Shannah Campbell

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Privacy Policy


TOUCHSTONE CRYSTAL DATA PRIVACY POLICY (Updated - US)

Version: June 2020

This “Privacy Policy” describes how Touchstone Crystal, Inc. (“Touchstone”) collects, uses and shares personal information about you. By interacting with Touchstone through our Consultants, Site (defined below), applications, products, and services, you consent to the use of information that is collected or submitted as described in this Privacy Policy. Touchstone collects, processes, discloses, holds, and uses your personal information and data securely, fairly, and lawfully in accordance with relevant U.S. federal and state laws. Such processing may be carried out electronically and automatically. We may change this Privacy Policy from time to time, without notice, to make sure it complies with applicable laws and conforms to changes in our business. If we make changes, we will post the revised version of the Privacy Policy on our website www.touchstonecrystal.com (the “Site”), update the “Version” date at the top of this page, so that you can tell if it has changed since your last visit, and may notify you in other ways as may be appropriate. We encourage you to review this page regularly to ensure you are comfortable with any revisions. Your continued interaction with Touchstone through our Site or Consultants’ parties constitutes your acceptance of the terms of this Privacy Policy as amended or revised by us from time to time.

If you reside in California, please see the Your Rights Under the California Consumer Privacy Act section for information regarding the rights of California residents under the California Consumer Privacy Act (the “CCPA”). Any terms used in the ‘Your Rights Under the California Consumer Privacy Act section have the same meaning as defined in Cal. Civ. Code 1798.140, including the term “personal information.”

 

I.  Information We Collect

Types of personal information we may collect include:
  • First and last name
  • Postal address
  • Zip code
  • Email address
  • Phone number
  • Date of birth or age
  • Gender
  • Payment information
  • Other payment details (in accordance with other laws and regulations)
  • Purchase and/or return history
  • Data concerning your use of our Site (including, but not limited to, the IP address and other user identification, username for social media, MAC address of smartphones or computers, cookies, date and time of visits, visited sites and contents, and referring websites)

As a reminder, personal information can be any information that we can use to identify, locate, or contact you. Personal information does not include aggregate or de-identified information.

Information You Provide to Us

We collect information you provide directly to us. By voluntarily providing your personal information to Touchstone through our Site, Consultants’ parties’ or products and/or services, you, the customer, give consent to Touchstone to collect, hold, disclose, and use your personal information. This consent can occur, for example, by registering your contact details with Touchstone.
If you choose not to provide information, we may not be able to provide you with the requested products, services or information.

If you provide us with personal information of other persons, for example: information about the receiver of a gift, please provide their personal information to us only if you are allowed to do so pursuant to applicable data protection laws and only if the other person would agree to you providing personal information to us for the purposes the information is collected and processed according to our data privacy notice.

Automated Information Collection. We and our service providers may automatically collect and process certain personal information from and about you when you access our Site. Examples of information we may collect include, but are not limited to: pages you visit, type of browser/device/hardware, MAC address of smartphones or computers, IP based geographic location and search terms. This information helps us recognize you as a customer to create a customized experience, enables customers to purchase Touchstone products, allows us to conduct market research with the goal of improving our website and product range, keeps customers informed about Touchstone’s market activities, and allows us to better delegate repairs or other logistical tasks to third parties. We may also use automated collection technologies for reporting and analysis purposes, such as the performance of our marketing efforts and your response to those marketing efforts, and as otherwise required to provide the best possible customer experience for you. We may connect information collected automatically with information we already have about you in order to identify you as a Touchstone customer. For example, we may collect information about you from other third parties, including demographic information, and combine this information with other information we collect about you. This allows us to provide you with a more personalized experience.

Cookie Policy. Touchstone uses tracking technology (“Cookies”), which help make the Site more user-friendly, efficient, and secure. This Cookie Policy provides you with information on the use of Cookies on the Site:

Cookies are small text files that are stored on your PC and used by your browser. Most of the Cookies Touchstone uses are session cookies, which are deleted automatically at the end of your visit.

Cookies will not harm your PC and do not contain any viruses. Nevertheless, if you do not want to use cookies, this will not prevent you from accessing the Sites in any way. The “help” portion of the toolbar on most browsers will provide information on how your browser may be configured so that cookies can be accepted with your permission or completely blocked. You may be able to change your browser settings so that they do not allow Cookies to be accepted or saved at any time. You can also delete Cookies that have already been saved at any time.

