Privacy

 

Ralph Lauren Corporation

 

WEBSITE, STORE AND RESTAURANT PRIVACY NOTICE

Last modified: December 1, 2017

Ralph Lauren Corporation and its affiliates (collectively, “Ralph Lauren”) respect your concerns about privacy.This Privacy Notice applies to personal information we collect (i) on this website, (ii) at Ralph Lauren Stores, Ralph Lauren Factory Outlet Stores (collectively, the “Stores”), and (iii) through the other channels described below. Ralph Lauren is responsible for this website.

The Privacy Notice describes the types of personal information we collect on this site, in our Stores, and in other ways discussed below, how we may use that information and with whom we may share it. The notice also describes the measures we take to protect the security of the personal information. We also tell you how you can reach us to ask us to (i) access, change, or not use the personal information you have provided to us; (ii) withdraw any consent you previously provided to us; (iii) tell us to refrain from communicating with you about our products or services; and (iv) answer any questions you may have about our privacy practices.

 

Information We Collect and How We Use It

Individuals may choose to provide personal information (such as name, contact details, and payment information) through this website, in our Stores, and through the other channels described below. Here are the ways you may provide the information and the types of information you may submit. We also tell you how we may use the information.

Our Website

Shopping

You may be able to purchase Ralph Lauren products and gift cards on this website. To process your purchase, we ask for information such as your name, billing and shipping address, telephone number, email address, and payment card information. We use this information to process your purchase, confirm your order, and deliver the items to you. If you give us permission, we also may use your contact information to communicate with you about our products, services, and promotions.

If you purchase an item or gift card on this site or ask us to deliver your purchase to someone else, we ask for the recipient’s name, postal address, and email address. We use this information to send the gift card or item 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.

My Account

You may be able to register to create an account on this website. To do so, we ask for information such as your name and email address. You also may provide your age and gender.

Through the “My Account” feature, you can Store billing and shipping information so you won’t have to enter it again when you make another purchase on this site. You also can Store payment card information and details of your past purchases. In addition, you can save your credit card information on your account for faster checkout. To use this feature, we ask you to provide your credit card information and the corresponding billing address.

You can also use the “My Account” feature to create a wish list of products you want and share your list by email with friends and family. If you choose to share your list, we ask for your name and email address and the recipient’s email address. This information is used only to email your list to your desired recipients.

You can create and save an address book on your account. You can delete entries in the address book at any time. We will not use or disclose the information you delete from your address book.

 

Surveys, Sweepstakes, and Promotions

On this website, you may be able to participate in surveys, sweepstakes, and other promotions. If you choose to participate in these promotions, we may ask you for information such as your name, email address, postal address, and telephone number. We use the information you provide to administer our contests, sweepstakes and other promotions. We also may use the information to communicate with you about our products, services, and promotions, but only if you have given us your consent to do so.

 

Electronic Newsletters

You may be able to sign up on this site to receive electronic newsletters and promotional emails from Ralph Lauren, including new ideas, special offers and event information. To sign up, we may ask you for information such as your name, email address, postal address, telephone number, age, gender, shopping preferences and email preferences. We use this information to send you communications about our products and services, invitations to specials sales and events at Stores located near you, and notices of new arrivals. We also use this information to tailor our newsletters to reflect your preferences. You can choose at any time not to receive marketing emails from us by clicking on the unsubscribe link within our marketing emails. You also may use the email preferences section of the “My Account” feature to opt out of receiving marketing emails or to specify which, if any, communications you would like to receive from us. There is no charge to you to unsubscribe.

  

Mobile Marketing

You may be able to sign up to receive communications about our products and services through your mobile device by submitting your mobile telephone number online or by texting us. If you sign up for mobile communications, we may send you autodialed marketing text messages about our products, services and promotions. It is your responsibility to notify Ralph Lauren in the event that you disconnect your mobile number or change carriers. In the U.S., you may opt out of receiving text message communications on your mobile device by sending a text message with the word “STOP” to short code 89448. You will receive one additional text message, confirming that your request has been received. Outside the U.S., you may opt out of receiving these communications by contacting us as specified in the “How to Contact Us” section below. Ralph Lauren does not charge you to unsubscribe. Depending on the terms of your mobile phone contract, you may incur charges for receiving and sending text messages on your mobile device. Ralph Lauren is not responsible for these charges. Message and data rates may apply. Text HELP to 89448 for help. Up to ten autodialed marketing messages may be sent per month to the phone number you provide at opt-in. Consent is not a condition of purchase.

