We may collect (and may have collected during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender expression, marital status, medical condition, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information: audio, electronic, visual, thermal, olfactory, and similar information
• Employment Information: professional or employment-related information such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement) the categories of personal information listed above for the purposes described in our Global Privacy Notice and for the following business purposes:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
• Providing advertising and marketing services;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Short-term, transient use, such as nonpersonalized advertising shown as part of your current interaction with us;
• Helping to ensure security and integrity;
• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them;
• Debugging to identify and repair errors;
• Undertaking internal research for technological development and demonstration;
• Managing career opportunities with us; and
• Managing our relationships with current or prospective partners, corporate customers and vendors and other business partner personnel.

We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

We will retain your personal information as described in the “How long we retain personal information” section of the Global Privacy Notice.

During the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you make a purchase in-store or online, call our Customer Service center, complete our customer information cards, attend one of our events or participate in a survey
• From your devices, such as when you visit Tiffany websites and other Online Channels
• Your family or friends, such as when they provide us with your contact information so we can send information that may interest you or when someone buys a gift for you
• Our affiliated entities and subsidiaries
• Service providers, contractors and vendors who provide services on our behalf
• Our retail and trade partners
• Social networks
• Online advertising companies (including advertising networks)
• Internet service providers
• Data analytics providers
• Operating systems and platforms
• Law enforcement authorities, regulators, third-party subpoenas and government entities
• Data brokers and data aggregators, including data append and cleansing companies
• Publicly available sources and databases
• Third parties in the event of a corporate transaction, such as a merger or acquisition

We do not sell your personal information in exchange for monetary compensation. We may, however, share your personal information with certain third parties (such as certain advertising services) or allow them to collect personal information via automated technologies on our Online Channels for cross-context behavioral advertising purposes. This kind of sharing may be considered a “sale” or sharing (for cross-context behavioral advertising) under California law when the personal information is exchanged for non-monetary consideration. You have the right to opt out of these types of disclosures of your information, as detailed below.

During the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement, we may have sold or shared the following categories of personal information:

• Identifiers,
• Commercial Information,
• Online Activity, and
• Inferences.

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

During the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Categories of Personal Information	Categories of Third Parties
Identifiers	Our affiliated entities and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as auditors and law firms Our retail and trade partners Our business partners Social networks Online advertising companies (including advertising networks) Data analytics providers Internet service providers Operating systems and platforms Data brokers and data aggregators, including data append and cleansing companies
Additional Data Subject to Cal. Civ. Code § 1798.80	Our affiliated entities and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as auditors and law firms Our business partners Data analytics providers Internet service providers Operating systems and platforms
Protected Classifications	Our affiliated entities and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as auditors and law firms Data analytics providers Data brokers and data aggregators, including data append and cleansing companies
Commercial Information	Our affiliated entities and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as auditors and law firms Our retail and trade partners Our business partners Social networks Online advertising companies (including advertising networks) Data analytics providers Internet service providers Operating systems and platforms Data brokers and data aggregators, including data append and cleansing companies
Online Activity	Our affiliated entities and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as auditors and law firms Our retail and trade partners Our business partners Social networks Online advertising companies (including advertising networks) Data analytics providers Internet service providers Operating systems and platforms Data brokers and data aggregators, including data append and cleansing companies
Geolocation Data	Our affiliated entities and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as auditors and law firms Internet service providers Operating systems and platforms
Sensory Information	Our affiliated entities and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as auditors and law firms Internet service providers Operating systems and platforms
Employment Information	Our affiliated entities and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as auditors and law firms Our business partners Data analytics providers Internet service providers Operating systems and platforms Data brokers and data aggregators, including data append and cleansing companies
Education Information	Our affiliated entities and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as auditors and law firms Internet service providers Operating systems and platforms
Inferences	Our affiliated entities and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as auditors and law firms Our retail and trade partners Our business partners Social networks Online advertising companies (including advertising networks) Data analytics providers Internet service providers Operating systems and platforms Data brokers and data aggregators, including data append and cleansing companies

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement, we may have disclosed personal information about you to government entities and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the categories of personal information we have collected, used, disclosed and sold or shared about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.

Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.

Deletion: You have the right to request that we delete certain personal information we have collected from you, subject to certain exceptions.

Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.

Shine the Light Request: Subject to certain limitations under California Civil Code § 1798.83, California residents may ask us to provide them with (a) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (b) the identity of those third parties.

