Vellir

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1. WHAT IS COVERED BY THIS PRIVACY POLICY AND DO OTHER POLICIES APPLY TO YOU?

This privacy policy covers situations where we, Vellir, access, collect, store process, use, disclose or transfer your personal information in paper or electronic form. It also covers situations where approved partners use your personal information on our behalf.

In some cases, other policies apply to you. It may be the case when you use certain products or services, and in this event:

- You will be notified of these other policies while using the products or services they apply to.

- Such policies will supersede this privacy policy unless they expressly refer to it.

This privacy policy does not cover products or services you might use as provided by other companies acting on their own account.

Our privacy policy does not extend to services provided by other companies acting on their own account, such as licensees or when you share information through social media (WeChat, WhatsApp, Baidu, Kakao Talk, Facebook, Twitter, Instagram, etc.), or other online platforms owned and managed by other companies. These other companies have their own privacy policies in place, so remember that the way they use any personal information you give them will be subject to their rules and not ours.

2. WHO COLLECTS & USES YOUR PERSONAL INFORMATION?

We, Vellir, act as the “data controller”, which means that we determine “why” and “how” your personal information is collected and used. To be able to deliver our products and services to you, we need to share your personal information with approved partners who generally act as our “data processors”. All are bound by an obligation to implement appropriate security measures to protect personal data in their possession, and are bound by a strict confidentiality agreement and specific contractual terms on “how” and “when” they are allowed to use your personal information on our behalf.

Please be aware that certain approved partners, such as our licensees or social media, could also determine “why” and “how” your personal information is used. They have their own privacy and cookies policies, so remember that the personal information you give them will be subject to their rules and not ours.

Your local legislation may not refer to the terms “data controller” or “data processor”, but respectively to terms such as “data user”, “owner”, “business”, “responsible party”, etc., and as “data intermediary”, “operator”, etc. In order to understand our role, please note that we, Vellir, are the entity who decides on the methods and purposes of the processing of your personal information by determining “why” and “how” your personal information is collected and used. Our “data processors” are entities who use your personal information on our behalf by receiving instructions from us on “how” and “when” they are allowed to use it.

3. WHAT PERSONAL INFORMATION DO WE COLLECT?

When you interact with us or our approved partners, you may provide us with the following categories of personal information (that may include sensitive information in accordance with applicable legislation).

A. Identifiers & Vellir profile information

This set of personal information enables us to identify you, manage your Vellir profile, provide you with customer service and assistance and, in some cases, to contact you, including by sending you relevant information and tailored marketing content on the ground of the legal bases set out in this privacy policy.

The list below is provided to give you an overview of the type of information we may collect. However, the collection of this information is not systematic: only the information necessary to fulfill each purpose will be collected and used.

It could include, when your applicable privacy legislation allows us to collect such personal information, your first name, last name, pseudonym, signature, email address, postal address, date of birth, place of birth, login name, phone number, unique personal identifier, customer number, online identifier, social media accounts (and related information collected through social log-in), gender, country of residence, lifestyle/interests, Internet Protocol (IP) address, account name, social security number, state identification card, driver’s license number, passport number, nationality, or other similar identifiers, physical characteristics or description (for example characteristics such as your size where relevant to the products and services we would offer you), and certain personal financial information. We will take steps to minimize information that is collected to what is necessary in relation to the purposes for which it is processed.

In some countries, some personal information could be considered sensitive, special or protected. We will collect and use such information only where no other option is available, and always comply with the applicable privacy legislation to collect, protect and use safely your personal information (in particular, by seeking your consent where required).

If you are an employee of a Kering entity, we may process certain information regarding your employment, and we invite you to refer to the employee privacy policy that has been made available to you.

B. Transaction information & commercial information (including audio)

This set of personal information enables us to provide you with the products and services you have requested, manage your Vellir profile, provide you with relevant customer service and assistance, secure our communications and to manage and better understand our business.

It could include personal information on the products and services you purchase, obtain or consider, their price, size, collection, when the product was bought, if it was returned, product defects, comments you made on the product or the service we have provided to you, purchasing and consumer histories or trends, etc. This could also include personal financial information relating to how you paid for your products or your bank details when you request a refund, or audio recordings (and their transcript) when you contact our customer service. We will take steps to minimize information that is collected to what is necessary in relation to the purposes for which it is processed.

