Last Updated – August 2023
- Who We Are
- What Information And Personal Information We Might Collect About You
- How We Use Your Information
- How Is Your Information Shared
- What Choices Can You Make About Your Data
- US State Privacy Rights
- Notice of Financial Incentive
- How Do We Protect Your Data
- How Do You Contact True & Co.
- Special Notice For Canadian Users
- Supplemental California Privacy Notice
1. Who We Are
2. What Information And Personal Information We Might Collect About You
Information that you provide
In order to handle your purchases, provide customer service, improve our products and services, provide in-person experiences or events, engage with you on social media and online, and send you information about our products, trends and promotions, we may ask you to provide your:
- Identifiers: such as your name, postal address, email address, social media handle, telephone number, or identification materials used to verify eligibility for discounts and other offers;
- Demographic information: such as your age, date of birth, or gender;
Transaction information: such as information regarding purchases, returns or exchanges; product reviews you provide;
clothing size/fit information; and communications between us;
- Payment information, including gift card information; and
- User generated content (UGC): such as photos, videos, blog posts, or social media posts, or direct or personal messages sent to us on social media platforms.
If you choose not to provide certain information to us, you may not be able to complete a purchase, participate in an experience, or receive other services or information.
Information that we automatically collect from you
When you visit any of our websites, applications, or stores, or access our in-store Wi-Fi, we may automatically collect:
- Identifiers: such as device ID, IP address, and online identifiers, such as cookie data;
Internet activity information: such as device type; browser types and version; browsing history; search history;
interactions with our websites, applications, communications, and advertisements; referring sites; network activities when using our Wi-Fi; and content and pages viewed;
- Location information: such as geo-location of your devices and in-store location;
- Audiovisual information: such as call recordings and CCTV;
- Inferences: such as your preferences and interests based on your online and in-store activities;
- Browsing behavior on our websites: such as when and how you visit our website, the amount of time spent viewing our website, the buttons and links you click, videos you watch, and where you scroll on our website, the search terms that you enter in our website, and the form submissions, purchases, and transactions you make through the website; and
- Text or other messages sent or shared through chat or chatbot services.
Other information we collect
We may collect information about you from activities related to other PVH businesses or third parties like web hosting providers, shipping providers, retail partners, analytics companies, social media platforms, data companies, and marketing and advertising services such as:
- Identifiers: such as updated contact information, social media handles, device identifiers, cookie data or similar online identifiers;
- Demographic information: such as your age, date of birth, or gender;
- Internet activity information: such as content or reviews you post on social media or other third-party platforms; and
- Inferences: such as information about your shopping preferences and interests.
The information that we obtain from social media platforms depends on your account and privacy settings within the platforms and the platforms privacy policies.
Some of the information above is collected on our websites through web browser cookies and other technologies (web beacons/gifs, pixels, page tags, script) that receive and store certain types of information whenever you interact with us or third parties that may direct you to our websites. We may use similar technologies to collect information when you use our applications. We use these tools for a variety of reasons, including to analyze and improve our websites and applications, or to remember your preferences and provide more personalized advertising.
Third party automated information collection and Interest-Based Advertising
3. How We Use Your Information
We use the information we collect for a variety of purposes, including:
- To process your transactions and provide you with the products and services you request
- To provide, maintain, protect, develop, and improve our websites, applications and services
- To improve your experience on our websites and applications, and in our stores
- For customer service, including to respond to your inquiries and requests
- To communicate with you about our and third-party products and services, in accordance with applicable laws and with your consent where required
- To analyze and learn about consumer trends and interests
- To learn about the devices you use to access our websites, applications and other online services
- To personalize the content you see on our websites and applications
- To administer contests, sweepstakes, surveys and other promotions
- To maintain your reward or loyalty program memberships
- To provide you with communications, recommendations, ads, and other information of interest to you, including via text message and email and interest-based advertising based on your online activities on our websites, applications and other online services
- To maintain our community programs and focus groups
- To use your UGC on our websites, social media accounts, and other marketing platforms (with your consent)
- To verify eligibility for discounts and other offers
- To protect our rights, as well as yours and others and
- To comply with our legal obligations
We may also use information for purposes disclosed to you at the point of collection, as authorized by you, or as otherwise permitted or required by law.
4. How Your Information Is Shared
We may share your information with our third party service providers that work on our behalf, including by providing or fulfilling the products and services you request, authorizing and processing your payments, performing fraud protection and credit risk reduction, product customization, marketing and promotional material distribution, website and application evaluation, data analysis, website improvements, and, where applicable, data cleansing, marketing, promotions and other services performed on our behalf or on behalf of our parent or affiliates.
In addition, we may share or transfer information about you to unrelated third parties:
- When you engage in activities that are sponsored by third parties (e.g., cobranded offerings);
- As required by law or a legal process, including investigating a potential crime;
- When we believe it is necessary to protect the rights, property, or safety of True & Co. or other persons.
We disclose the following categories of information for our business purposes:
- Identifiers: disclosed to service providers and contractors; payment processors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
- Demographic information: disclosed to service providers and contractors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
- Transaction information: disclosed to service providers and contractors; payment processors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
- Payment information: disclosed to service providers and contractors; payment processors; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; and retail partners.
