Here are a few general principles to keep in mind as you read through this Policy:
- The Site and our retail salons are owned and operated by Harry Winston Diamond Corporation and its corporate affiliates (referred to collectively in this policy as “we,” “us,” “our” and other similar pronouns).
- California’s Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternatively, businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes unless the customer has opted-in to such information sharing. Accordingly, we will not share your personal information with third parties other than our affiliates for the third party’s own marketing purposes unless you opt-in, for example by checking a consent check box when providing us with your information. We will, however, share your personal information with our affiliates for marketing purposes. To request a list of the affiliates with whom we have shared your personal information for marketing purposes in the last year, write to us at Harry Winston, 718 Fifth Avenue, New York, NY 10019 and include the words “California Shine The Light Request” in the “Regarding” line.
- As our business evolves, this Policy may change, so check back to this page periodically to make sure you understand how your personal information will be treated.
Opt In and Opt Out
You may have the right to opt in to or opt out of certain of our uses of your Personal Information. For example, when you are asked to provide Personal Information on this Site or at our salons, you may have the opportunity to elect to, or not to, receive messages from us by e-mail, text message, phone or postal mail. You may tell us that you do not want to receive our promotional messages by visiting the marketing preferences area of or Web site or by sending us your written request along with your name, address, e-mail and phone number to: email@example.com , Harry Winston, Inc., Privacy Officer, 718 Fifth Avenue, New York, NY 10019, or by calling (212) 315-7900. You can also opt-out of our promotional emails by clicking on the opt-out link within the e-mail you receive. To opt out of our SMS messages, please text STOP to the applicable short code. Please understand that it may take us time to process any opt out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us. Also, to stop receiving promotional messages from third parties who already have your contact information, please contact them directly.
What information is collected on this Site?
“Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information. We collect Personal Information such as your name; employer name; day and month of birth; postal addresses; e-mail addresses; telephone numbers; fax numbers; wireless device addresses (including text message addresses); photograph; gender; credit card and other payment information; purchase, Site browsing and transaction history; job history and application information; and interests, hobbies and demographic information. For example, we collect Personal Information when you make a purchase or inquiry at one of our salons; conduct a transaction on our Site; register on our Site or at a salon; sign up to receive emails from us; request a catalog; request a sales associate to contact you; schedule a visit to our salon; create an account on our Site; create a wish list on our Site; sign up for our newsletters; enter sweepstakes and contests; complete surveys; contribute to a chat room, bulletin board, list serve, blog, wiki or other social forum on the Site; or submit a comment or question to us using a “contact us” or similar feature on the Site.
IRS Form 8300: In addition, when you make a cash payment at one of our stores of over ten thousand dollars ($10,000), you are required to complete IRS Form 8300, which includes your Taxpayer identification number and Identifying document number and information (such as you driver’s license or state or federal ID information), and to allow us to make a copy of your identification document. You will be required to complete and sign this form in print, and we will submit it along with a copy of your identification documentation to the IRS and maintain a copy of them in a physically secure location in accordance with or records retention policy until we shred it upon disposal. Only Harry Winston personnel with a legitimate business need will have access to completed IRS Forms 8300.
Anti-money laundering: Under certain circumstances, when you make a purchase the circumstances of which meet certain criteria maintained by Harry Winston, you will be required to provide documentation of your identity, such as a driver’s license, state ID card or passport. We will make a copy of this document and maintain it in a physically secure location in accordance with our records retention policy.
Purchases on Credit Terms: For certain transactions involving the extension of credit, you will be required to provide documentation of your identity, such as a driver’s license, state ID card or passport. We will make a copy of this document and maintain it in a physically secure location in accordance with our records retention policy.
Tax or VAT Exempt Purchases: When you make a cash exempt purchase, you will be required to provide documentation of your identity, such as a driver’s license, state ID card or passport. We will make a copy of this document and maintain it in a physically secure location in accordance with our records retention policy.