Kindly note, however, that if you decline Cookies on the Site, some functions on the Sites may be limited or unavailable. As a result, to make it easier to use the Site, we recommend that your browser settings accept Cookies on the Site.

Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals and, therefore, Touchstone and the Sites do not recognize DNT.

Advertising and Analytics Services. We engage third parties to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons, and other technologies to collect information about your use of our Sites, such as your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Site and other websites and better understand your online activity. For more information about Internet-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit the following websites: www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices.

We may also work with third parties to serve ads to you as part of a customized campaign on other websites or platforms. One company we work with is Google, and we may use various Google tools to assist with analytics and advertising related to our Site. To learn how Google collects and processes data, including ways you may opt-out from receiving ads through Google tools, please visit: www.google.com/policies/privacy/partners.

Social Plug-ins. Touchstone uses so-called social plug-ins (in the following, plug-ins) of social networks such as Facebook, Twitter, YouTube, Pinterest or Instagram.

When you visit our Site, these plug-ins are deactivated by default, i.e. without your intervention they will not send any data to third parties. Before you are able to use these plug-ins, you must activate them by clicking on them. These plug-ins then remain active until you deactivate them again or delete your Cookies. After their activation, a direct link to the server of the respective social network is established. The contents of the plug-in are then transmitted from the social network directly to your browser and incorporated in the website by it.

Please note that we have no influence on the extent of the data retrieved by the social networks with their plug-ins. For information on the purpose and extent of the data retrieval by the social network concerned, and about the rights and settings possibilities for the protection of your private sphere, please refer to the privacy policy provided by the social network in question.

After activation of a plug-in, the social network can retrieve data, independently of whether you interact with the plug-in or not. If you are logged on to a social network, the network can assign your visit to the Site to your user account.

If you are a member of a social network and do not wish it to combine data retrieved from your visit to our Site with your membership data, you must log out from the social network concerned before activating the plug-ins.

II.  How We Use Your Information

We use your information to provide our services and to better enhance your customer experience. In addition to the examples given in Section I, we may use your information:
  • in connection with the services offered on our Site or to fulfill and manage purchases, orders, payments, and returns/exchanges;
  • to manage, maintain, and enhance our Site;
  • to respond to requests for information about our products and services on our Site;
  • to deliver personalized emails, mobile messages, social media notifications, surveys, and other marketing related materials;
  • to connect with you regarding customer service activities;
  • for our other internal business purposes, designed to improve and enhance your customer experience.

We may display targeted ads to you through social media platforms. These ads are sent to groups of people who share traits such as likely commercial interests and demographics. For example, we may target customers who have expressed an interest in shopping for necklaces, bracelets, etc. See the policies of each social media platform for additional information about these types of ads.

By providing your residential or wireless phone number(s) to us, you expressly consent to receive marketing and non-marketing calls and text messages from or on behalf of Touchstone. Your consent to receive calls or texts is not a condition of any purchase. Consent to receive calls or text messages can be revoked at any time -- please follow the unsubscribe link in the relevant communications or contact us using the link at the bottom of the message. Even after you opt-out or update your marketing preferences, however, we may still contact you for transactional or informational purposes. These include, for example, customer service issues, returns or product-related inquiries, surveys or recalls, or any questions regarding a specific order.

Use of automated collection technologies also help us prevent fraud or other harmful activities. We may also use your information to assist law enforcement and respond to regulators, investigate security breaches, or other legal inquiries.

In any circumstance other than those described in this Privacy Policy, we will ask for your consent before we share your personal information outside of our corporate family of companies.

III.  How We Share Your Information

In addition to the use cases set forth in this Privacy Policy, we may also provide your information to our service providers as necessary to enable them to perform certain services for us, including, but not limited to: email-providers, mobile marketing providers, analytics providers, web hosting providers, payment processors, fraud prevention providers, or shipping services providers. If you visit any of these websites, you may want to review the privacy policy on that site.

We may also disclose specific information when such disclosure appears necessary to comply with the law, a subpoena or other litigation process, or to protect the interests or safety of our visitors and customers, employees, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

In the event that part or all of Touchstone is bought, sold or otherwise transferred, or is in the process of a potential transaction, customer information will likely be shared for evaluation purposes and included among the transferred business assets.

We may share aggregate or de-identified data derived from information we collect with advertisers and other third parties.

