Data privacy

COMMITMENT TO PRIVACY

THOMAS SABO Ltd., as the operator of the THOMAS SABO Online Shop (“THOMAS SABO”), values its customers and respects their privacy. We have adopted appropriate measures to ensure the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used.

This privacy policy (this “Policy”) describes the personal information we may collect from you, the purposes for which we collect it, how we use it and when we may share it with third parties. This Policy also describes the choices you can make about how we collect, use and disclose your information. THOMAS SABO will not collect, use or disclose your personal information other than in compliance with this Policy.

By using the www.thomassabo.com website and/or making online purchases of products, you agree to the terms and conditions of THOMAS SABO's Policy. If our Policy changes in the future, we will notify our customers and website users of any such changes by posting an updated policy on our website.

Following the posting of such changes, your continued use of the www.shop.thomassabo.com website will constitute your acceptance of these changes and you will be bound by such changes. If you do not continue to use the www.shop.thomassabo.com website following a change to our Policy but take no other action with respect to your personal information, our use of that information will remain subject to our Policy as it was in effect prior to the change. You are responsible for regularly reviewing this Policy and any changes thereto.

INFORMATION COLLECTED BY THOMAS SABO

We may collect personal information from you when you save or otherwise provide your personal information to us, such as by setting up a user account and password, logging in as a registered user of www.shop.thomassabo.com, searching for a product, making an order for a product, providing information in your account (and you might have more than one, if you've used more than one e-mail address when shopping with us), communicating with us by e-mail, or otherwise. As a result of these actions, you might supply us with personal information such as your name, e-mail and postal addresses, phone numbers, credit card information, product interest information and financial information and, in certain circumstances, your opinions and individual preferences.

THOMAS SABO's website is directed for use by adults. THOMAS SABO does not knowingly collect any personal information from children under the age of 13. Those under age 13 should not use THOMAS SABO's website to provide THOMAS SABO with any personal information.

COLLECTION PURPOSES

THOMAS SABO may use your personal information to

1. process your order and to answer questions about the status of your order;
2. send you products that you have ordered;
3. send you products that you have ordered;
4. communicate with you (via e-mail, post or otherwise) and provide you with promotional materials and additional information regarding our products, services, promotions and special offers;
5. communicate with you (via e-mail, post or otherwise) and provide you with promotional materials and additional information regarding our products, services, promotions and special offers;
6. help us learn more about your shopping preferences;
   and
7. conduct marketing and performance research to assist us in measuring our customer service, benchmarking our performance and to help us improve our shopping experiences and product offerings.

Provided below, you may always choose not to receive promotional materials or marketing information.

SHARING OF INFORMATION WITH THIRD PARTIES

We do not sell or rent your personal information to non-affiliated third parties except as permitted by law. However, in the event of the sale of all or substantially all of our business or another similar transaction, we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information for the purposes of evaluating the proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in this Policy.

We may transfer personal information to non-affiliated third parties for processing pursuant to agreements that prohibit the third parties from using or disclosing the personal information other than for the purpose of processing and which impose security safeguards appropriate to the sensitivity of the information. Furthermore, we may forward your data to business information services and collection agencies for the purpose of credit and identity assessment, credit monitoring and direct debit processes. This is designed to prevent any payment difficulties and to counteract any damages arising from such matter.

We reserve the right to disclose your personal information as required by law, in response to legal process and law enforcement requests, and as necessary to protect the property, interest and rights of THOMAS SABO.

LINKS

THOMAS SABO's website may contain links to websites operated by third parties. These websites may collect your personal information. This Policy does not apply to the practices of third parties and THOMAS SABO does not assume any responsibility for, and by using this website and/or accessing a third party's website from this website, you release THOMAS SABO from any responsibility for, the actions, practices and omissions of third parties. Please check the privacy policy of each site you visit.

COOKIES

We use cookies (small text files stored on your computer's hard drive) to simplify navigation for you. Only these session cookies permit you to use, and comfortably read, the webpage-wide shopping basket displayed to ascertain how many articles you have in your shopping basket, and what the current shopping total is, at any given time. If you do not wish to use cookies, set your browser to block cookies. However, we would like to point out that this will also block the use of the shopping basket function.

ETRACKER

Furthermore, our online shop’s Website collects and saves anonymised data for marketing and optimisation purposes using etracker GmbH (www.etracker.com) technologies. This data can be used to create user profiles by means of a pseudonym. Cookies can be used here. The cookies enable the recognition of the Internet browser. Without the separately issued consent of the affected persons, the data cannot be used to personally identify visitors to our online shop and are not merged with personal data on the bearer of the pseudonym.

