Last Date Modified: June 15, 2018
Cece DuPraz, including its affiliates and subsidiaries respects your privacy and is committed to protecting your Personal Information (defined below). This privacy notice will let you know how we collect, use, process, maintain, and share your Personal Information, as well as your choices regarding the use, access, and correction of your Personal Information. What Personal Information we collect may vary based on your interaction with us.

We encourage you to read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.


I. IMPORTANT INFORMATION AND WHO WE ARE
II. WHAT CATEGORIES OF PERSONAL INFORMATION DO WE GATHER ABOUT YOU?
III. HOW IS YOUR PERSONAL INFORMATION RECEIVED, COLLECTED, AND USED?
IV. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
V. INTERNATIONAL TRANSFERS (EU/EEA, UK, AND OTHER APPLICABLE JURISDICTIONS)
VI. DATA INTEGRITY AND SECURITY
VII. MINIMIZATION, RETENTION, AND DELETION OF PERSONAL INFORMATION
VIII. ACCEPTANCE AND CHANGES TO THIS POLICY
IX. WHO SHOULD YOU CONTACT IF YOU HAVE QUESTIONS?


I. IMPORTANT INFORMATION AND WHO WE ARE
 

When we mention ”Cece DuPraz”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant affiliate or subsidiary of Cece DuPraz responsible for processing your information. Data and privacy law in certain jurisdictions differentiates between the “controller” and “processor” of information. Cece DuPraz is the controller and responsible for its websites.

This privacy notice aims to give you information on how Cece DuPraz receives, collects and processes your Personal Information in connection with our services and products, website, social media channels, electronic newsletters, and other digital properties (the “Digital Products”). Together with our services and products, Digital Products are sometimes referred to collectively as “Services”.

“Personal Information” is information that can be used to identify you, directly or indirectly, alone or together with other information. Personal Information may include, but is not limited to, your name, physical addresses, telephone numbers, e-mail addresses, company affiliations and associated interests. It may also include your history of transactional activities that you had on our digital properties. It does not include data where the identity has been removed (anonymous data). Certain information may not be personally identifiable when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and name).

Children’s Online Privacy Protection.
Our Digital Products and Services are not designed or intended for children under the age of 13. In accordance with the Children’s Online Privacy Protection Act we do not knowingly collect or store any Personal Information for children under the age of 13. If you are under 13, please do not provide us any personally identifying information.

Third party links and applications.
Our Digital Properties may include links to third party websites, platforms, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites, platforms and applications and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit or application you use when you use or enable these platforms and applications, or leave our Digital Properties.


II. WHAT CATEGORIES OF PERSONAL INFORMATION DO WE GATHER ABOUT YOU?

We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together follows:
  • Identity Data (for example, your first name, maiden name, last name, username or similar identifier, birth year, gender, marital status, title, or other basic demographic information).
  • Contact Data (for example, your billing address, delivery address, email address and telephone numbers).
  • Financial Data (for example your bank account and payment card details).
  • Transaction Data (for example, details about payments to and from you and other details of Services you have purchased from us).
  • Technical Data (for example, your internet protocol (IP) address, internet service provider (ISP), your login data, browser type and version, browser language, referring/exit pages, operating system, date/time stamp, clickstream data, time zone setting and basic geolocation, device type, unique device identifiers, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services and Digital Properties).
  • Usage Data (for example, information about how you use our Digital Properties and Services, including, for example, if you contact CeCe DuPraz, we may log information about the means through which you contacted us and our interaction with you).
  • Profile Data (for example, your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses).
  • Marketing and Communications Data (for example, your preferences in receiving marketing from us and our third parties, if any, and your communication preferences).

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information but is not considered Personal Information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this privacy notice.

Personal Information does not include, and this privacy notice does not cover, data from which individual persons cannot be identified, where the identity of an individual has been irretrievably removed, or situations in which personal information is anonymized.

