Last update: May 25th 2018
Ralph Lauren Europe Sàrl (24, route de la Galaise, 1228 Plan-les-Ouates, Switzerland) and its affiliated companies in Europe, Switzerland and Turkey, together “Ralph Lauren”, “we” or “us” respect your concerns about privacy and recognize the importance of being transparent regarding the personal information we collect about you.
This Privacy Notice applies to personal information we collect in connection with our products and services, for example when you visit our European websites (collectively “Websites”) and or any store operated by Ralph Lauren under any brand in the European Economic Area, Switzerland and Turkey (collectively “Stores”), when you engage with us through social media platforms or when you contact our Customer Assistance.
Ralph Lauren Europe Sàrl is the data controller and is responsible for the processing of this information. Each of Ralph Lauren Europe Sàrl’s affiliated companies in Europe, Switzerland or Turkey may also act as data controller in relation to the personal information collected in the Store you visit, to process your purchases and requests and to improve your customer experience.
This Privacy Notice describes the types of personal information we collect about you, how we may use that information, with whom we may share it and the rights you have regarding our use of that information. This notice also describes the measures we take to protect the security of the personal information, how long we retain it and how you can contact us to exercise your rights.
This Privacy Notice may be updated periodically to reflect changes in our personal information practices or relevant laws. We will post a prominent notice on the site and/or send you an e-mail to notify you of any significant changes and indicate at the top of the notice when it was updated.
WHAT PERSONAL INFORMATION DO WE COLLECT?
This section explains, for each situation, what personal information we may collect directly from you (either on a voluntary basis or through automated means) and what personal information may be collected (or we may receive) from other sources.
At the moment of collection, we will inform you whether the provision of personal information is optional or mandatory for us to provide a particular product or service. Where the collection is mandatory, we may not be able to provide you with the product or service you requested if you choose not to provide that information to us.
Please note that our products and services are not directed to children under the age of sixteen and we do not knowingly collect information from children under the age of sixteen. If we become aware that we have inadvertently received personal information from a customer under the age of sixteen, we will delete the information from our records.
When you purchase our products or use our services online or in-store
• For any type of purchase, we will collect your credit card numbers and other payment information. We will keep your shopping history (what you bought, when and where you bought it and how you paid for it) if we can relate the purchase to your account.
• If you are in contact with our Customer Assistance in connection with our products or services, we will record our calls for security and training purposes, and to improve the services we provide to you. We may also collect additional information through your correspondence with us.
• If you purchase an item or gift card or ask us to deliver your purchase to someone else, we will collect the recipient’s name, postal address and email address to send the item or gift card to the recipient. If you ask us to do so, we also may use this information to notify the recipient of your gift before it arrives.
• If you use our complimentary personal styling service (available exclusively at our Regent Street flagship store in London), we will collect names and contact details to book an appointment for you and your friends. We may also collect product sizes and fits and any other information you may voluntarily provide to offer you and your guests an enhanced service and personalise your experience with Ralph Lauren.
When you visit our Websites
• We obtain certain information by automated means when you visit our Websites, such as through cookies and web beacons. Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site. The information we collect in this manner may include the IP address of the device you use to connect to the Internet, information regarding your browsing behavior (such as the date and time of your visit, the time you spend on each page, the ads you click on or the website you link from) or the contents of your virtual shopping bag between visits.
• We may also collect information about your online activities from third-party websites on which our ads are served. You may see certain Ralph Lauren ads on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities and to show you advertisements tailored to your individual interests.
• If you decide to register to “My Account”, we will collect your name, address, e-mail address, country of residence, telephone number, username and password. You may also choose to provide us your gender, date of birth and to store billing and shipping information as well as credit card information, wish list of products or address book on a voluntary basis. We will also give you the opportunity to opt in to receive Ralph Lauren marketing communications.