The collection and saving of data can be revoked with effect for the future at any time here: etracker.de/privacy

GOOGLE ANALYTICS

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. In case of activation of the IP anonymization, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of the website provider Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB. You can refuse the use of Google Analytics by clicking on the following link. An opt-out cookie will be set on the computer, which prevents the future collection of your data when visiting this website: Disable Google Analytics Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms/gb.html or athttps://www.google.de/intl/en_uk/policies/. Please note that on this website, Google Analytics code is supplemented by “anonymizeIp” to ensure an anonymized collection of IP addresses (so called IP-masking). We also use Google Analytics for analysing AdWords and double click cookie data for statistical purposes. If you don't agree with this, you can disable it in the Ads Preferences manager (http://www.google.com/settings/ads/onweb/?hl=en).

REMARKETING

We use Google Remarketing, a service offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (hereinafter “Google”).

Here, Google collates information relating to your visit to our Website. For this, Google uses cookies, which are text files that are stored on your computer. Within the context of remarketing, such cookies are used – on the basis of your visit to our Website – to show you online advertising for our products and services when you visit other Websites.

You can find the Google data protection terms and conditions here.

You can deactivate the use of cookies with Google. For detailed information on deactivating cookies, go to the Google ads deactivation page. Alternatively, users can have the utilisation of cookies deactivated by third parties by logging on to the Network Initiative deactivate page. However, you will then not be able to fully use all the functions on our Website. For further tips and information, click here.

CRITEO

Furthermore, we are working with Criteo SA (http://www.criteo.com/privacy/). Criteo cookies are used for targeting/retargeting users of our Website, so as to display personalised ads in their future browsing.

On request, you can configure your browser by changing the browser settings so that cookies are restricted or completely blocked. Comprehensive information on how to do this with numerous browsers can be found by visiting the following Websites: youronlinechoices, Network Advertising Initiative and/or Digital Advertising Alliance. These contain information on how you can delete cookies from your computer along with general information on cookies.

Refer to your smart phone user instructions for information on how these settings can be carried out for your smart phone browser. Users can also select their settings by visiting the following platforms: IAB Opt-Out Plattform, Network Advertising Initiative Opt-Out platform, Digital Advertising Alliance platform, which offer options for making a decision for all companies registered on this platform.

Please note that – even following deactivation of personalised ads from Criteo and other advertising partners – you will continue to receive ads that are, however, less accurately tailored to your interests/browsing behaviour.

Acces or change to personal information, consent and inquiries or complaints.

OPTIMIZELY

This Website uses Optimizely, a Web analysis service owned by Optimizely, Inc., (‘Optimizely’). Optimizely uses so-called ‘cookies’, text files stored on your computer that permit the analysis of your use of the Website. Information on your use of this Website generated by the cookie is generally transmitted to an Optimizely server in the USA and saved there. In the event of activating the IP anonymisation on this Website, your IP address is however shortened by Optimizely in advance within European member states or in other contractual states covered by the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to an Optimizely server in the USA and shortened there. On behalf of the operator of this Website, Optimizely will use this information to evaluate your use of the Website and to compile reports on the Website activities. The IP address transmitted to Optimizely by your browser is not merged with other Optimizely data. You can prevent the saving of the cookies by correspondingly setting your browser software; however, we would like to point out that this may result in you being unable to fully use all functions of this Website . Furthermore, you can also deactivate Optimizely tracking at any time (and hence prevent the collation and transmission of the data generated by the cookie relating to your use of the Website - including your IP address - to Optimizely and the processing of this data by Optimizely) by following the instructions at http://www.optimizely.com/opt_out.

