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DELSEY LUGGAGE, INC. PRIVACY POLICY

Effective as of September 18, 2017
This Privacy Policy describes the principles and practices that apply to the collection and use of personal information (defined below) that Delsey Luggage, Inc. ("Delsey," "we" or "us") collects from or through the shop.delsey.com website ("Website") from individuals ("user" or "you").
TRUSTe Privacy Certification
 
Delsey Luggage, Inc. (and its parent/subsidiary company(ies) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework . Delsey is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. .

Delsey is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Delsey complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Delsey is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Delsey may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint/], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.


Delsey Privacy Policy

Summary
We will collect your personal information to provide you with the content, products and services that you request;
We may use your personal information to understand how to better market our products to you;
We will not share your personal information with third parties other than our service providers, or in the course of our business with you, or in the event of a dispute, unless required by law;
We will take reasonable measures to protect the security of your personal information;
We want to sell our products to you, but we do not want to annoy you. We provide numerous ways for you to limit our use of your personal information;
You are entitled to a transparent relationship. You will have the right to access, and obtain correction or deletion of, personal information about you.
Table of Contents

Definitions and background
For ease of use of this document, the following terms will have the specific meaning provided below.
"Device" means a computer, laptop, desktop, smart phone, tablet, and any other similar equipment that is used for online activities.
"Personal Information" means information that identifies an individual or that, when combined with other information available to the data holder may allow identifying an individual with reasonable certainty.
"Promotion" means survey, contest, webcast, or promotion that we organize alone or in cooperation with a business partner.
"Registered User" means an individual who has provided contact information in order to receive content from Delsey, such as a white paper or a newsletter or an offer for a special discount for a product.
"User" means an individual who uses the Website. A User can be an individual who merely explores the Website, or a Registered User.
"Website" is the website shop.delsey.com.

Scope
This Privacy Policy applies to the information that we collect or receive from Users of the Website; and any individual with whom we interact through telephone, correspondence, or electronic communications, newsletters, interviews, surveys, contests or promotions.

By using our Website, you are consenting to our processing of your information as set forth in this Privacy Policy. Your continued use of the Website, or continued interaction with us after we have notified you of a material change in our Privacy Policy in accordance with the Updates section will be deemed an acceptance of these new terms.

What information we collect and how
We collect Personal Information in a variety of ways:

- If you become a registered user - We require users to submit contact information if they wish to purchase products or services from the Website, receive our newsletter or other information, or participate in a Promotion. In this case, the user becomes a "Registered User."

- If you purchase a product or service from the Website - We may collect contact information, such as name, phone number, email address, payment information, and shipping address from individuals who purchase products online.

If you purchase a product for delivery to a third party - If you purchase a product for delivery to a third party (e.g. as a gift), we also collect the contact information and shipping address of that third party. If you provide us with the contact information and shipping address of an individual to whom you want to make a gift, you represent and warrant that the individual does not object to our collection of his/her personal information for the purpose of delivering the Delsey product or service to him/her.

If you contact us - We may keep a record of your contact information and correspondence, the purpose of your contacting us, and our interaction with you if you contact us for any purpose.

If you visit our Website - We collect information about your device. This information is automatically provided by your browser. This may include device information (type of device, operating system version, unique device identifier, browser type and version, and mobile network information) or log information (IP address, screen resolution, and referring domain).

Cookies - We may collect information through cookies and other technologies, such as information about a user's online activity, the pages of our Website that the user visited, the search terms used, and any link or advertisements on which the user clicks. For more information, please see the Cookies and other technologies section.

Other Sources - We may obtain personal information from affiliated entities, business partners, publicly available databases, and other independent third-party sources and add it to our contact database for marketing and sales purposes to combine it with other information that we have collected or obtained otherwise.

How we use personal information
Our primary goal in collecting personal information is to assist in completing the purchase of our product or services; interact with our users, such as providing information about our new products or services; know better the individuals who are interested in our products or services, so that we can find more efficient and effective ways to respond to their questions and inquiries, and market our products to them. The more we know about your interests, the better we can communicate with you, anticipate your needs and communicate with you in a productive and enjoyable manner. This interaction may occur in several different ways:

All Users - We use personal information to provide our users with access to the public areas of our Website and information about our products. We may also use personal information about our users to communicate with them, respond to their questions, or as otherwise described at the point of collection of information.