Some personal information will be linked to your Vellir profile when you identify yourself in the stores, through customer services or on our website. In addition, when contacting our customer service, we may record your conversation with prior notice to you.

Under certain applicable privacy legislation, particular transaction and commercial details are considered sensitive. We will collect, store and use such personal information with the highest level of care in accordance with the applicable legislation and with your consent where required.

C. Personal life information and inferences

This set of personal information enables us to always offer you the optimum service by understanding you better. We use it to manage your Vellir profile, provide you with relevant customer service and assistance and also, in certain circumstances, to contact you for example by sending you relevant information, updates and tailored marketing content.

It could include your preferences regarding fashion events, how you have used certain products, food allergies when you explicitly choose to share this information with us, personal information regarding your family (if you have obtained their consent to share such information with us, where this is required by applicable law), your life habits, how you use our website or third-party websites such as social media, your answers to our surveys or any other personal information we may collect when it is directly or indirectly linked to you. We may draw inferences from any of the information identified above to create a profile about you, reflecting your preferences, characteristics, trends, predispositions, aptitudes and attitudes.

Under certain applicable privacy legislation, some personal life information is considered sensitive. In this context, we will collect, store and use such personal information only where no other option is available and with the highest level of care in compliance with the applicable privacy legislation (including with your consent where required).

D. User-generated content

This set of personal information enables you to provide us with personal information relating to you or to third parties. In certain circumstances it enables us to contact you.

It could include pictures of you or other individuals, or any other type of content such as texts, feedbacks, opinions, personal information regarding other individuals you may provide us with (for example when participating in a contest or sharing personal information with our sales associates or through social media), “tagging” or “liking” our social media page or any content published by us, or any personal information you may provide in the public domain. You may remove such content at any time if you no longer want us to use it.

You shall avoid sharing third-party personal information through such means or you should ensure that they have given prior authorisation to such sharing.

E. Technical, electronic & localisation information

This set of personal information enables better delivery of the service you expect from us.

It could include personal information related to your interactions with us and allows us to manage your Vellir profile, provide relevant customer service and tailored marketing content, establish communications and conduct our business securely, assess and better understand our business, and optimize and manage our website and other means of communication.

This could happen in a store (e.g. when a purchase is made in a specific store and then linked to a Vellir profile), or when contacting our customer services (why do you contact us? what means have you used?) or when using our website (do you use tablets, phones, computers? what use are you making of our website?).

Some personal information will be shared with us automatically from the device or the service provider you are using (e.g. social media). We can collect personal information shared by your device such as your IP address, device type, unique device identification numbers (device identifier), browser type, time zone settings, broad geographic location (e.g. country or city-level location); online activity (such as your internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements) and other technical personal information or personal information shared by the service provider. Such service providers have their own privacy and cookies policies, so remember that the personal information you give them will be subject to their rules and not ours.

In addition, we may be able to collect personal information on how you have interacted with us, including certain personal navigation information (including the pages accessed and links clicked, bugs and errors, browsing patterns) and your preferences (such as your language preference).

Some of this personal information may be collected using cookies or other online advertising technologies.

F. Additional information for California residents

o Characteristics of classes protected under federal or California law

We will always try to avoid collecting and using the information in the list below. However, this may occur in cases where no other option is available. In this event, we will take steps to minimize the data collected, use the highest level of care and always comply with the applicable privacy legislation (in particular, by seeking for your consent where required).

It could include familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, age, or genetic information.

o Categories of information collected over the past 12 months.

Please note that the categories mentioned in this section What personal information do we collect? also represent the categories of personal information that we have collected over the past 12 months.

4. WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?

When you interact with us, either online or in person, you may share with us your personal information when:

A. You buy a product or subscribe to a service;

B. You create a Vellir profile, join our loyalty scheme, participate in a contest, join a reward program or link your social media account to your Vellir profile;

C. You subscribe to our newsletter;

D. You interact with us or seek advice and share personal information through our websites, our social media pages, our sales associates in a store, at a trade show, at events or through our customer services;

E. You use your device to browse activity across different websites:

F. A personal shopper, or any other agent acting on your behalf interacts with us in particular to buy a product or subscribe to a service for you;

G. Your information is shared with us by our approved partners, with your prior consent where required.

5. DO WE SELL YOUR PERSONAL INFORMATION?

We do not sell your personal information.

