1. INFORMATION WE COLLECT
1.1. User-Provided Information
When you register for a user account to use any part of the Platform (“Account”), we may ask you to provide certain information such as your full name, user name, password, email address, phone number, age, geography as well as your company name (if any). You may also provide additional email address(es) and other information when you send us an email or other communication, when you update information previously provided, or at other times when accessing the Platform. When you conduct searches and queries on the Platform, you provide search terms.
1.2. Third-Party Login Information
We may provide you the option of accessing and registering for the Platform with your user name and password from another service (“Integrated Service”), such as through the use of your Facebook, Google+, or other account credentials. By connecting your Account with any such Integrated Service, you understand and authorize us to access and store the credentials you provide, a unique identifying number or string of characters associated with you, your name, email address(es), date of birth, gender, current city, address information, profile picture, uniform resource locator (“URL”), and other information associated with your Integrated Service account (e.g., Facebook account or Google+ account) that you permit the Integrated Service provider to make available to us. We suggest you review your Integrated Service privacy settings to understand and change the information available to us through Facebook Connect or similar Integrated Service portal. You also understand that we may learn information about your affiliation with and activity on such Integrated Service(s), as well as about your online behavior, activities, tastes, and preferences.
1.3. Automatically-Recognized Information
We may collect usage information each time you visit any part of our Platform. This usage information is made available through your Web browser or mobile device, and may include information about your hardware, software, operating system, Web browser, connection speed, language, links, images, or other materials you click; your Internet protocol address (“IP Address”) and other information that may enable us to approximate your location; the pages and contents you view on the Platform; the dates and times you access the Platform; the websites and webpages that you visited just before or just after accessing the Platform; your advertisement click-through rates, articles you read and the time you spent reading them, pictures and videos viewed; and other information about how you use the Platform. This information is collected through the use of different types of technologies:
1.3.1. Log Files
As is true with most websites, we gather certain information automatically and store it in log files. This information includes IP Addresses as well as browser, internet service provider, referring or exit pages, operating system, date or time stamp, and click stream data. We generally use this information as we would any usage data, to analyze trends, administer and maintain the Platform, or track usage of various features within the Platform.
Another form of “automatically collected” information we may record is information stored by “Cookies,” which are small text files containing a string of alphanumeric characters. Cookies simplify and authenticate the log-in process for users of the Platform, facilitate online transactions, and enable traffic monitoring, among other useful purposes. Whenever you access or use the Platform, we may send, receive, and store one or more Cookies to your computer. By sending Cookies with values that are unique, we may be able to uniquely identify your Web browser or device each time you access the Platform. The Cookies we use will receive and record information on our server logs from your browser, including your IP address, session time, click-path analysis, browsing patterns, and the pages you request. We may use both “Session” and “Persistent” Cookies to collect, store, and sometimes track various types of information. A Session Cookie is one that is intended to disappear after you close your browser. A Persistent Cookie remains after you close your browser (and may be used by your browser to identify itself when you later return to the Platform). You can disable Cookies and also remove Persistent Cookies from your computer by changing your browser settings. Most browsers allow you to either turn off the Cookies function or turn on a “Do Not Track” function. However, if you limit, block, or remove Cookies, it is possible that some webpages on the Platform may not load properly, your access to certain information or content may be denied, and you may have to enter information about yourself more than once. Please review the “Help” file in your web browser or mobile device to learn the proper way to modify your Cookies settings. To learn more about Cookies, or how to control or delete them, please visit http://www.aboutcookies.org for detailed guidance.
220.127.116.11. Google Analytics
18.104.22.168. Marketing Cookies
- Network Advertising Initiative: http://www.NetworkAdvertising.org/choices/
- European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu/
- Digital Advertising Alliance: http://www.aboutads.info/choices/
Please note that this does not opt you out of being served with advertisements entirely; and that you may continue to receive non-targeted generic advertisements.
