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Privacy Policy


TOUCHSTONE CRYSTAL DATA PRIVACY POLICY (Updated - US)

Version: May 2024

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, such as Facebook, Instagram, YouTube, 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 includes information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Personal Information does not include aggregate or de-identified information.

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.

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 or services.  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, and information from cookies, web beacons, pixels and other technologies deployed on our Site.  This information helps us recognize you as a visitor or Consultant to create a customized experience, allows us to conduct market research with the goal of improving our Site and product range, , and allows us to better delegate logistical tasks to third parties.  We may also use automated collection technologies for reporting and analysis purposes, such as traffic on our Site, and as otherwise required to provide the best possible User experience for you.  We may connect information collected automatically with information we already have about you in order to identify you as a User or Consultant. 
Cookie Policy. Touchstone uses cookies, pixels, tags, and similar 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, 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 Site. 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

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. You can disable cookies on our Site by simply saving your acceptance or rejection preferences in the “About cookies on our Site’s pop up banner which appears when you enter 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. To learn more about this feature from Google, click here

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, there is not yet established universal standards for recognizable DNT signals and, therefore, Touchstone and the Sites do not recognize DNT.

reCAPTCHA
To protect your submissions via internet forms on this Site we use the reCAPTCHA service provided by Google Inc. (Google). The service determines whether the query was made by a human being or was the result of misuse, processed automatically by a computer. The service includes sending the IP address to Google and possibly other data if required by Google for reCAPTCHA.  For this purpose, your entry is sent and used by Google. This data collection is subject to the data protection regulations of Google (Google, Inc.). For more information on Google's privacy policy please visit https://policies.google.com/privacy?hl=en&fg=1

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.

Social Media Platforms & Third Party Websites
Touchstone uses the social network YouTube. When you visit our Site and you click to view a YouTube video, a direct link to the server of YouTube is established. The contents of the You Tube plug-in are then transmitted from YouTube directly to your browser and incorporated in the Site by it. Please note that we have no influence on the extent of the data retrieved by YouTube with their plug-in. For information on the purpose and extent of the data retrieval by YouTube, and about the rights and settings possibilities for the protection of your privacy, please refer to the privacy policy provided by YouTube.

After activation of a plug-in, a 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 data, you must log out from the social network concerned before activating the plug-in.

You can disable cookies and the YouTube plug-in by saving your acceptance or rejection preferences in the “About cookies on our website” pop up banner which appears when you enter our Site.

Please be aware that third-party websites and applications have privacy policies that differ from Touchstone’s Privacy Policy. If you choose to access our Site from or in a third-party website or application (for example, Facebook, Twitter, Tik Tok, Instagram, YouTube, or Google) “in-app”, such third-parties may collect information about your activity on our Site and how you use our Site. This information collected by such third-parties may be used to provide services like measurement services or to target ads. When accessing our Site via a third-party website or applications “in-app” we recommend that you review the privacy policy or privacy notice/statement posted on said website or application before disclosing any personal information. Please contact those third-parties directly if you have any questions about their privacy policies or if you wish to opt-out of the collection and use of your information for targeted advertising based on information about your activity on nonaffiliated applications and websites. We have no control over the privacy practices of third-party websites, applications or social media platforms that we do not own. Their use of your information is not governed by this Privacy Policy.

 

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 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.

Security. We take reasonable measures to help protect Personal 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.  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 13 without parental consent.  Our products are for purchase by adults only and our Site is not targeted to or intended for use by children. If you become aware that your child or an individual under 13 has provided their Personal Information through our Site, please contact us by: (1) calling +1 800-203-2488; or (2) sending an email to us at support@touchstonecrystal.com or us.privacy@swarovski.com. If we learn that we have received Personal Information on a child under the age of 13, we will delete that information from our records and systems.


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.
5. Right to Data Portability
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.
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.

7. Exercising Your Rights
Residents of Colorado, Connecticut, Utah, and Virginia 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 applicable law, we will verify your identity before complying with any such request, which may include confirmation of your name, email address. To assist us in complying with your request, please provide your full name, email address, in your request. 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 ask that you or the agent provide us with signed written authorization 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 they have been authorized by you to act on your behalf, or we cannot verify the agent’s identity. 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.

8. Right to Appeal
If you are a resident of Colorado, Connecticut, or Virginia, and you made a request to exercise any of the above data access rights and we were unable to comply with your request, you may request to appeal our decision. To appeal any data privacy request decision, please contact Touchstone by: (1) calling +1 800-203-24088; or (2) sending an email to us at support@touchstonecrystal.com or us.privacy@swarovski.com. If after you complete the appeal process with Touchstone, you are still unsatisfied with our response, you may contact your Attorney General to file a complaint. Below is the contact information for the appropriate entity for appeal inquiries: 

Colorado Residents:
Office of the Attorney General
Colorado Department of Law
Ralph L. Carr Judicial Building
1300 Broadway, 10th Floor
Denver, CO 80203
(720) 508-6000
https://coag.gov/

Connecticut Residents:
Office of the Attorney General
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)

Under California’s "Shine the Light" law (Cal. Civ Code § 1798.83), California residents who provide us certain Personal Information are entitled to request and obtain, free of charge, information about the Personal Information (if any) we shared with third parties during the immediately preceding calendar year for the purpose of direct marketing by the third-party. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. California residents who would like to make such a request may contact Touchstone using one of the methods listed in the section below titled “Exercising You Rights.” For email requests, indicate in the subject line “California Shine the Light Request,” state that the requester is a California resident, and provide the name and email address associated with the resident’s account. We are only required to respond to a customer request once per calendar year. We will not disclose the Personal Information of California residents who have opted out of third-party direct marketing.

VIII.  Additional Information for California Residents

California law requires businesses to disclose information regarding the rights of California residents pursuant to the California Consumer Protection Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”) (collectively, “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 make the following requests with respect to Personal Information in accordance with applicable law:

1. Right to Know
You may request that we disclose to you the following information covering the preceding 12 months:
  • The categories of Personal Information we have collected about you;

  • 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 you that we have sold and the categories of third parties to which the Personal Information was sold;

  • 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
You have the right to request that we delete any Personal Information about and collected from you, and that we direct any service provider to delete such Personal Information from its records. Pursuant to the CCPA, however, your Personal Information may not be deleted under certain circumstances. For more information about these and other situations in which we may not delete your Personal Information, please see Cal. Civ. Code Section 1798.105(d). 

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.
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 +1 800-203-24088; or (2) sending an email to us at support@touchstonecrystal.com or us.privacy@swarovski.com.

7. Non-Discrimination
We will not discriminate against you because you exercised your rights under the CCPA by:
      • 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

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
  • Business partners
  • 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
  • Business partners
  • 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 User's interaction with an internet website, application, or advertisement
  • You
  • Business partners
  • Service delivery
  • Research & Development
  • Marketing
  • Advertising
  • Compliance & Operations
  • Affiliates
  • Advertising partners
  • Service-related third parties
  • Professional advisors
  • Authorities and others

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.  

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 by: (1) calling +1 800-203-2488; or (2) sending an email to us  at support@touchstonecrystal.com or us.privacy@swarovski.com.  This Privacy Policy is not intended for the European Economic Area, Switzerland or the United Kingdom.  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, Switzerland or the United Kingdom, then such applicable law and resulting policies shall control.