Effective Date: May 26, 2014
We at WWRD US LLC ("WWRD US") are committed to protecting the privacy of customers and visitors who use our web sites. We have therefore created this policy statement (the "Policy") to explain the privacy practices and procedures pertaining to any online service location (e.g., web site or mobile app) that posts a link to this Policy (each a "WWRD US Web Site") (including, without limitation, both mobile and online versions), and also applies to your use of interactive features, widgets, plug-ins, applications, content, downloads and/or other services that we own and control and make available through a WWRD US Web Site and/or that posts a link to this Policy, including, but not limited to, the U.S. versions of Waterford.com, Wedgwood.com, RoyalDoulton.com and RoyalAlbert.com. To the extent we provide you notice on the WWRD US Web Sites of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
We believe that you should know what information we collect from you, as well as understand how we use, disclose, and protect that information. We believe that you should be able to communicate with us easily to limit the disclosure of any of your personally identifiable information, where practicable, and to address any questions or concerns that you may have. Except as provided in this Policy, we will not disclose personally identifiable information (as defined below) to unaffiliated third parties without your consent.
As further set forth below, WWRD US will revise and update this Policy as WWRD US changes its practices or adds new products or services or changes existing ones. You should refer back to this page for the latest information.
This Policy applies to WWRD US Web Sites, which are intended for the use of persons residing in the United States (including its territories and possessions), and for delivery of products and services within the United States. If you reside outside of the United States, or are seeking delivery of products or services outside of the United States, please visit the Global Websites section of our About Us page. If you are located outside of the United States, please be aware that information we collect, including personal information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the WWRD US Web Sites or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including personal information, in the United States as set forth in this Policy.
By using the WWRD US Web Sites, you are agreeing to the terms and conditions set forth in this Policy. For other terms and conditions that govern your use of this Site, please review our Terms and Conditions of Use.
INFORMATION WE COLLECT
We collect a variety of personally identifiable information about users of our products and services in order to ensure an enjoyable and seamless on-line shopping experience. When we use the term "personally identifiable information," we mean information that is directly associated with, or could be used to identify, a specific person. Such information includes a name, address, telephone number, e-mail address, or information about activities directly linked to that person which would permit the physical or online contacting of that person.
Our definition of personally identifiable information does not include "aggregate information" - this is data we collect about a group or category of products, services, or customers and from which individual customer identities have been removed. Aggregate data-for example, a report that indicates that a certain number of our customers reside in a particular state or region of the United States, or a report on how many of our customers visited particular pages of one of the WWRD US Web Sites-aids us in understanding trends and customer needs so that we can better consider new products and services or tailor existing products and services to customer preferences. WWRD US may purchase aggregate data from unaffiliated third parties, or sell it to, or share it with, unaffiliated third parties.
Our definition of personally identifiable information also does not include your Internet protocol ("IP") address, unless you have registered with us in the "My Account" section of our site, in which case your IP address is linked to your personally identifiable information.
We collect the following types of personally identifiable information through the WWRD US Web Sites:
Information You Give Us: We collect information you give us-such as your name, billing address, shipping address, telephone number, email address, and/or credit card number-when you purchase a product, use a service, participate in a promotion, or register with us in the "My Account" section on the WWRD US Web Sites. In some cases, such as gift purchases, we may collect information about someone other than you, including that person's name, shipping or mailing address, telephone number, and e-mail address. Please be aware that when you use any send-to-a-friend functionality on the WWRD US Web Sites or otherwise request us to ship to a third party, your contact information, name or user name and message may be included in the communication sent to your addressee(s). Some of these tools may be third-party tools subject to third-party privacy policies.
Information We Collect Automatically: We automatically collect certain types of information whenever you interact with us. For example, when you visit a WWRD US Web Site, our systems automatically provide us with your IP address and tell us what type of web browser you use. This information may be linked to personally identifiable information if you have registered with us in the "My Account" section of a WWRD US Web Site. Unless linked with personally identifiable information, this usage information is not subject to the terms of this Policy.
Tracking Technologies. We may use various methods and technologies to store or collect usage information ("Tracking Technologies"). Tracking Technologies may set, change, alter or modify settings or configurations on your device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a device when it is used to visit the WWRD US Web Sites. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included in the WWRD US Web Sites’ pages and messages.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the WWRD US Web Sites, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the WWRD US Web Sites, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).
Location-Identifying Technologies. Additionally, the WWRD US Web Sites may use GPS (global positioning systems) software and other location-based technologies such as iBeacons to locate you so we may verify your location, deliver you relevant content based on your location, as well as allow you to share your location to other users as part of the services we provide via the WWRD US Web Sites.