Registered Users - If you have registered on our Website, we will use the information that you provide in order to complete the purchase of our products or services; ship a product in accordance with your instructions, manage your Registered User account and give you access to the special service or document that you requested. We will assume that you are interested in our products or services, and may send you periodically additional information and news. You have the right to opt-out from receiving any future communications. See our User's rights section.

Gift Recipients - If you are the recipient of a gift that is purchased from our Website, we use your Personal Information to deliver the product or service that that been purchased for you. Once the delivery is complete, we may continue interacting with you, to ensure that you are able to use the gift and to make you aware of other products or services of Delsey that may be of interest to you. You have the right to opt-out from receiving any future communications other than administrative communications that are related to the delivery of your gift. See our User's rights section.

Send a Friend - If you choose to send a friend an item from your wishlist, we will ask for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. We store this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us through the information at the end of this policy to request that we remove this information from our database.

Correspondence -We may use your correspondence, contact information, email address, and any information that you provide in your messages, to respond to you.

Marketing and Business Development - We may use your contact details to solicit feedback from you, including through surveys. We may also use your personal information to estimate how likely you might be to become a customer, to send you marketing communications and promotional material; or to provide you with information about our white papers, our promotions, and our other products.

If you demonstrate an interest in a particular product or service, such as by affirmatively clicking on a link about the product or service, and we have your contact information, we may follow-up and send you an email or initiate communication with you about this product. You have the right to prevent future interaction with you. See our User's rights section.

Investigations - We may use Personal Information to prevent or investigate potentially prohibited or illegal activities, or to enforce the Delsey Website Terms of Use.

Analytics - We may aggregate Personal Information and usage data in order to obtain statistical information, such as to calculate the percentage of users who have a particular zip code or telephone area code. We also use aggregated information to understand how our Website is used, for research or product development, for example, to measure interest in, or monitor the use of any product or promotions that we provide through the Website, to improve these products or promotions, and for the technical administration of the Website.

With whom we share personal information
From time to time, we may disclose Personal Information to third parties, as follows:
Business Partners - We may team up with other companies ("business partners") to offer certain promotions, jointly sponsor and promote such promotions, and develop subsites or separate websites that are used for a promotion. If you decide to participate in one of these promotions, the Personal Information that is collected from the relevant subsite will be collected by both Delsey and the business partner(s) participating in the Promotion. We will use that information in accordance with this Privacy Policy, and our business partner will use it in accordance with its own privacy policy. Please note that we do not control the privacy practices of our business partners.

Service Providers - We may engage certain third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, customer relationship, storage, database management, credit card processing, shipping, fraud prevention, business analytics, chat, website analytics, website optimization, lead scoring, retargeting, direct marketing campaign and the sending of newsletters, or similar services.

We will share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your Personal Information.

Targeted Marketing - We may contract with publishers and advertising agencies to serve targeted advertisements about Delsey to individuals who have visited our Website so that our advertisements are presented to these individuals while they are visiting a third party's website. This is accomplished by combining cookies and action tags that are shared with these third parties. We believe that if you have visited our site you may be more interested in seeing advertisements about our products - and more likely to purchase these products. You have the right to opt out of this targeted marketing. See our User's rights section. You may also have this information no longer used for serving you targeted ads by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

To Defend or Enforce our Rights - We may use or share Personal Information to protect ourselves or protect the Website, to establish or exercise our legal rights, respond to a breach of our Website Terms of Use, when we believe it is appropriate to protect the property and rights of Delsey or a third party, the safety of our company, our customers or others, to investigate, prevent, take action against, or stop any fraudulent, illegal, unethical, or legally actionable activity, in connection with our Website, or other products the Delsey Website Terms of Use, or other agreements.

Business Transfers - If any or all of the assets of Delsey are acquired by, or merged with those of another entity, or in the unlikely event of a bankruptcy, we may disclose, share or transfer some or all of our users' Personal Information to or with this entity in preparation of the transaction, as part of the due diligence, or after the transaction has been consummated, so that the successor entity can continue providing our services to our users. If the recipient of the Personal Information has personal information practices that do not meet the substance of this Privacy Policy, you will be given the opportunity not to continue to use the Site.

Compliance with Laws and Third Party Requests - Delsey cooperates with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our reasonable discretion, believe necessary or appropriate to respond to and defend against legal claims, respond to legal process (including a facially valid subpoena, warrant, court order or other legal process), or otherwise as required by law. Please note that we may not be able to notify you of a request for the disclosure of your information as described above, either because it might be prohibited by law, or because doing so would jeopardize an investigation into illegal or fraudulent activity, or because we do not have your contact information.

