PRIVACY AND COOKIES POLICY

Effective Date: 21/03/2018

1. Who are we?

1.1 We areEmpire Outlet Limited.You can contact us at support@empireoutlet.co. Other contact details are on our website.

2. What’s the point of this policy?

2.1 It tells you what to expect when we collect your personal information. Please only use our service if you are completely happy with this policy.

2.2 Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies.

3. Might the policy change?

3.1 Yes.Please check whenever you visit our website. We will assume you agree to the new version of the policy if you use the site after its effective date.

4. What do we collect?

4.1 Information which you upload to our service or otherwise give us such as your name, address and contact details.

4.2 Automated information such as the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, clickstream data, details of your activity with date / time stamps including pages you visited and your searches / transactions.

5. What’s our reason / legal basis for collecting the information?

5.1 Because it’s necessary to provide you with our goods under our contract with you. We may use it for other purposes (such as email marketing) if you consent. In the case of automated information collected when you browse your site, we use this to manage and improve our service in accordance with our “legitimate interests”.

6. What about cookies?

6.1 We and/or third parties use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your computer. Our website’s functionality will be limited if you configure your browser to reject cookies.

6.2 Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Session cookies are temporary cookies that remain in the cookie file of your browser only until your browser is closed. They allow websites to link your actions during a browser session. Persistent cookies stay in the cookie file of your browser for longer (how long will depend on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete cookies already stored on your device, visit: www.allaboutcookies.org.

6.3 The following kinds of cookies may be used on this website:

a) Session cookies: These enable us to keep track of your movement from page to page and store your selections so you do not get asked repeatedly for the same information. They allow you to proceed through many pages of the site quickly and easily without having to authenticate or reprocess each new area you visit. For example, a session cookie remembers your shopping cart selection so you will have the items you selected when you are ready to check out.

b) Shopify cookies : Shopify provide our shopping cart technology. Shopify place session and persistent cookies (up to two years) to record statistics regarding your visit to our site and to store the contents of your shopping cart.

c) Fomo cookies: Fomo places persistent advertising cookies (up to 12 months) in order to track your activity on our site including details of your purchases.

d) Google cookies : Persistent cookies (up to four years we believe) are set in connection with the following Google services on our site and these cookies may involve certain non-personally identifying information being sent to Google:

i) Google Analytics (“GA”) : We use cookies to recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and what sites the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily. You can specifically opt out of GA here. See below for other opt out routes.

ii) GA Advertising Features: We may use the following GA Advertising Features: Remarketing with GA / Google Display Network Impression Reporting / GA Demographics and Interest Reporting / Integrated services that require GA to collect data via advertising cookies and anonymous identifiers. These features involve GA collecting data via Google or other advertising cookies including for display of ads which may be of interest based on your visits to this and other sites. You can specifically opt out of GA here. You can opt of GA Advertising Features at www.networkadvertising.org/choices . See below for other opt out routes.

iii) Google advertising cookies (AdSense, Doubleclick) : Google uses cookies in connection with Google advertising on our website to serve ads to you based on your visits to this and other websites, to avoid showing you repeat ads and for various other purposes. You can opt out at www.networkadvertising.org/choices . See below for other opt out routes

More information and opt out: Click here for Google’s privacy policy and here for more information about the kinds of cookies placed by Google. Click here for information about how Google uses data from its partners’ sites or apps as well as different ways to opt out of Google cookies.

e) Third party advertising cookies: Cookies are placed by third party advertisers and/or internet advertising companies (such as Criteo) who fill ad space on our website. The third parties may use persistent cookies and other similar technologies (known as action tags, single pixel gifs and web beacons) to assess information about your visits to this and other sites. This is so they can track the effectiveness of their campaigns (including whether these advertisements are clicked on or viewed by users and later purchases by such users), avoid showing you the same advertisement repeatedly and display advertisements on this and other sites tailored to your preferences. We do not have any access to or control over these third party technologies. If you would like more information about these practices and to know your choices about not having this information used by Criteo, please click here. For information about other advertisers, please visit www.youronlinechoices.com, www.networkadvertising.org/choices and/or www.aboutads.info/choices . Please contact the third parties directly for more information about their privacy practices.

