HAVEN WELL WITHIN PRIVACY POLICY

To view our Terms of Use click here.Terms of Use

Last Updated Date: January 5, 2023

Haven Well Within, an affiliate of The Talbots, Inc.

This Privacy Policy applies to information collected by or on behalf of The Talbots, Inc. and all affiliated companies and brands ("Talbots", "we", "us"), including but not limited to personal information collected through our websites www.talbots.com and mobile versions of our websites (collectively, the “Sites”), in our retail stores, by phone, and anywhere else we display this Privacy Policy (collectively with the Sites referred to as the “Platforms”). This Privacy Policy outlines the information we collect, how we use and share that information, and your rights and choices with regard to personal information we collect.

By doing business with or interacting with the Platforms in the manner described in this Privacy Policy at any time after the Last Updated Date, you are accepting the practices described in this Privacy Policy and you expressly consent to the application of this Privacy Policy to the collection, storage, use and disclosure of your personal information as described.  IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY AND THE APPLICABLE TERMS OF USE, DO NOT ACCESS OR USE THE SITES OR PROVIDE PERSONAL INFORMATION TO US THROUGH ANY CHANNEL OR PLATFORM.

TABLE OF CONTENTS

• Information We Collect
• How We Collect Information
• How We Use Information
• How We Share Information
• Our Use Of Cookies
• Marketing and Interest-Based Advertising
• Security
• Your Rights and Choices
• Text Messages
• International Users
• Canadian Users
• Links to Other Websites
• Children's Privacy
• Notice to California Residents
• Notice to Nevada Residents
• Changes to This Privacy Policy
• Contact Information

INFORMATION WE COLLECT

We collect information from you and about you, in order to provide you with the products and services you request, and to more effectively market our products.  The information we collect includes “Personal Information” as that term is defined under applicable laws.  Personal Information includes information that identifies you as a specific, identified individual, such as your name and address.  We will also treat additional information, including IP addresses and cookie identifiers as “personal information” where required by applicable law. For example, we may collect:

·       Contact information such as your name, postal or shipping address, telephone number, or e-mail address

·       Your billing address and payment method

·       Communication preferences for when and how you receive communications from Talbots, including marketing and promotional messages and catalogs

·       Birthday month, addresses, Classic Awards or gift card information, wish list items, and other details you save in your myTalbots account, as well as your myTalbots account user name and password

·       Feedback, survey responses and comments you submit to Talbots or video recorded feedback sessions (if you choose to participate in a focus group)

·       Transaction history, order details and shopping preferences such as your preferred sizes, brands, or products

·       Voice recordings and information that you share when you call our customer service center or stores

·       Browsing and device information such as IP address, device identifiers, cookies, browsing activities, location data or other information collected automatically when you visit or use the sites

For a more detailed description of the Personal Information we collect on this website, the purposes for which it is collected, and whether that information may be shared or sold, please see the detailed Notice at Collection  below. 

HOW WE COLLECT INFORMATION

We generally collect information in three ways: 1) information you provide to us, 2) information we collect automatically, and 3) information we receive from third parties, as described further below.

INFORMATION YOU PROVIDE

You may provide your personal information directly to Talbots when you:

·      Request products and services through the Platforms or any shopping channel (online through the sites, in our stores or by phone)

·      Register for an account, sign up for style appointments or personal stylist services, create wish lists, or sign up for catalogs and email alerts

·      Respond to surveys, participate in focus groups, submit reviews, enter contests or drawings, or register for and participate in loyalty programs

·      Contact customer service or other Talbots points of contact to submit questions or requests

INFORMATION COLLECTED AUTOMATICALLY

We may automatically collect and receive your personal information when you visit the Sites, purchase our products, or otherwise interact with us. We use this information to improve the Sites and the products we offer. If a combination of information we collect does identify you as an individual, we will treat the combined information as personal information. The following are examples of how we automatically collect information through the Sites:

Cookies. Like many online retailers, the Sites use 'cookies', small data files stored on your computer's web browser, or other passive means of data collection. Cookies are used to personalize your visit, remember your preferences, help place your order or to enhance your shopping experience and online browsing. We, or our service providers, may also use technologies, such as cookies, to provide you with personalized advertising tailored to your interests. For more information about our use of cookies on this website, and more information about your choices regarding personalized advertising, please see the sections titled “Our use of cookies” and "Marketing and Interest-Based Advertising” below. You can adjust your web browser to accept or reject cookies; however, if you disable all cookies, some features of the Sites may not work as intended.

