Privacy Notice

Last updated and is effective as of 28 January, 2019.

This Privacy Notice (the “Privacy Notice”) applies to Claire’s Stores, Inc. and all of the companies operating under the Claire’s brand that are owned or controlled by Claire’s Stores Inc. or under common control or ownership with Claire’s Stores, Inc., including those operating in the European Economic Area (“Claire’s”, “we”, “us” or “our”), the website claires.com (however accessed or used, whether via personal computers, mobile devices or otherwise) (the “Site”) and other interactive features or protocols that link to this Privacy Notice (including, without limitation, mobile sites, widgets & downloads). This Privacy Notice explains our practices and governs the use of personal information Claire’s collects from you or about you through the Site, its mobile applications, written or oral communications, when you visit its retail stores, or from other sources, including job application systems and careers sites.

Claire’s is an American jewelry and accessories retailer with headquarters in Hoffman Estates, Illinois, USA and operations in approximately 45 countries worldwide.

This Site is owned and maintained by “Claire’s Accessories UK Limited”, a company registered at the Companies Registration Office of England and Wales under the registration number 3115188, with registered office at Unit 4, Bromford Gate, Bromford Lane, Birmingham, B24 8DL, United Kingdom with VAT registration number GB927124727. We are registered with the UK Information Commissioner's Office. Our registration number is Z9591190.

By further browsing the Site, creating an account or registering on the Site, contacting Claire’s customer service, or applying for a position of employment with Claire’s you agree to this Privacy Notice and consent to the collection and use of your Personal Data as described in this Privacy Notice.

We take data privacy very seriously and work super hard to protect your personal information. When collecting and using your personal information we comply with the US and EU privacy laws then in effect and applicable to Claire’s; where our global presence subjects us to stricter requirements of personal data protection laws and regulations of a given country we commit to comply with those requirements. Please take a look at what we do with your information and the choices you can make about how it’s collected and used.

WHY WE COLLECT INFORMATION

In this Privacy Notice, “personal information” means any information that can be used to identify you. This can include your name and last name, address, username, email address, photographs, but can also include your IP address, your geolocation, and shopping preferences and interests. We collect personal information because it is necessary to enable us to deliver products and services. For example, if you order a product, we need to have information such as your billing address, product choice, delivery information, and payment processing information. In addition, your personal information helps us communicate to you the latest products, special offers, and information and events about which you might like to hear if you choose to. We also use your personal information to administer competitions, contests and sweepstakes, if you participate in these.

Additionally, we collect your personal information to help us design and deliver the Site operations, and to deliver targeted advertisements to you. We also may correlate your personal information obtained from you with information from other sources, which may help us to develop a more targeted user profile concerning you and/or your demographic information. For example, if you provide us with your personal information, we may cross-check that against information that might be otherwise available through other entities with whom we have business relationships in order to develop a more in-depth demographic profile of you. Similarly, we may process personal information to target specific items of interest to you.

We know that everyone is busy, and nobody likes their email cluttered up. As such we will only send you marketing messages if you choose to receive them from us. If you decide that you no longer want to receive our marketing emails you can opt-out at any time by clicking and selecting ‘Unsubscribe’ or email us at dataprotection@claires.com.

WHAT INFORMATION WE COLLECT

We may collect personal information at every point of interaction with you. The following generally describes the type of information we may collect about you.

SHOPPING

When you shop on the Site, we will collect the personal information necessary to process your order, such as your name and last name, e-mail address, shipping address, payment information (including credit card number and/or debit card number) and billing address. You may also choose to provide us with your gender and birth date, as well as other information that you might submit.

If you create an account on the Site, we will collect information about your purchases and payment methods, as well as the shipping addresses that you add to your address book, in order to make future shopping experiences faster and more convenient. We will use this information to process your transaction and dispatch your order. Any data that is necessary to process your order constitutes transactional data, and if you refuse to provide it we will not be able to process your order.

