Privacy Policy
TOUCHSTONE CRYSTAL DATA PRIVACY POLICY (Updated - US)
Version: November 2023
This “Privacy Policy” describes how Touchstone Crystal, Inc. (“Touchstone”, “we” or “our”) collects, uses and shares personal information about users of its website, customers, business associates, (together referred to herein as “Users”) and Touchstone Consultants and applicants to be Consultants (together referred to herein as “Consultants”; Users and Consultants collectively referred to herein as “you” or “your”, as applicable). By interacting with Touchstone through our Consultant, Site (defined below), applications, products, services, or any other applications that link to our Site, including third-party social media platforms with a social commerce component, such as Facebook, Instagram, or Tik Tok, you consent to the collection, use, and disclosure of personal information about you as described in this Privacy Policy. (Please note that we have no control over the privacy practices of third-party websites, applications, or social media platforms that we do not own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policy or privacy notice/statement posted on any external website before disclosing any personal information. Please contact those websites directly if you have any questions about their privacy policies.)
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, or other services constitutes your acceptance of the terms of this Privacy Policy as amended or revised by us from time to time.
I. Information We Collect
Personal Information we may collect include:
- First and last name
- Postal address
- Zip code
- Email address
- Phone number
- Date of birth or age
- Gender
- Information required for our third-party payment processor to process your payments
- Purchase and/or return history, including use of discount offers
- Data concerning your use of our Site (including, but not limited to, the IP address and other User identification, user name for social media, MAC address of smartphones or computers, cookie web beacon and pixel information, date and time of visits, visited sites and contents, and referring websites)
Information You Provide to Us
We collect information you provide directly to us. By voluntarily providing your Personal Information to Touchstone through our Site, our Consultants, our Consultants’ parties’, events, or through other products and/or services we offer, you, the customer or Consultant, give consent to Touchstone to collect, hold, disclose, and use your Personal Information for the purposes for which you provided it and as otherwise set forth in this Privacy Policy. This consent can occur, for example, by registering your contact details with Touchstone to find a Consultant or be a Consultant, to make a purchase, host a party, enroll in a sweepstakes, sign up for emails or other communications, participate in a survey, opportunity call, or special event or promotion, or request contact by us, or by applying to be a Consultant.
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 or a referral, 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 your providing Personal Information to us for the purposes for which the information is collected and processed according to this Privacy Policy.
Cookies are small text files, which may be offered by third parties, that are stored on your device and used by your browser. Touchstone Crystal primarily uses session cookies to enhance the user experience on our website. These cookies are automatically deleted at the end of your visit and do not contain any sensitive or customer-based information. We use the following types of cookies on our Site:
| Cookie Type | Description of Cookies |
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Necessary / Essential Cookies |
These are essential to enable you to move around our Site and to allow the features of the sites to work correctly. Without these, services you request – such as navigating between pages – cannot be provided. These cookies are used to collect information about how visitors use our Site. We use this information to compile reports and to help us improve the Site. These cookies are used to request for services, such as setting your privacy preferences, logging in or filling in forms, or updating account information, etc. Some may be set by us or by third-party providers whose services we have added to our pages. Some are used in connection with access to admin. Others are used to track a User's session. You can set your browser to block or alert you about these cookies, but some parts of our Sites may not work. These cookies do not store any personally identifiable information except as may be necessary to authenticate your access to our Site. |
| Personalization / Functional Cookies | These cookies record information about choices you have made and allow us to remember your preferences. These cookies enable our Sites to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly. |
| Statistics / Performance and Analytics Cookies | These cookies allow us to count visits and traffic sources, through various third parties, so we can measure and improve the performance of our sites. These enable us to collect information about how you use our Sites or read our publications, for instance which pages are viewed by visitors most frequently and how users interact with each of our Site. This information is used to compile reports to improve the respective site, including reports on the number of visitors to the Site, where the visitors are located, and what pages the users visit on the Sites. All information these cookies collect is aggregated. If you do not allow these cookies, we will not know when you have visited our Sites and will not be able to monitor site performance. |
How to disable cookies: Most browsers automatically accept cookies unless you change your internet browser settings. If you wish to restrict, block or delete the cookies which are set by our Sites, you can generally do this through your browser settings. 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. These settings are usually found in the 'options' or 'preferences' menu of your internet browser. You can also delete Cookies that have already been saved at any time. If you set your internet browser preferences to block all cookies, you may not be able to access all or parts of our site.
