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Claire’s European Privacy Notice
Effective date: 15/9/2021
This Privacy Notice sets out how Claire’s Stores Inc. (“Claire’s,” “we,” “us,” “our”) processes European personal data obtained via our website claires.com (the “Site”) – in our role as a data controller (i.e., when we are responsible for determining the purpose and means of the processing). This Notice also describes your data protection rights, including the right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your rights” section below.
Personal Data We Collect
Personal data collected via the Sites may include:
How and Why We Use Your Personal Data
We process personal data for the following purposes:
To fulfil a contract, or take steps linked to a contract: this is relevant where
As required by Claire’s to conduct our business and pursue our legitimate interests, in particular:
Where you give us consent:
For purposes which are required by law:
We have completed out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out in the “How to contact us”, section below.
How We May Share Your Personal Data
We may share your personal data:
How We Use Tracking Technologies
We may utilize online identification tools—such as cookies, web beacons, pixels or similar tracking technologies—in accordance with applicable law and requirements. “Cookies” are small text files placed on your device when you visit a website; they store information which is sent back to our servers or those of third parties. As described in more detail below, we use such technologies to:
Cookies are either “session” cookies, which are deleted when you end your browser session, or “persistent” cookies, which remain until you delete them or the party who served the cookie removes it.
Different types of cookies may be used for specific purposes, for example:
These cookies are required to enable core functionality and must be accepted for some Sites to work. They can be used for authentication, security or localisation purposes. Without these cookies, services you have asked for, like adding items to your shopping basket, cannot be provided. If you disable these cookies certain parts of the Sites will not function for you, for example, adding items to your basket, proceeding to checkout.
These cookies help us improve or optimise the experience we provide. They allow us to measure Site usage and improve performance. These cookies help us understand how visitors interact with Claire’s Sites and we use this information to improve user experience and performance.
These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. They remember the websites you visit and that information is shared with other parties such as advertisers. We may share this information with other parties, including our partners.
These cookies are used when you share information using a social media sharing button on a Site or other interactions you take on our Sites. The social network will record that you have done this. This information may be linked to targeting/advertising activities.
To see a list of all our cookies and their lifespan, or to opt-out of cookies, visit our cookie consent management platform available here.
You may also use your device or browser settings to disable certain tracking technologies. For example, you may turn off location tracking through your device’s or browser’s settings to disable the Sites’ location tracking technologies, or set your browser settings either to receive our cookies or to use our Sites without cookie functionality. Please note that if you restrict the use of tracking technologies, some functions of the Sites may be unavailable, and we may not be able to present you with personally-tailored content.
We may link the information collected by tracking technologies with other information we collect from you pursuant to this Privacy Notice. Similarly, the third parties who serve tracking technologies on our Sites may link personal data we collect from you to other information they collect.
For more information on how Google Analytics uses data collected through the Sites, visit: www.google.com/policies/privacy/partners/. To opt out of Google Analytics cookies, visit: http://www.google.com/settings/ads and https://tools.google.com/dlpage/gaoptout/.
To opt out of Adobe cookies, visit: https://www.adobe.com/privacy/opt-out.html.
You may opt out of Facebook Custom Audience by logging into your Facebook account and changing your privacy or advertising settings as per Facebook’s opt-out instructions. You may also use your Facebook account settings to unlink your Facebook account from the Sites.
For information on how Microsoft collects or receives personal information through tracking technologies to provide Microsoft Advertising, see the Microsoft Privacy Statements: https://privacy.microsoft.com/en-us/privacystatement.
To opt out of Mouseflow, visit: http://mouseflow.com/opt-out.
For more information on our use of tracking technologies and cookies, contact us at firstname.lastname@example.org.
How Long We Retain Your Personal Data
We will store your personal data for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove personal data from our systems and records or take appropriate steps to properly anonymize it.
Social Media and Links to Third-Party Online Services
The Sites may contain links to, or features facilitated by, other websites or online services. We are not responsible for the privacy practices, advertising, products, or content of websites or online services that we do not control. Please note that other online services have their own privacy policies and we are not responsible or liable for these policies.
The Sites may permit you to interact with another website or online service, such as enabling you to “like” Claire’s on another site or “share” content from the Sites with other sites (a “Social Features”). If you choose to “like” or “share” content or post information using Social Feature, that information may be publicly displayed, and the other party may have access to certain information about you and your use of the Sites. Similarly, if you interact with us through Social Features, we may have access to information about you (for example, if you “like” or “follow” our page on another website). Please note that if you mention or comment about Claire’s or the Sites in your post to another platform, that platform may, where legally permissible, allow us to publish your post on the Sites. You may also choose to use Social Features on the Sites, such as by posting a review or logging into the Sites with your username and password for another website (for example, using “Facebook Connect”). Use of such a feature may allow us to collect (or the other party to share) information about you, including your personal information.
Claire’s may share with Facebook actions that you take on our Site such as your visits to our Sites, your interactions on our Sites, information collected from cookies or similar technologies including the Facebook pixel data collected from logging into our Site using Facebook Connect and the ads you see. This allows us to measure the effectiveness of our advertising, improve our marketing practices, and helps us deliver more relevant advertising to you and people like you (including on social media such as Facebook). Claire’s are Joint Data Controllers with Facebook Ireland for this processing. This arrangement means that Claire’s has to provide you this notice, but you should contact Facebook if you wish to exercise your data protection rights. Further information, including how Facebook enables you to exercise your data protection rights, and subsequently processes your information as independent data controller can be found in Facebook Ireland's Data Policy. If you would like to know more, please contact us at the details outlined below (see Who can I contact with questions or concerns)
In addition, we may receive information about you if a user of another website gives us access to their profile and you are one of their “connections”, or information about you is otherwise accessible through that other user. We may also use your personal information to tailor and deliver communications to you and other people like you, including on social media. If you do not want your data used in this way, feel free to contact us at the details outlined below.
Personal Data Transfers
As Claire’s operates globally, we do need to transfer your personal information internationally. In particular, your personal information will be transferred to and processed in the United States.
Where information is transferred outside the UK, the European Economic Area or Switzerland, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission or the UK Government, data is adequately protected by EU Commission approved standard contractual clauses or a vendor's Processor Binding Corporate Rules. For further information on the specific mechanism used to transfer your personal data, please contact us at email@example.com.
Your Rights and Choices
Subject to certain conditions, where the rights apply under applicable law, you may ask us to take the following actions in relation to your personal data:
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in the GDPR, UK GDPR, its local implementing legislation and the UK Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
You may exercise some of these rights and choices through Site features such as editing your account settings when you are logged in. Additionally, you can submit these requests by email to firstname.lastname@example.org or our postal address provided below. We may request specific information from you to help us confirm your identity prior to processing your request. If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, you may contact us at email@example.com or submit a complaint to the data protection regulator in your jurisdiction. You can find information about your data protection regulator here.
How to Contact Us
To make a query, raise a concern, or exercise your data protection rights, please contact us at firstname.lastname@example.org.
The data controller for your personal data is Claire’s Stores Inc., which you may contact by via email at email@example.com or at the following address:
Claire’s Stores, Inc.
2400 West Central Road
Hoffman Estates, IL 60192