PRIVACY POLICY

Inner Expressions knows that your privacy is important to you, and we want you to know that it is important to us too. We created this Privacy Policy (“Privacy Policy”) to explain the types of information we collect through our Web sites (on which it is linked to in the footer) and the various social networking platforms that we use (each, a “Website”). This Privacy Policy does not apply to information that we collect offline, such as in our retail salons. This Privacy Policy describes how we will use, disclose and protect this information once it is collected, and how you can opt-out of some of our uses of your information.

Here are a few general principles to keep in mind as you read through this Privacy Policy:

• The Website is owned and operated by Inner Expressions, Inc. and its corporate affiliates (referred to collectively in this Privacy Policy as “we,” “us,” “our” and other similar pronouns).
• California’s Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternatively, businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes unless the customer has opted-in to such information sharing. Accordingly, we will not share your personal information with third parties other than our affiliates for the third party’s own marketing purposes unless you opt-in, for example by checking a consent check box when providing us with your information. We will, however, share your personal information with our affiliates for marketing purposes. To request a list of the affiliates with whom we have shared your personal information for marketing purposes in the last year, write to us at Inner Expressions, 66 West 47th St., New York, NY 10036 and include the words “California Shine The Light Request” in the “Regarding” line.
• As our business evolves, this Privacy Policy may change, so check back to this page periodically to make sure you understand how your personal information will be treated.
• This Privacy Policy is incorporated into, and part of, our Terms of Use, which govern your use of our Websites as a whole.
• If you are located outside of the United States, you should know that the information you provide to us is being transmitted to us and processed in the United States and will be protected subject to this Privacy Policy and United States laws, which may not be as protective as the laws in your country. Also, this Website places cookies and local shared objects on your computer or device which are further described below.

Opt In and Opt Out

You may have the right to opt in to or opt out of certain of our uses of your Personal Information. For example, when you are asked to provide Personal Information on this Website, you may have the opportunity to elect to, or not to, receive messages from us by e-mail, phone or postal mail. You may tell us that you do not want to receive our promotional messages by visiting the marketing preferences area of or Website or by sending us your written request along with your name, address, e-mail and phone number to: info@InnerExpressions.com, Inner Expressions, Inc., Privacy Officer, 66 West 47th St., New York, NY 10036. You can also opt-out of our promotional emails by clicking on the opt-out link within the e-mail you receive. Please understand that it may take us time to process any opt out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us. Also, to stop receiving promotional messages from third parties who already have your contact information, please contact them directly.

What information is collected on this Website?

User-Provided Information

“Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information. We collect Personal Information such as your name; employer name; day and month of birth; postal addresses; e-mail addresses; telephone numbers; fax numbers; photograph; gender; Website browsing and transaction history; job history and application information; and interests, hobbies and demographic information. For example, we collect Personal Information when you sign up to receive emails from us; request a catalog; request a sales associate to contact you; schedule a visit to our salon; create a wish list on our Website; sign up for our newsletters; enter sweepstakes and contests; complete surveys; contribute to a chat room, bulletin board, blog or other social forum on the Website; or submit a comment or question to us using a “contact us” or similar feature on the Website.

A “tell-a-friend” tool provided on the Website and/or in our e-mails allows you to send information about our products and offerings to another person. You may also be able to purchase gifts for another person on our Website. When you use these offerings, we ask you for the name and contact information of the other person, and that information will be protected pursuant to this Privacy Policy. We will not use the other person’s information for additional purposes without their consent.

Website Usage Information

As is the case with many websites, our servers automatically collect your IP address when you visit our Website, and we may associate that with your domain name or that of your Internet access provider. We may also capture certain “clickstream data” pertaining to your Website usage. Clickstream data includes, for example, information about your computer or device, Web browser and operating system and their settings, the referring page that linked you to the Website, the pages, content or ads you see or click on during your visit and when and for how long you do so, items you download, the next website you visit when you leave the Website, and any search terms you have entered on the Website or a referral site.

In addition, we may deploy various tracking technologies on the Website to collect additional information about your Website visits. For example:

• Cookies are small data files stored on your computer or device at the request of a website. A cookie assigns a unique numerical identifier to your Web browser, and may enable us to recognize you as the same user who was at our Website in the past, and relate your use of the Website to other information about you, such as your Website usage information and Personal Information. Cookies may also be used to enhance your experience on the Website (for example, by storing your username so you can log in easily, keeping you logged into the Website after you have provided your password, and storing the contents of your shopping cart as you browse) or to collect general usage and aggregated statistical information and detect and prevent fraud. Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of the Website or its features. To learn more about the use of cookies, including how to manage or delete them, click here.
• Local shared objects, such as “Flash cookies,” may be stored on your computer or device using a media player or other software installed on your computer or device. Local shared objects operate a lot like cookies, but cannot be managed in the same way. Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings. For information on managing Flash cookies, for example, click here.
• HTML5 (the language some websites are coded in) may be used to store information on your computer or device about your Website usage activities. This information can be retrieved by us to determine how our Website is being used by our visitors, how it can be improved, and to customize it for our users.
• A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a Web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our Web pages.

These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number to you and relate your Website Usage Information to other information about you, including your Personal Information.