Google Analytics: You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on. If you use more devices and/or browsers, you will need to disable cookies on each device and on each browser separately.
If you want to learn more about cookies, or how to control, disable or delete them, please visit http://www.aboutcookies.org for detailed guidance. In addition, certain third-party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing.
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, there is not yet established universal standards for recognizable DNT signals and, therefore, Touchstone and the Sites do not recognize DNT.
Analytics Services. We engage third parties to provide analytics services. These entities may use cookies, pixels, 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 and better understand your online activity. .We work with Google, and we may use various Google tools to assist with analytics related to our Site. To learn how Google collects and processes data please visit: www.google.com/policies/privacy/partners.
II. How We 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 and Consultant accounts;
- to respond to requests for information about our products and services on our Site and to provide non-marketing information concerning matters such as changes to our Privacy Policy or Terms and Conditions and/or Terms of Use, changes to product and service offerings, account verification, password reset, or incidents that could affect our products or services;
- to deliver invitations to events, discounts and other offers, newsletters, promotional activities, emails, mobile messages, social media notifications, surveys, and other marketing related materials;
- to connect with you regarding customer service activities;
- to administer sweepstakes, contests, or other promotional activities;
- to support a contemplated or actual corporate transaction such as reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including with any bankruptcy or similar proceedings);
- for our other internal business purposes, designed to improve and enhance your customer experience.
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 regulatory, investigate security breaches, or other legal inquiries.
III. Right to Opt-Out of the Sale or Sharing of Personal Information
Touchstone does not exchange your Personal Information for money or for any non-monetary consideration, which may be considered a “sale” of Personal Information under some state privacy laws. Additionally, Touchstone does not exchange or share your Personal Information for money or for any non-monetary consideration, for purposes of targeted advertising or cross-context-behavioral advertising. If you have any questions regarding Touchstone’s practices with respect to targeted advertising or cross-context-behavioral advertising, you may contact Touchstone by: (1) calling +1 800-203-2488; or (2) sending an email to us at support@touchstonecrystal.com or us.privacy@swarovski.com.
IV. 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, sweepstakes vendors, payment processors, fraud prevention providers, or shipping services providers.
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 Touchstone or 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 a division, asset, or 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. As noted above, such aggregate or de-identified data does not constitute Personal Information.
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.
V. Your Choice and Access
Updating and Changing Your Contact Information
Consultants who register their contact details through our Site, you may view and modify, correct, block or delete their data at any time by selecting Consultant Login and making your changes in their Account area of the Site. Customers of Touchstone can modify, correct, block or delete their data at any time by contacting their Consultant or by contacting Touchstone by: (1) calling +1 800-203-2488; or (2) sending an email to us at support@touchstonecrystal.com.
VI Nevada Privacy Rights
Touchstone does not exchange your Personal Information for money or for any non-monetary consideration, which may be considered a “sale” of Personal Information under some state privacy laws, including Nevada. Additionally, Touchstone does not exchange or share your Personal Information for money or for any non-monetary consideration, for purposes of targeted advertising or cross-context-behavioral advertising.
VI Additional Information for residents of Colorado, Connecticut, Utah, and Virginia
If you are a resident of Colorado, Connecticut, Utah, or Virginia, you have the following rights:
1. Right to Know and Access
You have the right to know whether we are processing your Personal information. You also have the right to access the Personal Information that we collected pertaining to you.
2. Right to Correct
Subject to certain exceptions, you have the right to request that we correct inaccurate Personal Information that we have collected about you. Once we receive your request and confirm your identity, we will review your request, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information to consider whether we can correct the data. We may also request additional information showing that the information you want to correct is inaccurate.
3. Right to Delete
You have the right to request that we delete any Personal Information about you that we collected from you. You also have the right to direct any of our service providers to delete such Personal Information from its records.
4. Right to Non-Discrimination
We will not discriminate against any of our Users for exercising their rights under applicable law. If, however, you are a resident of Colorado, Utah, or Virginia, you are granted the explicit right to non-discrimination in relation to exercising your privacy rights under applicable law. As such, we will not engage in the following acts:
• Denying goods or services to the Colorado, Utah, or Virginia 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 Colorado, Utah, or Virginia resident; or
• Suggesting that the Colorado, Utah, or Virginia resident will receive a different price or rate for goods or services or a different level or quality of goods or services.
