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(U.S. - California, Colorado, Connecticut, Nevada, Virginia, Utah)
Effective Date: July 1, 2023
Last Reviewed: June 20, 2023
On January 1, 2023, the California Privacy Rights Act (CPRA), which modified the California Consumer Privacy Act (CCPA), came into effect. Data privacy laws also have been passed in other U.S. states, including Colorado, Connecticut, Indiana, Montana, Nevada, Tennessee, Texas, Utah, and Virginia (the “other covered states”). These laws are similar, but not identical, in their requirements.
CATEGORIES OF PERSONAL INFORMATION
We have set out below in table format a list of the types of personal information we may collect and the business or commercial purposes for which it may be collected. Note that some types of personal information overlap categories, and we may use the same personal information for more than one purpose.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Physical location or movements.
Audio, electronic, visual, thermal, olfactory, or similar information.
Inferences drawn from other personal information
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Professional or employment-related data
Current or past job history or performance evaluations.
RETENTION OF PERSONAL INFORMATION
We retain personal information for as long as we believe it is needed to fulfill the purpose(s) we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In general, we will retain consumer personal information for as long as we engage with the consumer and, following that period, we will retain the personal information for as long as is reasonably necessary under the circumstances.
To determine the appropriate retention period for consumer personal information, we may consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the administrative burden to delete the personal information, the purposes for which we process the personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize personal information for analytical, statistical, or other purposes, in which case we may use or share this information indefinitely without further notice. Similarly, we may use or share aggregated data indefinitely without further notice.
PERSONAL INFORMATION WE HAVE COLLECTED
Within the last twelve (12) months, Movado Group has collected from direct interactions, automated technologies or interactions, community features, third parties, publicly available sources, and other persons the following categories of personal information about California residents: Identifiers; personal information categories listed in the California Customer Records statute, Cal. Civ. Code § 1798.80(e); protected classification characteristics under California or federal law; commercial information; biometric information; internet or other similar network activity; geolocation data; sensory data; inferences drawn from other personal information; and professional or employment-related data.
PERSONAL INFORMATION WE HAVE SHARED
We do not sell your personal information in exchange for monetary compensation. Moreover, few of the third parties with whom we share personal information are permitted to use that personal information for any purpose other than to provide services for us.
In those instances where a third party is permitted to use information for their own commercial purpose, we may be relying on a consumer’s intentional direction to share their personal information with that third party. We do not believe this is a “sale” under applicable U.S. law. For example, a consumer may wish to finance a purchase through a service like Affirm or Klarna. To do so, the consumer must select that offering, choose to engage with the third party, and share their Identity, Contact, Payment, Transaction or other information to enable the financing. To the extent Movado Group facilitates such information sharing, we rely on the consumer’s choice to engage with that third party. Consumers should always keep in mind that the third party’s terms and conditions and privacy policies and practices will apply to that third party’s services and offerings, and we urge you to make sure you understand them before you proceed.
In the preceding twelve (12) months, Movado Group has sold or shared the following categories of consumer personal information for business or commercial purposes, which may include cross-context behavioral advertising: Identifiers; personal information categories listed in the California Customer Records statute, Cal. Civ. Code § 1798.80(e); protected classification characteristics under California or federal law; commercial information; biometric information; internet or other similar network activity; geolocation data; inferences drawn from other personal information.
INTEREST-BASED ADVERTISING; THIRD PARY ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING
When you go to our websites, open our emails, use our apps or “smart” wearable devices, interact with Movado Group-related social media sites or tools, widgets, or plug-ins, or when you visit one of our physical stores (all digital and physical sources, our “Sites”), we may collect and store information about you, your online activities, or your geolocation information for use in providing you with advertising about products and services that is tailored to your individual interests. When using our Sites, you also may be presented with an opportunity to receive information and/or marketing offers from our curated third parties or in connection with referral programs. If you agree to such uses, including to receive such communications, your personal information will be disclosed to that third party or those third parties.