How to Submit a Request: To submit an access, correction or deletion request, please complete our Personal Information Rights Request form here or call us at 1-800-843-3269. To submit a Shine the Light request, email us at privacy@tiffany.com. You can opt-out of the sale or sharing of your personal information by clicking here. If you would like to opt-out of the sale or sharing of your personal information associated with a different device or browser, please submit an opt-out request or use the Global Privacy Control signal using that device or browser. Please note that if you clear your cookies on a particular browser or device, you may need to resubmit your opt-out request again from that device or browser. Requests sent using the Global Privacy Control will apply to the device and browser from which they are submitted. For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org/.

To submit a request as an authorized agent on behalf of a consumer, please email privacy@Tiffany.com with the subject line “Authorized Agent Request.”

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before complying with your access, deletion or correction request. If you request access to or deletion or correction of your personal information, we may require you to provide certain information, including:

• Contact information (such as name, phone number, and address); and
• Information about your transactions with Tiffany.

In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact privacy@tiffany.com to request this Statement in an alternative format. For questions or concerns about our privacy policies and practices, please contact us as described in the “How to contact us” section of the Global Privacy Notice.

Tiffany & Co. is a holding company that conducts business globally through its subsidiary companies (collectively, “Tiffany”). Tiffany is ultimately owned by LVMH Moët Hennessy Louis Vuitton SE (“LVMH”), a multinational conglomerate specializing in luxury goods, headquartered in France.

Through its subsidiaries, Tiffany designs, manufactures, and markets jewelry, watches, and luxury accessories. Tiffany maintains substantial control over its product supply chain through its and LVMH’s internal jewelry manufacturing and direct diamond sourcing. Tiffany manufactures jewelry in the United States in New York, Rhode Island and Kentucky, and through LVMH-owned facilities in France. Tiffany also polishes and performs certain assembly work on jewelry in the Dominican Republic and crafts silver hollowware in Rhode Island. In total, these internal manufacturing facilities produce approximately 66% of the units of jewelry sold by Tiffany.

The balance, and almost all non-jewelry items, is purchased from third parties that manufacture products to Tiffany’s specifications. To supply its internal manufacturing facilities, Tiffany processes, cuts and polishes rough diamonds at its facilities outside the U.S. and sources precious metals, polished diamonds and other gemstones, as well as certain fabricated components, from third parties. Both these third parties and those who supply finished goods to Tiffany constitute Tiffany’s “supply chain partners”.

Tiffany has long been committed to conducting business responsibly, sustaining the natural environment and positively impacting the communities in which the companies operate. Additional information about Tiffany’s global sustainability strategy and initiatives is available at https://www.tiffany.com/sustainability/.

Tiffany has an Ethics and Compliance Committee consisting of cross-functional leaders from throughout the organization, including its Chief Executive Officer and other members of its senior management team. The Committee is chaired by Tiffany’s Chief Compliance Officer and is responsible for leading and overseeing ethics and compliance matters at Tiffany. The Committee’s oversight includes matters pertaining to misconduct (including violations related to human rights risk) in Tiffany’s supply chain and owned operations.

Tiffany has actively promoted respect for human rights for more than two decades and continuously assesses human rights risks within its supply chain. Tiffany recognizes that there is the risk that slavery, modern slavery, forced labour, child labour or human trafficking may be used at any level or tier of the luxury goods supply chain and that use of migrant labour or unauthorized subcontracted labour is a possibility. In particular, sourcing raw materials and working with external manufacturing facilities continue to be areas of high risk that Tiffany closely monitors through its assessment programs.

With respect to raw materials, Tiffany recognizes that there are risks associated with the use and supply of precious metals, diamonds and gemstones, including the potential use of conflict diamonds in its supply chain, or sourcing of gold or gemstones from conflict affected high risk regions. In addition, Tiffany recognizes that the risks of slavery, modern slavery, forced labour, child labour or human trafficking vary around the world according to local regulations, local culture, and the enforcement of employment terms and conditions in applicable jurisdictions.

Tiffany uses robust independent data from Maplecroft, a global risk and strategic consulting firm, to bolster its risk assessments and to identify geographic risks within its supply chain. Maplecroft is an organization recognized as a benchmark for excellent assessment of global risks. Maplecroft’s human rights dataset comprises over 34 indices, forming a structured dataset covering the full spectrum of labour, civil, and political rights across all countries. Tiffany applies enhanced scrutiny to identified high risk situations, in addition to communicating to its supply chain partners that all slavery and modern slavery, including but not limited to forced and child labour, bonded labour, and human trafficking are zero tolerance issues that will subject the supply chain partner to a halt of business, and may lead to the removal of the supplier from the Tiffany supply chain.

Tiffany is committed to continuously improving its risk assessment processes to improve its ability to identify, mitigate and account for risks within its supply chain and its owned operations.