When you shop at Claire’s store, your payment information (such as your payment card number and other card information) is collected to process the purchase. Also, in some of the high-risk stores Claire’s uses video cameras to deter shoplifting, and, therefore, while you are on certain Claire’s premises your image may be captured.

GENERAL BROWSING

We do not automatically collect your home address, email address, telephone number, and product preferences unless you voluntarily input this information, such as during a registration or ordering process, or when you submit questions or comments, request information, or participate in online surveys, contests, promotions or other activities.

Even if you do not submit personal information through the Site, we gather navigational information about where visitors go on the Site and information about the technical efficiencies of the Site and services (i.e., time to connect to the website, time to download pages, etc.). This information allows us to see which areas of the Site are most visited and helps us better understand the user experience. This helps us improve quality by recognising and delivering more of the features, areas, and services our visitors prefer. In this process of gathering information, we may collect for example, domain type, browser type and version, service provider and IP address, referring/exit pages, operating system, date/time stamp, and click-stream data). We may also create and use electronic records to compile statistics about how our visitors collectively interact with the Site.

MARKETING

Only when you consent, we use your personal information to send you marketing materials and to conduct surveys. Personal information processed for marketing purposes includes your name and last name, home address, email, and contact phone number. We may request additional information from you where you participate in surveys such as personal opinions, preferences, interests, and information about your family members. We provide marketing communications via email, postal mail, online advertising, push notifications, social media, app messaging, and other means.

COMPETITIONS

Where you choose to enter one of our competitions, contests or sweepstakes, we will collect and use your name and contact information, along with your competition entry. Depending on the competition that you enter, your competition entry might consist of photos, videos, social media posts, personal opinions, or your preferences and interests. We process this personal information as necessary to fulfil the terms and conditions of the competition (for example, to enable us to process entries, select winners, communicate with entrants/winners about the competition, and arrange delivery of prizes).

CUSTOMER SERVICE CALLS

Certain customer experience and/or transactions may involve you calling us. To handle your requests and provide high-level customer service we need to collect your personal information such as your name and last name, phone number, and transaction details. We may also record our phone conversation for training and quality assurance purposes.

MOBILE APPLICATIONS

Claire’s makes available mobile applications for download on various mobile devices. When downloading these applications, you may be asked for certain personal information such as name and last name, email address, and phone number. If you are using one of our mobile apps, we may also collect information about the way you use our app.

SOCIAL MEDIA

The Site may permit you to interact with a third-party site or service, such as enabling you to “like” Claire’s on another site or “share” content from the Site with other sites (a “Social Networking Service”). If you choose to “like” or “share” content or to otherwise post information from or via the Site to a Social Networking Service, that information may be publicly displayed, and the third party may have access to certain information about you and your use of the Site. Similarly, if you interact with us through a Social Networking Service, we may have access to information about you (for example, if you “like” or “follow” our page on a third-party site). Please note that if you mention or comment on Claire’s or the Site in your post to a third-party platform, the third-party platform may allow us to publish your post on the Site.

You may also choose to use a social media tool offered by a third party, but available on the Site (such as posting a review or logging into the Site with your username and password for another site, such as the “Facebook Connect” feature). Use of such a feature may allow us to collect (or the third party to share) information about you, including your personal information. Information about you, including your name and profile photo, may be shown to other users of the Site if you are logged in through the Site or through a third-party website or service or if you have previously posted content to the Site while logged in. When you choose to use a social media tool available through the Site, you may be opting to link your activity on our Site with that third-party tool or service, which may then collect information about your visits to our Site and, if sharing function is enabled, may publish that activity to your profile with that third party. For example, when you link your Facebook account to the Site using “Facebook Connect”, your likes, product reviews, and “Wish List” additions will be shared on your Facebook account unless you disable that sharing.

In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third-party website or interactive service.

If you go to our Facebook page and click on a specific ad (advertised products or services, posted jobs etc.) we will start collecting your personal data using third-party tracking technologies when you are redirected to Claire’s landing page.