Movado Group also works with certain third parties (including network advertisers, ad agencies, and data analytics companies) to provide us with information regarding traffic on our Sites, to serve advertisements both on our Sites and elsewhere online, and to provide us with information regarding the use of the Sites and the effectiveness of our advertisements. Through these sources, we can target our messaging to users through demographic, interest-based, and contextual means. We can also track your online activities over time and use this information to show you advertisements that may be tailored to your individual interests. In addition, we can collect data about your visits to other websites that serve Movado Group advertisements, such as the pages or advertisements you view, where you viewed them, and whether you clicked through. This process helps us track the effectiveness of our marketing efforts.
THE RIGHT TO OPT-OUT
As prescribed in the applicable state law, residents and consumers in California and certain other covered states have the right to opt-out of the sale or sharing of their personal information for cross-context behavioral (targeted) advertising or for other purposes. You have the right to opt-out of our sale of your personal information. To inform us of your desire to exercise this right, you may click here;. This link will take you to the same webform that is available through the “Do Not Sell or Share My Personal Information” link enabled on our websites. Requests to opt-out of the sale or sharing of personal information also may be made by mail or by calling our Customer Service team at 1-800-810-2311. We aim to process all opt-out requests promptly and within the time permitted under applicable law and will notify you when the process has been completed.
Please understand that, even if you exercise this right to opt-out, we will still share your information in other ways, such as with our service providers for our own business purposes, including for our own online advertising. Accordingly, opting-out of the sale or sharing of your information for cross-context behavioral advertising does not necessarily mean that you will stop seeing ads for our own products and services, including interest-based ads.
Moreover, as explained in the Do Not Sell or Share My Personal Information tool, submitting the webform will not block the sale of personal information that may occur through cookies or other automated means placed on our Sites. If you wish to prevent such sales or sharing, please click here. This link will take you to the Manage My Cookies tool, where you may choose to block certain types of cookies, including cookies that enable targeted advertising. Please remember that you may need to repeat this step on each separate device you use to access our Sites and for each individual Site you visit. Blocking these cookies may not prevent our own ads, including ads served to you based upon your prior browsing history, from appearing.
In addition to these means of blocking the sale or sharing of personal information for cross-context behavioral advertising, our Sites will also detect and apply the signal from GlobalPrivacyControl.org (“Global Privacy Control”).
If you submit an opt-out request via webform, mail, or call to our customer service team, but choose not to change your cookies settings or enable the Global Privacy Control, then we will treat this as your direction to stop the sharing of personal information with third parties for marketing purposes that is not conducted through cookies while allowing us to continue to sell or share for cross-context behavioral advertising any information (including personal information) collected through Site cookies.
Anyone who has opted-out may request to opt back in at any time by using the Manage My Cookies tool, by calling our Customer Service team at 1-800-810-2311, or by re-joining our marketing list.
OTHER RIGHTS AND CHOICES
The CPRA and other state laws provide certain rights regarding personal information. This section describes those rights and explains how people protected by those laws may exercise them.
The Right to Know and Portability
Residents of California and certain other covered states have the right to ask us to disclose to them information about our collection and use of their personal information, which may include asking us to provide the information to them in a portable format. Our response may be limited to a certain time period (for example, the past 12 months) or for other legally acceptable reasons. California requests may seek information about:
We will provide the applicable information after receiving and confirming a verifiable consumer request.
The Right to Delete
Subject to certain exceptions, residents of California and consumers in certain other covered states have the right to request that Movado Group delete personal information that we collected and have retained about them. Once we receive and confirm a verifiable request, we will delete (and direct our service providers to delete) such personal information from our records, unless an exception applies.
We may deny a deletion request if retaining the information is necessary for us to
The Right to Correct
Residents of California and consumers in certain other covered states have the right to ask us to correct any personal information we have in our files. We encourage everyone who interacts with us, regardless of location, to keep their information up-to-date.
