California Consumer Privacy Act
Your California Privacy Rights
This section applies to California residents only whose personal information is subject to the California Consumer Privacy Act of 2018 (“CCPA”) and supplements the details provided in our main privacy notice. Below is a summary of the categories of personal information we collect from consumers, the categories of sources of the personal information, the purposes for which we use it, and the categories of third parties with whom we share consumer personal information.This notice came into effect on the 1 January 2020 and was last updated on 30 June 2020.
Information we collect
The categories of sources of personal information are detailed in the section “How we collect your data,” of the main privacy notice and are summarized as follows: (a) directly from you, (b) through automated technologies or interactions, and (c) from third parties.Use of your personal information
The business and/or commercial purposes for which we collect personal information are detailed in the section “Uses made of your personal data” and “Marketing preferences, adverts and cookies” and are part of the following general purposes: (a) performing services, (b) auditing, (c) legal and compliance, (d) quality assurance, (e) security, (f) debugging, (g) short term, transient use, (h) internal research, and (i) corporate reorganization.Sharing personal information
The categories of third parties to whom we disclose personal information for a business purpose are detailed in the section “How we share your data” and are summarized as follows: (a) entities to whom you have consented to the disclosure, (b) entities connected to the running of our business as technical support, payment processing, order fulfillment, marketing, website optimization, and affiliates, (c) entities connected to corporate transactions, (d) entities that assist us in the prevention of fraud and theft, (e) entities with whom we must share due to a legal obligation, and (f) entities that serve as professional advisers.Our data sharing practices are detailed in the chart below. The chart includes the categories of personal data we may collect and who we may disclosure it to
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Categories of Personal Information We May Collect
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Categories of Third Parties With Whom We May Disclose Personal Information for a Business Purpose
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Identifiers such as real name, postal address, country of origin, IP address, telephone number, email address, account name, date of birth, other similar identifiers. |
• Entities to whom you have consented to the disclosure.
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Personal information protected by Cal. Civ. Code 1798.80(e), such address, telephone number, credit card number, debit card number, and financial information. |
• Entities to whom you have consented to the disclosure.
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Characteristics of protected classifications under California or Federal Law, such as age and gender. |
• Entities to whom you have consented to the disclosure.
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Commercial information, including products or services purchased, obtained or considered, or other purchasing or consumer history. |
• Entities to whom you have consented to the disclosure.
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Internet or other electronic network activity information which may include but is not limited to, status/HTTP status code, operating system and its interface, version of browsing software, device ID, other device type information, browsing history, search history and information regarding a consumer’s interaction with our website, applications or advertisements including third party advertisements. |
• Entities to whom you have consented to the disclosure.
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Geolocation data, such as your precise or approximate location derived from information from your mobile device. |
• Entities to whom you have consented to the disclosure.
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Other audio, electronic, visual, thermal, olfactory, or similar information, such as electronic chat records. |
• Entities to whom you have consented to the disclosure.
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Inferences drawn from any of the information identified above to create a profile about a consumer such as consumer’s preferences, characteristics, predispositions, and behavior. |
• Entities to whom you have consented to the disclosure.
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Your Rights:
Subject to certain legal limitations and applicable exceptions, California residents may exercise the following rights by emailing us at DPO@karenmillen.com, customerservices@karenmillen.com or the 'Contact Us' page on our website.
• Right to Know. You have the right to request information about the categories of personal information we have collected about you, the categories of sources from which we collected the personal information, the purposes for collecting the personal information, and the categories of third parties with whom we have shared your personal information (“Categories Report”). You may also request information about the specific pieces of personal information we have collected about you (“Specific Pieces Report”).
• Right to Delete. You have the right to request that we delete personal information that we have collected from you.
• Right to Opt Out of the Sale of Your Personal Information. You have the right to opt-out from the sale of your Personal Information. However, we currently do not sell any personal information (including information about minors). If you are a resident of Nevada you may have the right to opt-out of any future sale of your personal information. Please email us at DPO@karenmillen.com, customerservices@karenmillen.com or the 'Contact Us' to make this request.
