PRIVACY POLICY

Personal Data We Collect

Personal data collected via the Sites may include:

• Contact data. You may provide us with your contact details, such as your name, phone number, mailing address, and email address. You may provide us this information when you contact us or sign up for newsletters.

• Payment Information. You may provide payment information and related information such as a billing and mailing address when you make purchases on the Sites.

• Feedback Information. You may also provide your personal data when you respond to surveys or provide feedback or other opinions.

• Account Information. Certain features of the Sites allow you to provide a username and password to access specific content. Once logged in, you can adjust wish list and payment information preferences and view account information such as your order history, date of birth, and store preference.

• Authentication Data. To verify the identity of registered users we may collect authentication information.

• Device Information. We may obtain information about devices that access our Sites, including the type of device, its operating system, device settings, unique device identifiers, and error data.

• Location Information. The Sites may also use GPS (global positioning systems) software, geo-filtering, and other location-aware technologies to locate you (sometimes precisely) and send you geo-targeted marketing communications where permitted.       You may be able to toggle on or off location technologies using your internet browser (e.g., Google Chrome). If you disable location technologies, you may not be able to use certain features of the Sites.

• Information About Others. You may submit to us personal data about other individuals. For example, you may submit someone else’s mailing address when you purchase a gift for them through the Sites. When you submit personal data about others, you represent that you have obtained their consent to disclose their personal data to us.

• User Generated Content: Where you give us permission we may collect user generated content from you or from sources such as your social media profile (such as Facebook, Google, Twitter and Instagram).This may include: your name; your social media handle; messages which you have shared publicly on social media; your gender; number of social media followers; social media profile preferences; your age/date of birth; and your home address and email address.

• Other Information You Provide. This includes emails and other communications that you send us or otherwise contribute, such as user support inquiries regarding the Sites.

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

• You make a purchase from us;

• We process your account registration and identify you as a user;

• We take payment for your purchases;

• We provide customer services and arrange the delivery or other provision of products or services;

• Managing our loyalty scheme where you are a participating member including administering the benefits of the loyalty program to you.

As required by Oak & Willow to conduct our business and pursue our legitimate interests, in particular:

• Responding to your comments, questions and requests, providing customer service, sending you informational notices, or to contact you if we need to obtain or provide additional information;

• Verifying your location so that we can redirect you to the correct site based on your country;

• Accessing and using information about your device location (such as based on IP address), or your account information, to suggest appropriate Oak & Willow locations;

• Facilitating, managing, personalizing, and improving our user and partner relationships. For example we use your online activity on our Sites, as well as your in-store and online purchases to help us better understand you as a customer and provide you with personalized offers and services;

• Providing you with relevant marketing. This may involve showing you online ads on our Sites and those of third parties or on other media channels;

• We process user generated content (as described above) to contact you regarding having your social media content used in a Claire’s campaign and using your social media content for our marketing and promotional purposes including (where needed, with your permission for intellectual property reasons) posting or reusing your content on social media platforms or media;

• Assessing the effectiveness of our marketing and the marketing activities we carry out including the marketing we carry out as part of our loyalty programme;

• Preventing and addressing fraud, breach of policies or terms, and threats or harm. This includes, among other matters, analyzing and improving the safety and security of the Sites together with implementing and enhancing security measures and protections to combat fraud, spam and abuse;

• Ensuring the security and integrity of the personal data we process;

• Complying with applicable legal requirements;

• Maintaining and improving the Site;

• Operating the Site and providing you with certain information and communications tailored to your preferences.

Where you give us consent:

• where consent is required by applicable law, we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners.

• we place cookies and use similar technologies (see How we use tracking technologies below)

• on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.

For purposes which are required by law:

• In response to requests by government or law enforcement authorities conducting an investigation;

• To comply with applicable tax and other government regulations.

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:

• With our affiliates, partner organizations, or suppliers when it is reasonably necessary or desirable, such as to help provide products and services to you or analyze and improve the Sites.

• With our staff, agents, vendors, consultants, and other service providers who perform functions on our behalf. 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.

• To abide by applicable law or protect rights and interests.       For example, we may disclose your personal data if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property, or interests, or prevent fraud or abuse.

• In the event we sell or transfer all or a portion of our business assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction), including negotiations of such transactions.

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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:

• Recognize new or past users;

• Store your profile or authentication credentials if you are registered on the Sites;

• Improve the Sites and to better understand your use of the Sites;

• Integrate with third-party social media websites;

• Serve you with interest-based or targeted advertising;

• Observe your behaviors and browsing activities over time across multiple websites or other platforms; and

• Better understand the interests of our Sites users.

Some cookies are required for certain uses of the Sites. For example, if you choose to register an account through the Sites, we will use cookies to facilitate your registration and remember your preferences.