• Our Websites may contain links to other websites or offer third party services applying their own privacy policies to the collection of other personal information. These websites or services may be operated by companies not affiliated with Ralph Lauren. We strongly recommend you to read their privacy policies if you visit any of these websites or use any of these third party services. We are not responsible for the content of any website or third party service not affiliated with Ralph Lauren.
When you visit our Stores
• We may collect your image on CCTV which our Stores use for the prevention and detection of crime and for protecting the safety of our customers. We may also use CCTV technology for traffic counting without collecting personally identifiable data about you.
• Depending on the selected payment method, we may collect a copy of documents you provide to prove your age or identity where required by law. Such documents may provide details of your full name, address, date and place of birth, gender and nationality.
• We may also collect information about your device (including MAC address, connection date, time and location) through sensors (only if your Wi-Fi is turned on) for store analytics. We will inform you by posting signs where sensors are used to collect this information. If you want to disable this functionality, please turn off Wi-Fi in your device settings.
• If you decide to use our complimentary Wi-Fi services, we will collect your e-mail address and connection information (such as your IP address and connection date and time). If you access the Wi-Fi by signing up through your social media account, we may also access and collect your public information on social media, except where your interests or fundamental rights and freedoms would outweigh our legitimate interest to collect that information.
• If you decide to join our Customer Registry, we will collect your name, postal address, e-mail address and telephone numbers. You may also choose to provide us with your birth date and your gender on a voluntary basis. We will also give you the opportunity to opt-in to receive Ralph Lauren marketing communications.
• As part of our clienteling programme, we may collect information relevant to you (such as your contact information, purchase history, product or lifestyle preferences, important dates or events, size information, etc.) to offer you highly personalised shopping experiences in our Stores.
When you participate in surveys, competitions, events or promotions
• We may collect your contact information including name, e-mail address and country of residence, mobile number, as well as your gender or birth date. We will always let you know whether providing the information is mandatory or optional, as well as any consequences for not providing the requested information.
• We may also collect any personal information submitted or received through customer surveys, competitions and events such as your feedback, responses, shopping preferences or image.
When you contact us or we contact you
• When you contact or are contacted by our Customer Assistance, we may collect information such as your name, address, e-mail address, telephone number, date of birth, payment information, shopping history and records of correspondence.
• If you contact us or we contact your on our social media pages, we may collect your social media username, your comments, questions or feedback.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We will use and process your personal information for the purposes described in this section. Please note that one or more purposes may apply simultaneously to the same personal information.
We may use your e-mail address to confirm your order and to send you marketing communications
To provide our products and services
• We will process the relevant personal information described in the previous section to provide you the products and services you have requested.
• We rely on the contract we have with you as the lawful basis to process your personal information for such purpose. If you choose not to provide the information, we have requested from you, we may not be able to perform properly our contractual obligations.
• When you purchase products on one of our Websites, we will use your name and address to deliver the products and your credit card details to effect payment.
• When you participate in a prize draw organized by Ralph Lauren, we will use your name, e-mail address and mobile number to administer the prize draw and communicate with you if you win.
To communicate and interact with you
• If you have given us you consent through an appropriate mechanism such as ticking a box, managing technical settings or any other action indicating clearly your consent, we will use your contact information to send you offers, news and updates about our products, services and events via the channel you have chosen (such as e-mail or mobile phone). We will personalise and tailor these communications to your preferences and interests based on our legitimate interest to improve your customer experience as explained in the next section.
• You can choose at any time to unsubscribe from marketing e-mails by clicking on the unsubscribe link included in each e-mail (or by contacting our Customer Assistance or Data Protection Officer if the unsubscribe link is not available). If you have opted in to receive text messages, you may opt out at any time (for example, by sending a ‘STOP’ text to a short number) free of charge (except the cost of sending the message).
• Based on our legitimate interest to do so, we may use your contact information to send you marketing communications by postal mail (you may opt out of receiving postal communications at any time by contacting our Data Protection Officer or Customer Assistance). We may also contact you about our services, for example to ask you to provide feedback about your experience in our Stores or to participate in a survey.