f) Social media cookies: We may use various social media and other third party features on our website including the “Like” button from Facebook, follow button from Twitter), Plus +1 button from Google, Pin It button from Pinterest, share / follow button from LinkedIn, embed button from YouTube , These features may involve the relevant companies using cookies or linking your visit with cookies previously placed by them on your computer in order for them to collect information relating to your visit to our website or your interaction with their services or otherwise. Click the links shown above for further information about the specific features and those companies’ cookie / privacy practices generally as well as to opt out where this is possible.

g) Facebook advertising cookies: Facebook places third party persistent cookies on our website to enable the display of interest-based ads (i.e. relating to your visit to our site) when you’re on Facebook. Click here for more information including how to opt out. Click here for Facebook’s full privacy policy.

h) Privy cookies: Privy places persistent cookies (up to 180 days) in order to collect information such as number of visits, average time spent, pages viewed, referral website links, navigation history through the website and other anonymous, de-identified statistics. Click here for more information.

i) Cookie-warning cookie: This cookie takes note of whether you are happy to accept cookies on this website based on your response to the message which appeared when you first visited the website. This persistent cookie will remember your preference for up to 90 days.

6.4 By continuing to use our website, having seen our cookie notice, we assume that you consent to use of the cookies outlined above.

7. What do we do with personal information?

7.1 Provide our service, e.g. send service messages, process payments, fulfil orders.

7.2 Send you marketing messages and/or invitations to post product photos or reviews, if you have given permission. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.

7.3 Use it to recognise you when you visit or return to our service to track anonymised traffic and usage patterns, prevent or detect fraud or abuses and help us improve our service.

8. How long do we keep it?

8.1 We will generally delete your personal information when you close your account. However, we may keep some limited information for up to six years after your account is closed - to help deal with any disputes. That timeframe may vary if we are legally required to keep information for a particular period. We will keep your information which we use for marketing until you tell us to stop sending you marketing messages.

9. To whom do we send or make available your personal information?

9.1 To other people who supply us with a service, e.g. couriers (to enable delivery of goods), e-commerce platform providers, website hosts, content delivery networks and businesses which help us send communications or monitor our website.

9.2 To Klaviyo, who we use to send emails. Please see their privacy policy for more information.

9.3 To Fomo, who we use to provide the “recently purchased” pop up on our website. Please see their privacy policy for more information.

9.4 To other users of our website, if you include personal information in a review, photo or other post on our website. Your first name and the first initial of your surname will be used to identify any review you post. Also, your first name (only) and city location may appear in the “recent purchases” popup on our site, e.g., “John in Wolverhampton, United Kingdom purchased Blue Estate Herringbone Tweed Jacket about 2 hours ago.” Please emails us at support@empireoutlet.co if you would like to stop your transaction automatically triggering the popup or to remove any of the above personal information from our site.

9.5 To the relevant authorities or complainants, if we think the personal information breaches our terms and conditions, or it is necessary to protect us or others, or that a criminal act may have been committed, or we are required to do so by law or appropriate authority.

9.6 To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.

10. What happens to your payment details?

10.1 These go direct to our payment partners. We do not receive such information. To ensure your details are not being used without consent, our payment partners may send your personal information to relevant third parties including credit reference and fraud prevention agencies, who may keep a record of that information.

11. Do we send your information outside the European Union?

11.1 Your personal information which we collect is stored within the EU and is not transferred to any third countries except for the following.

11.2 Your personal data is transferred to the US by Klaviyo and Fomo for the reasons explained above.

12. What rights do you have?

12.1 If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete or restrict or object to its use in certain circumstances or to “data portability”. (Some of these rights may not yet have come into effect.)

12.2 If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).

12.3 For more information about your rights, visit the ICO’s website: www.ico.org.uk.

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