including social media providers (such as Facebook, Instagram and Twitter). For example, we may use third parties to allow you to send messages, tweets, or make postings on social media sites, like Facebook. If you use accounts from other services on our Service, those third parties may share information about you with us, and we may share information that we collect with them. In addition, Charming Charlie may maintain social media accounts or fan pages where you may be able to post information and materials on sites that are owned or operated by a third party.
Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties.
PROTECTING PERSONAL INFORMATION
Charming Charlie takes reasonable measures to: (1) protect your personal information from unauthorized access, disclosure, alteration or destruction; (2) keep your personal information accurate and up-to-date, as appropriate; and (3) ensure our affiliates and service providers with whom we share your personal information exercise reasonable efforts to maintain the confidentiality of such personal information. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure, and we do not control the data security practices of any third-parties.
For your own privacy protection, we encourage you not to include sensitive personal information in any emails you send to us. Additionally, please do not send credit card numbers or other payment information to us via email.
We will not contact you by mobile/text messaging or email to ask for your confidential personal information or credit card details. We will only ask for your confidential personal information or credit card details by telephone when you are making a purchase by telephone. We will not contact you to ask for any membership or loyalty program account log-in information. If you receive this type of request, you should not respond to it. We also ask that you please notify us at helpdesk@CharmingCharlie.com.
CHANGING AND ACCESSING YOUR PERSONAL INFORMATION
If you are a member or one of our loyalty or membership programs, or if have an account on our website, you may access, review and update the information you provided to us at the time of registration any time by signing in to your account with our Service.
To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct and/or suppress personal information about you that we maintain in our active database. We will make all required updates and changes within the time specified by applicable law and, where permitted by law, we may charge an appropriate fee to cover the costs of responding to any such request. Such requests must be submitted in writing to the following address: Charming Charlie Customer Privacy Department, Attn. to Legal, 6001 Savoy Drive, Houston, Texas 77036, USA. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us. Please remember that if you make such a request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.
In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or that Charming Charlie cease using personal information about you by sending your written request to Charming Charlie Customer Privacy Department, Attn. to Legal, 6001 Savoy Drive, Houston, Texas 77036, USA. We will honor any such requests consistently with applicable law.
CHOICES – MARKETING COMMUNICATIONS
If you have given us your contact information (mailing address, fax number, email address or phone number), we may want to inform you about our products and services or invite you to events by email, telephone, mobile/text messaging (including SMS and MMS) or post.
If you are a member of one of our membership or loyalty programs or have an online profile, you may receive additional communications from us, including loyalty program statements, current status, points reminders, third-party news and offers, and co-branded messages from our business partners. You may change the communications you receive from us by: (1) logging on to your online account and managing your subscriptions; (2) using the "unsubscribe" function in any marketing e-mails; or (3) writing to us (and including your email address and your specific request) at Charming Charlie Customer Privacy Department, Attn. to Legal 6001 Savoy Drive, Houston, Texas 77036, USA.
If you opt-out of any of our communications, we aim to update your communication preferences promptly, and we will do so within any legally imposed deadline. Please note, however, that if you change the communications you receive from us as described above, we will not be able to remove your personal information from the databases of affiliates, franchisees or business partners with whom we have already shared your personal information (i.e., to whom we have already provided your personal information as of the date of your opt-out request).
SPECIAL NOTIFICATION FOR CALIFORNIA RESIDENTS
Individual customers who reside in California and have provided their personal information to Charming Charlie may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. You can submit such a request by writing to us at Charming Charlie, Attn. to Legal, 6001 Savoy Drive, Houston, Texas 77036, USA. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
SPECIAL NOTIFICATION FOR EUROPEAN RESIDENTS
Individual customers who are residents of a member state of the European Union may have the right to ask us not to process their personal information for marketing purpose. You can submit such a request by writing to us at Charming Charlie, Attn. to Legal, 60001 Savoy Drive, Houston, Texas 77036, USA.
We may modify this Policy from time to time. When we make material changes to this Policy we will prominently post a link to the revised Policy on the homepage of our site (www.charmingcharlie.com). You can tell when this Policy was last updated by looking at the link and at the date at the top of this Policy. Any changes to our Policy will become effective upon posting of the revised Policy on the site. Use of the site following such changes constitutes your acceptance of the revised Policy then in effect.
If you have any questions about this Policy or how Charming Charlie processes your personal information, please contact us by calling 1-888-675-2275 or by sending us postal mail at Charming Charlie Customer Privacy Department, Attn. to Legal 6001 Savoy Drive, Houston, Texas, USA.
DEFINITIONS OF TERMS USE IN PRIVACY STATEMENT
When you visit our ecommerce sites, web beacons will recognize specific cookies that have been placed on your browser. Web beacons can convey information that a browser with a recognized cookie has accessed a page or a certain part of a page on our website, depending on where the web beacon is located on the website. For example, a web beacon located on our purchase confirmation page will record that a browser with a recognized cookie accessed that page which means that we can conclude that the browser was used to purchase a product. The web beacon does not, however, tell us that you specifically (by reference to PII) have purchased a product because the cookie is only the browser’s identification card; it is not your personal identification card.
We use web beacons to measure the effectiveness of our advertising campaigns and to improve our websites by recognizing which pages are visited and whether those visits result in purchases. Web beacons also allow third-party advertising companies we work with to select and serve banner advertisements to your browser that you would be most likely to be interested in.
We work with industry-leading business partners who help us operate our websites and provide important services to our customers and visitors. Our business partners may change over time but we are committed to building relationships with third parties who are dedicated to providing you a safe and satisfying experience on our websites. Our business partners are obligated to collect and use any information collected from you on a Charming Charlie site or on behalf of Charming Charlie in a manner that is consistent with applicable data security laws.
Third-Party Advertising Companies
We allow certain companies to collect information from browsers of our websites to use to serve interest-based ads. These companies are usually third party ad servers, ad agencies, technology vendors or providers of sponsored content. Using cookies and web beacons, these companies collect data from a particular browser about web viewing behaviors over time and across unrelated websites and use such data to predict user preferences and to deliver advertisements to that browser which are calculated to target that browser’s predicted preferences.
Information collected through cookies and web beacons to keep track of what products you viewed and purchased and what areas or pages you viewed on our websites is called "analytics data". We use analytics data to improve the design and content of our websites, to help us learn things like what pages are most attractive to all of our visitors and what promotions visitors like to see, and to gauge the success of our advertising campaigns.
Interest-based advertising has become commonplace across the Web. It is the term we use for the activity that enables us to tailor ads to your interests and activities. Either Charming Charlie or third-party advertising companies we work with may look at your browsing activity, such as the types of content you access, ads you click on, and searches you conduct. We can then infer certain interests you have and place ads and offer you deals that meet your needs. Our goal for interest-based advertising is to show ads to people likely to be interested in the products we offer at Charming Charlie.
If you have questions, feedback or need assistance, don't hesitate to contact us.