6. CALIFORNIA

California Consumer Privacy Notice and Rights

Under the California Consumer Privacy Act (“CCPA”), California consumers have the right to request:

• The deletion of the Personal Information (as defined in the CCPA) we have about them

• Additional information about whether and how we have collected, used, disclosed and sold Personal Information about them

• The specific pieces of Personal Information we have about them

• The opt-out of the “sale” of Personal Information.

California consumers also have the right not to receive discriminatory treatment if they exercise the rights list above.

When you make a request, we may require that you provide information and follow procedures so that we may verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your identity, we will begin to process it. If we cannot verify your identity, we may ask you for additional information to help us verify your request. If we still cannot verify your identity, we will notify you with further explanation.

We will respond to your request within the 45-day time period required by applicable law. However, we may not always be able to fully comply with your request, and we will notify you in that event.

To make requests, California consumers may email us at Privacy@vellirapparel.com, or contact us through our web form. Consumers will be required to submit their name, email address, and request-related information. We may also ask you to confirm information from your order history, account settings, or government identification so that we may verify the request. Please provide as much of the requested information as possible to help us verify your identity. We will use information received in a request only for the purposes of responding to your request.

The CCPA permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a signed document addressing this topic or a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. If the authorized agent is an entity, it must be registered with the California Secretary of State. An authorized agency must follow the process described above to make a request, and we will additionally require you and your authorized agent to verify his/her own identity. Additionally, we may confirm the agent’s authority with the California consumer about whom the request was made.

We do not sell (as “sell” is traditionally understood) Personal Information. That means, we do not provide your name, email address or other Personal Information to third parties in exchange for money. But under California law, sharing Personal Information for certain marketing and advertising purposes may be considered a “sale.” In the last 12 months, we have shared Identifiers and Commercial Information with providers of advertising insights to help us tailor and target our marketing and advertising efforts in a manner that may be considered a “sale.” We do not knowingly “sell” Personal Information of individuals under the age of 16.

California consumers have the right to opt out of this “selling” of Personal Information, and they can do that by emailing us at privacy@vellirapparel.com, or contacting us through our web form. Opting-out of “sales” will not stop marketing and advertising, but it may be less tailored and useful for you. Even after you opt-out, we will continue to share Personal Information with our service providers.

Under California Civil Code §1798.83, if you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes during the preceding calendar year. To request a notice, please submit your request to privacy@vellirapparel.com. Please allow 30 days for a response. The following statement is made pursuant to The California Transparency in Supply Chains Act of 2010 (SB 657)

Vellir currently only sources its products domestically from third party vendors. These vendors must abide by current state and federal law in the United States. We currently assess each of our vendors on a monthly basis to make sure they are keeping up with the highest of ethics codes as it pertains to operating a responsible supply chain. We remain committed to responsible procurement.

California Privacy Rights - California Minors

As stated in our Privacy Policy, our websites, mobile/tablet sites, web pages, social media presence, marketing campaigns, applications, our stores and other Vellir controlled digital properties that link to this Policy (collectively, our “Platforms”) are “general audience” websites and not directed toward children. Certain areas of our Platforms may contain interactive features that allow registered users to post content or information (the “Interactive Services”). If any of our Interactive Services are either: (1) directed toward California residents under the age of eighteen (18); or (2) if Vellir has actual knowledge that a registered user of the Interactive Services is a California resident under the age of eighteen (18), Vellir will permit such registered user to remove (if applicable) or request that Vellir remove or anonymize such content or information as posted by the registered user, to the extent required by California Business and Professions Code § 22581. If you are under the age of eighteen (18) and would like to request the removal or anonymization of content or information you have posted on or to our Interactive Services, please send your request to privacy@vellirapparel.com.

7. HOW CAN YOU CONTACT US?

If you have any questions regarding our privacy practices or how we handle your information, please contact our privacy team and Data Protection Officer by sending an email to privacy@vellirapparel.com.

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