Information We Obtain from Other Sources: We may obtain information about you from outside sources and add it to, or combine it with, your personally identifiable information, including information such as:
- Credit information, which allows us to complete transactions for the purchase of WWRD US products and services;
- Commercially available demographic and marketing information from third parties, which aids us in serving you and informing you of products and services that may be of interest to you;
- Information submitted by third parties, such as the send to a friend functionality; and
- Updated delivery and address information from our shipping agents and other sources, which permits us to maintain accurate records and better serve you.
We also purchase e-mail lists from third parties for advertising purposes, but only lists of individuals who have specifically allowed sale of their e-mail addresses for marketing purposes. If you have previously consented to participate in an e-mail advertising program, the information we receive may include your name, information on previous transactions, or any other personally identifiable information you have provided with that consent.
To the extent we combine information we receive from those sources with your personally identifiable information we collect on the WWRD US Web Sites, it will be treated as personally identifiable information and we will apply this Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Policy apply to information we receive about you from third parties. To see how we use, disclose, and protect the personally identifiable information that we collect, please review the rest of this Policy.
COMPLIANCE WITH THE CHILDREN'S ONLINE PRIVACY PROTECTION ACT ("COPPA")
We understand the importance of protecting children’s privacy in the interactive world. We are a general audience service and, and WWRD US does not knowingly collect-either actively or passively-any information, including personal information as defined by COPPA, from children under the age of 13.
NETWORK AND INFORMATION SECURITY
We maintain a variety of physical, electronic, and procedural safeguards to guard your personally identifiable information. Specifically, we use commercially accepted procedures and systems to protect against unauthorized access to our systems. We use reasonable efforts to restrict access to your personally identifiable information to those employees and contractors-all of whom are covered by this Policy-who need to know that information to provide products or services to you, or otherwise assist you. We work to protect the security of your personally identifiable information during transmission via the WWRD US Web Site by using Secure Sockets Layer ("SSL") software, which is designed to encrypt information you input. And we use an SSL connection to enable you to view, enter, and change the information in the "My Account" section securely on WWRD US Web Sites. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that WWRD US cannot ensure the security of any information you transmit to us, and you use the WWRD US Sites and provide us with your information at your own risk.
You can take additional steps on your own to safeguard your personally identifiable information. For example, you should be sure to sign off when finished using a shared computer. And you should always log out of any web site, including a WWRD US Web Site, after viewing personal account information, such as the "My Account" section of the WWRD US Web Sites.
Please be advised that WWRD US has no control over the security of other sites on the Internet you might visit, interact with, or from which you might buy products or services.
OUR USE OF PERSONALLY IDENTIFIABLE INFORMATION
Our Internal Use: In general, we use personally identifiable information to serve our existing and prospective customers and to enhance and extend our customer relationships. By understanding how you use a WWRD US Web Site, we are able to customize and personalize our interactions with you. More specifically:
We use personally identifiable information for billing purposes, to provide products or services or complete transactions you have requested, to anticipate and resolve problems with your products and services (including warranty-related activities), to create and inform you of products or services from WWRD US or others that better meet your needs, for internal business purposes, and for purposes disclosed at the time you provide the information or as otherwise set forth in this Policy.
WWRD US uses e-mail and direct mail to inform you about products or services we think will interest you, if you created an online account with us or requested email communications. If you no longer wish to receive these types of communications you can edit your "My Account" settings or click here to unsubscribe or follow the directions in the applicable e-mail.
While you may choose not to receive marketing information from us, you will continue to receive invoices, customer service-related notifications, and other similar information from us electronically or otherwise. You will also continue to receive communications directly related to each product or service you purchase, including warranty information.
Our Customer Surveys: Periodically, you may be able to participate in our surveys to help us improve our products and services. Any personally identifiable information that we may collect from you in a survey will ONLY be used internally by WWRD US. Unless otherwise explained in the instructions for a particular customer survey, any personally identifiable information you provide to us for purposes of that survey will be used in accordance with this Policy.
Our Promotions: WWRD US may sponsor or participate in contests, giveaways, or other promotions in which you may participate. Unless otherwise explained in the rules for a particular contest, giveaway, or other promotion, any personally identifiable information you provide to us for purposes of that contest, giveaway, or other promotion will be used in accordance with this Policy.
Contact Us. Please note that information submitted to any of the Sites via a "contact us" or other similar customer inquiry function may not always receive a response. We will not use the information provided by you in a customer inquiry communication to contact you for marketing purposes unrelated to your request unless you agree otherwise.
Third-Party Use: To understand when and how WWRD US may disclose personally identifiable information to unaffiliated third parties, please read the Disclosure of Your Personally Identifiable Information section below.
