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CUSTOMER PRIVACY NOTICE

Last Modified: May 25, 2018

Ralph Lauren: Customer Privacy Notice

Ralph Lauren Europe Sàrl (24, route de la Galaise, 1228 Plan-les-Ouates, Switzerland) and its affiliated companies in Europe, Switzerland and Turkey, together “Ralph Lauren”, “we” or “us” respect your concerns about privacy and recognize the importance of being transparent regarding the personal information we collect about you.

This Privacy Notice applies to personal information we collect in connection with our products and services, for example when you visit our European websites (collectively “Websites”) and or any store operated by Ralph Lauren under any brand in the European Economic Area, Switzerland and Turkey (collectively “Stores”), when you engage with us through social media platforms or when you contact our Customer Assistance.

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Ralph Lauren Europe Sàrl is the data controller and is responsible for the processing of this information. Each of Ralph Lauren Europe Sàrl’s affiliated companies in Europe, Switzerland or Turkey may also act as data controller in relation to the personal information collected in the Store you visit, to process your purchases and requests and to improve your customer experience.

This Privacy Notice describes the types of personal information we collect about you, how we may use that information, with whom we may share it and the rights you have regarding our use of that information. This notice also describes the measures we take to protect the security of the personal information, how long we retain it and how you can contact us to exercise your rights.

This Privacy Notice may be updated periodically to reflect changes in our personal information practices or relevant laws. We will post a prominent notice on the site and/or send you an e-mail to notify you of any significant changes and indicate at the top of the notice when it was updated

WHAT PERSONAL INFORMATION DO WE COLLECT?

This section explains, for each situation, what personal information we may collect directly from you (either on a voluntary basis or through automated means) and what personal information may be collected (or we may receive) from other sources

At the moment of collection, we will inform you whether the provision of personal information is optional or mandatory for us to provide a particular product or service. Where the collection is mandatory, we may not be able to provide you with the product or service you requested if you choose not to provide that information to us

Please note that our products and services are not directed to children under the age of sixteen and we do not knowingly collect information from children under the age of sixteen. If we become aware that we have inadvertently received personal information from a customer under the age of sixteen, we will delete the information from our records.

When you purchase our products or use our services online or in-store

  • For any type of purchase, we will collect your credit card numbers and other payment information. We will keep your shopping history (what you bought, when and where you bought it and how you paid for it) if we can relate the purchase to your account.
  • If you make an online purchase, we will also collect your contact information including your name, billing and shipping address, e-mail address, telephone number. For certain countries to which orders are internationally shipped through our global ecommerce partner Borderfree, your personal information will be collected and controlled by Borderfree under the Borderfree Privacy Policy.
  • If you are in contact with our Customer Assistance in connection with our products or services, we will record our calls for security and training purposes, and to improve the services we provide to you. We may also collect additional information through your correspondence with us.
  • If you purchase an item or gift card or ask us to deliver your purchase to someone else, we will collect the recipient’s name, postal address and email address to send the item or gift card to the recipient. If you ask us to do so, we also may use this information to notify the recipient of your gift before it arrives.
  • If you use our complimentary personal styling service (available exclusively at our Regent Street flagship store in London), we will collect names and contact details to book an appointment for you and your friends. We may also collect product sizes and fits and any other information you may voluntarily provide to offer you and your guests an enhanced service and personalise your experience with Ralph Lauren.