- Internet activity information: disclosed to service providers and contractors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
- User generated content (UGC): disclosed to service providers and contractors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
- Location information: disclosed to service providers and contractors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing
Audiovisual information: disclosed to service providers and contractors;
affiliates and subsidiaries; law enforcement, public and
government authorities, and others; and advisors and
Inferences: disclosed to service providers and contractors; advertising and
marketing partners; affiliates and subsidiaries; law
enforcement, public and government authorities, and others;
advisors and consultants; retail partners; and joint marketing
At True & Co., we do not share your personal information with third parties in exchange for money. We do share certain information with advertising and marketing partners in exchange for insights, digital advertising, and other valuable services. Such sharing may be considered a “Sale,” “Sharing,” or “Targeted Advertising” under certain laws. We disclose the following information in such circumstances:
- Demographic information
- Internet activity information;
- Location information;
- Inferences; and
- Transaction information.
We may also share your data in the event of an actual or potential sale, merger, acquisition or transfer of our business or assets.
We may use or share information that does not reasonably identify you with any third party and for any purpose.
We retain the information we collect for as long as we have a legitimate business purpose to retain the data, as long as permitted by law, or until you request we delete the data if such a right exists in your jurisdiction.
5. What Choices Can You Make About Your Data
If you no longer wish to receive promotional emails or direct mail from True & Co., you can contact Customer Service. A request to opt-out may take three to five business days to take effect. If you have a Rewards Account with us, you may still receive communications related to your account, loyalty points or special offers (such as birthday discounts). An opt-out request will also not stop transactional emails related to your purchases.
If you no longer wish to receive the text messages that you had consented to previously, you can text “STOP” after receiving a message.
Accessing, Correcting or Deleting your Data
If you would like to receive a copy of the personal information that True & Co. has collected from or about you, you can complete this form or call 1-866-513-0513. You will be asked to verify your identity via the process outlined on the form, including providing your name and email address.
If you would like True & Co. to correct or delete your data, you can complete this form or call 1-866-513-0513. You will be asked to verify your identity via the process outlined on the form, including providing your name and email address.
You may continue to receive advertisements for True & Co. regarding our products. Those advertisements may be delivered to you based on your future interactions with us or based on the determination of our business or advertising partners that you are a member of the desired audience for a campaign.
If you wish to exercise one of the above rights on behalf of someone else, you may use the channels listed above.
Please note that if you create an account separately with a third party found on our site, such as to redeem a first responder discount, you will need to submit an access, deletion, or correction request directly with that third party.
Sale of Personal Information and Use for Targeted Advertising
At True & Co., we do not provide your personal information directly to third parties for their own marketing purposes in exchange for monetary consideration. However, as mentioned in this policy, we do engage in Interest-Based Advertising, where we allow third parties to place cookies, pixels, and trackers on our site to provide you with personalized ads. If you would like more information about how True & Co. manages your cookie preferences
please click here and read the State Privacy Rights section below for information about the rights you may have.
6. US State Privacy Rights
Depending on the state in which you reside, you may have the following privacy rights, subject to statutory limitations:
- Right to Opt Out of Sales and Sharing or Using Personal Information for Targeted Advertising: Consumers have the right to opt-out of our “sales” or “sharing” or use for targeted advertising of their personal information.
- Right to Limit the Use of Sensitive Personal Information: Consumers have a right to request that we use and disclose certain sensitive information only for certain purposes permitted under law.
- Right to Know: Consumers have the right to request that we disclose what personal information we collect, use, disclose and sell about them specifically. In your request, please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.
- Right to Correct: Consumers have the right to request that information we collected about them be corrected.
- Right to Delete: Consumers have the right to request the deletion of personal information that we collect or maintain about them.
- Right Not to Be Discriminated Against: You may not be discriminated against because you exercise any of your rights under state law.
To exercise the above rights, click here.
If you submit a request to exercise your rights, we may ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with state law. If we deny your request, we will explain why. If you would like to appeal a denial of your rights request, please contact firstname.lastname@example.org.
You can designate an authorized agent to make a request regarding your privacy rights on your behalf if you reside in California and:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
- You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know, right to opt-out of the “sale” or “sharing” of your personal information, or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described earlier:
- Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to True & Co. Privacy Office; and
- Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.
If you provide an authorized agent with power of attorney pursuant to California Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
7. Notice of Financial Incentive
From time to time, we may offer free shipping, order discounts, or other benefits to consumers who provide us their email address, phone number, and/or zip codes when they sign up to receive our marketing communications. Consumers may opt in by entering their information where prompted on our website. Consumers may opt out at any time by following the unsubscribe instructions in our marketing communications. The value of the consumer information that we collect is reasonably related to the expenses of providing the discounts and other benefits (which may vary depending upon the specific benefits offered or the value of the consumer relationship in terms of purchases.
