Effective Date/Last Updated: January 1st, 2020
Scope of Notice
What Are Cookies and Related Technologies
Cookies are small data files that are stored on your computer that allow us and our third-party partners and providers to collect certain information about your interactions with our email communications, websites and other online services. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).
What We Collect When Using Cookies
Third-party partners and providers may also collect personal information about your online activities over time and across different websites when you use our websites and online services.
Third Party Data Collection & Interest-Based Advertising
We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our services, on other websites, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”), which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider. See “Your Choices About Online Ads” below, to learn more about interest-based advertising.
Social Media Widgets and Advertising. Our services may include social media features, such as the Facebook Like button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks. You may learn more about advertising preferences by clicking on the links provided below. Please note that these links are provided for your convenience only and we do not control the content or features that may be available on these third party services.
Third Party Partners. The following is a sample of the third-party service partners we work with to provide advertising services. We will strive to update this list if or when we work with new partners which offer you choices about the collection of your information, but as partners change and new technologies become available, this list is likely to change over time and may not always reflect our current partners.
- Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our websites or services on your browser or mobile device, log in to your account on our services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/ . You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/ .
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
How We Use That Information
Your Choices About Cookies
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our online services, as some features and services on our online services may not work properly. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. Depending on your device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Your Choices About Online Ads
Controlling Cookies and Tracking Technologies. Most browsers allow you to adjust your browser settings to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Blocking or deleting cookies may negatively impact your experience using the Service, as some features and services may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all tracking technologies. You may set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you viewed or engaged with our emails.
Interest-Based Advertising. We support the self-regulatory principles for online advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.
If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:
- If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
- If you are a resident of the State of Nevada in the United States, please see below for Nevada-specific privacy disclosures.
Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. We do not sell your covered information, as defined by Chapter 603A of the Nevada Revised Statutes. If you reside in Nevada, you have the right to submit a request to [email protected] to opt out of the sale of covered information. Please include “Nevada Rights Request” in the subject line.
From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our services and, sometimes, we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction. We may link or combine your activities and information collected from you on our websites with information we have collected from you offline (e.g., in-store), information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.
Personal Information You Provide
We collect the following personal information you provide in connection with our services:
- Contact and Profile Information. We collect personal information, such as your name, email address, password, telephone number, gender, zip code, and address when you create an account, sign up for a newsletter, request a transaction or make a purchase online or in-store, redeem or participate in a promotion, purchase or redeem a gift card or otherwise communicate with us. We collect any communications between you and us and any other information you provide to us. We also collect information about your use of our services, such as your orders, and similar activity.
- Payment and Transaction Information. We may collect information such as items purchased, date and time of your transaction, amount purchased, order details, whether you used a particular coupon or deal, and payment information, such as your credit/debit card or gift card details, when you make an in-store or online purchase.
- Shopping History. For example, we may collect personal information about the items you viewed on our website, added to your cart, purchased or returned.
We use this information to operate, maintain, and provide to you the features and functionality of the services, as well as to communicate directly with you, such as to send you email messages. We may also send you service-related emails or messages (e.g., user account verification, change or updates to features of the services, technical and security notices) and communications from or about Pandora Jewelry.
Personal Information Automatically Collected When You Use our Services
Like most digital platforms, we collect certain personal information automatically when you visit our online services, including:
- Information About Your Device and Its Software. This may include your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to identify your browser or your account (including, for example, a persistent device identifier or an Ad ID), and other similar information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, that permit us to recognize and contact you across multiple devices.
- Information You May Post or Submit to Our Website. We may collect information about how you use and interact with our websites and services, including any content you post to the services.
- Information About The Way You Access And Use Our Services. This may include, for example, the site from which you came and the site to which you are going when you leave our services, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other actions you take on the services.
- Analytics Data. This may include the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and objects you view, click or otherwise interact with (also known as “Clickstream Data”). We may collect analytics data or use third-party analytics tools such as Adobe Analytics and Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners.
- Location Information. We collect information about your location for the purpose of providing our services. We may collect location through WiFi, wireless network triangulation and other methods or we may also approximate your location by your IP Address.
Personal Information Collected In-Store
- Payment and Transaction Information. We may collect information about your in-store transaction such as items purchased, items of interest, date and time of your transaction, amount purchased, and payment information, such as your credit/debit card or gift card details, when you make an in-store purchase.
Personal Information from Other Sources and Third Parties
We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.