When you visit our Websites

  • We obtain certain information by automated means when you visit our Websites, such as through cookies and web beacons. Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site. The information we collect in this manner may include the IP address of the device you use to connect to the Internet, information regarding your browsing behavior (such as the date and time of your visit, the time you spend on each page, the ads you click on or the website you link from) or the contents of your virtual shopping bag between visits
  • Cookies and web beacons are only used if you have accepted them on you first visit by continuing your navigation on our Website. Click here to know more about our use of cookies, web beacons and similar technologies and how to manage your settings and preferences at any time
  • We may also collect information about your online activities from third-party websites on which our ads are served. You may see certain Ralph Lauren ads on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities and to show you advertisements tailored to your individual interests.
  • If you decide to register to “My Account”, we will collect your name, address, e-mail address, country of residence, telephone number, username and password. You may also choose to provide us your gender, date of birth and to store billing and shipping information as well as credit card information, wish list of products or address book on a voluntary basis. We will also give you the opportunity to opt in to receive Ralph Lauren marketing communications.
  • Our Websites may contain links to other websites or offer third party services applying their own privacy policies to the collection of other personal information. These websites or services may be operated by companies not affiliated with Ralph Lauren. We strongly recommend you to read their privacy policies if you visit any of these websites or use any of these third party services. We are not responsible for the content of any website or third party service not affiliated with Ralph Lauren.
For example:
When shopping on our Websites, you may use the services of True Fit to obtain personalised size and fit recommendations. Any personal information you provide to TrueFit such as your gender, clothing size or preferred brands is collected by True Fit Corporation and subject to the True Fit Privacy Policy:. None of this information is transmitted back to Ralph Lauren.

When you visit our Stores

  • We may collect your image on CCTV which our Stores use for the prevention and detection of crime and for protecting the safety of our customers. We may also use CCTV technology for traffic counting without collecting personally identifiable data about you.
  • Depending on the selected payment method, we may collect a copy of documents you provide to prove your age or identity where required by law. Such documents may provide details of your full name, address, date and place of birth, gender and nationality.
  • We may also collect information about your device (including MAC address, connection date, time and location) through sensors (only if your Wi-Fi is turned on) for store analytics. We will inform you by posting signs where sensors are used to collect this information. If you want to disable this functionality, please turn off Wi-Fi in your device settings.
  • If you decide to use our complimentary Wi-Fi services, we will collect your e-mail address and connection information (such as your IP address and connection date and time). If you access the Wi-Fi by signing up through your social media account, we may also access and collect your public information on social media, except where your interests or fundamental rights and freedoms would outweigh our legitimate interest to collect that information.
  • If you decide to join our Customer Registry, we will collect your name, postal address, e-mail address and telephone numbers. You may also choose to provide us with your birth date and your gender on a voluntary basis. We will also give you the opportunity to opt-in to receive Ralph Lauren marketing communications.
  • As part of our clienteling programme, we may collect information relevant to you (such as your contact information, purchase history, product or lifestyle preferences, important dates or events, size information, etc.) to offer you highly personalised shopping experiences in our Stores.

When you participate in surveys, competitions, events or promotions

  • When you contact or are contacted by our Customer Assistance, we may collect information such as your name, address, e-mail address, telephone number, date of birth, payment information, shopping history and records of correspondence.
  • When we contact you by e-mail, we may use cookies and web beacons to know when you have clicked and opened our e-mail. Click here to know more about use of cookies, web beacons and similar technologies and how to manage your settings and preferences at any time.
  • If you contact us or we contact your on our social media pages, we may collect your social media username, your comments, questions or feedback.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We will use and process your personal information for the purposes described in this section. Please note that one or more purposes may apply simultaneously to the same personal information.

For example:
We may use your e-mail address to confirm your order and to send you marketing communications.

To provide our products and services

  • We will process the relevant personal information described in the previous section to provide you the products and services you have requested.
For example:
  • When you purchase products on one of our Websites, we will use your name and address to deliver the products and your credit card details to effect payment.
  • When you participate in a prize draw organized by Ralph Lauren, we will use your name, e-mail address and mobile number to administer the prize draw and communicate with you if you win
  • When you visit our Websites, we will use cookies that are strictly necessary to enable the services on our website that you have specifically requested (for example, use the shopping basket function or pay for your products).
  • We rely on the contract we have with you as the lawful basis to process your personal information for such purpose. If you choose not to provide the information, we have requested from you, we may not be able to perform properly our contractual obligations.

