Last Updated: January 2020
Collection of information
Information You Provide To Us
We collect information you provide directly to us when you use the Services or interact with us offline. For example, we collect information when you use our websites, shop in our stores, call us on the phone, create an online account, sign up to receive our emails, request a catalog, participate in a sweepstakes, contest, promotion or survey, communicate with us via social media sites, request customer support, apply for a job or otherwise communicate with us.
The information we collect includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. The categories of information we collect, which includes the kinds of information we have collected in the last 12 months, include the following:
- Contact Data, including your first and last name, email address, zip code, billing address, shipping address, phone number.
- Account Credentials, including your username, password, password hints, and information for authentication and account access.
- Demographic Information, including your age, gender, and country.
- Billing Data, including your payment instrument information (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
- Profile Data, including your interests, product preferences, and favorites.
- Content, including content within any messages you send to us (such as feedback and questions to customer support) or publicly post on the Services (such as in product reviews or blog comments).
- Personal Contact Data, including the first and last name, email address, and phone number that you provide about others, such as when you purchase a gift card for someone and request that we deliver it electronically, create and share a "wish list" or decide to purchase and ship products to someone. We collect this information with your consent and in order to fulfill your requests. We will not send marketing communications to your contacts unless they separately opt in to receive communications from us. Such functionality is only intended for U.S. residents. By using this functionality, you acknowledge and agree that both you and your contacts are based in the U.S. and that you have your contacts’ consent for us to use their contact information to fulfill your request.
- Resume Data, including your employment and education history, transcript, writing samples, and references as necessary to consider you for a job opening if you submit an application to us.
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
Information We Collect Automatically
We automatically collect information about you when you use the Services. The categories of information we have automatically collected in the last twelve months include the following:
- Service Use Data, including data about the features you use, the pages you visit, the emails and advertisements you view, the products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
- Device Connectivity and Configuration Data, including device identifiers such as IP address and Ad Id (e.g., IDFA or AAID); browser type; operating system characteristics; information about your use of our websites and mobile applications; and data regarding network connected hardware (e.g., computer or mobile device), such as unique device identifiers, type, model, version, MAC address, device or session ID, error related data status, capability, confirmation, functionality, performance data, and connection type.
- Transaction Information, including when you purchase or return a product, we collect information about the transaction, such as product details and the date and location of the purchase/return.
We use various current – and later – developed tracking technologies to automatically collect information when you use the Services, including the following:
- Log Information, which are files that record events that occur in connection with your use of the Services.
- Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website. They are temporarily downloaded onto your computer from our web server or another entity with whom we work, is active only while you are connected to the Services, and is deleted or deactivated thereafter. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Services. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
- Rolex Section: While navigating on the Rolex section of our website, some cookies are controlled by ROLEX SA which applies the following Cookies Policy.
- App Technologies, which are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include SDKs, which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Services and provide you with additional functionality, such as the ability to connect our Services with your social media account.
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Advertising and Analytics” and “Your Right and Choices” sections below.
Information from Other Sources
We also collect information from other sources. The categories of other sources from which we have collected information in the last 12 months include the following:
- Data Brokers or resellers, from which we purchase data to supplement the data we collect.
- Social Networks, when you engage with our content, reference our Services, or grant us permission to access information from the social networks.
- Partners, that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
- Publicly-available sources, including data in the public domain.
Use of Information
- Facilitate and improve your in-store and online shopping experience;
- Provide the products and services you request, process transactions and send you related information, including confirmations and receipts;
- Process your registration with our websites or mobile applications, including verifying that your email address(es) are active and valid;
- Respond to your comments, questions and requests and provide customer service;
- Communicate with you about products, services, offers, promotions, rewards and events and provide news and information we think will be of interest to you (for information about how to manage these communications, please see the “Your Rights and Choices” section below.
