CALIFORNIA CUSTOMER PRIVACY POLICY
Effective Date: January 2, 2023
This Privacy Policy (“Policy” ) describes how Claire’s Stores Inc. “Claire’s,” “us,” “we,” or “our”) processes personal information of customers who are California residents when using our Claires.com website (“Website”), mobile application (“App”), or in one of our retail locations (collectively, our “Services”). This Policy supplements our main Privacy Policy. Icing may provide other privacy policies or notices that may also apply to you depending on your interaction with Claire’s.
Table of Contents
- Personal Information We Collect, Why We Collect It, and How We Disclose It
- How Long We Keep Your Personal Information
- California Privacy Rights
- Financial Incentives
- California Shine the Light
- How To Contact Us
Personal Information We Collect, Why We Collect It, and How We Disclose It
Through our Services, Claire’s collects personal information, which includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California customers and households. Note that the personal information we collect may vary by customer depending on the nature of the customer’s interactions with us.
We may obtain your personal information from the following sources:
- Directly from you. Such as when you register or maintain a customer account with us, sign up to receive e-newsletters, register for events, or fill out online forms.
- Tracking technologies. Such as when you visit our online services (i.e., our website and app), which may have first party and third-party technology integrations (e.g., cookies) that help facilitate and personalize your visit to the Website or to other online services. For more information see our see our Privacy Policy’s section on “Tracking Technologies”.
- External sources. Such as our vendors and service providers, data resellers, advertising networks, Internet Service Providers, and social networks.
Personal information we collect includes:
| Category of Personal Information | Sources of and Purposes for Collections | Disclosure Purposes to Service Providers |
| Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers | Sources:
Purposes:
|
|
| Customer Records including name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or other financial information, | Sources:
Purposes:
|
|
| Characteristics of protected classifications under California or federal law, including age and date of birth, marital status | Sources:
Purposes:
|
|
| Commercial Information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | Sources:
Purposes:
|
|
| Internet or other electronic network activity information, including Internet or other similar activity, browsing history, search history, information on a consumer's interaction with a website, application logs, or advertisement | Sources:
Purposes:
|
|
| Geolocation Data such as general city | Sources:
Purposes:
|
|
| Audio, electronic, visual, or similar information including audio recordings of customer service calls, voicemails, and CCTV footage | Sources:
Purposes:
|
|
| Inferences used to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Sources:
Purposes:
|
|
In addition to above, we may disclose personal information fur the following purposes:
- Co-Branded Services. From time to time we may enter into an arrangement with another company that is not owned by or affiliated with us to provide additional features on the Website. These arrangements may include business partners, sponsors, and co-branded online services (referred to here as “co-branded services”). Any information, including personal information, that you provide on one of these co-branded services may be shared with these partners. By participating in activities or providing your information on these co-branded services, you direct us to provide your information to those partners. Separate privacy policies may apply to these partners’ uses of your personal information.
- Business Transactions. In the event of a business transaction, we may disclose personal information to prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.
- Legal Compliance. We may also disclose personal information for legal compliance, law enforcement, and public safety purposes. For example, to law enforcement, government or regulatory bodies, lawful authorities, or other authorized third parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.
We may combine your personal information with data we obtain from our services, other users, or third parties. We reserve the right to convert, or permit others to convert, your personal information into deidentified, anonymized, or aggregated data, as permitted by law.
We may share your PI with our affiliates, Service Providers, vendors (including those that facilitate interest-based advertising and other advertising and marketing), and other parties as described in the table above.
Selling and Sharing of Personal information. In accordance with the definition of “sell” and “share” under California law, we do not “sell” or “share” personal information outside of the context of using tracking technology vendors. We may disclose personal information to vendors that facilitate interest-based advertising and other advertising and marketing through cookies or other tracking technologies. For more information on tracking technologies and your choices of controlling such, see our Privacy Policy’s section on “Tracking Technologies”. and your right to opt-out of this “sell” and “share” below.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We keep the categories of personal information described above for as long as is necessary for the purposes described in this Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
- Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
- Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected;
- The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
- We are otherwise required or permitted to keep your information by applicable laws or regulations.
Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
CALIFORNIA PRIVACY RIGHTS
If you are a resident of California, you have the right to submit certain requests relating to your personal information as described below. To exercise any of these rights, please submit a request through our by emailing us at [email protected] or call us at 1-800-CLAIRES. Please note that, depending on your privacy request, you may be asked to provide 2-3 pieces of personal information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the email or toll-free number listed above.
Right to Know. You have the right to know what personal information we have collected about you, which includes:
- The categories of personal information we have collected about you, including
- a. The categories of sources from which the personal information was collected
- b. Our business or commercial purposes for collecting, selling, or sharing / or disclosing personal information
- c. The categories of recipients to which we disclose personal information
- d. The categories of personal information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of personal information
- e. The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of personal information
- The specific pieces of personal information we have collected about you
Right to to Delete Your Personal Information. You have the right to request that we delete personal information we collected from you, subject to certain exceptions.
Right to Correct Inaccurate Information. If you believe that personal information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Opt Out of Sales and Sharing of Personal Information. Although we do not currently sell or share for cross-behavioral advertising personal outside of the context of using tracking technology vendors, we may “sell” or “share” personal information in other contexts in the future. California consumers may opt out of the future sale of their personal information by following the instructions we provide here.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.
FINANCIAL INCENTIVES
We may offer financial incentives in exchange for your personal information, such a rewards program. Participation requires you to provide certain personal information. For the full terms and conditions applicable to our Claire’s Rewards Program, please click here.
We have made a good faith estimate that the value of consumers’ personal information provided in connection with our rewards program is equivalent to the relevant expenses related to the collection and retention of that personal information. Any difference in price or benefits provided to customers who participate in our rewards program is reasonably related to the value of the personal information provided. By joining our rewards program, you consent to any financial incentive associated with the program. You have the right to withdraw from the financial incentive at any time by cancelling your participation in the rewards program. To cancel your rewards membership, please call Claire’s at 1-800-804-7194 or email Claire’s at [email protected].
Unless you specifically request, submission of a request to delete your personal information will not erase information required for you to continue to participate in our rewards program. Should you wish to delete your personal information associated with our rewards program (and thereby cancel your participation in the program), please contact us at 1-800-804-7194 or email Claire’s at [email protected].
CALIFORNIA SHINE THE LIGHT
California's "Shine the Light" law permits California residents to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. Outside of context of tracking technologies, which may be used for behavioral advertising where third parties may access your personal information and use it for their own purposes, we do not disclose personal information with third parties for their direct marketing purposes. If you are a California resident, you may request information about our compliance with Shine the Light by contacting us at [email protected] or by sending a letter to: 2400 West Central Road, Hoffman Estates, IL 60192 (Attention: Legal Counsel). Any such request must include "California Shine The Light Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
CONTACT US
For more information regarding your California privacy rights, you may contact us at 1-800-CLAIRES or email us at [email protected]. You may also write to us at:
Attention: Legal Counsel
2400 West Central Road
Hoffman Estates, IL 60192