To communicate and interact with you

  • If you have given us you consent through an appropriate mechanism such as ticking a box, managing technical settings or any other action indicating clearly your consent, we will use your contact information to send you offers, news and updates about our products, services and events via the channel you have chosen (such as e-mail or mobile phone). We will personalise and tailor these communications to your preferences and interests based on our legitimate interest to improve your customer experience as explained in the next section.
  • You can choose at any time to unsubscribe from marketing e-mails by clicking on the unsubscribe link included in each e-mail (or by contacting our Customer Assistance or Data Protection Officer if the unsubscribe link is not available). If you have opted in to receive text messages, you may opt out at any time (for example, by sending a ‘STOP’ text to a short number) free of charge (except the cost of sending the message).
  • Based on our legitimate interest to do so, we may use your contact information to send you marketing communications by postal mail (you may opt out of receiving postal communications at any time by contacting our Data Protection Officer or Customer Assistance). We may also contact you about our services, for example to ask you to provide feedback about your experience in our Stores or to participate in a survey
  • We may send you communications required by law or which are necessary to inform you about our changes to the services we provide you (for example, updates to this Privacy Notice, product recall notices and legally required information relating to your orders). These messages will not include any promotional content and do not require your prior consent when sent by email or text message. If we do not use your personal information for these purposes, we will be unable to comply with our legal obligations.

To improve our products and services and personalise your experience with Ralph Lauren

  • We may use your personal information to understand your preferences, offer you products and services which are more relevant to you, deliver content and show you advertisements tailored to your interests, and send you personalised communications (if you have opted-in to marketing communications).To process your information, we rely on our legitimate interest to improve our products and services and personalise your customer experience.
  • If you have accepted the use of cookies on you first visit by continuing your navigation on our Website, we may use the personal information collected to:
    • offer you a customized browsing experience and provide you with a great shopping experience, for example by capturing the pages you have browsed or products you have viewed and remembering your choices and preferences (through functionality cookies).
    • show you interest-based advertising on third party websites after you have shown interest in our products or services (through third party advertising cookies). The objective is to make our online offers even more interesting for you.
      For example:
      Through the Facebook pixel added on our Websites, Facebook can determine a group of users who have visited our Websites as a target audience for the presentation of Ralph Lauren ads on Facebook (‘Custom Audience’). This service allows us to display Ralph Lauren ads to Facebook users who have shown interest in our Websites or people who resemble our customers. Facebook's processing of personal data is governed by Facebook Data Usage Policy: https://www.facebook.com/about/privacy. If you are logged into Facebook, you can disable the "Custom Audiences" remarketing feature at any time at https://www.facebook.com/settings/?tab=ads#_=_
    • determine advertising effectiveness, for example that you have visited our Websites after clicking on Ralph Lauren ads displayed by third party advertising companies (through analytics cookies) on certain websites you visit.
    • Click here to know more about use of cookies, web beacons and similar technologies and how to manage your settings and preferences at any time.
  • Based on our legitimate interest, we may also share limited personal information about you (such as your e-mail address) in an encrypted format with strategic partners (such as Facebook) to allow you to receive targeted advertising when you are visiting other websites.
  • We may finally use your personal information to conduct analytics and research based on our legitimate interest to understand our business, customers shopping patterns, trends and behaviors. For example, information collected in Stores through mobile devices may give insights about traffic patterns.

To provide customer support

We may process your personal information if you contact our Customer Assistance (or we contact you through our Customer Assistance). We will collect and process your personal information to perform our contractual obligations in relation with the products or services you have requested and to provide you the best service we can or to comply with our legal obligations

To identify and prevent fraud and other criminal activities

We use some of the personal information we collect from you based on our legitimate interest or where necessary to comply with our legal obligations to prevent and detect fraud and other criminal activities.

For example:
  • We may record your image on CCTV for the prevention and detection of crime and for protecting the safety of our customers in our Stores.
  • We store your password and login to prevent and block fraudulent access to your account on our Websites and ensure you are not victim of fraud.