- Manage your online account(s) and send you technical notices, updates, security alerts and support and administrative messages;
- Improve our websites or mobile applications or other Tourneau products and services;
- Personalize your online experience and provide advertisements, content or features that match your profile and interests;
- Monitor and analyze trends, usage and activities;
- Process and deliver contest, promotion and sweepstakes entries and rewards;
- Link or combine with information we get from others to help understand your needs and provide you with better service;
- Contact you regarding your use of our websites and mobile applications and, in our discretion, changes to our policies;
- Provide you with notices related to our websites, mobile applications, and other Tourneau products and services
- Conduct research, including focus groups and surveys, regarding our websites, mobile applications, and other Tourneau products and services;
- Preventing and addressing fraud, breach of policies or terms, and threats of harm;
- Carry out any other business or commercial purposes at your discretion or with your consent.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
Consent to Transfer Information
Sharing of Information
- Service Providers. We share information with entities that process the information on our behalf. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law;
- Vendors. We share information with vendors, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Advertising and Analytics” section below;
- Partners. We share information with our partners for purposes of offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
- Public Forums. We share information you make public through the Services, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information that you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below;
- Security and Compelled Disclosure. We share information to comply with applicable law or other legal process, and where required, in response to lawful requests of public authorities, including to meet national security or law enforcement requirements. We also share information if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, life, health, security and safety of us, the Services, or anyone else;
- Affiliates. We may share information with our related entities including our parent and sister companies for internal business purposes. For example, we share information with our affiliates for customer support, marketing, and technical operations;
- Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, amalgamation or any other type of acquisition of all or any portion of Tourneau assets, financing, disposal, conveyance or transfer of all or a portion of our business to another business;
- Facilitating Requests. We share information at your request or direction, such as when you choose to share information with a social network about your activities on the Services.
- Consent. We share information with notice to you and your consent.
We may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
Sweepstakes, Contests, and Promotions
We may offer sweepstakes, contests, surveys and other promotions (each, a “Promotion”) that may require registration. If you voluntarily enter a Promotion, we share information as set out in the official rules that govern the Promotion as well as for the administration of such Promotion, such as in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. By entering a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. Tourneau may offer opportunities to enter a contest or sweepstakes or other feature that we offer jointly with a separate entity. As a result of your participation in such feature, your information may be shared with the other entity that is jointly offering the feature, which will be disclosed at the time your information is collected.
Advertising and Analytics
We use analytics services, such as Google Analytics, to help us understand how users access and use the Services. In addition we work with agencies, advertisers, ad networks, and other technology services to serve advertisements on our behalf about our products across the Internet. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our own Services (including website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your browsing of the websites and mobile applications across time and services for purposes of associating different devices you use and deliver advertising and content relevant to your interests on our websites and other websites (“Internet-based Advertising”).
We also use audience matching services to reach people (or people similar to people) who have browsed our Services or are identified in one or more of our databases (“Matched Ads”). This is done by uploading a customer list to a technology service or incorporating a pixel from a technology service into our own Services, and the technology service matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Services and may share your email address with Facebook as part of our use of the Facebook Custom Audiences. Some technology services, such as LiveRamp, may provide us with their own data, which is then uploaded into another technology service for matching common factors between those datasets. This information is used for marketing purposes and to suggest to you relevant products offered by another retailer.
For further information on the types of tracking technologies we use on the Services and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information We Collect Automatically” and “Your Rights and Choices” sections.
Social Media and Technology Integrations
We offer parts of our Services through websites, platforms and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Services. Some examples include:
- Links. Our Services include links that hyperlink to websites, platforms, and other services not operated or controlled by us.
- Liking, Sharing, and Logging-In. We may embed a pixel or SDK on our Services that allows you to “like” or “share” our website content on other websites or services; to log-in to our websites using your social media username and password; to transmit content to our websites from your account on social media; and to otherwise connect our websites on social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.
We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we implement and maintain reasonable physical, technical, and administrative procedures to safeguard and secure information collected. Nevertheless, transmission via the Internet is not completely secure and we cannot guarantee the security of information about you.
The Services are intended for a general audience and are not targeted to children under the age of thirteen (13). We do not knowingly gather any personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at firstname.lastname@example.org and we will remove the data to the extent required by applicable laws.
In California, we do not knowingly “sell” personal information of minors under 16 years old.
If you are a California resident under 18 years old and you are registered with the Services, you can ask us to remove content or information you have posted to any of the Services. Email us at email@example.com with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed.
Your Right and Choices
A. Account Information
You may access, update, or remove certain information that you have provided to us at any time by logging into your account and navigating to the “My Account” page or by emailing us at firstname.lastname@example.org. We may require additional information from you to allow us to confirm your identity. Please also note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
B. Tracking Technology Choices
- Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you can use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Accordingly, unless and until the law is interpreted to require us to do so, Tourneau does not monitor or take action with respect to “Do Not Track” signals. To find out more about “Do Not Track,” you may wish to visit All About Do Not Track (DNT).
- App and Location Technologies. You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app or website by uninstalling the app or by adjusting the device’s location services and/or Bluetooth settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.
Please be aware that if you disable or remove tracking technologies some parts of the Services may not function correctly.
- Communication from Our Partners. You can opt-out of having your information shared with our partners by sending an email to email@example.com and specifying that you do not want your information shared with our partners.