  

Blogs

You may be able to submit comments to blogs we host on this website. You may include personal information in your comment, and you also may submit your name with your comment. We use your name to identify you as a commenter.

 

Email to a Friend

You may be able to share certain content from this website with your friends. To send information to your friends, we ask for your friends’ and your email addresses. We use this information only to fulfill your request. We do not retain the information you provide in connection with this feature, except to send the requested content. We will not include any other advertisements within the messages sent to your friends.

 

Contact Us

If you communicate with us through the “Contact Us” link on this site, we may ask you for information such as your name, email address, ZIP code, and telephone number. We use this information to respond to and communicate with you about your questions and comments.

  

Other Site Features

We offer visitors to this website various features for their information and enjoyment, which we may change from time to time. We may ask you to submit certain personal information so we can provide you with these features and send you communications about our products, services, and promotions.

 

Information Collected by Automated Means

We obtain certain information by automated means when you visit our website, such as through cookies, web beacons, and web server logs. The information we collect in this manner includes the IP address of the device you use to connect to the internet, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, dates and times of website visits, and the pages accessed. By collecting this information, we learn how to best tailor our website to our visitors and understand what products and services you might prefer. Both we and others (such as our service providers) may collect personal information about our visitors’ online activities over time and across third-party websites.

Like many companies, we use “cookies” on this website. 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. We use cookies, for example, to preserve the contents of your virtual shopping bag between visits. We also use cookies to measure activity on the site and determine which areas and features of the site are the most popular.

Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Without cookies, however, you may not be able to take full advantage of all our site features. For example, if you turn off cookies or refuse them, you will not be able to make purchases on the site.

Certain pages on this website contain “web beacons” (also known as internet tags, pixel tags, and clear GIFs). Web beacons are used for internal purposes, such as to obtain the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, and the type of browser used to view the page. We also retain service providers who use web beacons to assess the effectiveness of our email communications and learn what pages our visitors viewed.

We use information collected through these automated means for purposes such as (i) customizing our users’ visits to our website, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our sites, and (iii) managing our sites and other aspects of our business. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.

We also may use third-party web analytics services, such as those of Adobe Analytics and Google Analytics, to measure the effectiveness of our advertising and determine how visitors use this website. These service providers’ tools, including cookies and web beacons, allow us to collect information such as the state and ZIP code from which our visitors come and the IP addresses of our visitors’ computers. To opt out of aggregation and analysis of data collected by Adobe Analytics and Google Analytics, please click here and here.

 

Interest-Based Advertising

We may collect information about your online activities on our website to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. This section of our Privacy Notice provides details and explains how to exercise your choices.

You may see certain ads on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based, and contextual means. These partners track your online activities over time and across websites by collecting information through automated means, including through the use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our website and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize Netmining’s targeted advertising services to show you our ads on other websites based on your prior visits to our site and other online activity. You can opt out of this feature by clicking here.

 

You also may opt out of ad network interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/.

 

Our Stores

Here are some of the ways we collect personal information in our Stores and a description of how we use the information:

 

Shopping

When you buy products or obtain services in our Stores, we ask you for information we need to process your purchase or provide you with the services you requested. Depending on the payment method you use, and as permitted by applicable law, we may ask for information such as your name, mailing address, telephone number, driver’s license or ID number, passport number, and checking account information or payment card information. We also collect information about your purchase, such as the items you bought, the price of the items, the payment method you used, and if the product was on sale. We use this information to process your transaction.

 

Customer Registry

You may join our Customer Registry at our Stores. To join, we ask for your name, postal address, email address, and mobile and home telephone numbers. You also may choose to provide us with your birth date and gender. We use this information to communicate with you about our products, services and promotions, and for other marketing and Customer Assistance purposes.

 

Customer Satisfaction Surveys

When you buy products or obtain services in our Stores, we may ask you to complete a customer satisfaction survey. If you choose to do so, you may provide information such as your name, email address, telephone number, age, gender, and other demographic information, in addition to your comments. Providing any of this information is optional. We use the information you provide to improve our products and services, and enhance your shopping experience.

