1. Introduction

For any purchases made anywhere outside of the United States, the terms “Ethra”, “we”, “us”, or “our” means Ethra LLC FZ.

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and we use your data.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

When you are using www.weareethra.com, Ethra LLC FZ is the data controller.

Acceptance of This Privacy Policy

By using our Website (whether or not you register or create any kind of account with us), you accept the terms set forth in this Privacy Policy as well as in our Terms and Conditions, and Refund Policy (the “Agreement”). Anyone that does not agree to the terms of our Privacy Policy, Terms and Conditions, and Refund Policy should not use our Website. The only recourse if you do not agree to the terms of our Privacy Policy, Terms and Conditions, and Refund Policy shall be to discontinue using our Website and visiting our Website. By using our Website, you consent to having your personal data transferred to and processed by us and in the United States and any other country in which our servers may be based.

Consent

By using this Website, you consent to our Privacy Policy, as well as the limitation of liability, arbitration, refund policy and all the other terms and conditions that form the Agreement.

Changes to This Privacy Policy

We reserve the right to revise or amend the terms of our Privacy Policy at any time without prior notice to you and you agree that the revisions or amendments will be effective upon updating on our Website. Continued use of the Website following changes shall mean that you accept those changes.

YOU AGREE THAT WE SHALL NOT BE RESPONSIBLE FOR ANY LOSS CAUSED BY THE USE OF OUR WEBSITE, OR THE USE OF OUR PRODUCTS OR SERVICES OR FOR ANY LOSS CAUSED BY ANY UNAUTHORIZED PERSON OR ENTITY USING THE INFORMATION OR CONTENT YOU DISCLOSE ON OUR WEBSITE.

1. Explaining the legal basis we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.

For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.

Legal complianc

If the law requires us to, we may need to collect and process your data.

For example, we can pass on details of people involved in fraud or other criminal activity affecting Amouage (or its affiliates or subsidiaries) to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we will use your purchase history to send you or make available personalised offers.

We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.

1. How do we collect your data?

You directly provide us with most of the data we collect. We collect data and process data when you:

• Register online or place an order for any of our products.
• Voluntarily complete a customer survey or provide feedback on our Website or any of our social media platforms or via email.
• Use or view our website via your browser’s cookies.
• Data gather software or information that is available for free from the internet.
• Third-party service providers that gather data for sale

1. When do we collect your personal data?

• When you visit our website, and use your account to buy products and services.
• When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
• When you create an account with us.
• When you purchase a product or service by phone but don’t have (or don’t use) an account.
• When you engage with us on social media.
• When you contact us by any means with queries, complaints etc.
• When you ask one of our employees to email you information about a product or service.
• When you choose to complete any surveys we send you.
• When you comment on or review our products and services.
• When you fill in any forms.
• When you’ve given a third party permission to share with us the information they hold about you.

1. What sort of personal data do we collect?

If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we may keep an encrypted record of your login password.

Details of your interactions with us over the phone, in store or online. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, web pages you visit and how and when you contact us.

Shipping address

• Details of your visits to our website, and which site you came from to ours.
• Information gathered by the use of cookies in your web browser.
• Encrypted Payment card information.
• Your comments and product reviews.

To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.

Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

Security – How we store your data

We are committed to ensuring that personal information is secure. All non-financial information provided to us is stored on our secure servers. In order to prevent unauthorized access or disclosure, We have taken all reasonable steps and put in place suitable safeguards to secure the information we collect from you.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received personal information, we will use the necessary procedures and security features to try to prevent unauthorized access. We will take all reasonable steps necessary to ensure that personal information and data is treated securely and in accordance with this Privacy Policy.

1. How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

We then use this to offer you promotions, products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in Section below “What are your rights over your personal data?”

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us. Here’s how we’ll use your personal data and why:

To process any orders that you make by using our websites or in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds etc.

To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to provide information about any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of providing you with the best service and understanding how we can improve our service based on your experience.

To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest. For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.

To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud. If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities.

With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone about relevant products and services including tailored special offers, discounts, promotions, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time.

To send you communications required by law, or which are necessary to information about our products, such as product recall notices and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests. For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having

To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law

Combining your data for personalized direct marketing. We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered from our website as described above, for example your shopping history at our website.

Additionally, from time to time, personal financial information (including credit card information) may be transmitted to facilitate transactions between us and our customers who are placing orders. We will not share such personal financial information with third parties other than those third parties such as banks, processing gateways and merchant processors required to process a customer’s order, and you as a customer understand that we cannot control how the banks, processing gateways or merchant processors will use such personal financial information. Therefore, you hereby consent to such sharing of personal financial information and agree to assume the risk and agree that it is your responsibility to properly handle, secure, not store and destroy such personal financial information as may be necessary to protect it from misuse. We shall not be liable to you or any third party for misuse of such personal financial information.

We may disclose information we collect from you to an affiliate or other third party in the event of any merger, sale, joint venture, assignment, reorganization, liquidation, transfer or other disposition of all or any portion of our business, assets or stock.

We may use third-party advertising companies to serve ads when you visit our Website. These third-party advertising companies may use advertising technologies such as cookies, web beacons and other similar advertising technologies. These companies may use aggregated information about your visits to our Website and third party sites in order to provide advertisements and promotions about products and services we believe you may find of interest.

We may also release your information when We believe release is appropriate to comply with the law, enforce our Website policies and Terms and Conditions, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for data analysis, improving our services, marketing, promotional, advertising, or other uses.