- Promotional Communications. You can opt-out of receiving promotional communications from us at any time by doing the following:
- To opt out of direct mail (such as catalogs and post cards): Email us at firstname.lastname@example.org.
- To opt out of promotional emails: Follow the instructions provided in those communications by clicking on the unsubscribe link, or email us at email@example.com with the word UNSUBSCRIBE in the subject field of the email. Please note that even if you opt out of receiving promotional communications, you cannot opt out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.
- If you sign up to receive SMS or MMS messages that may be offered on our websites, you may unsubscribe from any SMS or MMS messages received by replying “STOP” or by sending an email to firstname.lastname@example.org and specifying you want to opt out of text messages.
- Push Notifications. If you have opted-in to receive push notification on your device, you can opt out at any time by adjusting the permission in your device or uninstalling our app.
Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.
D. Analytics and Interest-Based Advertising.
Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics here and by Google Analytics for certain Display Advertising or the Google Display Network here.
Microsoft provides tools to allow you to opt out of the use of certain information collected by Microsoft Ads. Learn more here.
The companies we work with to provide you with targeted ads are required by us to give you the choice to opt-out of receiving targeted ads. Most of these companies participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for interest-based ads. To learn more about the DAA AdChoices Program and how to opt-out, please visit: (i) for website targeted ads from DAA participants, click here; and (ii) for app targeted ads from DAA participants, click here. Bounce Exchange, Inc. (“BounceX” or “Bounce Exchange”) is a behavioral automation software and analytics company that help drive higher engagement from their website visitors. To learn more about opting out of Bounce Exchange, click here. Criteo helps brands, e-commerce sites and other advertisers promote their products and services. To learn more about opting out of Criteo, click here. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (NAI). The NAI has developed a tool that allows consumers to opt out of targeted advertising delivered by NAI members' ad networks. To learn more about opting out of targeted advertising or to use the tool, click here. Please be aware that, even if you are able to opt out of certain kinds of targeted advertising, you will continue to receive generic ads.
To opt out of us using your data for Matched Ads, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of matched ads. We will request that the applicable technology service not serve you matched ads based on information we provide to it. Alternatively, you may directly contact the applicable technology service to opt out.
You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device setting and selecting “Limit Ad Tracking” (iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.
Your Nevada Rights
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at email@example.com.
663 Fifth Avenue
New York, NY 10022
Additional Disclosures for California Residents
These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
A. California Notice of Collection
In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:
- Identifiers, including name, email address, phone number account name, IP address, and an ID or number assigned to your account.
- Customer records, billing and shipping address, and credit or debit card information.
- Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
- Commercial information, including purchases and engagement with the Services.
- Internet activity, including your interactions with our Service.
- Audio or visual data, including pictures or vides you post on our Service.
- Geolocation data, including location enabled services such as WiFi and GPS.
- Employment and education data, including information you provide when you apply for a job with us.
- Inferences, including information about your interests, preferences and favorites.
For more information on information we collect, including the sources we receive information from, review the Collection of Information section. We collect and use these categories of personal information for the business purposes described in the Use of Information section, including to provide and manage our Services.
Tourneau does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in the Analytics and Advertising section as a “sale,”, we will comply with applicable law as to such activity. Tourneau discloses the following categories of personal information for commercial purposes: identifiers, demographic information, commercial information, internet activity, geolocation data and inferences. We use and partner with different types of entities to assist with our daily operations and manage our Service. Please review the Sharing of Information section for more detail about the parties we have shared information with.
B. Right to Know and Delete
If you are a California resident, you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold; and
- The business or commercial purpose for collecting or selling the personal information.
You also have the right to request the specific pieces of personal information we have collected about you.
In addition, you have the right to delete the personal information we have collected from you.
To exercise any of these rights, please submit a request through our online form available here, call our toll free number at (800)348-3332, or email us at firstname.lastname@example.org. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
If personal information about you has been processed by us as a service provider on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.
C. Do Not Sell My Personal Information.
To the extent Tourneau sells your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information. You may also submit a request to opt-out by calling our toll-free number at (800) 348-3332, or emailing us at email@example.com.
D. Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
E. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
F. Financial Incentives.
Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them.
We do not knowingly sell information of minors under 16 who are residents of California without their affirmative authorization, or the affirmative authorization of their parent or guardian for minors under 13.
California residents who are under 18 years of age and registered to use the Services may request removal of any content posted by them on the Service. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Minor” request. We may require additional information from you to allow us to verify your identity as well as details about where the content is posted. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
G. Shine the Light.
Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in the “Contact Us” section above and specify that you are making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.