To minimize the risk of slavery, modern slavery, forced labour, child labour or human trafficking in its supply chain, Tiffany adheres to the policies and processes described below. Policies Concerning Modern Slavery and Human Trafficking Tiffany has long been committed to ensuring respect of the International Labour Organization Core Conventions, United Nations Universal Declaration of Human Rights, and United Nations Global Compact. These standards are central to its responsible business policies and are the foundation for many of Tiffany’s labour-related policies.

Tiffany’s worldwide Business Conduct Policy (“Business Conduct Policy”) sets forth rules and principles that apply to the work conducted by Tiffany to ensure compliance by Tiffany and its employees with Tiffany’s expectations regarding ethical behavior. As a subsidiary of LVMH, Tiffany incorporates the LVMH Code of Conduct into its Business Conduct Policy to ensure that Tiffany and its employees also adhere to the ethical framework for actions and decisions expected by LVMH. All employees are required to sign an annual commitment to the principles set forth in the Business Conduct Policy (and the incorporated LVMH Code of Conduct), including commitments to act responsibly, with social awareness and with respect for human rights and fundamental freedoms.

The Tiffany Human Rights Policy captures Tiffany’s approach to integrating human rights across its value chain in addition to addressing its most salient human rights risks, impacts, and opportunities. This policy integrates existing Tiffany policies with human rights touchpoints, articulating a unified vision and approach to managing and promoting human rights. All Tiffany employees are required to complete training on the Tiffany Human Rights Policy during new hire onboarding.

Tiffany’s commitment to identifying, preventing, and mitigating risks of slavery, modern slavery, forced labour, child labour and human trafficking is also in the LVMH Supplier and Business Partner Code of Conduct (the “Supplier and Business Partner Code”), which Tiffany rolls out to its supply chain partners and other key business partners, including by making the Supplier and Business Partner Code available online through Tiffany’s website at https://www.tiffany.com/faq/a-tiffany-diamond-faq/tiffany-co-supplier-code-of-coduct/. The Supplier and Business Partner Code, which Tiffany amends from time to time, sets out general principles and requirements that are applicable to all suppliers. Further, Tiffany’s supply chain partners, their subcontractors that are approved to provide goods or services to Tiffany, and select service providers, are required to fully comply with the Supplier and Business Partner Code as a part of Tiffany’s purchasing agreements. The Supplier and Business Partner Code sets clear expectations for Tiffany’s suppliers, including that all employment must be voluntary and that the LVMH Group does not tolerate any form of abusive or illegal labor in its supply chain, with the current Supplier and Business Partner Code specifying as follows:

The LVMH Group does not tolerate any form of abusive or illegal labor in its supply chain such as forced labor or human trafficking. All forms of forced labor, slavery, servitude or trafficking in human beings by Business Partners, as well as withholding identity papers or work permits or requiring workers to deposit a bond or the use of any other constraint, is strictly prohibited. All workers are entitled to accept or leave their employment freely. Business Partners must respect workers freedom of movement. Business Partners cannot require workers to work to repay a debt to them or to a third party.

Tiffany’s expectations and requirements covering responsible recruitment, slavery, forced or child labour, indentured, debt-bonded or convict labour, and human trafficking are further detailed in its Supplier and Business Partner Code of Conduct Guidance (“Code Guidance”). This Code Guidance is distributed to its supply chain partners and compliance with the requirements is mandatory. The Code Guidance is regularly updated to ensure that Tiffany is consistently communicating requirements and methods to respond to specific challenges. All requirements in the Code Guidance are applicable throughout the supply chain, such that a supplier with which Tiffany has a direct relationship in turn bears the responsibility for ensuring compliance across its own supply chain.

All Tiffany stakeholders can notify Tiffany through various channels if any of its requirements are not being met, including those concerning modern slavery and human trafficking. Stakeholders can contact either the Tiffany Alertline or the LVMH Alert Line to notify Tiffany and LVMH of any suspicions or observations related to modern slavery or human trafficking (among other matters). Employees can also discuss these topics with their direct manager, human resources, the legal department, or the internal audit team. All individuals who report suspected policy violations in good faith are protected from retaliation arising from such reporting in any form, including disciplinary action, intimidation, or otherwise, even when reports are ultimately proven unfounded. Representatives of the human resources, legal, and internal audit team, collect and review all cases and ensure they are investigated and responded to by the appropriate teams.

To identify and mitigate risk in its supply chain, Tiffany completes due diligence assessments and audits as part of its Social and Environmental Accountability Program (“SEA Program”). Tiffany’s jewelry manufacturing and diamond polishing facilities, supply chain partners, and other key suppliers are regularly assessed for adherence to its Supplier and Business Partner Code through the SEA Program.