In accordance with applicable law, we will not discriminate against you for exercising these rights.
When submitting your request, please include your first and last name, email address, and additional information identified in the “Verification” and “Signed Declaration” sections below as appropriate.
Verification:
In order to exercise your rights, we will need to obtain information to verify your identity. If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth in this section. • For a Specific Pieces Report, we will request your name, email address linked to your account, the date of your last order, the order number of your last order and the postcode of your last order to verify your identity and seek a signed declaration, under penalty of perjury, that you are who you say you are. (See the section “Signed Declaration” for the language to include in your request for a Specific Pieces Report.) • For a Categories Report, we will request your name, email address linked to your account, the date of your last order and the order number of your last order to verify your identity. • For a Right to Delete request, we will request your name, email address linked to your account, the date of your last order and the order number of your last order to verify your identity. In certain circumstances, we may require additional or different data in order to verify your identity.
Signed Declaration:
When making a request for a Specific Pieces Report, please email a copy of your signed document containing the following language:
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Declaration of Consumer
I am a resident of California seeking to receive the specific personal information collected about me in the past 12 months (the “Request”) by Karen Millen. I hereby declare, under penalty of perjury under the laws of California and the United States, that I am the consumer whose personal information is the subject of the Request.
Signature: __________________________________________
Print First and Last Name: _____________________________
Date of my last order: ______________________________________________
Order number of my last order: ______________________________________________
Email Address linked to my account: ______________________________________
Postcode of your last order:______________________________________
Date: _____________________________________________
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Authorized Agents:
Authorized agents may exercise rights on behalf of consumers. If you are an authorized agent, we will request written and signed authorization from the consumer and will seek to verify the consumer as described above, or we will accept a legal Power of Attorney under the California Probate Code. We will also require evidence of the agent’s identity and proof of registration with the California Secretary of State. To make a request as an authorized agent, please email us at DPO@karenmillen.com or customerservices@karenmillen.com, and include:
• Your name;
• The name of the consumer on whose behalf you are acting;
• Whether you are requesting a Categories Report, Specific Pieces Report, and/or Deletion;
• A written and signed authorization to you from the consumer or a copy of a legal Power of Attorney under the California Probate Code; and
• Proof of your identity;
Timing:
We will respond to Requests to Delete and Requests to Know within 45 days, unless we need more time in which case we will notify you and may take up to 90 days total to respond to your request.
Notice of Financial Incentives
Karen Millen(“we,” “our,” or “us”) is providing you with this notice to explain the material terms of a financial incentive (as defined by the California Consumer Privacy Act (“CCPA”)) we are offering ( “Incentives”) so that you may make an informed decision on whether to participate.
From time-to time-on certain Websites we may offer a “sign up and save” offer. This means we will provide you with an Incentive (such as a one-time percentage off discount) if you provide us your contact details and agree to receive marketing materials. We also offer various Incentives for registering an account with us, which may include (but not be limited to) discounts on your first order, reduced or free delivery. We may also run competitions which include giveaways which require you to provide us with your contact details to enter. These Incentives may vary from time to time, but will be clearly presented to you at the time you sign up.
You can take advantage of any Incentives we offer by providing your information where requested, such as entering your email in the box to sign up for marketing communications, entering information of the designated registration page (such as name, date of birth, telephone number, postal address and email address), or in other ways that will be described to you at the time the Incentive is presented. By providing this information, you agree to receive marketing and advertising and that your personal information may be used and shared consistent with our Privacy Notice.
You can withdraw from the Incentive at any time by emailing us on customerservices@karenmillen.com, using the “Contact Us” section on our website, or by unsubscribing to our email marketing by clicking the “unsubscribe” link in the footer of any marketing email received.
The Incentive is reasonably related to the value of your personal information that you are providing to us. Our good faith estimate of the value of your personal information is the value of the Incentive offered to you (such as the value of the discount code, value of reduced shipping costs or the value of a competition prize or giveaway). We calculated the value of your personal information based on our expenses related to providing the Incentive.