In any circumstance other than those described in this Privacy Policy, we will ask for your consent before we share your personal information outside of our corporate family of companies.


IV.  Access

Security. We take reasonable measures to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction. Unfortunately, no data collection or storage process can be guaranteed 100% secure. We only allow parties to access your information for permitted business purposes. Any information you provide to Touchstone is done so entirely at your own risk.

Children. Touchstone is concerned about the privacy and safety of children when they use the Internet. We do not knowingly collect any personal information from children under the age of 15 without parental consent. Our products are for purchase by adults only and our Site is not targeted to or intended for use by children.


V.  Your Rights Under the California Shine the Light Law (Cal. Civ. Code Section 1798.83)

California residents are permitted to opt out of the disclosure of their personal information, as defined in Cal. Civ. Code 1798.83 (e)(7), to third parties for the third parties’ direct marketing purposes. To opt out, email us at us.privacy@swarovski.com or call us at +1-800-203-2488. We will not disclose the personal information of California residents who have opted out to third parties for the third parties’ direct marketing purposes.

VI.  Your Rights Under the California Consumer Privacy Act (CCPA)

California law requires businesses to disclose information regarding the rights of California residents pursuant to the CCPA. Any terms defined in the CCPA (Cal. Civ. Code Section 1798.140) have the same meaning when used in this section.

California residents may request that we disclose to them the following information covering the preceding 12 months:
  • The categories of personal information we have collected about them;
  • The categories of sources from which the personal information was collected;
  • The business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with which we share personal information;
  • The categories of personal information about them that we have sold and the categories of third parties to which the personal information was sold;
  • The categories of personal information about them that we have disclosed for a business purpose and the categories of third parties to which the personal information was disclosed;
  • The specific pieces of personal information we have collected about them.

A California resident may request the disclosure of the information listed above by calling +1-800-203-2488 or submitting a request at us.privacy@swarovski.com. Such a request may be referred to as a right to know request. Pursuant to California law, we will verify the California resident’s identity before complying with any such request, which may include confirmation of the California resident’s name, email address, a recent purchase, and other information, as well as the California resident’s submission of a signed declaration under penalty of perjury that they are in fact the California resident whose personal information is the subject of the request. To assist us in complying with your request, please provide your full name, email address, postal address, and information regarding a recent purchase (identify item, location where purchased, and approximate date). Please be aware that if we cannot verify your identity from the information we already maintain, we may require additional information from you to verify your identity prior to complying with your request. Such additional information will be used only for the purposes of verifying your identity and for security or fraud-prevention purposes, and will be deleted as soon as practicable after processing your request. If we are unable to verify your identity to the requisite degree of certainty, we will not be able to process your request and will so inform you and explain why.

A California resident has the right to request that we delete any personal information about the California resident that we have collected from the California resident, and that we direct any service provider to delete such personal information from its records. Such a request may be referred to as a request to delete. However, pursuant to the CCPA, a California resident’s personal information may not be deleted under certain circumstances, including where maintenance of your personal information is necessary to: complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, to provide a good or service that they requested or that is reasonably anticipated within the context of their ongoing business relationship with us, or to otherwise perform a contract between Touchstone and you; to detect security incidents, protect against or prosecute fraudulent or illegal activity; to enable solely internal uses that are reasonably aligned with their expectations based on their relationship with us; to comply with a legal obligation; or to otherwise use their information internally in a lawful manner that is compatible with the context in which they provided the information. For more information about these and other situations in which we may not delete a California resident’s personal information, please see Cal. Civ. Code Section 1798.105(d). A California resident may request the deletion of their personal information by calling +1-800-203-2488 or submitting a request at us.privacy@swarovski.com. Before deleting a California resident’s personal information, we will obtain confirmation that the person wishes to have their personal information deleted and verify their identity, as required by the CCPA. Verification may include confirmation of the California resident’s name, email address, a recent purchase, and other information, as well as the California resident’s submission of a signed declaration under penalty of perjury that they are in fact the California resident whose personal information is the subject of the request. To assist us in complying with your request, please provide your full name, email address, postal address, and information regarding a recent purchase (identify item, location where purchased, and approximate date). Please be aware that if we cannot verify your identity from the information we already maintain, we may require additional information from you to verify your identity prior to complying with your request. Such additional information will be used only for the purposes of verifying your identity and for security or fraud-prevention purposes, and will be deleted as soon as practicable after processing your request. If we are unable to verify your identity to the requisite degree of certainty, we will not be able to process your request and will so inform you and explain why.