The information we collect is subject to this Privacy Policy. The information collected and stored by the third parties remains subject to the third parties’ privacy practices, including whether the third parties continue to share information with us, the types of information shared, and your choices with regards to what is visible to others on that third-party website and service. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected.

JOB APPLICATIONS

If you choose to apply for a position of employment with Claire’s, we process your personal information, including name and last name, date of birth, address, contact information, login and password for users of clairescareers.com, resume, cover letter, work experience, education, professional and work-related licenses, and audio and video recordings of interviews. You may choose to provide other information as part of your application. We do not require and will instruct you to abstain from voluntarily providing the information regarding your sexual orientation, race, ethnic origin, political opinions, religious and philosophical beliefs, and trade union membership unless the local employment laws require otherwise.

HOW WE COLLECT INFORMATION

We collect information in three primary ways:

1. You give us information: We collect information from you when you sign up to receive marketing, purchase a service or a product from us, participate in our competitions, or when you interact with us about a product or service we offer or provide.

2. We collect information automatically: We automatically collect certain types of personal information when you visit the Site or use products and services. For example, we automatically collect various types of technical information when you use the Site as described in this Privacy Notice.

3. We collect information from other sources: We may obtain information about you from outside sources. For example, we may obtain commercially available information about you from third parties, such as demographic information for advertising and marketing purposes. We may also receive information from third parties who provide third-party tracking services through web-beacons as otherwise discussed in this Privacy Notice.

PERSONAL INFORMATION FROM CHILDREN

We recognize the importance of children's safety and privacy. We do not knowingly collect personal information from children under the age 13 without their parent’s or legal guardian’s consent. Some countries establish the age of 16 as the threshold beyond which parental authorization for a child’s data processing is not required. In the countries where the law imposes stricter requirements and require parental consent for children under 16 years of age for processing of their personal information we rigorously adhere to those requirements.

If you are under the age of 16, please seek the consent of your parent or legal guardian for your personal data to be used by Claire’s for browsing this Site. You will be able to create an account, place orders, and purchase goods and/ or services on the Site only if you verify your age.

PARENTAL PARTICIPATION. As a parent or legal guardian, please do not allow your children to submit personal information without your permission.

USE OF COOKIES

To see a list of all our cookies, click here

The Site uses cookies. Cookies are bits of electronic information that a website may transfer to a visitor's computer to identify specific information about the visitor's visits to a website. The Site uses a browser feature known as a cookie, which assigns a unique identification to your computer. Cookies are typically stored on your computer's hard drive and are used to help track clicks as you go through the pages within the Site. Our cookies do not contain any personally identifiable information, such as your name, address or payment details.

We may also use cookies to tell us whether you have previously visited the Site. We also use cookies which may be set by third parties with whom we have entered into agreements which may enable us to obtain other information about you as may be available from those third parties, such as demographic data about you. You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. You may also use commonly available tools in your browser to remove cookies which may have been placed onto your computer. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that store cookies. Alternatively you may wish to visit www.aboutcookies.org which contains comprehensive information on how to manage cookies on a wide variety of browsers. However, please note that if you disable the use of cookies on your computer, some functionality of the Site will not work, however you will still be able to browse and shop on the Site.

Below we explain the types of cookies that may be used on our Site:

(a) 'Strictly Necessary' cookies. These cookies are essential for the operation of the website and enable you to access certain site features. Without these cookies, we would be unable to provide you with the online services you request. These cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.

(b) Functional cookies. Functional cookies are used to recognize you when you return to the website. They also remember your preferences (such as your username, language and region) on our Site and enable us to personalize our content for you. The information collected by these cookies is usually anonymized, so we cannot identify you personally. Functional cookies do not track your internet usage or gather information which could be used for selling advertising, but they do help with serving advertising.

(c) Analytical cookies. Analytical cookies are used to monitor the performance of our Site. For example, they allow us to recognize and count the number of visitors and to see how visitors move around our Site when they are using it. The information provided by these cookies allows us to analyze patterns of user behavior and we use that information to enhance user experience or identify areas of the Site which may require maintenance. All of the information collected by these cookies is anonymous and is only used for statistical purposes.