Site Usage Information
As is the case with many Web sites, our servers automatically collect your IP address when you visit our Site, and we may associate that with your domain name or that of your Internet access provider. We may also capture certain “clickstream data” pertaining to your Site usage. Clickstream data includes, for example, information about your computer or device, Web browser and operating system and their settings, the referring page that linked you to the Site, the pages, content or ads you see or click on during your visit and when and for how long you do so, items you download, the next Web site you visit when you leave the Site, and any search terms you have entered on the Site or a referral site.
In addition, we may deploy various tracking technologies on the Site to collect additional information about your Site visits. For example:
- Local shared objects, such as “Flash cookies,” may be stored on your computer or device using a media player or other software installed on your computer or device. Local shared objects operate a lot like cookies, but cannot be managed in the same way. Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings. For information on managing Flash cookies, for example, click here.
- HTML5 (the language some Web sites are coded in) may be used to store information on your computer or device about your Site usage activities. This information can be retrieved by us to determine how our Site is being used by our visitors, how it can be improved, and to customize it for our users.
- A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one- pixel – that can be placed on a Web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our Web pages.
These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number to you, and relate your Site Usage Information to other information about you, including your Personal Information.
How is your information used?
We or our service providers may use the information we collect from and about you to perform the following business functions:
- processing and fulfilling your transactions
- enabling users to use our Site and its features
- administering the Site and your account with us
- responding to your requests, questions, and concerns
- market research
- developing new features and offerings
- consistent with any communications preferences you have conveyed to us, sending you marketing and other communications, including information about products, services, and events, of ours and of others, that we think might interest you. (You may opt out of receiving such notices from us by following the instructions in the Right to Opt In and Opt Out section above.)
- protecting our rights and property
- recovering debt and preventing fraud
- customizing our Site to your interests and history with us
- tailoring ads displayed to you on our Site and elsewhere to your interests and history with us
- other purposes disclosed when personal information is submitted to us
To perform the above functions, we may match information collected from you through different means or at different times, including both Personal Information and Site Usage Information, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Site, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.
Do we share Personal Information and Site Usage Information with others?
Yes. We may share the information we collect on the Site and in our salons with others for a variety of reasons. In addition to the kinds of information sharing you might expect, such as sharing with third parties who need your information in order to provide services to us (or on our behalf and subject to confidentiality commitments) and sharing what you voluntarily post to public areas on the Site with other Site users, we may share your information:
- with our affiliates
- with unaffiliated third parties for their marketing and other purposes, if you have opted-in to this sharing
- with our co-sponsor(s) if we obtain your information in connection with a contest, sweepstakes, offering, or other promotional activity that is jointly offered by us and any third parties, unless you instruct us not to by following the instructions in the Opt-in and Opt-out section above
- when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, authenticate transactions and the identity of individuals making purchases, investigate or prevent fraud or illegal activity, respond to a government, law enforcement, judicial or other legal request, or to comply with the law.
- with credit bureaus, such as late payments, missed payments, or other defaults on your account
- in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business
In addition, we may share non-personally identifiable Site Usage Information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.
Text Message Service
Your Access Rights
You may review, update or modify certain of the Personal Information that is stored in your user account on the Site (if you have one) by logging in to the “My Account” or similar area of the Site or by contacting us using the “Contact US” information below. We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. Your right to delete your information is subject to our records retention policies.
While we endeavor to protect the security and integrity of sensitive Personal Information collected via this Site, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. If you correspond with us by e-mail, text message, or using Web forms like a “contact us” feature on our Site, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If you create an account on our Site, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security. If we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at firstname.lastname@example.org.
“Linked-To” Web Sites
The Site may contain links, banners, widgets or advertisements that lead to other Web sites. We are not responsible for these other sites, and so their posted privacy policies (not this Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of each Web site visited after leaving the Site to learn about how your information is treated by others.
We may change this Policy from time to time. When we do, we will let you know by posting the changed Policy on this page with a new “Last Updated” date. In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you. In some cases, we may request your consent to the changes.
If you have any questions or comments regarding our privacy practices, you may contact us at:
1330 Avenue of the Americas
New York, NY 10019
We also can be reached by e-mail at email@example.com.