Last Updated – January 2021
- Who We Are
- What Information And Personal Data We Might Collect About You
- How We May Use Your Personal Data
- How Is Your Information Shared
- What Choices Can You Make About Your Data
- How Do We Protect Your Data
- Contact Information
- California Supplemental Privacy Notice
- Special Notice for Canadian Users
- Who We Are
- What Information and Personal Data We Might Collect About You
Information that you provide
In order to improve our products, 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 the eligibility for discounts and other offers;
- Demographic information: such as your age, date of birth, or gender;
- User generated content (UGC): such as photos, videos, blog posts, or social media posts.
- Information: such as purchases, product reviews that you provide, and clothing size and fit information
Information that we automatically collect from you
When you visit any of our websites or applications we may automatically collect:
- Identifiers: such as device ID, IP address, and online identifiers, such as cookie numbers;
- 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; and content and pages viewed;
- Location information: such as geo-location of your devices; and
- Inferences: such as your preferences and interests based on your online activities.
Other information we collect
We may collect information about you from activities related to other PVH businesses or third parties like web hosting providers, analytics companies, social media platforms, data companies, and advertising services such as:
- Identifiers: such as updated contact information, social media handles, device identifiers, cookie numbers or similar online identifiers;
- Demographic information: such as your age, date or 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
- How We Use Your Information
We use the information we collect for a variety of purposes, including:
- To provide you with information related to our products and services
- To provide, maintain, protect, develop, and improve our websites, applications and services
- To improve your experience on our websites and applications
- 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 our community programs and focus groups (click here for community program terms and conditions)
- 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
- To comply with our legal obligations
- How Your Information Is Shared
We may share your information with our third party service providers that work on our behalf, including by performing fraud protection and credit risk reduction 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 (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; 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; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
Internet activity information: disclosed to service providers; 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; 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; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
Audiovisual information: disclosed to service providers; affiliates and subsidiaries; law enforcement, public and government authorities, and others; and advisors and consultants.
Inferences: disclosed to service providers; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
At True & Co., we do not share your personal data 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” under certain laws. We disclose the following information in such circumstances:
- Internet activity information;
- Location 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.
- 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 here. A request to opt-out of email may take three to five business days to take effect. A request to opt-out of physical mail may take 45-60 days. An opt-out request will also not stop transactional emails related to your purchases.
Accessing or Deleting your Data
If you would like to receive a copy of the personal data that True & Co. has collected from or about you, you can complete this form or call (888) 968-8783. You will be asked to verify your identity via the process outlined on the form.
If you would like True & Co. to delete your data, you can complete this form or call (888) 968-8783. 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.
Sale of Personal Data
At True & Co., we do not share your personal data directly with 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 want to opt out of such advertising, please click here.
If you are a California resident, you have the right, once per year, to request that we provide you with information about our sharing of information with third parties for their direct marketing purposes. If you would like to exercise this right, please contact us at email@example.com.
We may not discriminate against you for exercising your rights under the California Consumer Privacy Act. We may, however, provide a different level of service or charge a different rate if the difference is reasonably related to the value of your information.
- 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. 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 they contact us at firstname.lastname@example.org.
- How Do You Contact True & Co.
- Who and what information is subject to the CCPA?
The CCPA protects California residents as “consumers” with respect to their personal information, although a number of exceptions apply. 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.
- Supplemental CCPA Disclosures
We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and describe, for each category of personal information collected, the business or commercial purposes for which the information was collected. Each of the categories of personal information listed in the table are collected directly from consumers. Each of the categories of personal information in the table may also be shared with the following categories of third parties: (i) our Service providers and business partners (ii) Government entities as required by applicable law (iii) other recipients at your discretion or with your consent (iv) Third parties in the event of a proposed or actual business transaction involving all or any portion of our business.
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 4.|
|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, fulfill 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 fulfill 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 4.|
|User Generated Content (UGC)||We may use this information for any of the purposes described in section 4.|
|Geolocation data.||We may use this information to enable consumers to view nearby stores.|
|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.|
|Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics and attitudes.||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.|
During the past 12 months, we shared certain categories of personal information about California residents with third parties and business partners in a manner that may constitute a “sale” under the CCPA, as described below:
- Online Promotions and Advertising: We work with one or more third parties to 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 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), and may retain rights to use some of this information for their own purposes.
- CCPA Rights
California residents have the following rights:
- Right to Opt-out of Sale: California residents have the right to opt-out of our “sales” of their personal information. To exercise this right fill out the form located here.
- Right to Know: California residents have the right to request that we disclose what personal information we collect, use, disclose and sell about them specifically. To exercise this right fill out the form located here.
- Right to Delete: California residents have the right to request the deletion of personal information that we collect or maintain about them. To exercise this right fill out the form located here.
- Right Not to be Discriminated Against: You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code § 1798.125.
- Financial Incentives: From time to time we offer consumers who provide their email address, phone number and/or zip code to us for the purposes of receiving our marketing communications, free shipping, or sometimes a discount on an order. Consumers may opt in by entering their information when prompted upon first visiting our website. Consumers may opt out of marketing communications at any time by following the instructions in such communications. The financial incentive is permitted under the CCPA because it is not discriminatory in nature—it does not deny consumers their rights under the CCPA or discriminate against consumers who may have exercised their rights under the CCPA.
If you submit a request to exercise your CCPA 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 the CCPA. If we deny your request, we will explain why.
You can designate an authorized agent to make a request under the CCPA on your behalf if:
- 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” 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:
- Email a certified copy of your written declaration authorizing the authorized agent to act on your behalf to PVH Corp. Privacy Office at email@example.com; 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.
- 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.