8. How Do We Protect Your Data
We use commercially reasonable technical, administrative and physical security measures to protect the information that we collect or receive, in addition to contractual safeguards. Our websites use an industry standard encryption protocol known as Secure Sockets Layer (SSL) to protect your order information. Each payment transaction made through our websites and applications (or any successor or similar digital property) will be transmitted using SSL encryption. We review our security measures periodically. Despite these measures, please be aware that no security measures are perfect or impenetrable. If you believe that you were the victim of a scam related to True & Co., visit the PVH Anti-Fraud Information Guide. Fraudulent charges need to be raised with your financial institution.
Children’s Personal Information
True & Co. is concerned about the safety of children when they use the Internet. Our websites and applications are not directed to children under the age of 13. If we become aware that a user is under the age of 13 and has registered without prior verifiable parental consent, we will remove their information from our files. If a parent or guardian discovers that a child under the age of 13 has provided us with information, we ask that you contact us at email@example.com.
9. How Do You Contact True & Co.
Other requests can be sent to Customer Service Department here..
10. Special Notice For Canadian Users
We may store or process your personal information on servers in jurisdictions outside of Canada, including in the United States of America. While your personal information is in a jurisdiction it may be accessed by the courts, law enforcement and national security authorities of that jurisdiction, or otherwise, in accordance with the laws applicable in that jurisdiction.
A. Who and what information is subject to the CCPA?
The CCPA protects Californians with respect to their personal information. As a result, the Supplemental CCPA Disclosures and relevant CCPA Rights subsections below may not apply when they restrict our ability to comply with a court order or regulator with competent authority, federal, state or local laws, cooperation with law enforcement, exercise of our legal claims, or collection or use of de-identified information.
B. Supplemental CCPA Disclosures
Additional information about sales of information can be found below the table.
|Category of personal information:||
We collected such personal information for the following purposes:
|Identifiers: such as your name, postal address, email address, social media handle, telephone number, or Identification materials||
We may use this information for any of the purposes described in section 3.
|Categories of personal information described in subdivision (e) of Section 1798.80 of the California Civil Code, including name, signature, address, telephone number, passport number, and credit card number, debit card number, or any other financial information.||We use this information to process payment, fulfil your order, or process a return.|
|Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||We use this information to fulfil your order, manage consumers’ online account with us, personalize and optimize consumers’ shopping experience with us (for example, letting you know when a favorite product is back in stock, recording certain information from past purchases which can be used in future purchases such as preferred address and favorite store locations), provide consumers with customer care, and customize a product per a consumer’s specific request.|
|Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.||
We may use this information for any of the purposes described in section 3.
|User Generated Content (UGC).||
We may use this information for any of the purposes described in section 3.
We may use this information to enable consumers to view
|Audio, electronic, visual, or similar information.||We use audio, visual or similar information that you may voluntarily provide in connection with customer care inquiries or when you engage with our social media initiatives for purposes of providing and improving customer service, training, resolving complaints or inquiries, legal compliance, and exercising or defending legal claims. .|
Inferences drawn from any of the information identified in
this subdivision to create a profile about a consumer
reflecting the consumer’s preferences, characteristics
We use such information to personalize and optimize
consumers’ shopping experience with us, enable
consumers to use our “wish list” or “add
to closet” features online, tailor our marketing
efforts, and develop and improve our products and services.
|Sensitive personal information, including account credentials and precise geolocation.||
We use account credentials for the security purposes and
• To process your transactions and provide you with the products and services you request.
We retain personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we retain your personal information for a period of time that enables us to:
- Maintain business records for analysis and/or audit purposes.
- Comply with record retention requirements under the law or other relevant legal or regulatory requirements.
- Defend or bring any existing or potential legal claims.
- Deal with any complaints regarding the services.
- Preserve historical records of transactions.
During the past 12 months, we have shared Identifiers; Demographic information; Internet activity information; Location information; Inferences; and Transaction information. certain categories of personal information about California residents with third parties and business partners in a manner that may constitute a “Sale” or “Sharing” under the CCPA, as described below:
- Online Promotions and Advertising: We work with one or more third parties to: (i) administer and analyze effectiveness of advertising or promotional campaigns. These third parties may place cookies on individuals’ computers to receive information about traffic to our site, browsing and purchasing activity on our online services, and (ii) From time to time third parties may help us to provide a more tailored user experience. These third parties may collect information about individuals’ internet or other similar network activity and browsing patterns, IP address, page interaction (such as scrolling, clicks and mouseovers), and information obtained via cookies with these third parties (such as the site visited before or after). To opt out of these disclosures, please click: Do Not Sell or Share My Personal Information. We also recognize the “Global Privacy Control” (GPC) to allow you to opt out of the sale of your personal information and the sharing of your personal information for targeted advertising on our websites. The GPC is a proposed specification designed to allow Internet users to notify businesses of their privacy preferences, such as whether or not they want their personal information to be sold or shared. To learn more about the GPC and how you can use it to opt out of the sale or sharing of your personal information you can visit their website here. If you visit our website with a browser transmitting GPC, we will not share for targeted advertising or sell your personal information associated with your visit.
- We do not use or disclose information deemed sensitive under applicable law for purposes other than permitted under such law. We do not knowingly sell or share the personal information of individuals under 16.