 

Ralph Lauren Credit Card

At some of our Stores, you may obtain and complete an application for a Ralph Lauren credit card. Ralph Lauren credit cards are offered by a third-party credit card issuer. If you choose to complete an application at one of our Stores, at your request, we will forward your application to the issuer or you may submit the application directly to the issuer by postal mail. Ralph Lauren does not maintain any information associated with your credit card application. The information you provide in connection with your credit card application is managed solely pursuant to the issuer’s terms of use and privacy notice. We strongly recommend that you review these documents if you apply for a Ralph Lauren credit card. This Privacy Notice does not govern the collection or use of the information you provide in connection with your credit card application.

 

Other Ways We Collect Personal Information

 

In-Store Wi-Fi Data Collection

In certain Stores, we use a service that analyzes Wi-Fi signals from mobile devices to measure Store occupancy and to identify customer traffic patterns in the Store. The service determines the location of a smartphone or wireless device by observing Wi-Fi or Bluetooth signals that are broadcast from that device. Individual devices are identified by a media access control (“MAC”) address that was assigned to the device when it was manufactured. For the service to collect information from your device, the device’s Wi-Fi must be turned on while you are in the Store. If your device’s Wi-Fi function is enabled, you will receive a pop-up message that asks whether you agree to allow your device’s Wi-Fi data to be collected while you are connected to the in-Store Wi-Fi network. The service provider that collects information from mobile devices in our Stores hashes MAC addresses to anonymize the addresses before using them for analysis purposes. The service provider’s reports to us contain only aggregated statistics about visitors to the Store. If you change your mind after agreeing to allow your device’s Wi-Fi data to be collected, you can opt out by turning off your device’s Wi-Fi function or by clicking here.

 

QR Codes

We use QR codes in connection with certain promotions, contests, and special events. If you scan our QR code, you will get an invitation on your mobile device to join our mailing list. To sign up, we ask you for information such as your name, mailing address, email address, telephone numbers, and age. We use the information to communicate with you about our products, services, and promotions.

 

Customer Assistance

You may call our Customer Assistance line for information about our products or personal shopping advice. If you do so, we may ask you for information such as your name, email address, postal address, telephone number, and, if you choose to make a purchase, your payment card information. We use this information to respond to your request and process your transaction.

  

Ralph Lauren Restaurants and Bars

When you make a reservation at a Ralph Lauren restaurant or bar, including RL Restaurant and The Polo Bar, we ask you to provide your name, telephone number, and email address. In connection with your reservation, you may choose to provide additional personal information such as food allergies and information about others. We use this information to communicate with you, to process your reservation, and to enhance your experience at our restaurants and bars.

When you visit a Ralph Lauren restaurant or bar, we may ask you to complete a form so that we can communicate with you about our products, services, promotions, and special events. If you choose to do so, you may provide information such as your name, telephone number, postal address, and email address. We use this information to process your request.

If you communicate with us through the “Contact Us” link on the RL Restaurant’s website, we ask you for personal information such as your name, telephone number, email address, ZIP code, and other information you may choose to provide. We use this information to communicate with you about your questions and comments. In addition, if you order a gift certificate for the RL Restaurant, we ask for your name, telephone number, shipping address, and payment card information. We use this information to process your order.

Reservations at our restaurants and bars may be made through third-party reservation platforms. We are not responsible for the content of any third-party platforms that are not affiliated with us, any use of these platforms, or the privacy practices of the operators of these platforms.

  

Department Stores

Our products are available for sale in many department Stores. Personal information collected in these department Stores is not provided to Ralph Lauren. This Privacy Notice does not address the information practices of department Stores in which our products are sold. Department Stores may have their own privacy notices or policies, which we strongly suggest you review when you provide them with your personal information. We are not responsible for the department stores’ personal information practices.

 

  

Information We Share

 

We do not sell or otherwise disclose personal information about our customers, except as described here. We may share the personal information you provide to us with our affiliates worldwide, licensees, and joint venture partners for the purposes described in this Privacy Notice. We also may share the information with our service providers who perform services on our behalf based on our instructions. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

As described above, if you apply for a Ralph Lauren credit card at one of our Stores, we may provide the information on your application to the credit card issuer to fulfill your request.