DISCLOSURE OF YOUR PERSONALLY IDENTIFIABLE INFORMATION
Except as set forth in this Policy, we do not share personally identifiable information with unaffiliated third parties, nor do we sell it to third parties. We may share non-personally identifiable information, such as aggregated user statistics, with third parties. We may share your device identifiers with third parties along with data related to you and your activities. If we de-identify data about you, it is not treated as personally identifiable information by us, and we may share it with others freely. We disclose personally identifiable information only as detailed below.
Your Consent: WWRD US will not disclose personally identifiable information other than in accordance with this Policy. In general, that means that you must consent to the disclosure in advance, except as otherwise set forth in this Policy. Depending on the product or service, we may obtain your consent in a number of ways, including:
• In writing
• Online, by clicking a button; or
• Through the use of a dialing string or buttons on a telephone handset.
For example, your consent to disclose personally identifiable information can be implied simply by the nature of your request, such as when you ask us to deliver a product to you using our shipping agent.
Information You Submit: The WWRD US Web Sites may permit you to submit ideas, photographs, user profiles, writings, wishlists, data, questions, comments, suggestions or other content, including personally identifiable information (collectively, "User Content"). We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including personally identifiable information, in connection with your User Content. Please note that WWRD US does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the WWRD US Web Sites or what others do with information you share with them on the WWRD US Web Sites. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the WWRD US Web Sites. We may also publish your name, voice, likeness and other personally identifiable information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.
Disclosure to Unaffiliated Third Parties: In using the WWRD US Web Sites, you consent to our disclosure of personally identifiable information to unaffiliated third parties as follows: we share personally identifiable information with unaffiliated third parties ONLY as necessary to complete a transaction or perform a service that you have requested, or to perform data analysis services, or to support the technical operation and maintenance of the WRD Web Sites. When the unaffiliated third party acts solely on our behalf - such as with a web site hosting company - WWRD US requires that party to follow our privacy practices. WWRD US DOES NOT SELL, LEND, LEASE TO, OR SHARE WITH, UNAFFILIATED THIRD PARTIES ANY PERSONALLY IDENTIFIABLE INFORMATION ASSOCIATED WITH ITS CUSTOMERS THAT IS COLLECTED THROUGH A WWRD US WEB SITE, UNLESS YOU HAVE CONSENTED TO SUCH DISCLOSURE.
Third-party analytics and other service providers may set and access their own Tracking Technologies on your device and they may otherwise collect or have access to information about you, potentially including personally identifiable information, about you. We are not responsible for those third party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available at the end of this Policy. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on the WWRD US Web Sites or link to them from the WWRD US Web Sites. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. It may also include ordering or purchasing products from third parties through us where we indicate that the third party rather than us is the seller. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
Business Transfers: Information about our customers, including personally identifiable information, may be disclosed as part of any merger, acquisition, or sale of company assets, including during due diligence. It may also be disclosed in the unlikely event of insolvency, bankruptcy, or receivership in which personally identifiable information would be transferred as one of the business assets of the company. We may share your information, including personally identifiable information, with our parent, subsidiaries and affiliates.
Promotions: If you choose to enter a sweepstakes, contest or promotion (collectively, a "Promotion"), personal identifiable information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
Protection of WWRD US and others: We release personally identifiable information when we believe release is appropriate to do the following:
- To comply with the law and regulatory obligations (e.g., a lawful subpoena);
- To enforce or apply our agreements to sell products or services to you;
- To bill and collect for products and services; and/or
- To protect our rights or property.
OUR USE OF TRACKING TECHNOLOGIES
Cookies allow us to do the following:
- Complete transactions you have requested;
- Collect information to determine which products, services, and sections of the WWRD US Web Sites are most and least popular;
- Personalize the WWRD US Web Sites and make recommendations to you based on products and services you have liked in the past; and
- Improve the ease of use of the WWRD US Web Sites, sometimes in conjunction with web beacons.
We also use a session-based cookie to maintain continuity of navigation for you when viewing one of the WWRD US Web Sites during a particular on-line session. After closing the browser, the session cookie simply terminates; it is not stored on your computer's hard drive thereafter.
Third-party advertisers who display ads on our site may also use their own cookies. The cookies of those advertisers are governed by the privacy policies of the entities placing the ads, and not by the Policy of WWRD US.
Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies or other Tracking Technologies. For information on disabling Flash cookies go to Adobe’s website www.adobe.com.