(d) Targeting and advertising cookies. These cookies may be placed on your device by us or by trusted third parties. They remember that you have visited our Site and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising (OBA) and involves the monitoring of interests based upon web browsing history. Your web browsing history can be used to infer things about you (for example, your age, gender etc.), and this information may also be used to make advertising on websites more relevant to you. Although behavioral advertising cookies can track your activity around the internet they cannot identify you personally, even if you are signed in to our Site. Without these cookies, online advertisements you encounter will be less relevant to you and your interests. If you would like more information about OBA, including how to opt-out of these cookies, please visit www.youronlinechoices.com.

We will not use FLASH cookies, unless you are specifically notified that we intend to use them for a specific service, and you are given the opportunity to opt-out from receiving such cookies. FLASH cookies are cookies that are placed on your computer that are not removed through normal browser management tools, but the developer of the FLASH programming language currently has an on-line management tool to allow you to remove these FLASH cookies.

When you browse the Site some cookies may be set by third parties, over which we have no control. When you visit a page with embedded third party content, the service provider may set their own cookies on your device. You may also encounter third party cookies resulting from our use of third party services, which help us monitor traffic on the Site. We do not control the use of these cookies and you should refer to the relevant third party websites for more information.

USE OF WEB BEACONS, CLEAR-GIFS, PIXEL TAGS AND JAVASCRIPT

We also use other technologies such as “pixel tags” (also called “action pixels”, “web beacons” or “clear gifs”) and/or JavaScript plug-ins placed on the Site and in our emails to you.

These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or in an email message which are used for such things as recording web pages and advertisements clicked-on by a user, or for tracking the performance of email marketing campaigns. These devices help us analyze our customers' online behavior and measure the effectiveness of the Site and advertising. We also work with third-party service providers that help us track, collect, and analyze this information. Third-party entities with whom we have agreements may place these devices on the Site and/or in e-mails sent to you to use information obtained from them such as pages viewed, items purchased, e-mails opened and items upon which you may click in e-mails. These third-party providers may also place cookies onto your computer. Those third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and your preferences from these third-party sources as well as our information we have about you.

WIDGETS AND SERVER LOGS

A “widget” is generally an application that can be embedded in a web page. Widgets can provide real-time information to the page. Widgets are often provided by third parties and we may provide widgets on the Site. Widgets may enable the third parties that provide them to collect data about users visiting the Site. We may also obtain information shared with us through the providers of these widgets.

A web “server log” is a record of activity created by a computer that delivers certain web pages to your browser. Certain activities that you perform on the Site may record information in server logs, such as if you enter a search term into a search box located on the Site. The server log may record the search term, or the link you clicked on to bring you to the Site. The server log may also record information about your browser, such as your IP address and the cookies set on your browser.

SEARCH QUERIES ON OUR WEBSITE

We may provide you with options to search for information on the Site. If you enter information in a search query box, we may store that information and we may aggregate that information with other information we may have about the browser and/or IP address from which the search query originated.

INFORMATION FOR BUSINESS PARTNERS AND SUPPLIERS

If you represent a business partner or a supplier of Claire’s we may need to collect and process your personal information to administer and develop the business relationship with you or the party you represent, to perform contractual obligations, to conduct satisfaction surveys, and to monitor compliance. Claire’s may need to collect all the information that can be found on your business card or in your email signature with a few exceptions: first name, last name, job title, employer name, work address, business email, and business phone number. We may share your personal information with third parties that provide services to Claire’s, but we do not sell your personal information or share it for marketing purposes.