Online eCommerce Platform

We use an online e-commerce platform that allows us to sell products to you. Your information, including personal information, may be transmitted through and stored on third-party servers. By using our Website, you consent to our collection, disclosure, storage, and use of your personal information in accordance with this Privacy Policy and our Terms and Conditions.

Social Media, Posts, Texts, Forums and Profiles

You agree that we may make available through our Website and third party sites or certain forms of media either now existing or to be created in the future (for example, social media, message boards, chat functionality, videos, pictures, images, profile pages, text messaging and blogs) to which you may be able to post content. Please note that any content, text, post or review you provide on these various forms of media may become public, and may be available to visitors to the Website, third party sites, and to the general public, including without limitation the ratings and reviews that accompany pages on our Website and third party sites. We urge you to exercise discretion and good manners when providing content, texts, posts, reviews or deciding to disclose any personal information. YOU AGREE THAT WE SHALL NOT BE RESPONSIBLE FOR ANY USE BY US OR ANY THIRD PARTY SITE OF ANY CONTENT, TEXT, POST OR REVIEW YOU PROVIDE THROUGH OUR WEBSITE OR THIRD PARTY SITES.

Security Not Guaranteed

We use reasonable organizational, technical, and administrative measures to protect your personal information under our control. However, we cannot guarantee 100% percent protection and security of such personal information. Please do not email or text us credit card information and/or other sensitive information.

Children Online Privacy

Anyone under 13 years of age should not access this Website and should not use our Website to purchase our products. Our Website is not intended for children under 13, and we will not knowingly collect any information from any children under the age of 13. If we discover that we have collected any personally-identifying information from a child under the age of 13, we will promptly remove that information from our database.

1. What we don’t do with the information we gather:

We will not disclose, sell, distribute, rent, lease or use any of your data or pass on any such personal information to third parties, which are not our officers, directors, members, managing members, employees, business partners, affiliates, strategic partners, licensors, licensees, independent contractors, third party service providers, agents or representatives, unless we have your permission or are required by law to do so.

We do not store your credit card information. The credit card information and actual processing does not take place on and is not stored on our servers. The transaction is processed on the servers of the particular credit card processor that we use to process the transaction.

1. How do we store your data?

We securely store your data on our cloud servers.

Our Company will keep your personally identifiable information for ten (10) years unless you request we delete it by contacting us at hello@weareethra.com. Once this time period has expired, we will delete your data by erasing it from our systems.

1. How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. We secure access to all transactional areas of our websites and apps using ‘https’ technology. Access to your personal data is password-protected. We regularly monitor our system for possible vulnerabilities and attacks.

1. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected, which will include sending you updated products about our services and specials, however you can unsubscribe at any time.

1. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties. For example, delivery couriers, for fraud management, to handle complaints, to help us personalize our offers to you and so on. Here’s the policy we apply to those organizations to keep your data safe and protect your privacy:

We provide only the information they need to perform their specific services. They may only use your data for the exact purposes we specify in our contract with them. We work closely with them to ensure that your privacy is respected and protected at all times. If we stop using their services, any of your data held by them will either be deleted or rendered anonymous. Examples of the kind of third parties we work with are:

IT companies who support our website and other business systems. Operational companies such as delivery couriers. Direct marketing companies who help us manage our electronic communications with you. Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. Data insight companies to ensure your details are up to date and accurate.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies. We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

1. Use of Cookies

Our Website uses cookies. A cookie is a small file which asks permission to be placed on a computer's hard drive. Once someone has accepted the cookie, the file is added and the cookie helps analyze web traffic and browsing habits, such as what areas of the Website are visited most frequently. At times we may gather information through the use of a cookie file which enables us to gather statistical information regarding the use of our Website. This helps us to improve not only our Website, but the services we can provide to you. We may use analytical software to track user habits and trends.

You do have the choice to decline cookies. Most web browsers automatically accept cookies, but people can usually modify their browser setting to decline cookies if they prefer. Should you choose to decline cookies you may be unable to access certain information or parts of our Website, and some or all of the services may not work properly. Our advertisers and promoters may also use cookies, over which we have no control.

IP Address

An IP (Internet protocol) Address is automatically assigned to the computer that someone is using by their Internet Service Provider (ISP) and is identified and logged automatically in our server log files whenever someone visits our Website. This also allows us to identify the time(s) of visit(s) and the page(s) of the Website that have been visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many Third Party Sites.

Location Information

We may also obtain information about your physical location, such as by use of GPS and other geolocation features in your computer, laptop or mobile device, or from other information we collect. For example, a your IP Address indicates the general geographic region from which you are connecting to the Internet.

1. Where your personal data may be processed

Sometimes we will need to share your personal data with our employees or third parties for marketing and customer relationship management and those employees or third parties may be located anywhere in the world.

Protecting your data

For example, this might be required in order to fulfil your order, process your payment details or provide support services. If we do this, we have procedures in place to ensure your data receives the necessary protection.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

1. What are your rights over your personal data?

An overview of your different rights

1. You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.

1. You have the right to request a copy of any information about you that Ethra holds at any time, and also to have that information corrected if it is inaccurate.

• To ask for your information, please email to hello@weareethra.com
• To ask for your information to be amended, please update your online account, or contact our Customer Services at hello@weareethra.com
• If we choose not to action your request we will explain to you the reasons for our refusal.

1. Your right to withdraw consent

• Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

1. Where we rely on our legitimate interest

• In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

1. Direct marketing

• You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

1. Checking your identity

• To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorized a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

1. How can you stop the use of your personal data for direct marketing?

Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails. Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

1. Any questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you via hello@weareethra.com