Aggregate Information - We may prepare reports, market analysis, and trend analysis that are based on compilation of data that Delsey has collected. These reports do not contain specific user information, but only aggregate information regarding a group of users. Data aggregation is a process in which data are gathered and expressed in a summary form for purposes such as statistical analysis, in order to obtain information about a particular group based on specific variables. This aggregated information is used for industry analysis, demographic profiling, and other purposes.



Tracking Technologies
Delsey and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Finally, other cookies are used to collect information about your perceived interest in our products so that we can arrange for advertisements regarding these products to display on other sites that you visit on the Internet. This way when you visit other sites that display advertisements, the advertisements that you see are more relevant to you.

When Users visit the Website, we may store a number or code in their browsers using one or several cookies to remember their visit. This unique number or code identifies a browser on a specific computer. Browsers may be associated with demographic information, such as gender or age range, based on the other websites that were visited by that browser.

We use tags to monitor the traffic patterns of users from one page within our Website to another, to deliver or communicate with cookies, to understand whether you have come to our Website from an online advertisement displayed on a third-party website, and to improve Website performance. We also may allow our service providers to use tags to analyze visitor traffic and actions on our Website and to help us understand which pages are more attractive to Users, or which emails have been opened by recipients. This helps us measure the effectiveness of our content and other offerings.

If you have any other questions about cookies and other technologies, please visit http://www.allaboutcookies.org/ or http://networkadvertising.org/ or contact us as indicated in the How to contact us section below.


California Disclosures
Do Not Track – California law requires that operators of websites disclose how they respond to a “Do Not Track” signal. However, because there is not yet a common understanding of how to interpret Do Not Track signals, Delsey does not currently respond to Do Not Track signals, if any, it might receive from browsers. We will continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.

If you want your use of our Website not to be tracked, so that we can send you targeted advertisements, you can use our cookie management tool at http://preferences-mgr.truste.com/.

Third Party Cookies - California law requires that operators of websites disclose whether third parties may collect personally identifiable information about an individual’s online activities. We allow third parties with which we have a separate agreement to use cookies or other technologies to collect information about Users visit to our Website. These third parties include business partners, which may collect information when you view or interact with certain areas of this Website, and advertising networks, which may collect information about your interests or preferences, so that they can display promotional material on this Website, or across the Internet tailored to your apparent interest.

If you want your use of our Website not to be tracked, so that we can send you targeted advertisements, you can use our cookie management tool at http://preferences-mgr.truste.com.

We do not share with these third parties any information that would readily identify you, such as an email address, but these third parties may have access to information about your device, such as an IP or MAC address.

California privacy rights - We do not share Personal Information with third parties for their direct marketing purposes other than as described in this Privacy Policy. If our practices changes we will provide you with the relevant information as required by applicable law. We want our users to enjoy their visit to our Website, and we respect their privacy. To this end, we provide numerous privacy choices, as described below.

While we have tried to provide our users with all the tools necessary so that they can manage their interaction with us, you may prefer to interact directly with us.

You can contact us at any time with your questions or requests for assistance. Please refer to the How to contact us section below.


User's rights

Right not to provide information - You can choose not to provide us with any Personal Information. However, if you wish to obtain access to certain content, ask us a question, initiate a transaction, or to take advantage of certain features of the Website, you may be required to provide certain contact or other Personal Information, as indicated in the relevant form.

Right to block cookies - You can choose to block cookies. To do so, please review the Cookie and other technology section. Please note that if you refuse to accept cookies from this Website, you will not be able to access certain portions of the Website.

Right to object to new uses of your Personal Information - If at any time we wish to disclose, or use your personal data in a way, or for a purpose other than as described in this Privacy Policy, we will give you the opportunity to choose (opt out) whether your personal data may be used for a purpose other than the purposes that are set forth in this Privacy Policy before the changes become effective.

Right to know about third party marketing - We do not currently share your Personal Information with third parties for their direct marketing purposes. If at any time we wish to disclose, or use your personal data in a way, or for a purpose other than as described in this Privacy Policy, we will give you the opportunity to choose (opt out) whether your personal data may be disclosed to a third party.

Right to block marketing communications - If you no longer wish to receive marketing information or communications from us or from our affiliates entities, you can unsubscribe from our distribution list by following the unsubscribe instructions provided in the communications that you receive from us as indicated in the How to contact us section.