FACEBOOK

Furthermore, THOMAS SABO uses  a so-called Facebook Pixel, whose cookie consent is deployed within our Web presence. It is a product owned by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (‘Facebook’). It allows the tracking of user behaviour once the user has been forwarded to the advertiser’s Website by clicking on a Facebook advert. This procedure is used to evaluate the effectiveness of Facebook adverts for statistical and market research purposes and can help optimise future advertising measures. The collated data are anonymous for us, therefore offer no conclusions regarding the identity of the users. However, the data are saved and processed by Facebook to enable a connection to the respective user profile and so that Facebook can utilise the data for its own advertising purposes in accordance with the Facebook data utilisation guidelines (https://www.facebook.com/about/privacy/). You can enable Facebook and its partners to display adverts both on Facebook and outside. Furthermore, it can save a cookie on your computer for this purpose. Consent for the utilisation of Facebook Pixel audience tracking can only be given by users who are over the age of 13. If users are younger, we request that they ask for the permission of a parent or guardian. Please click here if you would like to revoke your consent: https://www.facebook.com/settings?tab=ads

USE OF SOCIAL PLUGINS

We use Facebook, Twitter, Google+ and Pinterest social plugins on this Website. When you visit a Website that includes such a plug-in, your browser can connect directly to the Facebook, Twitter, Google + or Pinterest servers and transfer data on your visitor behaviour to the Facebook, Twitter, Google + or Pinterest servers.

Using Twitter plugins and the ‘Twitter’ button Twitter – a social network operated by Twitter Inc., 795 Folsom Street, Suite 600, San Francisco, CA 94107, USA – plugins are used on these Web pages. If you use Twitter and in particular the ‘Share’ function, Twitter will link your Twitter account to that of the Web pages you visit. This will be shared with other Twitter users, particularly your followers. This also means that data is transmitted to Twitter. As the host of our Website, we are not informed of the content of the transmitted data or the data utilisation by Twitter. You can access further information using the following link: http://twitter.com/privacy However, please note that you have the possibility to change your data protection settings in Twitter in the account settings under http://twitter.com/account/settings

Using Google plugins and the ‘g+’ button:
These Web pages use the ‘+1’ button from Google Plus, a social network operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA, (hereinafter referred to as ‘Google’). Using the ‘g+’ button on our Website creates a connection to the Google servers in the USA. Here, both your IP address and the information regarding which of our Web pages you have visited is transmitted to the Google servers. If you are also a Google Plus member and are logged on to Google Plus while using the plugin, the collated information on your Website visit will be linked to your Google Plus account and shared with other users. In the case of interactions that are possible with various Google plugins, the corresponding information on you is also collated and transmitted to, and saved by, Google. An overview of the various types of Google plugins can be viewed here: https://developers.google.com/+/plugins If you have made your profile publicly accessible in the Google Plus settings, Google can insert your ‘g+’ as references – together with your profile name and your photo – into Google services, such as search results, your Google profile or in other places on Websites and in Internet adverts. More detailed information on how Google collates and uses the data, on your relevant rights and on the privacy options can be found in Google’s data protection policy: www.google.com/intl/de/+/policy/+1button.html. By installing corresponding add-ons in your browser, you also have the possibility to block Google plugins.

Using Pinterest plugins:
These Web pages use plugins from Pinterest, a social network operated by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA (‘Pinterest’). The various logos contained within the plugin (i.e. the ‘Pin-it’ button or the ‘P’ button), can be viewed using the following link: http://business.pinterest.com/pin-it-button/; the ‘P’ button is used on our Website. Here, both your IP address and information on which of our Web pages you have visited is transmitted to the Pinterest servers in the USA. If you are also a Pinterest member and are logged on to Pinterest while using the plugin, the collated information on your Website visit will be linked to your Pinterest account and shared with other users. Even in the case of interactions that are possible with the various Pinterest plugins, the corresponding information on you is collated and transmitted to, and saved by, Pinterest. Further information on the collation and utilisation of data by Pinterest can be viewed under http://de.about.pinterest.com/privacy/.

WHERE DO YOU GET INFORMATION ABOUT YOUR STORED DATA

THOMAS SABO will ensure that the personal information it collects is as accurate, complete and up to date as is necessary for the purposes for which it is to be used. You are entitled to request access to in correction of your personal information collected by us. In order to make such a request, or if you have any questions or to make any complaint in relation to this Policy and THOMAS SABO's privacy practices, please contact our Privacy Officer by writing to:

Privacy Officer
THOMAS SABO LTEE
16766 Transcanadienne, Suite 401
Kirkland, QC, H9H 4M7
Canada

However, this does not apply to the data required for processing your orders. Once we have received your written withdrawal, we will not use, process or forward the relevant data for purposes other than processing your orders and we will discontinue sending you marketing materials, including our catalogues.

RETENTION OF PERSONAL INFORMATION

We will keep your personal information only as long as is reasonably necessary for the purposes described in this Policy or such longer period as may be required by applicable law.

SECURITY

We have adopted appropriate measures to ensure the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used.

Status: August 2016