A California resident may use an authorized agent to submit a right to know request or a request to delete. To use an authorized agent, the California resident must provide the agent with written authorization. In addition, the California resident may be required to verify their own identity with us. We may deny a request from an agent that does not submit proof that they have been authorized by the California resident to act on their behalf. Such requirements, however, will not apply where a California resident has provided the agent with power of attorney pursuant to Cal. Prob. Code Sections 4000 to 4465.

In the preceding 12 months, we have collected the following categories of personal information about California residents from the following sources and for the following purposes. The CCPA requires that we refer to specific categories of personal information enumerated in the CCPA. We may collect only certain pieces of personal information described in a given category and may not collect certain pieces of personal information described in each category. In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information about California residents to the following categories of third parties (to the extent the disclosure was made to a third party).

Category of Personal Information Collected

Category of Source of Collection

Business or Commercial Purpose of Collection Category of Third Party to Which Personal Information May Have been Disclosed for a Business Purpose

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number; driver’s license number, passport number, or other similar identifiers

  • You
  • Our customers
  • Business partners
  • Automated Collection from website visitors

  • Service delivery
  • Research & Development
  • Marketing
  • Advertising
  • Compliance & Operations
  • To create anonymous, aggregated or de-identified data
  • Affiliates
  • Advertising partners
  • Service-related third parties
  • Professional advisors
  • Authorities and others
Categories of personal information described in subdivision (e) of Cal. Civ. Code Section 1798.80 (Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, physical characteristics or description, address, telephone number, driver's license or state identification card number, bank account number, credit card number, debit card number, or any other financial information)
  • You
  • Our customers
  • Automated Collection from website visitors
  • Service delivery
  • Marketing
  • Advertising
  • Research & Development
  • Compliance & Operations
  • To create anonymous, aggregated or de-identified data
  • Affiliates
  • Advertising partners
  • Service-related third parties
  • Professional advisors
  • Authorities and others
Characteristics of protected classifications under California or federal law (Profile data which is optional: gender and/or age)
  • You
  • Our customers
  • Automated Collection from website visitors
  • Service delivery
  • Marketing
  • Advertising
  • Research & Development
  • Compliance & Operations
  • Affiliates
  • Advertising partners
  • Service-related third parties
  • Professional advisors
  • Authorities and others
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
  • You
  • Our customers
  • Automated Collection from website visitors
  • Service delivery
  • Research & Development
  • Marketing
  • Advertising
  • Compliance & Operations
  • Affiliates
  • Advertising partners
  • Service-related third parties
  • Professional advisors
  • Authorities and others
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 website, application, or advertisement
  • You
  • Business partners
  • Automated Collection from website visitors
  • Service delivery
  • Research & Development
  • Marketing
  • Advertising
  • Compliance & Operations
  • Affiliates
  • Advertising partners
  • Service-related third parties
  • Professional advisors
  • Authorities and others

Touchstone does not sell your personal information as that term is defined under the CCPA.

We will not discriminate against a California resident because the California resident exercised any of their rights under the CCPA, including, but not limited to, by:
  • Denying goods or services to the California resident;
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Providing a different level or quality of goods or services to the California resident; or
  • Suggesting that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by that resident’s data. In addition, we may offer financial incentives, including payments to California residents as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information. We may also offer a different price, rate, level, or quality of goods or services to the California resident if that price or difference is directly related to the value provided to us by that resident’s data. We will notify California residents of such financial incentives and we will enter a California resident into a financial incentive program only if the California resident gives us prior opt in consent which clearly describes the material terms of the financial incentive program, and which may be revoked by the California resident at any time. We will not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.

We currently do not offer any financial incentives.

Contact Information. If you have questions about this Privacy Policy and Touchstone’s practices regarding the collection and use of your information, please feel free to contact us at 1-800-203-2488 or us.privacy@swarovski.com. This Privacy Policy is not intended for European Union Residents. Our Site may offer links to other websites. If you visit any of these websites, you may want to review the privacy policy on that site. In the event that the activities covered by this notice are governed by other data protection policies, are evident from the circumstances, or are governed by applicable laws of the European Union and the European Economic Area, then such applicable law and resulting policies shall control.