Online Privacy Notice 

Effective Date: July 12, 2019

We at David Yurman Enterprises LLC and David Yurman France SAS (“David Yurman”) respect your concerns about privacy. This Online Privacy Notice describes the types of personal information we collect at www.DavidYurman.com (the “Site”) and in our retail stores (“Stores”), how we use the information, with whom we share it and the choices available to users of our Site regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.

Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.  You can view the following region-specific information below:

· European Union

· People’s Republic of China

· Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”)

INFORMATION WE COLLECT

The types of personal information users of our Site and customers in Stores submit include:

• contact information (such as name, postal address, telephone number and email address);
• date of birth and anniversary date;
• login credentials for the Site;
• payment information (such as payment card details); and purchase and transaction information (including serial numbers for timepiece registration).

The provision of your personal information is voluntary. However, if you do not provide us with your personal  information, we may not be able to provide you with our goods and services, fulfil your requests, or respond to your inquiries.

INFORMATION WE COLLECT BY AUTOMATED MEANS

When you use our Site, we may collect certain information by automated means, using technologies such as cookies, web server logs, web beacons (including tags and pixels from third parties such as Facebook and JavaScript.

Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Site may use cookies (such as HTTP cookies) and other types of local storage (such as browser-based or plugin-based local storage). Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies you may not be able to use all of the features of our Site or other websites and online services.

In conjunction with gathering information through cookies, our web servers may log information such as your device type, operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs also may record information such as the address of the web page that referred you to our Site and the IP address of the device you use to connect to the Internet. They also may log information about your interaction with the Site, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons,” which are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the Site.

Our Site also uses third-party plug-ins for Instagram, Facebook, Pinterest, Twitter and YouTube. The providers of these plug-ins may collect your data using automated means when you interact with them. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers.

We may use third-party web analytics services on our Site, such as those of Google Analytics and Adobe Omniture. These service providers help us analyze how users use the Site. The information collected for this purpose (including your IP address or other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn more about opting out of these providers’ activities, click the relevant link below:

• Google Analytics

• Adobe Omniture

HOW WE USE THE INFORMATION WE COLLECT

We may use the information described above to:

• provide products and services;
• create and manage your account;
• process your payment;
• to the extent permitted by applicable law and with your consent where required, send you catalogs and other promotional materials, and communicate with you about, and administer your participation in, special events, programs, offers, surveys and market research;
• respond to your inquiries;
• perform data analyses (including anonymization and aggregation of personal information);
• operate, evaluate and improve our business (including developing new products and services; enhancing and improving our products and services; managing our communications; analyzing our products and services; and performing accounting, auditing and other internal functions);
• protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities; and
• comply with and enforce applicable legal requirements, relevant industry standards and our policies

We also may use the information in other ways for which we provide specific notice at the time of collection.

To the extent permitted by applicable law and with your consent where required, we also use information collected through automated means for purposes such as (i) customizing our users’ visits to our Site, (ii) delivering content (including advertising) tailored to our users’ interests and the manner in which our users browse our Site, and (iii) managing our Site and other aspects of our business. To the extent permitted by applicable law, we also may use this information to provide you with ads about our products when you browse this and other websites.

ONLINE TRACKING

You may see our ads on other websites based on your visits to the Site because we engage in retargeting. For example, if you view a particular product on the Site, you may see an ad for that product on a third-party website. Our retargeting activities are handled by service providers that track your activity on the Site and third-party sites (using automated means such as cookies). Accordingly, to the extent permitted by applicable law, we and our service providers may collect information about our visitors’ online activities over time and across third-party websites. To learn how to opt out of retargeting, click here

Our Site is not designed to respond to “do not track” requests from browsers.