Web Beacons: WWRD US uses web beacons on WWRD US Web Sites. A web beacon (sometimes called a "web bug" or "clear GIF") is a tiny graphic image (usually a 1-by-1 pixel) displayed in a web page, web-based document, or e-mail message, but it is usually invisible, as it is usually the same color as the background of the web page, document, or e-mail message. When the user's web browser reads the HTML code for the web beacon to retrieve the image, it can along pass along the IP address of the user's computer, the time the web beacon was viewed and for how long, and the type of browser used. Web beacons can also be linked to a user's cookies and any personally identifiable information that may be stored in them.
WWRD US uses web beacons and may link a web beacon to those customers' cookies. Web beacons allow us to provide you with a seamless experience on the WWRD US Web Sites, ensuring that you are recognized as our customer when moving between different areas of the WWRD US Web Sites. Web beacons also allow us to gather aggregate information, as described above in Information We Collect. WWRD US does not use web beacons that link to personally identifiable information on unaffiliated third-party web sites. WWRD US does not permit unaffiliated third parties to place such web beacons in advertisements on WWRD US Web Sites.
Tracking Technologies in General: In addition to as set forth above, we may use Tracking Technologies for a variety of purposes, including:
Targeting Related. We may use Tracking Technologies to deliver content, including ads, relevant to your interests on the WWRD US Web Sites and third party sites based on how you interact with our advertisements or content. This includes using Tracking Technologies to understand the usefulness to you of the advertisements and content that have been delivered to you.
Tracking Technologies Choices and Consent: We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.
Third Party Tracking and Do Not Track: There may be other Tracking Technologies now and later devised and used by us in connection with the Sites. Further, third parties may use Tracking Technologies in connection with the WWRD US Web Sites, which may include the collection of information about your online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with use of the WWRD US Web Sites and accept that our statements under this Policy do not apply to the Tracking Technologies or practices of such third parties. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
BANNER ADS AND THIRD PARTY CONTENT
The WWRD US Web Sites may contain content that is supplied by a third party, and those third parties may collect usage information and your device identifier when pages from the WWRD US Web Sites are served to you. In addition, when you are on the WWRD US Web Sites you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you "click" on a link, the "click" may take you off the WWRD US Web Sites onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including personally identifiable information, and may or may not have their own published privacy policies.
We also encourage you to note when you leave the WWRD US Web Sites and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.
CHECKING "MY ACCOUNT" INFORMATION FOR ACCURACY
You can review or change the information in the "My Account" section of the WWRD US Web Sites by using the "Update Account" feature in that section, or by telephoning or writing to Customer Service. As noted in the Information We Collect About You section above, we may also use updated delivery and address information obtained from our shipping agents and other sources to update our records. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).
OUR POLICY ON CONTACTING YOU
At WWRD US, we will send e-mail messages to you only if you have specifically requested that we do so. We include an unsubscribe link in any advertisement we send to you by e-mail which you can use to request that we stop sending e-mail advertisements to you. If you have previously requested that we send you e-mail messages but you no longer wish to receive them, let us know by filling in our unsubscribe form, and we will remove your e-mail address from our database as soon as practicable.
Please note that we reserve the right to send you certain communications relating to your account or use of the WWRD US Web Sites, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. When you communicate with us electronically, such as via e-mail and text message, you consent to receive communications from us electronically.
UPDATING OF OUR POLICY
WWRD US will revise or update this Policy if our practices change, as we change existing products or services, add new products or services, or develop better ways to inform you of products we think will interest you. You should refer back to this page for the latest information and the effective date of any changes. However, we will not use your previously collected personal information in a manner materially different than represented at the time it was collected without your consent.
YOUR CALIFORNIA PRIVACY RIGHTS
WWRD US may from time to time elect to share certain information about you collected by us on the Sites with third parties for those third parties’ direct marketing purposes. California Civil Code Section 1798.83 permits California residents who have supplied personal information, as defined in the statute, to us to, under certain circumstances, to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2014 will receive information about 2013 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing at: WWRD US, LLC (Attn: Privacy Officer) P0 BOX 1454, Wall, New Jersey, 07719-1454.
If you have any questions, comments or concerns about this Policy, please e-mail us using our Contact Us form. Or you can write to us at:
WWRD US, LLC
Attn: Privacy Officer
PO Box 1454
Wall, New Jersey 07719-1454
WWRD US is committed to the policies set forth in this Policy.
The following third parties that collect information from you on or in connection with our Service have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows:
For More Information: http://www.google.com/analytics/learn/privacy.html
Use of Tracking Technologies: Yes
Privacy Choices: https://tools.google.com/dlpage/gaoptout
PLEASE NOTE: We are not responsible for third-party policies or practices. We try to keep this information current, and will add to and subtract from the chart above as appropriate, but it is provided as a courtesy and may not be current or accurate. Please contact the applicable third parties regarding their privacy and data security policies and practices.