Pixel Tags. We use 'pixel tags' (small graphic images also called web beacons or clear gifs) or similar technologies to track information in the aggregate about your use of the Sites like the web pages you view, the links you click, and the time you spend on a page. We use this information to monitor the effectiveness of our advertising and marketing campaigns so we can learn how to best deliver your customer experience. We also use pixels to track our email campaigns to determine whether recipients opened the email and what links they clicked on from the email.

Embedded Scripts:  An embedded script is programming code that is designed to collect information about your interactions with the Sites, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected to a Site and is deactivated or deleted thereafter. 

Analytics tools and aggregate data. The Sites use analytics tools such as Google Analytics and Adobe Analytics, web analytics services provided by Google, Inc. and Adobe, Inc., respectively. Google Analytics and Adobe Analytics use cookies to help the Sites analyze how you use the Sites. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google and Adobe, respectively, in aggregate form. Google and Adobe may use this aggregated information in order to evaluate use of the sites, compile reports on Sites activity and other services relating to Sites activity and usage. You can learn more about how Google Analytics and how to opt out here: https://tools.google.com/dlpage/gaoptout. You can learn more about Adobe Analytics and how to opt out here: https://www.adobe.com/privacy/opt-out.html#customeruse.

Session replay tool. Our Sites also use a session replay analytics tool provided by Quantum Metric to help us reconstruct the user experience on the sites. Quantum Metric collects data through this tool on our behalf, and is prohibited by contract from using this data for any other purpose, or from selling or sharing any data collected by Talbots using the Quantum Metric tool. We use this tool to troubleshoot issues with and improve user experience on our sites. The tool provides insight into what works and what doesn’t work for users of the sites, and it allows us to, for example, identify and repair technical errors such as broken links that impair the sites’ functionality. We may also use the tool to authenticate users, enable Sites features, prevent fraud, and implement security measures. The tool uses cookies and similar technologies to collect and analyze information related to user behavior on our sites, such as mouse movements, clicks, user inputs, scrolling, access times, visit duration, pages viewed, IP address (including location), operating system, page reloading, crash data, performance data, and other diagnostic data. The tool also collects name, email address, phone number, and physical address if you enter this data during a session.

Chat Technology. Our Sites use an automated customer service chat feature powered by Linc Global and a live customer service chat feature powered by Cisco and New Era Tech to respond to customer inquiries. These chat features collect personal information, including but not limited to email address and the content of chat communications, on our behalf. The Linc chat feature uses “chatbot” technology, which provides automated answers to frequently asked questions. Conversations with both our automated and live chat features are recorded.  Recorded chat sessions are used by us internally and are not sold, shared, or used for purposes of targeted advertising. 

INFORMATION COLLECTED FROM THIRD PARTIES

We may also collect your personal information from third parties, including:

·      Third-Party Platforms. If you connect or interact with us on third-party sites or applications such as social media platforms, the third-party platform may send us your information such as your profile information from that platform. The information collected and disclosed to us is controlled by the third-party platform and its terms and privacy policy or as you direct by adjusting your privacy settings on the third-party platform.

·      Other Sources. To the extent permitted by applicable law, we may also receive additional information about you from third-party service providers and/or partners, such as demographic and aggregated transactional information, and combine it with information we have about you to better customize our offerings to you.

HOW WE USE INFORMATION

We may use your personal information to accomplish our business purposes including to:

·       Complete your transaction, process and ship your order, or respond to your questions or requests

·       Personalize your experience, store your preferences, and provide user-experience features and to operate our business and provide our products and services

·       Administer our business (e.g., to make improvements to the sites, conduct analytics and enhance our products and services)

·       Facilitate your participation in our loyalty programs, personal style services and other customer offerings

·       Allow you to create and maintain wish lists and other information in your myTalbots account

·       Communicate with you, including by electronic means, about your order, special offers, promotions and other products or services we think may be of interest to you

·       Create and administer contests, drawings, special events and surveys

·       Enhance and customize your customer experience and customer service in our stores, call centers and on the sites

·       Respond to reviews, comments, or other feedback you provide or questions you submit

·       Manage and customize promotional offers and advertisements we think may be of interest to you and to conduct data analysis and related activities

·       Detect and prevent fraud and protect the security and integrity of the Sites and our stores and systems

·       Protect our legal rights or the health or safety of our customers, employees or others

·       Comply with our legal obligations or to respond to law enforcement or legal and regulatory inquiries or requests or legal proceedings

HOW WE SHARE INFORMATION

Except as described in this Privacy Policy, Talbots does not share your personal information outside of our corporate family of companies without your consent. When appropriate, Talbots may share personal information with:

·       Talbots Corporate Family of Companies. We may share your information with our family of companies, including Talbots parent company, subsidiaries, and affiliates for business operations and to send you information about products or services we think may be of interest to you.