INFORMATION WE SHARE

We do not sell or otherwise disclose personal information we collect about you, except as described in this Online Privacy Notice. We may share personal information with service providers who perform services on our behalf based on our instructions. These service providers include: to provide targeted and personalized content, offers and advertising; process credit card payments; provide web hosting services.  We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share certain personal information with our affiliates for the purposes described in this Online Privacy Notice. In addition, to the extent permitted by applicable law and with your consent where required, we may share personal information with third parties whose products or services may interest you, or with third-party database providers that other companies may use for their own purposes, including marketing. You have the option to prevent disclosure of your information in connection with a marketing database. Accordingly, you may object at any time free of charge to the use of your personal information in connection with a marketing database or withdraw any consent you previously provided to us and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal. 

If you do not wish for your personal information to be used in connection with a marketing database for direct marketing purposes, or, where applicable, you wish to withdraw any consent you previously provided to us, you may ask us to opt out of this use by contacting us as indicated in the How To Contact Us section of this Online Privacy Notice.

In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government entities, and (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 fraudulent or 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 (including in the event of a reorganization, dissolution or liquidation).

NOTICE TO CALIFORNIA RESIDENTS

To the extent required by applicable law, California residents may ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request, California residents may contact us as specified in the How to Contact Us section below.

YOUR RIGHTS AND CHOICES

We offer you certain choices in connection with the personal information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the How To Contact Us section of this Online Privacy Notice. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal.

DATA TRANSFERS

We may transfer the personal information we collect about you through the Site to countries other than the country in which the information originally was collected, including to the United States. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Online Privacy Notice.

HOW WE PROTECT PERSONAL INFORMATION

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide on the Site against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

LINKS TO OTHER WEBSITES

Our Site may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.

UPDATES TO OUR ONLINE PRIVACY NOTICE

This Online Privacy Notice may be updated periodically to reflect changes in our personal information practices. We will post a prominent notice on our Site to notify you of any significant changes to our Online Privacy Notice and indicate at the top of the notice when it was most recently updated, and/or take any further action required by law.

CHILDREN’S PERSONAL INFORMATION

Our Site is designed for a general audience and is not directed to children.  We do not knowingly collect or solicit personal information from children under the age of 13 (or other relevant age, as applicable, pursuant to relevant law) through our websites and apps.  If we become aware that we have collected personal information from a child under such age, we will promptly delete the information from our records.  If you believe that a child under such age may have provided us with personal information, please contact us as specified below. 

HOW TO CONTACT US

If you have any questions or comments about this Online Privacy Notice, would like to exercise your rights, or you would like us to update information we have about you or your preferences, please contact Senior Manager of Customer Care by email at  CUSTOMERCARE@DAVIDYURMAN.COM.You also may write to:

Senior Manager of Customer Care

Customer Care
David Yurman Enterprises LLC
24 Vestry Street
New York, NY 10013

European Union Addendum

If you are a resident of the European Union (EU), the following EU-specific provisions apply to our processing of your personal information (i.e., personal data within the meaning of the General Data Protection Regulation (GDPR)) in lieu of the relevant sections of the Online Privacy Notice:

· We will collect the following categories of personal information through the Site:  contact information you have provided us; date of birth and anniversary date, your login credentials (if you have registered with us); personal information found in content you provide; and traffic data via automated means of processing (such as cookies).

· We will process the information described above to provide products and services; create and manage your account; send you catalogs and other promotional materials; communicate with you about, and administer your participation in, special events, programs, offers, surveys and market research; respond to your inquiries; perform data analyses (including web analytics);  operate, evaluate and improve our business (including developing new products and services; enhancing and improving our products and services; and performing accounting, auditing and other internal functions); protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities; comply with and enforce applicable legal requirements, relevant industry standards and our policies; customize your visits to the Site; and deliver content (including advertising) tailored to your interests.

· We use the information listed above in accordance with our legitimate business interests, in the interests of performing a contract with you, to comply with applicable legal obligations or with your consent to the processing (where required), which you may withdraw at any time.

· We may transfer the personal information we collect about you through the Site to countries outside of the EU that may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will safeguard that information as described in this Online Privacy Notice

· We retain your personal information as long as needed for the purposes for which we obtained it, which generally means for the duration of our relationship or as long as you keep your account open with us, plus a reasonable period to take into account the applicable statute of limitation period or to comply with mandatory applicable law.