The SEA Program work includes:

• Screening of suppliers to ensure that Tiffany works with supply chain partners and other key suppliers that share its commitment to human rights, fair and safe labour practices that do not involve slavery, modern slavery, forced labour, child labour or human trafficking, environmental protection, and ethical business conduct.
• Conducting biennial site mapping reviews and risk assessments with all of Tiffany’s jewelry manufacturing and diamond polishing facilities, supply chain partners, and other key suppliers to identify regional and supplier risks related to social and environmental compliance.
• Conducting regular third-party audits based on the results of such risk assessments to determine conformance with Tiffany-specific requirements. Corrective action plans are required for non-conformances, and verification re-audits are required for all critical risk audits.

Based on its risk mitigation approach, Tiffany includes key portions of its supply chain in its monitoring program and requires its supply chain partners to communicate its social and environmental responsibility expectations to their own supply chains. Both Tiffany’s risk assessment and supplier audits screen for modern slavery indicators such as overtime requirements, the existence of foreign migrant labourers in employment, grievance mechanisms and freedom of association.

The last biennial risk assessment was conducted in 2024. Using the results of the risk assessment, Tiffany engaged a sampling of supply chain partners to conduct third-party audits throughout 2024 and into early 2025. Final audit results will be received in 2025 and corrective action plans have been, or will be, issued to suppliers (with verification re-audits being conducted where critical risks are identified). In 2024, Tiffany also continued to roll out its program by conducting risk assessments and pre-sourcing audits, and reassessing its risks as it engaged and contracted with new supply chain partners. While SEA Program assessments identified some gaps in human rights-related policies and procedures for a fractional percentage of Tiffany’s total supply chain partners in 2024, no acts of slavery, modern slavery, forced labour, child labour or human trafficking have been identified in Tiffany’s active supply chain. For all identified gaps in policies and procedures, corrective action plans were established with the respective supply chain partners to address identified gaps and ensure that robust monitoring systems are in place to minimize the risk of modern slavery entering their supply chains.

Tiffany works to establish lasting partnerships with its suppliers and provides them with training and development programs as well as sharing best practices. Tiffany also works jointly with industry partners, non-governmental organizations (NGOs), and local stakeholders to identify human rights-related risks and further the improvement of the most complex challenges in human rights and labour. For example, with the goal of improving the coloured gemstone industry, Tiffany has worked with a group of luxury brands and gemstone miners (the “Coloured Gemstone Working Group”) to launch a community platform that includes trainings, policies and support on human rights and modern slavery topics. The Gemstones and Jewellery Community Platform, launched in 2021 by the Coloured Gemstone Working Group, is freely available to all companies who are part of the gemstone and jewelry industry, from mining through to cutting and polishing, trading and retailing. Modules on Human Rights and Equality and Labor Rights and Fair Working Conditions will educate those along the coloured gemstone supply chain on risk and mitigation strategies for modern slavery and human trafficking.

Tiffany helped launch the Initiative for Responsible Mining Assurance (IRMA) in 2006 and remains steadfast in its commitment to work with suppliers, employees, the industry at large, NGOs and other local stakeholders to foster responsible mining. IRMA published a Standard for Responsible Mining, which represents a robust, practicable and comprehensive set of requirements for responsible mining, which incorporate human rights and modern slavery, as well as other environmental, social, ethical, and transparency considerations.

Respect for human rights is embedded throughout the entirety of Tiffany’s business as a result of its emphasis on human rights in its policies and procedures. Tiffany’s monitoring and training programs are designed to continuously monitor effectiveness and ensure appropriate awareness of Tiffany’s commitment to human rights. In particular, audits and re-audits of supply chain partners through Tiffany’s SEA Program are designed to assess effectiveness, including by identifying any repeat non-conformities or improvements. See “Due Diligence Processes” above for more information. In addition, Tiffany’s SEA Program is regularly audited by third parties (including certain of its own suppliers and trade associations) for reviews of effectiveness as related to modern slavery and human trafficking as part of renewals and certifications with such third parties.

Tiffany provides ongoing training resources and communicates expectations related to its Supplier and Business Partner Code through an online responsible sourcing education platform for its supply chain partners. Training webinars and e-learning modules on the Supplier and Business Partner Code, on the Tiffany Human Rights Policy and on Forced Labour Prevention are available to its supply chain partners year-round. With respect to Tiffany’s employees, all employees who work directly with the companies’ supply chain partners are required to participate in mandatory training on the SEA Program biennially. The training covers a range of topics, including topics related to forced labour and child labour, among others. In 2024, Tiffany also launched a responsible sourcing summit for the benefit of these employees, providing them with additional resources including tools to increase awareness of red flags related to slavery, modern slavery, forced labour, child labour or human trafficking.