WHO DO WE SHARE YOU PERSONAL INFORMATION WITH?

We do not sell or otherwise disclose your personal information except as described in this section

With other Ralph Lauren Companies

We may share your personal information with our affiliated companies , with Ralph Lauren Corporation and Club Monaco US, LLC in the United States, for the purposes described in this Privacy Notice.

With our Service Providers

We may also share personal information with our Service Providers processing your data on our behalf for the purposes described in this Privacy Notice.

Examples of service providers we may share your data with:
  • Service provider operating the contact centre to provide Customer Assistance to users of our Websites.
  • Transportation companies delivering products purchased on our Websites to our customers.
  • Companies providing technical support and infrastructure for ourWebsites.

Where our service providers need to have access to your personal information, we will (1) select providers who respect your privacy and comply with data protection laws at any time ; (2) only give them access to the information they need to perform their services; (3) ensure that they will only use the information for the purposes agreed in our contract with them; (4) ask them to delete or return any personal information when we stop using their services.

Other reasons for sharing personal information

We may also disclose personal information about you (1) if we are required to do so by law or legal process (such as court order), (2) in response to a request by law enforcement authorities, or (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or suspected or actual illegal activity.

We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use the personal information you have provided to us in a manner consistent with this Privacy Notice. Following such sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that personal information.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

Security safeguards

We maintain appropriate administrative, technical and physical safeguards to protect the personal information you provide on this website against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use and other unlawful forms of processing.

We use Secure Sockets Layer (“SSL”) technology to protect the transmission over the Internet of your payment card data. You can check the security of your connection by looking at the URL line of your browser. When accessing a secure site, the first characters of the site address change from “http” to “https.” If you are using a web browser or firewall that does not permit communications through secure sites, you will not be able to make purchases on our site.

Transfer of personal information to other countries

We will transfer the personal information we collect about you to our affiliates and third party service providers in other countries that the country in which you originally provided it, including the United States, and that have not been recognized as providing an adequate level of data protection. In this event, we will implement appropriate safeguards to ensure an adequate level of data protection, including selecting service providers that are certified to the EU-US Privacy Shield framework, or executing data transfers agreements based on the European Commission’s Standard Contractual Clauses. You may obtain a copy of these safeguards by contacting us as indicated in the “How to contact us?” section below.

Our US affiliates Ralph Lauren Corporate and Club Monaco US, LLC, are certified to the EU-US Privacy Shield frameworks. . Click here to view our certification and here [Page Jump to the EU-U.S. PRIVACY SHIELD section below] to read our EU-US Privacy Shield Policy. US companies certified to the Privacy Shield are recognized by the European Commission as providing an adequate level of data protection.

HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

We keep the personal information we collect for the duration of our relationship with you, plus a reasonable period in order to take into account the applicable legal retention requirement or statute of limitation period, or otherwise as required for our business purposes described above.

If you consent to receive marketing communications, we will keep the information necessary to send you these communications for a period of three (3) years following the end of our customer relationship or following their collection, if you are a prospective customer.

At the end of the retention period, your personal information will be deleted completely or anonymised so that it can be used in a non-identifiable way for statistic and analytical purposes.

WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL INFORMATION?

Subject to applicable law, you may (1) request access to the personal information we maintain about you, (2) request that we update, correct, amend, or erase your personal information or (3) request the restriction of our use of your personal information.

In addition and also subject to applicable law, you may receive, in a structured, commonly used and machine-readable format, the personal information that you have provided to us about you. In appropriate circumstances, you have the right to have this information transmitted to another company, where it is technically feasible.

You also may object at any time to the use of your personal information, on grounds relating to your particular situation, where we use that information based on our legitimate interests as described above.

If we use your personal information to send you marketing communications, you may object at any time and without providing any reasons (e.g., by clicking in the unsubscribe link in our marketing emails or by contacting our Customer Assistance or Data Protection Officer), and we will apply your preferences going forward. You also may withdraw any consent you previously provided to us. If you do so, this will not affect the lawfulness of our use of your information based on your consent before its withdrawal.