·       Service Providers. We engage with select service providers who provide services to support our operations such as: order processing and fulfillment, market research, advertising and promotion of products, managing promotions and contests, websites analytics, and other support services. Such parties may, from time to time, have access to your information to enable them to provide the services. Service Providers are prohibited from selling or sharing your information, or for using your information for purposes beyond the scope of the services they are providing on our behalf.

·       Third-Party Marketing Services. We may share the following types of personal information with third parties, including marketing cooperatives and service providers for marketing purposes: name, information associated with your browser or device, approximate location data, customer ID, postal address, email address, phone number, customer loyalty information, transaction related information (such as payment type, date, item purchased, and method of purchase), commercial preferences, and preferences related to marketing communications. One such purpose may include sharing your name, city, zip code, and commercial preferences with third parties for the third parties to send you offers or marketing materials such as catalogs through the mail. In addition, please note that we partner with third parties that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you or your business. Our partners use this information to recognize you across different channels and platforms, including but not limited to, computers, mobile devices, over time for advertising (including addressable TV), analytics, attribution, and reporting purposes.

·       Other Third Parties. As further described in the “HOW WE USE INFORMATION” section above, we may share your information to protect your safety or the safety of others when we have reason to believe that disclosing the information is necessary to identify, contact or bring legal action against someone who may be causing injury to you, our employees or otherwise injuring or interfering with Talbots rights, property or operations, other customers, or anyone else who could be harmed by such activities; to comply with legal obligations, such as when required by law, or in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation; and to maintain the security of the Sites and services and to resolve or troubleshoot technical issues.

·       When you agree to receive information from third parties or request that we share your information.  We will disclose your information to a third party (or parties) when you direct us to do so or you consent to the sharing, and your information will then be subject to the privacy policy and practices of that third party. For example, you may be presented with an opportunity to receive information or marketing offers from one or more third parties or to use an interactive feature or third-party application. 

·       Talbots Credit Card. When you apply for and use a Talbots branded credit card, you will provide certain information to the issuing bank directly, and Talbots may share certain information at your direction to facilitate your application and use of the card. The issuing bank will share information with Talbots relating to your use of the card, and we will use this information for our business purposes, including to administer our rewards program and to provide you with marketing messages and offers.

·       Successor Entities. We reserve the right to sell, rent, disclose or transfer your personal information to a successor entity in the event of a corporate merger, consolidation, sale of assets or other corporate changes respecting Talbots or our affiliated companies.

OUR USE OF COOKIES

Talbots uses cookies, pixel tags, web beacons or similar technologies to provide the functionality of our websites, as well as to help better understand the ways our websites is used, and to serve personalized advertising messages and measure the effectiveness of our marketing efforts.

Most web browsers automatically accept cookies. You can usually modify your browser settings to decline cookies but doing so may prevent you from accessing all functionality of the sites. If you are using our mobile application, you should modify the settings for the native browser on your device.

This section describes the different types of cookies used on our websites, and your choices regarding our use of cookies.

·       Strictly necessary cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will no longer work. These cookies do not store any personally identifiable information.

·       Functional cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we utilize on our website, and also allow us to measure visits to our websites and traffic sources and improve the performance of our websites, including by allowing us to identify which pages of our websites are visited during a particular session, and to understand the paths taken by visitors to our websites. You may opt-out of the use of Functional Cookies on our website by clicking   to manage your cookie settings. If you do not allow these cookies, then some or all of these services may not function properly

·       Marketing/advertising cookies: These cookies are set by third parties and are used to target, serve and measure advertisements and marketing efforts on our behalf, including targeted advertising based on your browsing activity. You can opt-out of the use of Advertising Cookies on our Website by clicking   to manage your cookie settings. You can read more about these cookies, and your choices regarding interest-based advertising, below.

