Website Policies

This California Consumer Privacy Statement supplements the Global Privacy Notice and applies solely to California consumers, such as our customers, website visitors, job applicants and business partners.  This Statement does not apply to Tiffany personnel.  

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020)  and its implementing regulations (collectively, the “CCPA”). 

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.