Accessing, Changing or Deleting Personal Information - Upon request Delsey will provide you with information about whether we hold any of your personal information. If you are a Registered User of the Website, you may update, delete or correct the information you provided to us by logging into your account and making the applicable changes or by requesting us to make such changes as indicated in the How to contact us section. We will respond to your request within a reasonable timeframe.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us as indicated in the How to contact us section.

Please note, however, that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will respond to requests for access within 30 days.

Security
Delsey employs administrative, physical, and electronic measures designed to protect your information from unauthorized access, loss, misuse, disclosure, alteration, and destruction. While we do our best to implement security measures, we do not guarantee that our safeguards will always work.
When we need to transfer information out of our firewall, we use industry-standard technological means to protect Personal Information while in transit through the Internet. We use encryption and a comprehensive authentication protocol to provide reasonable security when transmitting sensitive information (such as credit card information). However, please remember that no security system on the Internet is perfect.

Limitation of liability
We exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure. We will not be liable for unauthorized disclosure of personal data that occurs through no fault of Delsey including, but not limited to, errors in transmission, access to your account by anyone, uses of your user ID and password by a third party, your failure to comply with your security obligations, and the unauthorized acts of Delsey 's employees.

Links to social media networks and other websites
This Privacy Policy addresses only the use and disclosure of information that we collect from you through the Website or through our interaction with you. Our Website may contain links to other websites or to social media features, such as the Facebook Like button. These other websites may place their own cookies or other files on your computer, collect data, or solicit Personal Information from you. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site.
The fact that we link to social media networks or other websites is not an endorsement, authorization or representation of our affiliation with these third parties. We do not exercise control over third party websites. We do not exercise control over third party websites. These other websites follow their own rules regarding the use or disclosure of the Personal Information you submit to them. Your interactions with these other websites and/or features are governed by the privacy policy of the company providing them. We recommend that you to read the privacy policies or statements of these other websites

Our policy towards children
The Website is not directed to persons under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, he or she should contact us as indicated in the How to contact us section. If we become aware that a child under 13 has provided us with Personal Information, we will remove such information from our files.

International transfer
Your information may be transferred, stored, maintained, and processed in the United States or in other countries where we have facilities or where we have engaged a service provider. This storage, maintenance or processing will be performed under privacy and security laws and standards that may not be as protective as those in your jurisdiction. By using our Website or by providing information to us, you consent to such storage, maintenance and processing outside your country of residence.

Disputes
If you have any concerns or claims with respect to our Privacy Policy, please contact us as indicated in the How to contact us section. We will investigate and attempt to resolve any complaints and disputes regarding our use and disclosure of personal data. If the complaint or dispute cannot be resolved through our internal process, or Delsey does not adequately respond to your question, please contact our U.S.based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
If our U.S. based third party dispute resolution provider cannot resolve the issue to your satisfaction, please contact the Maryland office of the American Arbitration Association, which will serve as a liaison with Delsey to resolve your concerns. If arbitration is necessary, it will be conducted by telephone and email, and if it must be done in person, it will be conducted in Maryland. The arbitration will be conducted by one arbitrator member of the American Arbitration Association, and under the rules of commercial arbitration of the American Arbitration Association. Both parties will bear equally the cost of arbitration (exclusive of legal fees and expenses). All decisions of the arbitrator will be final and binding on both parties and enforceable in any court of competent jurisdiction.

Updates
This Privacy Policy may be updated from time to time in order to reflect changes in our practices. We will notify you of any material changes prior to them becoming effective by email or by posting a notice on the Website, and will obtain the necessary consents as may be required under applicable law if we seek to collect, use or disclose personal data for purposes other than those for which consent has been obtained. Except as stated above, all changes will apply to the personal data that are already collected, and to personal data that are collected after the effective date of the revised policy. If any proposed change is unacceptable to you, you will have the right to terminate your account with us. You are advised to consult this Privacy Policy regularly for any changes.

How to contact us
Delsey Luggage, Inc. owns and operates the Website shop.delsey.com and provides the products described on the Website.
If you have any questions, comments or complaints about this Privacy Policy or our use of your Personal Information, please contact us as follows:
  1. • By email: privacy@delsey.com
  2. • By postal mail: Delsey Luggage, Inc., 6090 Dorsey Rd, Suite C, Hanover, Maryland- 21076, Attn: Privacy Office.