MARKETING AND INTEREST-BASED ADVERTISING

Like many retailers, Talbots contracts with third-party vendors to serve or send advertisements on our behalf. We partner with these advertising vendors that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you. Our advertising partners may place or recognize a cookie on your computer, device, or directly in our emails/communications, and we may share personal information with them if you have submitted such information to us, such as your name, postal address, email address, or device ID. Our partners may link the information we share with them to the cookie stored on your browser or device and collect information such as your IP address, browser or operating system type and version, and demographic or shopping information. Our partners use this information to recognize you across different channels and platforms over time to assist us with our operations including for advertising, analytics, attribution, and reporting purposes.

The data sharing that occurs via advertising cookies may constitute a sale or sharing of your personal information under state privacy laws. You may opt-out of this type of automated sale or sharing of Personal Information by clicking  to manage your cookie preferences. If you de-activate advertising cookies, the advertisements you see will be less tailored to you and your interest, but you will still see advertisements. Please note that if you later delete your cookies, or if you access our Channels through a different device, you may need to set your opt-out preference again. Turning off advertising cookies also will not opt you out of receiving our marketing materials, and it will not opt you out of other types of sales or sharing of your personal information that may occur in other ways. In order to opt out of other sales or sharing of your personal information, please click here.

Talbots cookie management tool is configured to recognize a “Global Privacy Control” (GPC) signal, that you can be set using certain browsers or browser plug-ins. If you have enabled the GPC and set it to opt-out of the sharing of information, our website will recognize this signal, and functional and advertising cookies will be disable. 

In addition to the cookie management options provided on this website, many of Talbots marketing service providers are members of the Network Advertising Initiative (NAI), or the Digital Advertising Alliance (DAA), and have agreed to honor consumers' requests to opt-out of behavior-based online advertising submitted through those organizations' websites. To learn more about your choices regarding this type of data collection or to opt-out of interest-based advertising by members of the NAI or the DAA, please visit http://optout.networkadvertising.org or https://www.aboutads.info.

SECURITY

Talbots undertakes reasonable and appropriate physical, administrative, and technical security measures to help safeguard your personal information and prevent unauthorized access and disclosures. However, the security of information transmitted over the Internet is not guaranteed. We suggest you take steps to help protect the confidentiality of your information, such as: using complex passwords to secure your account, using a unique password for each Sites on which you have an account, and keeping your password confidential; keeping the operating system, anti-virus and other protections on your computer or mobile device up-to-date; sign out of your account when not using it; and contact our customer service team if you receive any suspicious mail, emails, phone calls or other communications purporting to be from Talbots.

YOUR RIGHTS AND CHOICES

You can choose not to give us personal information we request but, in some cases, we will not be able to provide our products or services or respond to your request without certain information. You may also Contact Us using the methods provided on our Contact Us page to exercise any of your rights and choices, which include the following:

·       Update Your Information. You may view, update and correct your personal information by logging into your myTalbots account or by using the methods provided on our Contact Us page. It may take up to 10 business days for your requested changes to take effect.

·       Managing Your myTalbots Account. You may update your preferences and options included in your myTalbots account at any time by logging into your account or by using the methods provided on our Contact Us page. You may create a Wish List using your myTalbots account and to help protect your privacy, we initially set your Wish List account to a "Private" setting. You can update your Wish List privacy settings to make your Wish List "Private" (not publicly searchable) or "Public" (publicly searchable through our sites). You may also cancel your myTalbots account at any time by notifying us using the methods provided on our Contact Us page.

·       Communication Preferences. You may request to be removed from our marketing emails by clicking  or by contacting us using the methods provided on our Contact Us page. For calling, catalog or postal mailing lists removal request, use the contact methods provided on our Contact Us page. For calling list removal, it may take up to 30 days to process your request. For postal mailing list removal, it may take up to 6-8 weeks to process your request as our customer personal information is collected in advance due to printing schedules. Please note that even if you opt out of receiving marketing communications, you may continue to receive emails, mailings or calls relating to order confirmations and/or other transaction-related communications.

·       Marketing Preferences. If you prefer not to have your name and address shared with third parties for the third parties’ direct marketing purposes (e.g., sending you catalogs), please click here and complete the form.

·       Sale or Sharing of Personal Information. You have the right to opt-out of sale or sharing of personal information, as defined California Law (Cal. Civ. Code 1798.140), or to opt out of the processing of your personal information for purposes of cross-context behavioral advertising. We are allowing all consumers to exercise this opt-out right. To opt out, visit the DO NOT SELL OR SHARE MY PERSONAL INFORMATION button below.