We also may disclose information about you (i) if we are required to do so by law or legal process (such as a court order), (ii) in response to a request by law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of 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 a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

 

Links to Other Sites

This website may contain links to other sites for your convenience and information. These sites may be operated by companies not affiliated with Ralph Lauren. Linked sites may have their own privacy policies, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with Ralph Lauren, any use of those sites, or the privacy practices of those sites.

  

How We Protect Personal Information

We maintain appropriate administrative, technical, and physical safeguards to protect the personal information you provide on this website or in our Stores 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.

We strive to protect the confidentiality and security of Social Security numbers (“SSNs”) in our possession, custody, or control by employing reasonable safeguards seeking to (i) restrict employee access to and use of SSNs, (ii) prevent unauthorized third-party access to SSNs, and (iii) prohibit unlawful disclosure of SSNs.

  

Transfer of Personal Information to Other Countries

We may transfer the personal information we collect about you to recipients in countries other than the country in which you originally provided it. These countries may not have the same data protection laws as the country in which you provided the information. When we transfer your information to recipients in other countries, we will protect that information as described in this Privacy Notice and will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries other than the one in which you provided the information.

If you are located in the European Economic Area (“EEA”), with respect to transfers of personal information to the U.S., Ralph Lauren and its affiliate Club Monaco US, LLC are certified under the EU-U.S. Privacy Shield framework developed by the U.S. Department of Commerce and the European Commission regarding the transfer of personal information from the EEA to the U.S.

 

 

Access and Correction

Subject to applicable law, we provide you with access to personal information we have retained about you and the ability to review, correct, update, block, or delete the information where it is inaccurate. Subject to applicable law, we may limit or deny access to personal information where providing such access is unreasonably burdensome or expensive under the circumstances. Please submit your request to the address specified in the “How to Contact Us” section below. Please include your name, email address, and postal address in your request.

  

Your Choices

We offer you certain choices about how we communicate with you and what information we collect from you. You may withdraw any consent you previously provided to us or object at any time on legitimate grounds and free of charge to the processing of your personal information, and we will apply your preferences going forward.

You can choose not to receive marketing communications from us by clicking on the unsubscribe link in our marketing emails, clicking here, or contacting us as specified in the “How to Contact Us” section below. Please include your name, email address and postal address if you send us your request by email or postal mail. Our website is not designed to respond to “do not track” signals received from browsers.

If you are a California resident, you may ask us to refrain from sharing your information with certain of our affiliates and other third parties for their marketing purposes.

To opt out of aggregation and analysis of data collected by Adobe Analytics and Google Analytics, please click here and here. To opt out of Netmining’s targeted advertising services, click here. To learn how to opt out of ad network interest-based advertising generally, click here or visit http://www.aboutads.info/choices/.

To opt out of Wi-Fi data collection in our Stores after you have opted in, either turn off your device’s Wi-Fi function or click here.

 

Children’s Privacy

This website is not directed to children under the age of 13 and we do not knowingly collect personal information from children under the age of 13 on the site. If we become aware that we have inadvertently received personal information from a visitor under the age of 13 on this site, we will delete the information from our records.

  

Updates to Our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices or relevant laws. We will post a prominent notice on the site to notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was updated.

 

How to Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us as indicated below:

Ralph Lauren Corporation

Attention: Chief Privacy Officer

c/o Legal Department

625 Madison Avenue

12th Floor

New York, New York 10022

 

If you are located in the EEA or Switzerland, please write to:

Ralph Lauren Europe Sàrl

Attention: General Counsel EMEA

24, Route de la Galaise

1228 Plan-Les-Ouates

Switzerland

 

Email: eu.privacy@ralphlauren.com

   

 

EU-U.S. PRIVACY SHIELD PRIVACY POLICY

Effective date: September 20, 2016

 

Ralph Lauren Corporation, along with its affiliate Club Monaco US, LLC (collectively, “Ralph Lauren”), respect your concerns about privacy. Ralph Lauren participates in the EU-U.S. Privacy Shield framework (“Privacy Shield”) issued by the U.S. Department of Commerce. Ralph Lauren commits to comply with the Privacy Shield Principles with respect to Consumer Personal Data the company receives from the EU in reliance on the Privacy Shield. This Policy describes how Ralph Lauren implements the Privacy Shield Principles for Consumer Personal Data.

