Website Policies

Effective: January 1, 2020

 

This California Consumer Privacy Statement supplements the Global Privacy Notice and applies solely to California consumers.  This Statement does not apply to Tiffany personnel.  

 

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”). 

 

We may collect the following categories of personal information about you:

 

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; client number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
•  Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender expression, marital status, medical condition, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information: audio, electronic, visual, thermal, olfactory, and similar information
• Employment Information: professional or employment-related information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences:  inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in our Global Privacy Notice.  In addition, we may use such categories of personal information for certain business purposes specified under the CCPA, as described in this table: 

 

Purposes		Categories of Personal Information
Performing Services: Performing services, including maintaining or servicing accounts, providing client care, processing or fulfilling orders and transactions, verifying client information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences
Auditing: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity and Inferences
Short-term Use: Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction		Identifiers; Commercial Information; Online Activity; Geolocation Data and Inferences
Security Purposes: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences
Debugging: Debugging to identify and repair errors that impair existing intended functionality		Identifiers; Online Activity and Geolocation Data
Internal R&D: Undertaking internal research for technological development and demonstration		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information and Inferences
Safety: Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us		Identifiers; Commercial Information; Online Activity; Geolocation Data; Sensory Information and Inferences

 

In addition, we may also use the following categories of personal information for purposes of managing career opportunities with Tiffany: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences.

 

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement.  For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.

 

a.       Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

 

Categories of Sources of Data Collection		Categories of Personal Information
Directly from you, such as when you make a purchase in-store or online, call our Client Care center, complete our client information cards, attend one of our events or participate in a survey		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Sensory Information; Employment Information and Education Information
From your devices, such as when you visit Tiffany websites and other Online Channels		Identifiers; Online Activity; Geolocation Data and Inferences
Your family or friends, such as when they provide us with your contact information so we can send information that may interest you or when someone buys a gift for you		Identifiers and Protected Classifications
Our affiliated entities and subsidiaries		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences
Vendors who provide services on our behalf		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences
Our retail and trade partners		Identifiers; Commercial Information; Online Activity and Inferences
Our business partners		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Employment Information and Inferences
Social networks		Identifiers; Commercial Information; Online Activity and Inferences
Online advertising companies (including advertising networks)		Identifiers; Commercial Information; Online Activity and Inferences
Law enforcement authorities, regulators, third-party subpoenas and government entities		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences
Consumer data resellers and data aggregators, including data append and cleansing companies		Identifiers; Protected Classifications; Commercial Information; Online Activity; Employment Information and Inferences
Publicly available sources and databases		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information and Inferences
Third parties in the event of a corporate transaction, such as a merger or acquisition		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

 

b.       Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

 

Categories of Third Parties		Categories of Personal Information
Our affiliated entities and subsidiaries		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences
Vendors who provide services on our behalf		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences
Professional services organizations, such as auditors and law firms		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences
Our retail and trade partners		Identifiers; Commercial Information; Online Activity and Inferences
Our business partners		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Employment Information and Inferences
Social networks		Identifiers; Commercial Information; Online Activity and Inferences
Online advertising companies (including advertising networks)		Identifiers; Commercial Information; Online Activity and Inferences
Data analytics providers		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Employment Information and Inferences
Law enforcement authorities, regulators, third-party subpoenas and government entities		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences
Consumer data resellers and data aggregators, including data append and cleansing companies		Identifiers; Protected Classifications; Commercial Information; Online Activity; Employment Information and Inferences
Third parties in the event of a corporate transaction, such as a merger or acquisition		Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

 

c.       Sale of Personal Information

We do not sell your personal information in exchange for monetary compensation.  We may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our Online Channels or otherwise share personal information with such parties in exchange for non-monetary consideration (such as an enhanced ability to serve you content and advertisements that may be of interest to you).  You have the right to opt out of this disclosure of your information, as detailed below.

During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have sold the following categories of personal information: Identifiers, Commercial Information, Online Activity and Inferences.

 We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.

 

d.       Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties the following categories of personal information for a business purpose: Identifiers, Additional Data Subject to Cal. Civ. Code § 1798.80, Protected Classifications, Commercial Information, Online Activity, Geolocation Data, Sensory Information, Employment Information, Education Information and Inferences. 

 

You have certain choices regarding our use and disclosure of your personal information, as described below.

 

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months. 

 

Deletion: You have the right to request that we delete certain personal information we have collected from you, subject to certain exceptions.

 

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.  Please understand that we will still share your information in ways that are not a “sale,” such as with our service providers, for our own online advertising purposes.  Your opt-out will be specific to the web browser or device you use at the time you exercise your opt-out rights; if you use multiple web browsers or devices, you will need to opt-out from each browser and device.  Please note that opting-out of the sale of your information for interest-based advertising purposes does not mean you will stop seeing ads, including interest-based ads, and your information that was collected and sold prior to 90 days before your opt-out request may be further used and sold for interest-based advertising purposes.

 

Shine the Light Request: Subject to certain limitations under California Civil Code § 1798.83, California residents may ask us to provide them with (a) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (b) the identity of those third parties.

 

How to Submit a Request: To submit an access or deletion request, please complete our Personal Information Rights Request form here or call us at 1-800-843-3269.  To submit a Shine the Light request, email us at privacy@tiffany.com.  To learn more about the information we collect, use and disclose for interest-based advertising purposes, and how to opt-out of the sale of your information for interest-based advertising purposes, please refer to the interest-based advertising section of our Global Privacy Notice.  To opt-out of other potential sales of your personal information, please complete the Do Not Sell form here or call us at 1-800-843-3269.

 

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.  In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.  If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us.

 

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.  This Statement is available in alternative formats upon request.  Please contact privacy@tiffany.com to request this Statement in an alternative format.