·       Deletion of Personal Information. You have the right to request that we delete personal information about you that we have collected from you. We are providing this right to all consumers, not only residents of states that have enacted consumer privacy legislation. Please note that certain exceptions apply to this right, such as when we must retain your information to comply with law or protect our legal interest. We will retain a record of any transactions completed with us, and your deletion request. In addition, if you have any merchandise credits with us, we will retain your information until your balance is zero. If your information is to be retained for any other reason, we will notify you of any such exceptions as applicable to your request. To exercise this right, please submit your request using the RIGHT TO DELETE button below to complete our web form and to confirm your request or by using the toll-free number or other methods provided on our Contact Us page. You will be required to provide certain information which we will use to verify your identity and your request.

TEXT MESSAGES

·       Texts from Talbots stores. While shopping with us, a Talbots sales associate may give you the option to opt-in to receive text messages from your local Talbots store about new product information, style appointments, promotional events and transactional information on the mobile phone number(s) you have shared with us. We will not contact you via text messages for marketing purposes without your prior affirmative consent. You do not have to opt-in to text messages to make purchases from Talbots. If you opt-in, we may send you text messages and alerts using an autodialer, automated SMS or autodialed technologies and standard messaging and data rates may apply. Message frequency may vary. You can always opt-out of text messages from your local Talbots store by replying STOP. You will then receive a confirmation text that you have been opted out. For more information regarding our text messaging, please contact us using the methods provided on our Contact Us page. Any such text messaging activities are subject to our Terms & Conditions.

·       Marketing and Promotional Texts. You may also sign up to receive marketing or promotional text messages from Talbots, including special online or catalog offers. These promotional text messages are separate from text messages you may have opted in to receive from your local Talbots store. To subscribe to receive marketing or promotional text messages click here. You do not have to opt-in to text messages to make purchases from Talbots. If you opt-in, we may send you text messages and alerts using an autodialer, automated SMS or autodialed technologies and standard messaging and data rates may apply. Message frequency may vary. You can always opt-out of text messages by replying STOP. You will then receive a confirmation text that you have been opted out. For more information regarding our text messaging, please contact us using the methods provided on our Contact Us page. Any such text messaging activities are subject to our Terms & Conditions.

·       Order Tracking Update Texts. You may also sign up to receive order updates via text messages, and you will receive text messages when each of your package(s) is shipped, out for delivery, delivered, or encounters an exception or delay. If you sign up, we will send you text messages and alerts using an autodialer, automated SMS or autodialed technologies and message and data rates may apply. Text Message frequency will be based on the number of account orders you place. You can always opt-out of these tracking order update text messages by replying NO to (866) 291-8566 or switch off the SMS alert option on the Order Status Tracking page. For more information regarding our text messaging, please contact us using the methods provided on our Contact Us page. Any such text messaging activities are subject to our Terms & Conditions.

INTERNATIONAL USERS

Talbots is based in the United States. Our products and services and the Sites are not targeted at individuals outside North America. If you are visiting the Sites from outside Canada or the United States and provide us with personal information, please note that your personal information may be accessed by or transferred, stored and processed by us or our affiliates in Canada and/or the United States. The data protection or privacy laws in Canada or the United States may be different than those in your country. By doing business or interacting with Talbots or our Sites or stores, you are consenting to the transfer of your personal information to facilities located in Canada and/or the United States and understand that such information will be stored and processed in accordance with this Privacy Policy and U.S. and/or Canadian law, as applicable.

CANADIAN USERS

Canadian customers can also request access to their personal information stored by Talbots by contacting us using the methods provided on our Contact Us page and we will inform you about what type of personal information we have on record or in our control, how it is used and to whom it may have been disclosed, provide you with access to your personal information so you can review and verify the accuracy and completeness and request changes to the personal information and make any necessary updates to your personal information. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. If we do not provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Canadian customers should direct their inquiries to our Canadian Privacy Officer, who can be contacted at the address and phone number listed above or by email at Canada.privacy.officer@talbots.com .

LINKS TO OTHER WEBSITES AND APPLICATIONS

We may provide links on the Sites to third-party websites we think may be of interest to you, including plug-ins that link to social media sites such as Facebook, LinkedIn, Twitter, Pinterest, and Instagram.

The Sites may also contain links to third-party embedded applications, including the True Fit application. Please note that True Fit does not share any of the customer information it collects with Talbots.