The Right to Limit Use
Residents of California have the right to ask us to limit the use of any sensitive information, as defined under the CPRA, about them.
How to Exercise These Rights
Covered people and their authorized agents may submit a request to know or request to delete by:
In California, only the data subject, or a person registered with the California Secretary of State authorized to act on a data subject’s behalf, may make a verifiable consumer request. In other covered states, we will honor a request by the data subject or by a verified agent of the data subject. Covered people also may make a verifiable consumer request on behalf of their minor child. Frequency of requests may be restricted. The verifiable consumer request must:
The webform includes the minimum information we believe is necessary to understand, evaluate, and respond to a request. If you choose to submit a request by mail or telephone call, we will ask you to provide the same information. In order to properly verify, track, and process requests, we ask you to please use one of these three methods. We do not accept emails.
We cannot respond to a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.
Response Timing and Format
We endeavor to respond to requests within forty-five (45) days[DK1] of verification or such shorter time as required by applicable law. If we require more time and more time is permitted under applicable law, we will inform you of the reason and extension period in writing.
We will deliver our written response electronically, unless you instruct us to deliver it by mail.
Any disclosures we provide will cover the 12-month period preceding our receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know particular information and that necessitate a voluminous response, we will select a format to provide your personal information that is readily useable.
We generally do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
How to Appeal
If we refuse to take action in response to a permissible data subject request, you may appeal our decision by writing to us at the address stated below. Your appeal must be received within 30 days of our decision and must be accompanied by a reasonably detailed explanation of the reason(s) you believe our decision to be unsupported by applicable law. We will respond to the appeal within 60 days of its receipt, and our response will include a written explanation of the reason(s) for our decision. If your appeal is denied, you may contact your state’s attorney general or, in California, the California Privacy Protection Agency.
Statistics on Consumer Privacy Requests
Movado Group receives requests to exercise data privacy rights from people around the globe. The following data* is provided about requests Movado Group received during calendar year 2022.
Number of Processed Requests
Number of Rejected Requests**
Average No. Days to Respond to Requests***
Requests to Delete:
Do Not Sell Requests:
*Data is provided for all individuals globally. This data does not include requests submitted in an undesignated manner, requests initiated by clicking the “unsubscribe” link in marketing communications, or consumers who changed their settings to block targeted cookies.
** Requests were rejected as either unverified or repetitive.
*** Non-rejected requests only.
****As of January 17, 2023, six requests submitted in December, 2022 were still in progress.
Non-Discrimination & Financial Incentives
Some laws, including the CPRA, CDPA, and VCDPA, prohibit businesses from discriminating against a covered people for exercising their rights under the law. Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices. However, businesses are permitted to provide differing levels or quality or different prices where the difference is reasonably related to the value of the consumer’s personal information to the business.
We may offer certain programs or financial incentives that can result in different prices, rates, or quality levels, provided that such programs or incentives are reasonably related to the value of your personal information to us. For example, we may offer a coupon to consumers who sign up for our mailing list, or we may offer a loyalty program that provides consumers with certain benefits associated with repeat purchases. In such instances, we have determined that the amount of the coupon or the benefits provided is reasonably related to the value we receive from the consumer’s participation in the program or incentive.
When Movado Group offers these programs or incentives, your participation is optional. If you choose to participate, your participation will be subject to any applicable terms, and you may withdraw at any time.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of our Websites who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make this request, California residents may contact us by mail or email (privacy@movadogroup). Please do not use this email address for other purposes, including exercising the other rights summarized above. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing list. You also must include sufficient detail that allows us to properly understand, evaluate, and respond to your request. We are not responsible for notices that are not labelled or sent properly or do not have complete information.
OUR MAILING ADDRESS
Movado Group, Inc.
650 From Road
Paramus, NJ 07652
Attn: Legal Department
[DK1]CA, CT, CO, VA, UT all provide for 45 days for non-sale requests
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