Date: 6th April 2020
This website is owned and run by THE NET‑A‑PORTER GROUP LIMITED ("we", "our", "us"), part of YOOX NET‑A‑PORTER GROUP. If we use the term "our Group", this means us and our subsidiaries, our ultimate holding company and its subsidiaries (or any of them). The term "our online services" refers to NET‑A‑PORTER, MR PORTER, THE OUTNET, our mobile and tablet applications, our pages on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Google+ and any other websites or apps we own or run from time to time. The term "our services" refers to our online services and any of our other products and services, such as PORTER magazine, offered from time to time. If you use any of our services, we will refer to you using the terms "user", "visitor", "you", "your", "yours" in this policy.
1. What personal data do we collect from you and how?
We collect and process only the data that is required to allow us to provide our services to you. We collect the following data when you browse or shop at www.net-a-porter.com:
- We process the personal data required to complete and despatch your purchase, including your name, billing address, delivery address, payment details, mobile number, telephone number and email address. We collect your email address in order to send you confirmation of your order; we collect your telephone number so that we can contact you if there are any issues with the order.
- We collect your email address when you sign up to receive NET‑A‑PORTER News.
- If you register for a NET‑A‑PORTER account, we collect your name, email address, password, country and additional data regarding your favourite designers and your marketing preferences.
- When you contact our Customer Care team, we may collect additional data to help us resolve any queries relating to your order, delivery, payments, marketing, the website or any other queries.
- We collect and process data about your browsing on www.net-a-porter.com, including the pages you visit and how you interact with these pages. If you have registered for an account, we collect browsing data about your access to the dedicated areas of the website.
- If you are a customer of www.net-a-porter.com, or if you have given us your consent, we collect and process your personal data for direct marketing activities.
- If you provide us with someone else's data - for example, if you purchase a product to be delivered to a friend or as a gift - we will collect and process the personal data required to complete the transaction such as the name, delivery address and other contact details for your friend. If you are receiving an item as a gift, we will process your data only to fulfil the gift request and our contractual obligations.
- When you use the App version of our website, we will ask for your consent to collect personal data from you in order to send you brief messages, "push notifications" about products and services that we believe may be of interest to you. With your consent, we will also collect data regarding your use of the App and your IP address, in order to improve our service to you. You can disable push notification at any time by updating the App settings in your mobile device.
- If you subscribe to PORTER magazine, we will collect and process the personal data required to complete and despatch your purchase, including your name, billing address, delivery address, payment details, telephone number and email address. We collect your email address in order to send you confirmation of your order; we collect your telephone number so that we can contact you if there are any issues with the subscription. You have the option to provide us with your birth day and month and to subscribe to our marketing communications and those from our partners.
- When you call our Customer Care team, your call will be recorded for training and fraud prevention purposes.
2. What about cookies? What are cookies?
3. How this information may be used
Whenever you give us your personal information we will use it in accordance with applicable privacy laws and for the purposes set out in this policy, on the data entry forms you complete, in any relevant terms and conditions and on pages or emails which link to the data entry forms.
**When you use our services: **If you use any of our services, register for or attend one of our events, set up, look at or change your account details or contact a member of our Customer Care team, we will record your personal details. Your information will be used in the first place to provide the products, services or information you have asked for and to provide you with a personalized shopping experience. We keep the information you provide and may use it for several purposes, including: (i) accounting, billing, reporting and audit; (ii) credit checking or screening; (iii) authentication and identity checks; (iv) credit, debit or other payment card verification and screening; (v) debt collection; (vi) safety, security, health, training, administrative and legal purposes; (vii) data matching and dedupe, statistical and market analysis, and marketing information; (viii) advertising and marketing for us, our Group and third parties; (ix) developing, testing and maintaining systems; (x) studies, research and development; (xi) customer surveys; (xii) customer care and to help us in any future dealings with you, for example by identifying your requirements and preferences; (xiii) where required by law or in connection with legal proceeding or disputes; and (iv) any other uses set out in the terms and conditions for use of our services. For these purposes we may disclose your information to one or more of the other organisations listed in the section called “who we will share your personal information with”.
Saved payment card details will only be shared with our payment partner and not with any other third parties and will only be used to process your order, using our payment partner's systems.
We may also use your personal information to send you marketing updates, as detailed in the next section.
**Testimonials: **If you give us feedback, we may use it to improve our services and we may publish it online or offline to promote our business and our services. We will ask for your permission before we publish it.
**Comments and reviews submitted to our online services: **If you wish to submit a comment or feedback on a blog or article featured on our services, we may (but are not obliged to) publish your comment online or offline to promote our business and our services. We will collect your name or username which will be displayed next to your comment and e-mail address, which will not be published, but which we may use to contact you in relation to your comment.
**Mobile services: **When you request our mobile services, we may keep your mobile phone number, the make and model of your phone, the operating system used by your phone and details of your network operator, and we will link a unique identifier to your mobile phone number. We’ll store your device language, app language, country, We need this information in order to provide the features and services enabled through our mobile services and to administer our mobile service.