These websites and embedded applications are independent from Talbots and have their own separate privacy policies. Talbots is not responsible for the privacy practices or content of such third-party websites and embedded applications. Whenever you click on links on the Sites that take you to a third-party websites or embedded application, you will be subject to the third-party's privacy policies. We recommend that you review the third-parties’ privacy polices before you visit these websites and embedded applications.

CHILDREN'S PRIVACY

The Sites are not intended for use by children under the age of 18. We do not knowingly collect or solicit any personal information from children under the age of 18 or knowingly allow such persons to register for an online account. Should we learn that someone under the age of 18 has provided any personal information to or on the Sites, we will remove that information as soon as possible.

NOTICE TO RESIDENTS OF CALIFORNIA, COLORADO, CONNECTICUT, UTAH AND VIRGINIA

Residents of California, Connecticut, Colorado, Utah and Virginia have certain privacy rights under state law. The below section describes these data rights and how residents of these states can exercise them. Talbots makes the consumer data rights described below available to all customers, but may prioritize requests made by residents of California, Connecticut, Colorado, Utah and Virginia, in order to comply with legal obligations under the laws of those states. 

If you have questions about this Privacy Policy, including anything in this section for residents of California, Colorado, Connecticut, Utah or Virginia, or would like a printed copy of this Privacy Policy, please Contact Us at 1-800-TALBOTS (1-800-825-2687) or by email at Privacy@talbots.com. You may also print a copy of this Privacy Policy by selecting the “Print” button in your web browser.

NOTICE At COLLECTION

The Personal Information we collect about you will depend upon how you use our Sites or otherwise interact with us. The below chart describes the categories of Personal Information, as defined under California law, that we may collect about you when you visit our Sites or interact with us, the Business Purpose for which the data is collected, how the information may be shared or sold.  The below chart also describes the manner in which Personal Information was collected and used in the past 12 months.

 

Categories of Sources from which the Information was collected	Business or Commercial Purpose(s) for which Information is Collected	Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose	Categories of Third Parties to whom this Type of Personal Information is Sold/Shared
Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address or account name (Cal. Civ. Code. §1798.140(v)(1)
·       Directly from you when you place an order, or provide it to us in connection with a service you request ·       Automatically, when you visit our Sites ·       From third party sources, such as data brokers, or third-party social media platforms.	·       To complete your order or service request, or to communicate with you ·       To provide the Sites and their functionality to you ·       To analyze and understand our customers’ preferences and use of our Sites and services ·       To inform our marketing efforts	·       Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column	We may share information with third party marketing services as described in the “How we share information” section above.

 

Categories of Personal Information as defined in Cal. Civ. Code §1798.80, including name, physical characteristics or description, address, telephone number, driver’s license or state identification card number, education, occupation or field, and gift card information
·       Directly from you ·       From third parties, such as data brokers or social media platforms	·       To complete your order or service request, or to communicate with you ·       To better tailor our product and service offerings and to market them to you	·       Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column	We may share information with third party marketing services as described in the “How we share information” section above.
Characteristics of protected classifications under California Law.  Including race, ethnicity, or national origin, marital status, veteran or military status, and sex (including gender)
·       Directly from you ·       From third parties, such as data brokers or social media platforms	·       To better personalize your experience and our marketing efforts	·       Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column	We do not share this data with third party marketing services
Commercial information, including records of products or services purchased
·       Directly from you, when you make a purchase from us	·       To complete your order ·       To comply with legal obligations ·       To analyze our business, inform inventory and product decisions, and inform marketing efforts	·       Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column	We may share information with third party marketing services as described in the “How we share information” section above.
Internet or other electronic network activity information, including but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement
·       Automatically, when you visit our Sites	·       To provide the Sites and their functionality to you ·       To analyze the use of our Sites and performance of our business and marketing efforts, and to improve the functioning of our Sites and the effectiveness of our marketing	·       Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column	We may share information with third party marketing services as described in the “How we share information” section above.
Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
·       We may draw these inferences ourselves or acquire them from third party data resellers	·       To help us better personalize your experience, our websites, and our marketing efforts	·       Service providers who facilitate the provision of a requested service, or support our business purposes described in the previous column	We may share information with third party marketing services as described in the “How we share information” section above.
Sensitive Personal Information
·       When you place an order, we will collect your payment information	·       To process your order	·       Service providers, such as payment processors	We do not use or disclose Sensitive Personal Information for any reasons other than the permissible business purposes set out in Cal. Civ. Code Sec. 1798.140(e) (2), (4), (5), and (8), and as authorized by regulations adopted by the California Privacy Protection Agency

 

We will retain the above Personal Information at least as long as necessary to accomplish the business purpose for which it was collected, comply with any laws or regulations, resolve disputes, and enforce our agreements.

