DELSEY LUGGAGE, INC. PRIVACY POLICY

Last updated on December 12, 2019
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").
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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, if 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 and you have the right to access and obtain correction or deletion of your Personal Information.

Table of Contents

Definitions and Background
For ease of use of this Privacy Policy, 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 to access the Website;

"Device Information" means information that identifies the Device, including 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), physical location of the Device;

"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, including : name, birthday date, postal address (including billing and shipping addresses), telephone number, email address, credit and debit card number, date of first purchase, profile picture, social media account ID, travel information, including trip flight information;

"Promotion" means survey, contest, webcast, or promotion that we organize alone or in cooperation with a business partner;

"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 residents of the United States only. 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. Please note that California users must also consult the supplement below as well.

By using our services, you are consenting to our processing of your information as set forth in this Privacy Policy.


How we collect your Personal Information
We collect Personal Information in a variety of ways, including:

- If you visit our Website: We collect your Device Information which are automatically provided by your browser.

- If you become a Registered User: If you wish to purchase products or services from the Website, receive our newsletter or other information, or participate in a Promotion, you become a "Registered User", and in this case, we collect your Personal Information.

- 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 certain Personal Information of that third party. If you provide us with Personal Information of an individual, you represent and warrant that the individual does not object to our collection of his/her Personal Information for the purpose of delivering our product or service to him/her.

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

- Offline: We may collect Personal Information from you offline, such as when you visit our stores, attend one of our trade shows, place an order over the phone or contact customer service.

- Cookies: We may collect Personal Information and/or Device 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. We may also receive your Personal Information from social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties. In addition, if you elect to connect your social media account to your Website account, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends' profiles.

- Third-party payment service: We may use a third-party payment service to process payments made through the Website. If you wish to make a payment through the Website, your Personal Information may be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.


Personal Information collected according to the type of User
Our primary goal in collecting Personal Information is:

- to assist you in completing the purchase of our product or services;
- interact with you, such as providing information about our new products or services;
- know better who are interested in our products or services, so that we can find more efficient and effective ways to respond to your questions and inquiries, and market our products to you.

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 depending on your type of User:

All Users - We use Personal Information to provide you with access to our Website and information about our products. We may also use Personal Information to communicate with you, respond to your questions, or as otherwise described in this Privacy Policy.

Registered Users - If you are a Registered User, we will use your Personal 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. At any time, 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. At any time, 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 one our product, we will ask for your friend some of his/her Personal Information. We will automatically send your friend a one-time email inviting him or her to visit the Website. We store his/her Personal 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 his/her Personal Information from our database.


How we may use Personal Information
Delsey may use Personal Information we collect from and about you for a variety of business purposes, as presented below. We are committed to protecting and maintaining the privacy of your Personal Information. Therefore, we will process your Personal Information only in accordance with applicable law and this Privacy Policy. We and our services providers may use Personal Information:

- to respond to your inquiries and fulfill your requests, such as to complete your transactions and provide you with related customer service;
- to send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest;
- to personalize your experience on our services by presenting products and offers tailored to you and to facilitate social sharing functionality;
- to allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules containing additional information about how we use and disclose your Personal Information;
- to validate your warrantee information;
- for our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our products and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities;
- to prevent or investigate potentially prohibited or illegal activities, or to enforce the Delsey Website Terms of Use.;
- to obtain statistical information, to understand how our Website is used, for research or product development, 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.


For example:

- we may use your Personal Information to solicit feedback from you, including through surveys, 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; and/or
- If you demonstrate an interest in a particular product or service, such as by affirmatively clicking on a link about the product or service, we may follow-up and send you an email or initiate communication with you about this product. Being specified that you have the right to prevent future interaction with you. See our User's Rights section.



With whom we disclose Personal Information and/or in what situations
From time to time, we may disclose Personal Information:

To our affiliate: We are part of the Delsey Group, a group of companies controlled by the same entity; all of these companies therefore constitute our affiliates. And so, we may disclose Personal Information for the purpose described in this Privacy Policy:

To our Business Partners: we may team up with other companies to:
• offer certain promotions, jointly sponsor and promote such promotions, and develop subsites or separate websites that are used for a promotion;
• 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;
• 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.


We will disclose Personal Information with these Business Partners, 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.

In such cases, both Delsey and its Business Partners may collect Personal Information. We will use Personal Information in accordance with this Privacy Policy, and our Business Partners will use it in accordance with their own privacy policies. Please note that we do not control the privacy practices of our Business Partners.