HOW WE USE THE INFORMATION WE COLLECT

We use your information for many purposes, such as to: (i) deliver the products or services you order, including processing orders, returns and third party payments; (ii) process entries to competitions, select winners, communicate with entrants/winners about the competition, and arrange delivery of prizes; (iii) analyze trends and conduct research about improving our products and services; (iv) provide support and respond to questions from customers and the Site visitors; (v) improve the Site, products or services; (vi) learn about customers’ needs; (vii) contact consumers for research, informational, and marketing purposes, including customizing our product recommendations to you based upon your information and purchases; (viii) track traffic patterns and the Site usage; (ix) enable online ordering and provide customer service with respect to such orders; (x) correlate information with other commercially available information to identify demographics and preferences to assist us in our marketing efforts; (xi) provide specific relevant marketing, promotional, or other information to you; (xii) address information security and/or privacy practices control, network functioning, engineering, and troubleshooting issues; (xiii) investigate claims and/or legal actions, violations of our policies and procedures, and compliance with relevant applicable laws and legal process; (xiv) comply with law, or based on our reasonable belief that it is necessary to conform or comply with the law, or otherwise to disclose information to the agencies concerned to prevent fraud, to reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights and freedoms of individuals, property and safety of visitors to Claire’s stores, the Site, and of the public in general.

WHEN AND HOW WE SHARE YOUR INFORMATION WITH OTHERS

We may also share personally identifiable information and non-personally identifiable information externally with third-party service providers that have a need to know your personal information in order for us to accept and fulfill your order, provide services requested by you or comply with applicable law or regulation. This might include, but is not necessarily limited to the companies that handle our order dispatch service, pay our delivery company, business entities that provide e-mail address management and communication contact services, network equipment and application management providers and hosting entities, credit and debit card payment gateways and processors and the issuing and acquiring banks involved in the funds settlement procedures necessary to charge your cards or financial accounts, entities which obtain information such as demographic information which might be aggregated with information we have about you, judicial, administrative and/or legal or financial accounting providers in the event that information must be reviewed or released in response to civil and/or criminal investigations, claims, lawsuits, or if we are subject to judicial or administrative process (such as an injunction) to release your information or to prosecute or defend legal actions, and other service providers which may be involved in the other types of services and activities otherwise discussed in this Privacy Notice. In the cases where it is required by data protection legislation, we will enter into written agreements with these third parties to place contractual restrictions on these third parties from further transmitting your personal data and the treatment of said data outside of the uses and processing necessary to fulfill their contracts with us. We will only provide these third parties with the information which they need to carry out their jobs and to the extent necessary to perform contractual obligations.

Some elements on the Site, such as any sponsored links advertising, are supplied to us by third parties under contract. We may supply some of the information we collect from you to those third parties so that they can provide those elements for display. We may share the following information with such third parties: (a) your Internet Protocol (IP) address; (b) the address of the last URL you visited prior to clicking through to the Site; (c) your browser and platform type; (d) your browser language; (e) the data in any undeleted cookies that your browser previously accepted from us; and (f) the search queries or word look-ups you submit.

YOUR RIGHTS & CHOICES ABOUT THE INFORMATION WE COLLECT

It is important that you are able to control your personal information. At Claire’s we are committed to provide you with control over your personal information that you share with us. To the extent allowed by applicable law, you have the right to request a copy of your personal information that we maintain in our systems and databases and, where appropriate, request that we update, correct, or delete your personal information, or that we no longer contact you. Please be aware that it is not always possible to completely delete or erase all your personal information from our systems and databases without some residual data backups to comply with legal obligations, necessity to perform contracts, resolve disputes and for other legitimate reasons. We are also be unable to delete your transactional data related to your purchases and returns because we need to keep these records as long as required by the applicable law. We will process all the requests within 30 days from receipt or within such other time as specified by applicable law. Such requests should be submitted to dataprotection@claires.com. For verification purposes and to protect your confidentiality, we can only respond to the requests sent from an email address that you provided to us or used for registering an account on the Site.

If you have a registered account with Claire’s and would like to update or delete your contact information, please visit the ‘My Account’ section and update your personal information details.

OPT-OUT FROM MARKETING. You have the right to request us to stop processing your personal information for marketing purposes. We will inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by refraining from checking certain boxes or providing an email address on the forms we use to collect your personal information for marketing purposes. Alternatively, you can contact us to withdraw your marketing consent at any time.