We receive the same categories of personal information as described above from the following sources and third parties:
- Information We Receive from Third-Party Sites You Connect to Our Services. Some parts of our services may allow you to login through a third party social network or authentication service such as Facebook. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site.
- Social Networks Through Your Interactions. When you interact with our services through various social media networks, such as when you “Like” us on Facebook or when you follow us or share our content on Facebook, Twitter, Snapchat, LinkedIn, Instagram or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third party websites and social media networks and services before linking or connecting them to our services.
- Information Provided by Others. From time to time, we may receive information about you from third parties and other users. For example, we may obtain information from our marketing partners or from third parties to enhance or supplement our existing user information. We may also collect information about you that is publicly available. We may combine this information with the information we collect from you directly.
- Information Provided by Pandora Jewelry Entities. We may receive information about you from other Pandora Jewelry companies and affiliates, so that information you provide may be used by Pandora Jewelry to provide you services, communicate with you or provide you advertisements or other personalized content.
- Information Provided by Franchisees. We may receive information about you from franchisees that operate Pandora Jewelry-branded stores.
We and the third parties we work with may use personal information:
- To process your registration on our services, including verifying your information to ensure its accuracy and validity.
- To fulfill your requests (e.g., to allow you to place an order in-store or online, have it delivered to you, or to provide you with information that you request).
- To fulfill your purchases (e.g., to process credit card payments in connection with your transaction). For example, we use this information to provide the services to you across our operations, including by supporting your in-store experience when you engage with our Pandora-owned & operated and franchisee-owned locations.
- To personalize your experience (e.g., to locate the Pandora Jewelry stores closest to your location) and customize content on our services relevant to your interests, including but not limited to targeted offers and ads through our website, email, social media channels, third-party sites, or on other devices you may use.
- To operate, maintain, and provide to you the features and functionality of the products and services.
- To send you important information regarding the services, such as certain changes to our terms, conditions, policies, and/or other administrative information. Because this information may be material to your use of the services, you may not opt out of receiving such communications.
- To inform you of products, programs, services, and promotions that we believe may be of interest to you, including, without limitation, adding you to our email/mailing lists and permitting you to participate in sweepstakes, contests, and similar promotions (collectively, “Promotions").
- To evaluate your eligibility for certain types of Promotions, offers, products, or services that may be of interest to you.
- To help maintain the safety, security, and integrity of our service, technology assets, and business.
- For our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, enhancing the services, improving our services, identifying usage trends, and determining the effectiveness of our promotional campaigns, including to inform our machine learning for purposes such as user engagement.
We may also use aggregate personal information in a manner such that the end-product does not uniquely identify you or any other user of the services.
We disclose personal information in the following ways:
- Our Franchisees: We may share your personal information with our franchisees, particularly when we collaborate in providing the services to you. For example, we may share certain personal information so that our franchisees can view your account and purchase history in-store to better serve you. We may also need to share certain personal information with a franchisee in order to provide return or refund information that you may request through the services. We also may share information with our franchisees in order to provide local offers and promotions that might interest you.
- Promotional Partners: We may share limited information with third parties with whom we partner to provide contests and sweepstakes, or other joint promotional activities. These partners will usually be clearly identified in the contest rules or promotional materials.
- Third Parties at Your Request: You may choose to share your activities on the services with your friends through email or on various social media networks.
- The Public: When you provide feedback or post user content on our services (e.g., if you post a product review on our website or comment on our social media sites), your information (e.g., your first name and comments) may be displayed on our websites or on our social media pages. When you engage with us on social media, we may tag your social media account or the social media account of others (e.g., to give photo credit to another user).
- Service Providers. We share personal information with third-party vendors, consultants and other service providers who perform functions or services on our behalf and under our instructions to make our services available to you. For example, this may include vendors and providers who engage in marketing or advertising activities or provide mailing or email services, tax and accounting services, auditing and compliance, fraud prevention, infrastructure provisioning, analytics services, IT services, product fulfillment, and web hosting.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to detect, suppress, or prevent fraud;
- to reduce credit risk and collect debts owed to us;
- to protect the health and safety of us, our customers, or any person; or
- as otherwise required by applicable law.
We may also share personal information which has been aggregated or de-identified in a manner such that the end-product does not uniquely identify you.
Profile and settings: You may update your account information and adjust your account settings by logging into your account. Please note that changes to your settings may require some time to take effect.
How to control your email preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices). You may also be able to adjust certain communications preferences by logging into your account.
Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.