• We may send you communications required by law or which are necessary to inform you about our changes to the services we provide you (for example, updates to this Privacy Notice, product recall notices and legally required information relating to your orders). These messages will not include any promotional content and do not require your prior consent when sent by email or text message. If we do not use your personal information for these purposes, we will be unable to comply with our legal obligations.
To improve our products and services and personalise your experience with Ralph Lauren
• We may use your personal information to understand your preferences, offer you products and services which are more relevant to you, deliver content and show you advertisements tailored to your interests, and send you personalised communications (if you have opted-in to marketing communications).To process your information, we rely on our legitimate interest to improve our products and services and personalise your customer experience.
• offer you a customized browsing experience and provide you with a great shopping experience, for example by capturing the pages you have browsed or products you have viewed and remembering your choices and preferences (through functionality cookies).
• show you interest-based advertising on third party websites after you have shown interest in our products or services (through third party advertising cookies). The objective is to make our online offers even more interesting for you.
Through the Facebook pixel added on our Websites, Facebook can determine a group of users who have visited our Websites as a target audience for the presentation of Ralph Lauren ads on Facebook (‘Custom Audience’). This service allows us to display Ralph Lauren ads to Facebook users who have shown interest in our Websites or people who resemble our customers. Facebook's processing of personal data is governed by Facebook Data Usage Policy: https://www.facebook.com/about/privacy. If you are logged into Facebook, you can disable the "Custom Audiences" remarketing feature at any time at https://www.facebook.com/settings/?tab=ads#_=_
• determine advertising effectiveness, for example that you have visited our Websites after clicking on Ralph Lauren ads displayed by third party advertising companies (through analytics cookies) on certain websites you visit.
• Based on our legitimate interest, we may also share limited personal information about you (such as your e-mail address) in an encrypted format with strategic partners (such as Facebook) to allow you to receive targeted advertising when you are visiting other websites.
• We may finally use your personal information to conduct analytics and research based on our legitimate interest to understand our business, customers shopping patterns, trends and behaviors. For example, information collected in Stores through mobile devices may give insights about traffic patterns.
To provide customer support
We may process your personal information if you contact our Customer Assistance (or we contact you through our Customer Assistance). We will collect and process your personal information to perform our contractual obligations in relation with the products or services you have requested and to provide you the best service we can or to comply with our legal obligations.
To identify and prevent fraud and other criminal activities
We use some of the personal information we collect from you based on our legitimate interest or where necessary to comply with our legal obligations to prevent and detect fraud and other criminal activities.
• We may record your image on CCTV for the prevention and detection of crime and for protecting the safety of our customers in our Stores
• We may record your image on CCTV for the prevention and detection of crime and for protecting the safety of our customers in our Stores
WHO DO WE SHARE YOU PERSONAL INFORMATION WITH?
We do not sell or otherwise disclose your personal information except as described in this section.
With other Ralph Lauren Companies
We may share your personal information with our affiliated companies, with Ralph Lauren Corporation and Club Monaco US, LLC in the United States, for the purposes described in this Privacy Notice.
With our Service Providers
We may also share personal information with our Service Providers processing your data on our behalf for the purposes described in this Privacy Notice.
Examples of service providers we may share your data with
• Service provider operating the contact centre to provide Customer Assistance to users of our Websites
• Transportation companies delivering products purchased on our Websites to our customers.
• Companies providing technical support and infrastructure for ourWebsites.
Where our service providers need to have access to your personal information, we will (1) select providers who respect your privacy and comply with data protection laws at any time ; (2) only give them access to the information they need to perform their services; (3) ensure that they will only use the information for the purposes agreed in our contract with them; (4) ask them to delete or return any personal information when we stop using their services.