You have the right to request that we provide a copy of the Personal Information we have collected about you, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Once we receive your request and confirm your identity, we will provide you with a copy of your data.
6. Right to Opt Out of the Sale or Sharing of your Personal Information.
7. Exercising Your Rights
8. Right to Appeal
Colorado Residents:
Colorado Department of Law
Ralph L. Carr Judicial Building
1300 Broadway, 10th Floor
Denver, CO 80203
(720) 508-6000
https://coag.gov/
Connecticut Residents:
165 Capitol Ave
Hartford, CT 06106
(860) 808-5318
https://portal.ct.gov/AG
Virginia Residents:
Office of the Attorney General
202 North 9th Street
Richmond, Virginia 23219
Phone: (804) 786-2071
https://www.oag.state.va.us/
VII. Your Rights Under the California Shine the Light Law (Cal. Civ. Code Section 1798.83)
VIII. Additional Information for California Residents
1. Right to Know
- The categories of Personal Information we have collected about you;
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The categories of sources from which the Personal Information was collected;
- The business or commercial purpose for collecting or selling Personal Information;
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The categories of third parties with which we share Personal Information;
- The categories of Personal Information about you that we have sold and the categories of third parties to which the Personal Information was sold;
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The categories of Personal Information about you 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 you.
2. Right to Portability
You have the right to request that we provide a copy of the Personal Information we collected about you, in a portable and, to the extent technically feasible, readily usable format that allows transmittal of the data to another entity without hindrance. Once we receive such a request and confirm your identity, we will provide you with a copy of your data as required under the CCPA. We may provide this data through your Touchstone’s User account, or via email to the email address provided.
3. Right to Limit Use and Disclosure of Sensitive Personal Information
You have the right to request that we limit the use of your “Sensitive Personal Information” (as defined under the CCPA) to use that is only necessary to perform the services or provide the goods reasonably expected by the resident.
4. Right to Delete
5. Right to Correct
Subject to certain exceptions, you have the right to request that we correct inaccurate Personal Information that we collected pertaining to you. Once we receive your request and confirm your identity, we will review the request, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information to see if we can correct the data. We may also request additional information to show that the information pertaining to the correction inquiry is inaccurate.
6. Right to Opt Out of the Sale or Sharing of your Personal Information.
7. Non-Discrimination
• Denying goods or services to you;
• 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 you; or
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
We may, however, charge you 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 your data.
Persons with disabilities may obtain this notice in alternative format upon request by contacting us at support@touchstonecrystal.com or calling +1 800-203-2488.
Exercising Your Rights
You may make any of the requests listed above by: (1) calling +1 800-203-2488; or (2) sending an email to us at support@touchstonecrystal.com or us.privacy@swarovski.com. Pursuant to California law, we will verify your identity before complying with any such request, which may include confirmation of your name, email address, a recent purchase, and other information, as well as your submission of a signed declaration under penalty of perjury that you 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, and postal address, in your request, and provide 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.
An authorized agent may act on your behalf to submit a request. To use an authorized agent, we may ask that you or the agent provide us written document signed by you authorizing the agent to act on your behalf. In addition, we may request information to verify the agent’s identity. We may deny a request from an agent where we have not been provided proof that the agent has been authorized by you to act on your behalf, or where we cannot verify the agent’s identity. Such requirements, however, will not apply where the agent has a power of attorney pursuant to Cal. Prob. Code Sections 4000 to 4465.
Receipt of requests will be confirmed no later than10 days after such request is received. Requests will be processed with undue delay, but in all cases within 45 days of receipt of the properly submitted request. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests. In such a case we will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Categories of Personal Information
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. 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 |
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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 |
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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) |
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| Characteristics of protected classifications under California or federal law (Profile data which is optional: gender and/or age) |
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| Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
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| Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a User's interaction with an internet website, application, or advertisement |
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Touchstone does not exchange your Personal Information for money or for any non-monetary consideration, which may be considered a “sale” of Personal Information under some state privacy laws. Additionally, Touchstone does not exchange or share your Personal Information for money or for any non-monetary consideration, for purposes of targeted advertising or cross-context-behavioral advertising. If you have any questions regarding Touchstone’s practices with respect to targeted advertising or cross-context-behavioral advertising, you may contact Touchstone by: (1) calling +1 800-203-2488; or (2) sending an email to us at support@touchstonecrystal.com or us.privacy@swarovski.com.
Notice of Financial Incentives
We currently do not offer any financial incentives.
IX. Contact Information.