Do Not Track Disclosures

This Website does not process Do-Not-Track headers transmitted by Web browsers. Our third-party web analytics companies collect information about your online activities over time. These third parties do not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings.

How is your information used?

We or our service providers may use the information we collect from and about you to perform the following business functions:

• processing and fulfilling your transactions
• enabling users to use our website and its features
• administering the Website and your account with us
• responding to your requests, questions, and concerns
• notifying the winners in competitions arranged online
• market research
• developing new features and offerings
• consistent with any communications preferences you have conveyed to us, sending you marketing and other communications, including information about products, services, and events, of ours and of others, that we think might interest you. (You may opt out of receiving such notices from us by following the instructions in the Right to Opt In and Opt Out section above.)
• protecting our rights and property
• preventing misuse or improper use of our services
• recovering debt and preventing fraud
• customizing our website to your interests and history with us
• test and improve our systems by which the services are provided
• tailoring ads displayed to you on our Site and elsewhere to your interests and history with us
• other purposes disclosed when personal information is submitted to us

To perform the above functions, we may match information collected from you through different means or at different times, including both Personal Information and Website Usage Information, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Website, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.

Social Networking

We maintain presence on several social networking and blogging platforms, and we also incorporate some third-party social networking features onto our Website. Through these platforms and features, we receive some Personal Information and some Website Usage Information about you, and this Privacy Policy applies to that information as well. In addition, third party social networking platforms and blogging platforms have their own privacy policies which explain how the third parties that provide them will use and protect your information. In accordance with those policies (and your privacy settings within your social networking accounts) information about your activities on our Website (such as “Mary Jane “likes” our Diamond Tassel necklace”) may be published to your social network.

Do we share Personal Information and Website Usage Information with others?

Yes. We may share the information we collect on the Website with others for a variety of reasons. In addition to the kinds of information sharing you might expect, such as sharing with third parties who need your information in order to provide services to us (or on our behalf and subject to confidentiality commitments) and sharing what you voluntarily post to public areas on the Website with other Website users, we may share your information:

• with our affiliates and retail salons both in the US and abroad
• with unaffiliated third parties for their marketing and other purposes, if you have opted-in to this sharing
• with our co-sponsor(s) if we obtain your information in connection with a contest, sweepstakes, offering, or other promotional activity that is jointly offered by us and any third parties, unless you instruct us not to by following the instructions in the Opt-in and Opt-out section above
• when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, authenticate transactions and the identity of individuals making purchases, investigate or prevent fraud or illegal activity, respond to a government, law enforcement, judicial or other legal request, or to comply with the law
• with third parties to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, executing customer satisfaction surveys, providing customized advertising, providing search results and links (including paid listings and links), processing credit card payments and providing customer service. They have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Policy and as permitted by applicable data protection laws
• with credit bureaus, such as late payments, missed payments, or other defaults on your account
• in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business

In addition, we may share non-personally identifiable Website Usage Information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.

Your Access Rights

You may review, update or modify certain of the Personal Information that is stored in your user account on the Website (if you have one) by logging in to the “My Account” or similar area of the Website or by contacting us using the “Contact US” information below. We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. Your right to delete your information is subject to our records retention policies.

Interest Based Advertising and Website Analytics

We may collect information about your online activities on our Website to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. This section of our Privacy Policy provides details and explains how to exercise your choices.

You may see certain ads on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites by collecting information through automated means, including through the use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our website and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our ad partners’ targeted advertising services to show you our ads on other websites based on your prior visits to our website and other online activity. Below is a chart that lists our current advertising partners that provide these features together with corresponding links to describe how you may opt out of them.  Opting-out does not mean that you will stop receiving ads from us. It means that you still stop receiving ads from us that have been targeted to you based on your visits and browsing activity across websites over time.

Provided that a company participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you also may opt out of ad network interest-based advertising generally through the Network Advertising Initiative website or by visiting https://www.aboutads.info/choices/.   To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance.

We also may use third party Web analytics services on our Website, such as those of Google Analytics. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the Website. The information collected through these means (including the state and zip code from which our visitors come and the IP addresses of our visitors’ computers) is disclosed to these service providers, who use the information to evaluate use of the Website. You may deactivate the ability of Google Analytics to analyze your browsing activities on our Website.

To learn more about web Google Analytics services, and exercise your choice with respect to their collection of information on our Website, please download the browser add-on for the deactivation of Google Analytics provided by Google at https://tools.google.com/dlpage/gaoptout?hl=en.   To learn more about Google Analytics security and privacy principles please consult the Google Analytics overview provided by Google at: https://www.google.com/intl/en/analytics/privacyoverview.html.

Security

While we endeavor to protect the security and integrity of sensitive Personal Information collected via this Website, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

If you correspond with us by e-mail or using Web forms like a “contact us” feature on our Website, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

If we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at info@InnerExpressions.com.

“Linked-To” Websites

The Website may contain links, banners, widgets or advertisements that lead to other websites. We are not responsible for these other sites, and so their posted privacy policies (not this Privacy Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of each Web site visited after leaving the Website to learn about how your information is treated by others.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. When we do, we will let you know by posting the changed Privacy Policy on this page with a new “Last Updated” date. In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you. In some cases, we may request your consent to the changes.

Contact us

If you have any questions or comments regarding our privacy practices, you may contact us by e-mail at info@innerexpressions.com