 

YOUR Consumer data RIGHTS AND HOW TO EXERCISE THEM

Residents of California, Colorado, Connecticut, Utah and Virginia have certain rights under state law. Please see the information below for a summary of your rights, how to exercise your rights and the information we require in order to respond to your requests. Please note that we may ask for certain information to verify the request in accordance with applicable law.

·      Right to Know. You have the right to request that we disclose the categories of personal information we collected used, disclosed or sold about you; the purposes for which we collected, sold or disclosed that information; and the categories of third parties to whom we disclosed and/or sold such information about you in the last 12 months. To exercise your right to know, please submit your request using the link immediately below to complete our web form or by using the toll-free number or other methods provided on our Contact Us page. You will be required to provide certain information which we will use to verify your identify and your request.

·      You also have the right to be informed, at or before the point of collection, as to the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.

RIGHT TO KNOW

·      Right to Correct. You have the right to request that we correct inaccuracies in any of your personal information that we collected from you and retained, taking into account the nature of the personal data and the purposes of processing your data.  To exercise your right to correct, please submit your request using the link immediately below to complete our web form or by using the toll-free number or other methods provided on our Contact Us page. You will be required to provide certain information which we will use to verify your identify and your request. You may also view, update and correct your personal information by logging into your myTalbots account or by using the methods provided on our Contact Us page.

RIGHT TO CORRECT

·      Right to Access. You have the right to request access to the personal information specific to you individually, that we collected, used, disclosed, and/or sold about you in the last 12 months. You also have the right to request that we provide to you a copy of the individual pieces of personal information we have collected about you in the last 12 months.  To exercise your right to access, please submit your request using the link immediately below to complete our web form or by using the toll-free number or other methods provided on our Contact Us page. You will be required to provide certain information which we will use to verify your identity and your request.

RIGHT TO ACCESS

·      Right to Delete. You have the right to request that we delete personal information that we have collected about you which we have collected from you. Please note that certain exceptions apply to this right, such as when we must retain your information to comply with law or to protect our legal interest. We will retain a record of any transactions completed with us, and your deletion request. In addition, if you have any merchandise credits with us, we will retain your information until your balance is zero. If your information is to be retained for any other reason, we will notify you of any such exceptions as applicable to your request. To exercise this right, please submit your request using the link immediately below to complete our web form and to confirm your request or by using the toll-free number or other methods provided on our Contact Us page. You will be required to provide certain information which we will use to verify your identity and your request.

RIGHT TO DELETE

·      Right to Appeal. If you submit a consumer data rights request under this section, and we deny the request, or fail to act on the request within a reasonable period of time, you have a right to appeal the denial or failure to act. To initiate an appeal, please submit your request to privacy@talbots.com. We will contact you to provide certain information which we will use to verify your identify and your request.   

 

·      Right to Opt-Out of Sale or sharing / Right to opt-out of processing for certain purposes. You have the right to opt-out or ask us not to sell or share your personal information. To exercise this right, please submit your request using the DO NOT SELL OR SHARE MY PERSONAL INFORMATION button immediately below or located on the home page of our Sites to complete our web form or by using the toll-free number or other methods provided on our Contact Us page. Please note, certain information may be collected automatically via cookies on our website and shared with third parties for marketing purposes.  To opt out of this automated sharing, please manage your cookie setting by clicking HERE.   

DO NOT SELL or Share MY PERSONAL INFORMATION

·      Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of any of your CCPA rights. However, we may offer certain financial incentives, charge reasonable fees related to your requests, or deny your right to know, right to request deletion, or right to opt-out of sale or sharing in accordance with applicable law.

California residents may use an authorized agent to submit a request to delete, a request to know, a request to access, a right to request to correct, or a request to opt-out of the sale or sharing of their personal information. To use an authorized agent, a California resident must provide the agent with signed permission to submit the request. An authorized agent should submit requests to Privacy@talbots.com and should include proof of signed permission from the California resident to submit the request. An authorized agent may also call our toll-free number, 1-800-TALBOTS (1-800-825-2687), to submit a request. Talbots may deny a request from an agent that does not submit signed permission demonstrating that it has been authorized by the California resident to submit the request. For requests to delete, requests to know, requests to access, and requests to correct, California residents may also be required to verify their own identity to Talbots and directly confirm that they have provided the authorized agent permission to submit the request; however, this requirement and the requirement that an authorized agent submit proof of signed permission will not apply if the California resident has provided the authorized agent with power of attorney pursuant to Cal. Prob. Code Sections 4121 to 4130. In addition, the requirement for an authorized agent to obtain and provide written permission from the California resident does not apply to requests made by an opt-out preference signal. 