If you wish to exercise these rights, please contact our Data Protection Officer as specified in the How to Contact Us section. Please include your name, email address, postal address. and a copy of your identity card or passport in your request. To protect the confidentiality of your information, we will also ask you to verify your identify by providing a copy of your identity card or passport in your request. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

If you have an online customer account, you can also access, amend or update your information by logging into My Account on our Website and amending your details as appropriate.

If you are not satisfied by our response or if you consider your privacy rights have been breached, you may lodge a complaint with a data protection authority, in particular in the EEA country of your habitual residence, place of work or place of our alleged infringement of the European data protection rules.

How to Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like to exercise your rights, please contact our Data Protection Officer as indicated below:

Ralph Lauren Europe Sàrl
Attention: Data Protection Officer
24, Route de la Galaise
1228 Plan-Les-Ouates
Switzerland

Email: DataProtectionOfficer@RalphLauren.com

EU-U.S. Privacy Shield PRIVACY POLICY

Last Modified: September 2016

Ralph Lauren Corporation, along with its affiliate Club Monaco US, LLC (collectively, “Ralph Lauren”), respect your concerns about privacy. Ralph Lauren participates in the EU-U.S. Privacy Shield framework (“Privacy Shield”) issued by the U.S. Department of Commerce. Ralph Lauren commits to comply with the Privacy Shield Principles with respect to Consumer Personal Data the company receives from the EU in reliance on the Privacy Shield. This Policy describes how Ralph Lauren implements the Privacy Shield Principles for Consumer Personal Data.

For purposes of this Policy:

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Consumer” means any natural person who is located in the EU, but excludes any individual acting in his or her capacity as a Worker.

“EU” means the European Union and Iceland, Liechtenstein and Norway.

“Partner” means any licensing or franchising partner or other third party operating a store under any of the Ralph Lauren brands.

“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Ralph Lauren in the U.S. from the EU, and (iii) recorded in any form.

“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.

“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.

“Sites” means www.ralphlauren.com, www.clubmonaco.com, www.ralphlauren.de, www.ralphlauren.fr and www.ralphlauren.co.uk.

“Store” means a store operated under any of the Ralph Lauren brands by Ralph Lauren or any of its affiliates or Partners, which store is located in the EU.

“Worker” means any current, former or prospective employee, temporary worker, intern, contractor or other non-permanent employee of Ralph Lauren or any of its affiliates, who is located in the EU.

Ralph Lauren's Privacy Shield certification, along with additional information about the Privacy Shield, can be found at https://www.privacyshield.gov/. For more information about Consumer Personal Data processing with respect to information obtained through Ralph Lauren's Sites and Stores, please visit the company's privacy notices on the Sites.

Types of Personal Data Ralph Lauren Collects

Ralph Lauren collects Personal Data directly from Consumers through the Sites and in Stores. Ralph Lauren obtains, uses, discloses and otherwise processes Personal Data about its Consumers to (i) process transactions they request, including e-commerce and mobile transactions, (ii) improve its Stores, Sites, quality of service, and Consumers' shopping experience, (iii) send communications about its products, services, campaigns and promotions, (iv) prevent and detect fraud and abuse, (v) process information or claims in connection with incidents at Stores, (vi) enable service providers to perform certain activities on the company's behalf, and (vii) comply with legal obligations, policies and procedures and for internal administrative and analytics purposes.

The types of Consumer Personal Data Ralph Lauren collects includes:

  • Name;
  • age;
  • date of birth
  • gender;
  • demographic information;
  • billing and shipping address;
  • driver's license or ID number;
  • passport number;
  • telephone number;
  • email address;
  • payment card information;
  • checking account information;
  • shopping preferences and purchase history;
  • information obtained by automated means when Consumers visit the Sites, such as through cookies, web beacons, and web server logs (including the IP address of the device the Consumer uses to connect to the Internet, domain name, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on the Sites, dates and times of Site visits and the pages accessed); and
  • any other information Consumers provide or generate on the Sites and in Stores.