If you elected to receive marketing materials from us and prefer to no longer receive any marketing materials from us, you may opt-out at any time by using the unsubscribe link located in our e-mails or by sending an email to dataprotection@claires.com. Opt-out requests can take up to 30 days to be effective.

We may also use your personal information to contact you in ways other than e-mail or regular mail, such as via telephone number and/or mobile messaging and texts to your mobile phone or through SMS. When you provide your mobile number to Claire’s to receive marketing materials, you agree to receive messages from Claire’s on your mobile phone. The text messages may include, but are not limited to, updates, alerts and exclusive offers. If you sign up to receive SMS or MMS messages from Claire’s, you may unsubscribe from any SMS or MMS messages received by replying “STOP”.

If you have installed our mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app. You can stop all further collection of information by our mobile app by uninstalling the mobile app.

RETENTION OF YOUR PERSONAL INFORMATION

We retain personal information about you for the period necessary to fulfill the purposes outlined in the Privacy Notice unless a longer retention period is required or permitted by applicable law. For example, we are required to keep your basic personal information (name, address, and contact details) under UK tax law for six years. Your personal information shared by you for direct marketing purposes will be kept with us until you notify us (by opting out) that you no longer wish to receive marketing materials from us.

INTERNATIONAL TRANFERS OF PERSONAL INFORMATION

When visiting the Site your connection will be through and to servers located in the United Kingdom and the United States. All information you receive from us will be created on servers located in the United Kingdom and the United States, and all information you provide will be maintained on web servers and systems located in the United Kingdom and the United States. By using the Site and/or submitting information to us, you specifically consent to the transfer of your information to the facilities and servers in the United Kingdom and the United States, and to those with whom we may share your information.

Claire’s has its headquarters in the United States. Information we collect from you will be transferred and processed in the United States. By using the Site or providing us with any information you consent to the transfer and processing of such information to and in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR (the EU General Data Protection Regulation 2016/679). When transferring your personal information outside of the country of collection for the purposes stated therein, Claire’s complies with the applicable laws. For the data transfer outside the European Economic Area, Claire’s uses standard contractual clauses adopted by the European Commission.

LINKS

For your convenience, the Site may contain links to third party websites. We are not responsible for the privacy practices, advertising, products, or the content of such third party websites. None of the links should be deemed to imply that we endorse or have any affiliation with the links. Please note that these websites have their own privacy policies and that Claire’s does not accept any responsibility or liability for these policies.

SECURITY

We believe in providing a safe and secure experience for all of our customers and the Site visitors. To that end we have implemented security measures to protect the information collected from you. All information you provide to us is stored on our secure servers and on the servers of cloud-based service providers. Payment transactions may be undertaken by third party service providers and will be encrypted using industry standard SSL technology. Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Every employee accessing systems containing your personal information has a separate unique username and password. Access to your personal information is limited to those employees who require such access to perform their job duties. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your personal information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

Although we make every effort to protect the personal information which you provide to us, please note that no data transmitted over the Internet or stored and utilized for business purposes can be guaranteed to be completely secure. No security measures are perfect or impenetrable. We cannot ensure that information you share on the Site will not become publicly available. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to the Site and that any such transmission is at your own risk. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up to date antivirus software.

COMPLAINTS

In the European Economic Area, you have the right to lodge a complaint to our supervisory body for data protection matters (namely the Information Commissioner’s Office at https://ico.org.uk/concerns/ or seek a remedy through local courts if you believe your rights have been breached.

QUESTIONS / CHANGES IN NOTICE

If you have questions or concerns with respect to our Privacy Notice, please contact us at dataprotection@claires.com. We reserve the right to change or amend this Privacy Notice at any time, without notice to you; in such event, we will post the amended Privacy Notice on the Site. We may email you to notify about the material changes thereto, but you should check our Site to see the current Privacy Notice in effect.