1.3.3. Web Beacons
We may also employ web beacons to help us better manage content in the Platform by informing us what content is effective. Web beacons are tiny graphics with a unique identifier, similar in function to Cookies, and are used to track the online movements of internet users. Unlike Cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on websites. We tie the information gathered by web beacons to Personal Information we otherwise collect, and use them in our HTML-based emails to learn which emails have been opened by recipients. This allows us to gauge the effectiveness of our marketing campaigns as well as to operate and improve the Platform. You can opt-out of these emails by following the unsubscribe instructions within such marketing emails.
We may use analytics software to allow us to better understand the functionality of our Platform on your mobile device or television. This software may record information such as how often you use the Platform, the events that occur when you use the Platform, your user behavior on the Platform, your aggregated usage of and time spent on the Platform, performance data concerning your use of the Platform, and where the Platform is accessed from.
1.3.5. Push Notifications
We may send you push notifications from time-to-time in order to update you about any content, events or promotions that may interest you. If you no longer wish to receive these types of communications, you may turn them off at the application or operating system level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user or device identification information, as well as your responsiveness or desire to receive push notifications.
We may collect your location-based information for the purpose of locating a place that you may be searching for in your area. If you no longer wish to allow us to track your geo-location information in the mobile application you may turn this off at the device level.
1.4. Usage Data
Personal Information does not include “Usage Data” which we define as encoded or anonymized information or aggregated data we collect about a group or category of services, features or users which does not contain personally identifying information. Usage Data helps us understand trends in usage of the Platform so that we can better consider new features or otherwise tailor the Platform. In addition to collecting and using Usage Data ourselves, we may share Usage Data with third parties, including our customers, partners and service providers, for various purposes, including to help us better understand our customers’ needs and improve the Platform as well as for advertising and marketing purposes. We do not share Usage Data with third parties in a way that would enable them to identify you personally.
1.5. Retention Period
2. INFORMATION USE
We may use the information you provide or that we collect, including any Personal Information, to develop, operate, administer, support, maintain, improve, and enhance user experience and our Platform, to develop new services and offerings, to customize, personalize, and target content that may be more interesting, relevant, or useful to you, including targeted advertisements, promotions, marketing campaigns, offers, content, products and services (subject to your opt-out option), and for other administrative purposes, including to:
(a) send notices, updates, and contact you for feedback about the Platform;
(b) conduct research, audits, data analysis, quality control, and improve user experience;
(c) provide anonymous reporting for internal and external purposes;
(d) notify you of technical updates or changes in policy; and
(e) contact you for marketing and promotional purposes.
3. INFORMATION SHARING
3.1. Personal Information
Except as necessary to provide the Service, we will not share, loan, lease, or sell your Personal Information for any purpose other than those listed herein.
3.1.1. Sharing with Other Users
We may share personal information with third-party companies, outside organizations, or individuals if we have your consent to do so. We may also seek your additional consent for purposes subsequently notified to you.
3.1.2. Sharing with Our Business Partners
Notwithstanding the foregoing, we may share your Personal Information with our affiliates or other third party contractors if they agree under contract (e.g., a Non-Disclosure Agreement) to implement and maintain reasonable security procedures and practices appropriate to the nature of the information, to protect the Personal Information from unauthorized access, destruction, use, modification, or disclosure, and to not disclose Personal Information to other parties without your permission.
3.1.3. Disclosing for Law Enforcement Purposes
3.2. Non-Specifically Identifying Aggregated Information
We may freely use, disclose, and share, without restriction, any information we collect in the aggregate (i.e., all information, even if based on Personal Information, that is summarized into large groups of users so that no individual customer is uniquely identifiable) with vendors, service providers, marketing agencies, advertisers, business partners, joint-venturers, affiliates and other third parties.