**Direct marketing: **For information on how we may market to you, please read the section called “marketing opt-in and opt-out provisions”.
4. Who we will share your personal information with
5. Where we process your personal information
When we use your information as described in this policy, this may involve sending your information outside the European Economic Area (EEA). When we do this, we make sure that appropriate steps are taken to protect your personal information and your rights. By providing us with your personal information, you agree that we may transfer, store and process your information outside the EEA. Governments in certain countries such as the USA have broad powers to access data for security, crime prevention and detection and law enforcement purposes.
6. Marketing opt-in and opt-out provision
We offer you the chance to receive news and fashion updates which, depending on your preferences, we will discuss with you by phone or live chat or send to you via email, SMS and/or direct mail. These include alerts for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions. You can opt-out of receiving these updates, if you wish.
We, or our third party business partners, may also ask you if you want to receive marketing if you enter a promotion or attend an event thrown or sponsored by us. Other companies in our Group may also pass your personal information to us for marketing use.
Marketing communications you subscribe to will only be sent by our Group.
You have the right to ask us not to use your personal information for marketing. At all times, we will offer you the opportunity to unsubscribe from any service or update to which you have subscribed, if you change your mind. Whenever you receive direct marketing from us, we will tell you how to unsubscribe. Alternatively you can change your marketing preferences by signing into My Account. To opt out of direct mail, please contact our Customer Care team on +1 877 678 9627 or by email at firstname.lastname@example.org
If you tell us that you do not want to receive direct marketing, we will still contact you in order to provide you with products and services you request and for administration purposes.
7. How you can access your personal information and keep it up to date
You have the right to see information we hold about you, with some exceptions which are described in the privacy laws. If you would like a copy of your personal information, please contact us at email@example.com.
You have the right to review and update your personal details. If for any reason you are concerned that the personal information we hold is not correct, please visit our online services and, after logging into the site using the "Sign In" menu on the home page, your personal information will be made available for review and change in the "My Account" section. Only you or, upon your request, our Customer Care team, may access your personal data from our online services using your user ID and password. Information may be changed online within “My Details”, “Shipping Details” and “My Email Preferences”. You can change or delete saved credit/debit card details each time you make a purchase. You will also be able to delete saved credit/debit card details by adding or editing a shipping/billing address. If you change your billing or shipping address while your order is still being processed, the order will be re-processed through security validation checks. If you prefer, you may contact us by email at firstname.lastname@example.org and we will amend your personal details.
Our Live Chat provider stores all chat conversations for 13 months. To receive a copy of your chat conversation simply request this when exiting Live Chat or contact our Customer Care team by emailing email@example.com for NET‑A‑PORTER chats, firstname.lastname@example.org for MR PORTER chats and email@example.com for THE OUTNET chats.
8. Safeguarding your personal information
We will take reasonable care to maintain appropriate safeguards to ensure the security, integrity and privacy of the information you have provided to us. We have put in place technology and security policies which are designed to protect the personal information we hold about you. We also follow the security procedures that applicable privacy laws require. These cover storing, using and releasing any information you have provided and, as well as measures designed to prevent unauthorised access or use. When you place an order or access your account information, we use a Secure Socket Layer (SSL) encryption which encrypts your information before it is sent to us to protect it from unauthorised use.
9. Why we link to other websites
11. Where and how to ask questions or contact us about this policy
If you wish to talk to a Customer Care representative, please call us on +1 877 678 9627.
11. California privacy rights
This section applies solely to the Californian consumers’ personal information processing (excluding our employees, applicants, staff and contractors). This section is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018 (the “CCPA”), and uses certain terms having the meaning given in the CCPA.
Your information, sources and purposes: please refer to the sections above explaining what data we collect , how we use the personal data and the cookie collected for a description of the personal information we may collect about you (or have collected in the preceding 12 months) and the sources of such information (such as directly from you and your device or through certain third parties). These also describe the purposes for which we may use or have used such information.
**Selling your information: **we have not sold personal information in exchange for monetary compensation. We may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our platforms in an effort to serve you content and advertisements that may be of interest to you. You have the right to opt out of this disclosure of your information, as described in the cookie section.
Your rights: subject to exceptions under applicable law, you may have certain choices regarding our use and disclosure of your personal information, as described below:
- Access: you have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you during the past 12 months and details regarding our collection, use, disclosure of such information.
- Deletion: you have the right to request that we delete the personal information we have collected from you.
- Opt-Out: You have the right to manage the activation of the cookies as described in the cookie section.
To exercise your rights, described above, you can:
- call the toll-free number +1 877 678 9627 excluding public holidays; or
- contact us directly at the e-mail address firstname.lastname@example.org. If you exercise your rights, we may require you to provide certain information to verify your identity (such as your name, email address, phone number and/or address).
No discrimination: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.
Personal, family and household clients: In addition, under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an e-mail message to our e-mail address below with “Request for California Privacy Information” in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide you, by e-mail, a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties’ names and addresses. Please note that not all personal information sharing is covered by Section 1798.83’s requirements.