For purposes of this Policy:

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Consumer” means any natural person who is located in the EU, but excludes any individual acting in his or her capacity as a Worker.

“EU” means the European Union and Iceland, Liechtenstein and Norway.

“Partner” means any licensing or franchising partner or other third-party operating a Store under any of the Ralph Lauren brands.

“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Ralph Lauren in the U.S. from the EU, and (iii) recorded in any form.

“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.

“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.

“Sites” means www.ralphlauren.com, www.clubmonaco.com, www.ralphlauren.de, www.ralphlauren.fr and www.ralphlauren.co.uk here.

“Store” means a Store operated under any of the Ralph Lauren brands by Ralph Lauren or any of its affiliates or Partners, which Store is located in the EU.

“Worker” means any current, former or prospective employee, temporary worker, intern, contractor or other non-permanent employee of Ralph Lauren or any of its affiliates, who is located in the EU.

Ralph Lauren’s Privacy Shield certification, along with additional information about the Privacy Shield, can be found at https://www.privacyshield.gov/. For more information about Consumer Personal Data processing with respect to information obtained through Ralph Lauren’s Sites and Stores, please visit the company’ s privacy notices on the Sites.

 

Types of Personal Data Ralph Lauren Collects

Ralph Lauren collects Personal Data directly from Consumers through the Sites and in Stores. Ralph Lauren obtains, uses, discloses and otherwise processes Personal Data about its Consumers to (i) process transactions they request, including e-commerce and mobile transactions, (ii) improve its Stores, Sites, quality of service, and Consumers’ shopping experience, (iii) send communications about its products, services, campaigns and promotions, (iv) prevent and detect fraud and abuse, (v) process information or claims in connection with incidents at Stores, (vi) enable service providers to perform certain activities on the company’ s behalf, and (vii) comply with legal obligations, policies and procedures and for internal administrative and analytics purposes.

  • Name;
  • age;
  • date of birth
  • gender;
  • demographic information;
  • billing and shipping address;
  • driver’ s license or ID number;
  • passport number;
  • telephone number;
  • email address;
  • payment card information;
  • checking account information;
  • shopping preferences and purchase history;
  • information obtained by automated means when Consumers visit the Sites, such as through cookies, web beacons, and web server logs (including the IP address of the device the Consumer uses to connect to the internet, domain name, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on the Sites, dates and times of Site visits and the pages accessed); and any other information Consumers provide or generate on the Sites and in Stores.

 

 

Ralph Lauren also may obtain and use Consumer Personal Data in other ways for which the company provides specific notice at the time of collection.

 

In addition, Ralph Lauren obtains Personal Data, such as contact information and financial account information, of representatives of vendors and other business partners. Ralph Lauren uses this information to manage its relationships with its vendors and business partners, process payments, expenses and reimbursements, and carry out the company’ s obligations under its contracts with the relevant organizations.

Ralph Lauren’s privacy practices regarding the processing of Consumer Personal Data comply with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

 

Notice

Ralph Lauren provides information in this Policy and the privacy notices on the Sites about its Consumer Personal Data practices, including the types of Personal Data Ralph Lauren collects, the types of third parties to which Ralph Lauren discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data, and how to contact Ralph Lauren about its practices concerning Personal Data.

Relevant information also may be found in notices pertaining to specific data processing activities.

 

Choice

Ralph Lauren generally offers Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the Privacy Shield Principles, Ralph Lauren obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact Ralph Lauren as indicated below regarding the company’ s use or disclosure of their Personal Data. Unless Ralph Lauren offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy.

Ralph Lauren shares Consumer Personal Data with its affiliates and subsidiaries. Ralph Lauren may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. Ralph Lauren also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

 

Accountability for Onward Transfer of Personal Data

This Policy and the privacy notices on the Sites describe Ralph Lauren’s sharing of Consumer Personal Data.

Except as permitted or required by applicable law, Ralph Lauren provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Ralph Lauren requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (iii) notify Ralph Lauren and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.