Other reasons for sharing personal information:
We may also disclose personal information about you (1) if we are required to do so by law or legal process (such as court order), (2) in response to a request by law enforcement authorities, or (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or suspected or actual illegal activity.
We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use the personal information you have provided to us in a manner consistent with this Privacy Notice. Following such sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that personal information.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We maintain appropriate administrative, technical and physical safeguards to protect the personal information you provide on this website against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use and other unlawful forms of processing.
We use Secure Sockets Layer (“SSL”) technology to protect the transmission over the Internet of your payment card data. You can check the security of your connection by looking at the URL line of your browser. When accessing a secure site, the first characters of the site address change from “http” to “https.” If you are using a web browser or firewall that does not permit communications through secure sites, you will not be able to make purchases on our site.
Transfer of personal information to other countries
We will transfer the personal information we collect about you to our affiliates and third party service providers in other countries that the country in which you originally provided it, including the United States, and that have not been recognized as providing an adequate level of data protection. In this event, we will implement appropriate safeguards to ensure an adequate level of data protection, including selecting service providers that are certified to the EU-US Privacy Shield framework, or executing data transfers agreements based on the European Commission’s Standard Contractual Clauses. You may obtain a copy of these safeguards by contacting us as indicated in the “How to contact us?” section below.
Our US affiliates Ralph Lauren Corporate and Club Monaco US, LLC, are certified to the EU-US Privacy Shield frameworks. Click here to see our EU-US Privacy Shield Certification and and here to read our EU-US Privacy Shield Policy. US companies certified to the Privacy Shield are recognized by the European Commission as providing an adequate level of data protection.
HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?
We keep the personal information we collect for the duration of our relationship with you, plus a reasonable period in order to take into account the applicable legal retention requirement or statute of limitation period, or otherwise as required for our business purposes described above.
If you consent to receive marketing communications, we will keep the information necessary to send you these communications for a period of three (3) years following the end of our customer relationship or following their collection, if you are a prospective customer.
At the end of the retention period, your personal information will be deleted completely or anonymised so that it can be used in a non-identifiable way for statistic and analytical purposes.
WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL INFORMATION?
Subject to applicable law, you may (1) request access to the personal information we maintain about you, (2) request that we update, correct, amend, or erase your personal information or (3) request the restriction of our use of your personal information.
In addition and also subject to applicable law, you may receive, in a structured, commonly used and machine-readable format, the personal information that you have provided to us about you. In appropriate circumstances, you have the right to have this information transmitted to another company, where it is technically feasible.
You also may object at any time to the use of your personal information, on grounds relating to your particular situation, where we use that information based on our legitimate interests as described above.
If we use your personal information to send you marketing communications, you may object at any time and without providing any reasons (e.g., by clicking in the unsubscribe link in our marketing emails or by contacting our Customer Assistance or Data Protection Officer), and we will apply your preferences going forward. You also may withdraw any consent you previously provided to us. If you do so, this will not affect the lawfulness of our use of your information based on your consent before its withdrawal.
If you wish to exercise these rights, please contact our Data Protection Officer as specified in the How to Contact Us section. Please include your name, email address, postal address. and a copy of your identity card or passport in your request. To protect the confidentiality of your information, we will also ask you to verify your identify by providing a copy of your identity card or passport in your request. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
If you have an online customer account, you can also access, amend or update your information by logging into My Account on our Website and amending your details as appropriate.
If you are not satisfied by our response or if you consider your privacy rights have been breached, you may lodge a complaint with a data protection authority, in particular in the EEA country of your habitual residence, place of work or place of our alleged infringement of the European data protection rules.
HOW TO CONTACT US?
If you have any questions or comments about this Privacy Notice, or if you would like to exercise your rights, please contact our Data Protection Officer as indicated below:
Ralph Lauren Europe Sàrl
Attention: Data Protection Officer
24, Route de la Galaise
1228 Plan-Les-Ouates Switzerland