 

DISCLOSURE OF PERSONAL INFORMATION

·      During the last 12 months:

• We disclosed personal information to third parties for our business purposes as further described in the HOW WE SHARE INFORMATION section above.
• We have disclosed name, postal address, commercial information (including transaction history and information, commercial preferences, and loyalty member status), and Talbots employment status. With marketing cooperatives, which may be considered a sale or sharing of Personal Information under California law. In addition, we have disclosed name, postal address, and information about past purchases to the designated marketing agents of retailers, not-for-profit organizations, trade organizations, and educational and arts organizations, which may also be considered a sale or sharing of Personal Information under California law. If you would like to have your information removed from such disclosures, please click the DO NOT SELL OR SHARE MY PERSONAL INFORMATION button indicated above.
• We also use cookies on our Sites that collect data as further described in the MARKETING AND INTEREST-BASED ADVERTISING section above and that information is disclosed to advertising networks, which may also be considered a sale or sharing under California law. Please refer to the MARKETING AND INTEREST-BASED ADVERTISING section to learn more about opt-out options for third-party cookies and click the DO NOT SELL OR SHARE MY PERSONAL INFORMATION button indicated above to opt out of first-party cookies we deploy on our sites.
• We do not knowingly collect the personal information of minors under age 18 and do not sell or share such information.

THIRD-PARTY MARKETING DISCLOSURE

Under California Civil Code Section 1798.83, California residents with whom we have a business relationship can request information about the types of personal information, if any, we shared with third parties for the direct marketing purposes of the third parties and the identities of the third parties with whom we shared such information in the immediately preceding twelve months. You may request this information by contacting us using methods provided on our Contact Us page.

NOTICE TO NEVADA RESIDENTS

If you are a Nevada resident, you have the right to request us not to sell your personal information. To exercise this right, please submit your request using the DO NOT SELL OR SHARE MY PERSONAL INFORMATION button immediately below or located on the home page of our Sites to complete our web form or by using the toll-free number or other methods provided on our Contact Us page. Please note that we may ask for additional information to verify the request in accordance with applicable law.

DO NOT SELL OR SHARE MY PERSONAL INFORMATION

CHANGES TO THIS PRIVACY POLICY

Talbots reserves the right to modify this Privacy Policy at any time and may apply changes to previously collected information, as permitted by applicable law. Any updates to this Privacy Policy will be posted on the Sites and we will indicate the last updated date of the changes. Your continued use of the Sites or other Talbots services covered by this Privacy Policy means you accept those changes as of the posted updated date.

 

nOTICE OF FINANCIAL INCENTIVE

Under California law, certain aspects of our loyalty and similar programs, which provide benefits to consumers, may be considered a financial incentive program. We collect personal information from you in connection with our loyalty program, e.g. contact information (name, email address, residential address) and commercial information (like purchase history) for a number of reasons, including to administer the program, contact you with regard to your account (if any), to provide the benefits to you, to better serve you, and to fulfill your requests associated with the program.

To opt in to our loyalty or similar programs, as set forth herein, you will need to provide certain information to register for an account and agree to the applicable program terms, or otherwise follow the instructions associated with the loyalty or other similar programs. Participation in our loyalty or other similar programs is voluntary and you can withdraw at any time.

To the extent that we provide programs that may be considered a financial incentive because the program is directly or reasonably related to the collection, deletion or retention of consumer personal information, the value is reasonably related to the overall value we receive from the personal information participants provide specific to the program, minus the costs and expenses we incur in providing the program. 

CONTACT INFORMATION

If you have any questions about this Privacy Policy, please Contact Us. Talbots postal address is:

Talbots, Inc.
One Talbots Drive
Hingham, MA 02043

You can contact us by telephone at 1-800-TALBOTS (1-800-825-2687), FAX 1-800-438-9443, or by email at Privacy@talbots.com. Canadian customers should direct their inquiries to our Canadian Privacy Officer, who can be contacted using the Contact Information or by email at Canada.privacy.officer@talbots.com.