3.3. Public Area Activity Information
Some of your activities on and through the Platform may be publicly viewable to all other users of the Platform by default. Such activities may include, but is not limited to, content you have posted publicly on our website or mobile application. Users may receive and re-share some of this information associated with or through their own user accounts. If you choose to provide Personal Information using certain publicly viewable features of the Platform, such information will likely be available to all other users of the Platform. Individuals reading such information may share, read, collect, reproduce, distribute, or otherwise use it in whole or in part without our control and without your knowledge, and search engines may index that information. We encourage you to think carefully about including any specific information you may deem private or sensitive in content that you create, post, or submit through the Platform. PLEASE NOTE THAT IN ANY OF THESE SITUATIONS, THE RECIPIENT OF THE PERSONAL INFORMATION MAY BE LOCATED IN ANOTHER JURISDICTION THAT MAY NOT PROVIDE AN EQUIVALENT LEVEL OF DATA PROTECTION, DATA PRIVACY, OR DATA SECURITY TO THE LAWS IN YOUR HOME COUNTRY
3.4. Website Administration
We may disclose your information to any third parties we engage to the extent that we believe it is necessary for them to have in order to perform certain technical and administrative services related to the Platform, including but not limited to hardware, software, networking, maintenance, data processing, storage, studies, data analytics, email and text message distribution, and surveys.
3.5. Merger or Acquisition or Sale of Assets
In the event that the Platform is acquired by or merged with another company, or a similar change in control event takes place, or sale of all or a portion of our assets, we may need to transfer all of the information we maintain about you to another company(s) to facilitate such merger or acquisition or sale of our assets. But if we do, we will first notify you to provide you a chance to opt out of such disclosure, either by sending an email to your last known email address or by at least posting a notice on this Website.
4. INFORMATION SECURITY
5. THIRD PARTIES’ PRIVACY PRACTICES
6. DO NOT TRACK
Our Platform does not respond to “Do Not Track” signals. Each browser and device works differently and there is no consensus across the industry relating to these signals.
7. CHILDREN’S PRIVACY
7.1. Note to Parents and Guardians
Because it is difficult for us to verify a person’s age online, it is entirely YOUR responsibility to supervise your child’s online activities at all times. Parental control tools like filtering software and hardware are commercially available to help you limit a child’s access to potentially harmful material on the Internet. If you discover that your child or minor has obtained an Account on our Platform, please email us immediately at Legal@GlobalFashionChannel.com so we can promptly obtain parental consent or remove the child’s Personal Information from Platform.
8. YOUR PRIVACY RIGHTS UNDER US LAW
8.1. Exception for California Residents
As an exception to the foregoing, under California’s “Shine the Light” law, California residents who provide Personal Information in obtaining products or services for personal, family, or household use are entitled to request from us, once a calendar year, information about the user information we shared, if any, with other third parties and businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., residents who make the request in 2015 will receive information regarding 2014 sharing activities). If you are a California resident and wish to obtain this information, please e-mail us Legal@GlobalFashionChannel.com with “Request for California Privacy Information” in the subject line and body of your message. We will respond with the requested information to the same e-mail address from which you sent the request. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. We will not accept requests via the telephone or by facsimile, and we are not responsible for notices that are not labeled properly, delivered properly, or that do not have the complete information as requested herein.
9. PRIVACY SHIELD NOTICE FOR USERS IN THE EUROPEAN UNION
10. ACCESS AND CHOICE
We recognize that certain users have relatively higher privacy concerns, and we make several opt-out options to accommodate as follows.
10.1 Change or Removal of Personal Information
You may update or change the Personal Information you have provided to us by logging into the Platform and providing such additional information where applicable. You also have a right to remove your Personal Information. To do this, please disable your Account from the settings menu in our Platform. We may, for a reasonable time, maintain a residual copy of your data as a backup. If you have any questions about your Personal Information, please email us at Legal@GlobalFashionChannel.com.
10.2. GFC Marketing Communications Opt-Out
Where you have provided us with the appropriate permissions, or where we are legally entitled to do so, we will provide you with marketing materials by email or other electronic correspondence. If you would like to opt-out of receiving marketing communications, please email us at Legal@GlobalFashionChannel.com, or follow the unsubscribe instructions that can normally be found at the bottom (footer) of each marketing email or correspondence.
10.3. Third Parties Opt-Out
Requests to opt-out of transfers of your information to our business partners will also be considered, but technical and other limitations on data sharing may make it difficult or impossible to provide the Platform in this manner. If you would like us to consider this special accommodation, please email us at Legal@GlobalFashionChannel.com.
12. COMPLIANCE REVIEW AND QUESTIONS?