With respect to transfers of Consumer Personal Data to third-party Processors, Ralph Lauren (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Ralph Lauren’s obligations under the Privacy Shield Principles, (v) requires the Processor to notify Ralph Lauren if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Ralph Lauren remains liable under the Privacy Shield Principles if the company’ s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Ralph Lauren proves that it is not responsible for the event giving rise to the damage.

 

Security

Ralph Lauren takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

 

 

Data Integrity and Purpose Limitation

Ralph Lauren limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. Ralph Lauren does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes, Ralph Lauren takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Ralph Lauren relies on its Consumers to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact Ralph Lauren as indicated below to request that Ralph Lauren update or correct relevant Personal Data.

Subject to applicable law, Ralph Lauren retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer.

 

Access

Consumers generally have the right to access their Personal Data. Accordingly, where appropriate, Ralph Lauren provides Consumers with reasonable access to the Personal Data Ralph Lauren maintains about them. Ralph Lauren also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. Ralph Lauren may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’ s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting Ralph Lauren as indicated below.

 

Recourse, Enforcement and Liability

Ralph Lauren has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Ralph Lauren conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Ralph Lauren makes about its Privacy Shield privacy practices are true and that Ralph Lauren’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Consumers may file a complaint concerning Ralph Lauren’s processing of their Personal Data. Ralph Lauren will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact Ralph Lauren as specified below about complaints regarding Ralph Lauren’s Consumer Personal Data practices.

If a Consumer’ s complaint cannot be resolved through Ralph Lauren’s internal processes, Ralph Lauren will cooperate with JAMS pursuant to the JAMS Privacy Shield Program, which is described on the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over Ralph Lauren. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Ralph Lauren’s compliance with the Privacy Shield Principles.

 

How to Contact Ralph Lauren

 

To contact Ralph Lauren with questions or concerns about this Policy or Ralph Lauren’s Consumer Personal Data practices:

 

Write to:

Ralph Lauren Corporation

Attention: Chief Privacy Officer

625 Madison Avenue

5th Floor

New York, New York 10022

 

or

Ralph Lauren Europe Sàrl

Attention: General Counsel EMEA

24, Route de la Galaise,

1228 Plan-Les-Ouates

Switzerland

 

E-mail: eu.privacy@ralphlauren.com.

 

MOBILE APPLICATION PRIVACY NOTICE

This Mobile Application Privacy Notice applies to each of the Ralph Lauren mobile applications (“Apps”). We are not responsible for the content, use, or privacy practices of any third-party sites linked from or otherwise accessible from the Apps that are not operated by Ralph Lauren.

 

Personal Information You Provide and How We Use It

Through our Apps, you can find the location of the nearest Ralph Lauren Store by entering your ZIP code or by allowing the Apps to use your current location to locate the nearest Store. You also may access Ralph Lauren’s website from the Apps. When you visit our website, we may collect certain personal information about you as described above in the Privacy Notice applicable to our website.

We may share personal information we collect through the Apps with service providers that perform services on our behalf and our affiliates. We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets.

The Apps are not directed to or marketed to children under the age of 13 and we do not knowingly collect personal information from children under the age of 13 through the App. If we become aware that we have inadvertently received personal information from a visitor under the age of 13 through the Apps, we will delete the information from our records.

 

Access

We provide you with reasonable access to personal information we have retained about you and the ability to review, correct or update this information. To request access, please write to the address specified in the “Contact Us” section below.

 

Security

We maintain administrative, technical and physical safeguards to help protect the personal information you provide through the Apps.

 

Changes to the Mobile App Privacy Notice

We may update this Mobile App Privacy Notice periodically and without prior notice. We will post a notice on the Ralph Lauren.com website and on the Mobile App Privacy Notice appearing on the App itself to notify you of any significant changes and indicate at the bottom of this page when the Notice was most recently updated.

 

Contact Us

If you have any questions or comments about this Mobile App Privacy Notice, please contact us by writing to:

Ralph Lauren Corporation

Attention: Chief Privacy Officer

625 Madison Avenue

11th Floor

New York, New York 10022

 

Effective Date of Mobile Application Privacy Notice: February 25, 2013