Ralph Lauren also may obtain and use Consumer Personal Data in other ways for which the company provides specific notice at the time of collection.

In addition, Ralph Lauren obtains Personal Data, such as contact information and financial account information, of representatives of vendors and other business partners. Ralph Lauren uses this information to manage its relationships with its vendors and business partners, process payments, expenses and reimbursements, and carry out the company's obligations under its contracts with the relevant organizations.

Ralph Lauren’s privacy practices regarding the processing of Consumer Personal Data comply with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

Notice

Ralph Lauren provides information in this Policy and the privacy notices on the Sites about its Consumer Personal Data practices, including the types of Personal Data Ralph Lauren collects, the types of third parties to which Ralph Lauren discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data, and how to contact Ralph Lauren about its practices concerning Personal Data.

Relevant information also may be found in notices pertaining to specific data processing activities.

Choice

Ralph Lauren generally offers Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the Privacy Shield Principles, Ralph Lauren obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact Ralph Lauren as indicated below regarding the company's use or disclosure of their Personal Data. Unless Ralph Lauren offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy.

Ralph Lauren shares Consumer Personal Data with its affiliates and subsidiaries. Ralph Lauren may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. Ralph Lauren also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

Accountability for Onward Transfer of Personal Data

This Policy and the privacy notices on the Sites describe Ralph Lauren's sharing of Consumer Personal Data.

Except as permitted or required by applicable law, Ralph Lauren provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Ralph Lauren requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (iii) notify Ralph Lauren and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.

With respect to transfers of Consumer Personal Data to third-party Processors, Ralph Lauren (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Ralph Lauren's obligations under the Privacy Shield Principles, (v) requires the Processor to notify Ralph Lauren if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Ralph Lauren remains liable under the Privacy Shield Principles if the company's third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Ralph Lauren proves that it is not responsible for the event giving rise to the damage.

Security

Ralph Lauren takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

Data Integrity and Purpose Limitation

Ralph Lauren limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. Ralph Lauren does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes, Ralph Lauren takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Ralph Lauren relies on its Consumers to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact Ralph Lauren as indicated below to request that Ralph Lauren update or correct relevant Personal Data.

Subject to applicable law, Ralph Lauren retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer.

Access

Consumers generally have the right to access their Personal Data. Accordingly, where appropriate, Ralph Lauren provides Consumers with reasonable access to the Personal Data Ralph Lauren maintains about them. Ralph Lauren also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. Ralph Lauren may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer's privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting Ralph Lauren as indicated below.

Recourse, Enforcement and Liability

Ralph Lauren has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Ralph Lauren conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Ralph Lauren makes about its Privacy Shield privacy practices are true and that Ralph Lauren's privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Consumers may file a complaint concerning Ralph Lauren's processing of their Personal Data. Ralph Lauren will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact Ralph Lauren as specified below about complaints regarding Ralph Lauren's Consumer Personal Data practices.

If a Consumer's complaint cannot be resolved through Ralph Lauren's internal processes, Ralph Lauren will cooperate with JAMS pursuant to the JAMS Privacy Shield Program, which is described on the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over Ralph Lauren. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Ralph Lauren's compliance with the Privacy Shield Principles.

How to Contact Ralph Lauren

To contact Ralph Lauren with questions or concerns about this Policy or Ralph Lauren's Consumer Personal Data practices:

Write to:

Ralph Lauren Corporation
Attention: Chief Privacy Officer
625 Madison Avenue
5th Floor
New York, New York 10022

or

Ralph Lauren Europe Sàrl
Attention: General Counsel EMEA
24, Route de la Galaise,
1228 Plan-Les-Ouates
Switzerland

E-mail: DataProtectionOfficer@RalphLauren.com

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