· Only authorized personnel of David Yurman, its affiliates and our service providers will have access to your personal information.

· We will not share your personal information with any third parties (such as database providers) for those third parties to market their products or services to you without your consent. 

· Some of our staff members (including our IT and marketing personnel) and our service providers are located in the United States.  They will have access to your information for global customer relationship management purposes or to perform services for the company.

· We require our service providers to process personal information only in accordance with our instructions and to ensure the security of the information.

· In accordance with the GDPR, you have the right to access your personal information, to have your information rectified or deleted, and to restrict or object to the processing of your personal information. You also have the right to receive, in a structured, commonly used and machine-readable format, the personal information that you have provided to us about you, with your consent or based on a contract to which you are party. You have the right to have this information transmitted to another company, where it is technically feasible. You also may lodge a complaint with a data protection authority if you are not satisfied with our responses.

· To exercise your rights, please contact us by email at customercare@davidyurman.com or write to us at

Customer Care
 David Yurman Enterprises LLC
 24 Vestry Street
New York, NY 10013

· We use the following categories of cookies on our Site.

o   Essential Cookies

These cookies are essential to use and navigate our Site. Essential cookies help us collect information, such as your session ID and other server information, that enables us to authenticate users.

o   Functionality Cookies

These cookies collect information about your choices or remember your preferences so we can show you relevant content. They allow us to identify your location and remember your language during a browsing session. 

o   Analytics Cookies

We use analytics cookies to collect information on how users navigate and use our Site, such as the pages they view, how long they stay on a page and whether the page is displayed correctly or whether errors occur. Some of these cookies are provided by third-party analytics providers, including Google Analytics. For more information about these third-party providers’ cookies, please click on the links below.

                                Google Analytics

                                Qubit 

· For further information please see below a list of the specific cookies that we use on our Site. We will not drop any non-essential cookies on your device without your consent.

·  If you don’t want to allow cookies at all, or only want to allow use of certain cookies, please refer to your browser settings. You can use your browser settings to withdraw your consent to our use of cookies at any time and delete cookies that have already been set. Your browser help menu or the website www.allaboutcookies.org contains comprehensive information about the process of opting out on different browsers. Please note, however, that without cookies you may not be able to use all of the features of our Site or other websites and online services.

· For convenience, we have provided links below to the cookie management instructions for popular web browsers:

                        - Internet Explorer
                        - Microsoft Edge
                        - Google Chrome
                        - Safari
                        - Firefox

· If you would like to opt out of third party cookies relating to interest based advertising, please go to www.youronlinechoices.com/uk/your-ad-choices or www.aboutads.info. Note that opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. Opting out of cookies and data collection from one browser, device or app will not necessarily opt you out of collection from all browsers, devices or apps.

People’s Republic of China Addendum

If you are a resident of China, in addition to the relevant sections of the Online Privacy Notice, the following China-specific provisions apply to our processing of your personal information:

· We may process your personal information using automated processing methods to:

o   Communicate with you about, and administer your participation in, special events, programs, product introductions, offers and special promotions, surveys and market research; and

o   develop mailing lists to facilitate our communications with you, and use these lists to send emails to you from time to time that contain commercial advertising.

By providing your personal information to us, you consent to our use of your information for the purposes listed in (1) the Online Privacy Notice and (2) this Addendum

Hong Kong Addendum

If you are a resident of Hong Kong, in addition to the relevant sections of the Online Privacy Notice, the following Hong Kong-specific provisions apply to our processing of your personal information for direct marketing purposes:

· We intend to use your name and contact information to send you marketing and promotional materials about our products and services, and your consent is required in order for us to do so.

· We also intend to share your name and contact information with our third-party vendors  and our affiliates who provide services to better market products and services to you, and your written consent is required in order to do so.

How to Contact David Yurman

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

Write to:

Customer Care
David Yurman Enterprises LLC
24 Vestry Street
New York, NY 10013