In the case of targeted marketing, Personal Information disclosure may be accomplished by combining cookies and action tags that are shared with these Business Partners. You have the right to opt out. See our User's Rights section. You may also have Personal 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 you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public;

To your friends associated with your social media account, to other website users and to your social media account provider, in connection with your social sharing activity. By connecting your services account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media provider's privacy policy.

To defend or enforce our rights: We may use or disclose 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.

In the context of 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 Website.

Our Advisors: We may also share your Personal Information with our auditors, legal advisors, and similar third parties in connection with our receiving their professional services, subject to standard confidentiality obligations.

For compliance with applicable laws: Delsey cooperates with government and law enforcement officials or private parties to enforce and comply with applicable laws.


Cookies and other Technologies
Delsey and its business 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.

Other cookies are used to collect Personal 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 All About Cookies or Network Advertising ; or
- contact us as indicated in the section See our How to Contact Us below.

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/.


User's Rights
Right not to provide information – You can choose not to provide us with any Personal Information; however, for certain actions such as making a purchase, we can only complete them upon receipt of your Personal Information which you can later delete as provided hereunder.

Right to object to new uses of your Personal Information - If at any time we wish to disclose, or use your Personal Information for a new purpose other than as described in the last updated Privacy Policy, you have the opportunity to choose (opt out) whether your Personal Information may be used for the new purpose.

Accessing, Changing or Deleting Personal Information - Upon your request, we will provide you with information about whether we hold any of your Personal Information. If so, you may review, update, delete, restrict or correct the information you provided to us by:

(i) logging into your account and making the applicable changes; or
(ii) by requesting us to make such changes as indicated in the How to Contact Us section. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information.

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you are a Registered User, we will deliver our written response to that account. If not, we will deliver our written response by mail or electronically, at your option.

At your request, we undertake to transmit, if necessary, your requests concerning your Personal Information to our services providers.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).

We may also deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• debug products to identify and repair errors that impair existing intended functionality;
• exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• comply with any legal obligation;
• engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
• enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• make other internal and lawful uses of that information that are compatible with the context in which you provided it.

There may also be residual information that will remain within our databases and other records, which will not be removed.


Our Policy towards Minors
Our Website is not designed or intended to be used by children under the age of 16, and we do not knowingly collect Personal Information from children under 16.

If you are under 13 years of age, please do not use the Website at any time or in any manner, unless you provide Delsey with prior verifiable written consent of you parent or guardian, for the collection of your Personal Information.

If you learn that your child under 13 years of age provided us with Personal Information without your consent, please contact us. We will delete the Personal Information from our systems.

More generally, at any times, parent, guardian and minor aged 13 - 16, can exercise all the rights listed in the User's Rights section.


Data Retention
We will retain your Personal 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 Personal 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 Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Links to Social Media Networks and other Websites
This Privacy Policy addresses only the use and disclosure of Personal 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 Website, 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 Website.

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

Security
Delsey uses administrative, physical, and electronic measures designed to protect your Personal 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 Personal 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 Information; 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 Information 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.

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Website or otherwise to us.

International Transfer
Personal 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 Information. 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 TRUSTE.

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.

California Consumer Privacy Act supplement
This section supplements and is expressly made part of the information contained in this Privacy Policy and applies solely to California residents, as defined in Section 17014 of Title 18 of the California Code of Regulations (“California Consumers” or “You”), within the meaning of the California Consumer Privacy Act (“CCPA”).

We adopt this section to comply with the CCPA.

Any terms defined in the CCPA have the same meaning when used in this section.

Personal Information that Delsey does not collect

Please note that Personal Information, as provided in this Privacy Policy, does not include Sensitive Personal Information, as defined by the CCPA, i.e.: the social security, driver’s license, state identification card, or passport number; a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; a consumer's precise geolocation; Personal Information revealing a consumer's racial or ethnic origin, religion, or union membership; the contents of a consumer's private communications, unless the business is the intended recipient of the communication; a consumer’s biometric information; data concerning a consumer’s health; data concerning a consumer's sexual orientation; or other data collected and analyzed for the purpose of identifying such information.

Disclosures of Personal Information for a business purpose

In the preceding twelve (12) months, Delsey has disclosed Personal Information for the purpose listed in the How we may use Personal Information section.

Sales of Personal Information

In the preceding twelve (12) months, Delsey has not sold Personal Information.

Your rights and choices

The CCPA provides California Consumers with specific rights regarding their Personal Information.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable California Consumer request related to your Personal Information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; and/or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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.


Updates
We may change this Privacy Policy at our discretion and at any time. The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of our services following these changes means that you accept the revised Privacy Policy.