 
III. HOW IS YOUR PERSONAL INFORMATION RECEIVED, COLLECTED, AND USED?

We may collect, receive, and use your Personal Information in different situations, including:
  1. To Provide Services/Products. We may collect your Personal Information from you, third parties, online, offline or public resources in order to process your order and provide Services, including in order to maintain, support, personalize, and improve our Services (including products and Digital Properties), deliver and provide the requested Services, communicate with you about those Services (including to request feedback) or request your participation in surveys and comply with and enforce contractual obligations. In order to process your orders and manage your payment methods, it may be necessary for us to share your information with a third party service provider and/or to combine your information with other information we have collected from you, third parties, or public sources.
  2. To Provide Relevant Information about Cece DuPraz Services that may be of interest to you. When you sign up to receive our Services, we may collect and use your Personal Information in order to provide you with information about a Service that may be of interest to you, major changes to our Services, an upcoming event, or other marketing communications on our behalf, and we may share your information between CeCe DuPraz affiliates for these purposes. We may share your Personal Information with third party service providers to facilitate these communications on our behalf and at our direction. We may also obtain information about you from other companies that have your permission to share that information, as well as from other online and offline sources, which we may then combine with information that we collect directly and indirectly from you, for these purposes.
  3. To Deliver Targeted Advertising from Cece DuPraz and Our Partners. When you sign up to use our Services, we may collect and use your Personal Information to communicate with you about products and services that may be of interest to you, and which may be provided by us, or by our advertisers, partners, third party marketing partners, or other third parties. You can manage which communications you would prefer to receive, or elect to not receive these direct marketing communications by: a) not initially selecting the option provided to receive such communications, b) using the unsubscribe link in a direct marketing email, or c) emailing us at bespoke@cecedupraz.com. Please note that, in such cases, it will remain necessary for us to process your Personal Information to the extent it is needed to maintain a suppression list, and we may also be required to disclose your opt-out information to third parties so they can suppress your name, from future solicitations.
  4. Inquiry/Request Response. We may collect your Personal Information when you contact us for information or support for our Digital Properties, Services, or other information, in order to respond and provide the appropriate assistance and response.
  5. Participating in Promotions. We may need to collect Personal Information when you choose to participate in a promotion, prize draw or other competition. The information we collect will be needed to administer such promotions as well as communicate with you about the same. For example, we may need to collect your name, age, birth year, contact information, and other Personal Information to comply with the rules and legal requirements governing the promotion and to verify participants and the winner’s identity.
  6. Surveys, Feedback, Testimonials, and Exemplars. We may collect your Personal Information when you choose to engage with us in a consumer panel, survey, or otherwise give us feedback. Also, we may use your testimonials or exemplars in or on our Digital Properties or other Cece DuPraz marketing materials, which may require the inclusion of Personal Information, such as your name, photograph, or other identify or Profile Data.
  7. Monitor Digital Properties Usage, Trends, and Experience. As is true with most websites and digital properties, when you interact with our digital properties, or by email, we may automatically collect, or facilitate the collection of, Personal Information on your interactions with us and our Digital Properties and about your equipment. For example, we may collect Personal Information by using first and third party cookies, Flash cookies, HTML5 local storage, server logs, web beacons, clear gifs, and other similar technologies. We use these automated technologies and the Personal Information collected for different purposes.

    For example, some are strictly necessary for the core functionality of our Digital Properties and providing our Services, including performance analytics, personalization, and in order to provide secure Digital Properties and Services, and are automatically deployed. For certain Digital Properties, we may tailor your interactions with our Digital Properties when you are logged in using your user account by remembering information you entered on our websites or to provide information you requested on our Digital Properties. These cookies also help us know where you have indicated certain cookie and advertising preferences, including refusals, to ensure your preferences are honored.

    We also use functional cookies and technologies to help us improve our Digital Properties and Services, as well as user relationships and experiences.
  8. Vendors, Consultants, and other Service Providers. We may receive your Personal Information from various third parties and public sources in connection with the operation of our business and the Services we provide you, including for the functionality and security of our Digital Properties and to satisfy legal obligations or enforce legal rights, to enhance and otherwise improve our Digital Properties and Services, and to provide you with enhanced experiences. These third parties and public sources could include: our business partners, subcontractors in technical, payment, and delivery services, advertising networks, analytics providers, marketing partners, search information providers, social media platforms, or credit reference agencies.
  9. Third Party Sites. We may allow you to register and pay for third party products and services or otherwise interact with a third party’s website, mobile application, or digital property (collectively “Third Party Sites”) through our own websites, apps, or digital properties. When doing so, we may collect Personal Information that you share with Third Party Sites depending upon that Third Party’s privacy practices. We do not control these third party websites, platforms and applications collecting your Personal Information and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit or application you use when you use or enable these platforms and applications, or leave our Digital Properties. Some sections of our websites are operated by third parties.
  10. Marketing Research/Statistics. We may collect your Personal Information directly or through our third party marketing partners (“Marketing Partners”) as necessary to help us and our Marketing Partners research and develop new products, services, updates, generate business or the like on our behalf. For example, we may analyze statistical, demographic, and marketing information for product development purposes and to understand usage and traffic trends to improve our relationship with you. We may also obtain certain data about you from third party sources including our Marketing Partners or other vendors, consultants and Service Providers to help us provide and improve our products, services, websites and digital properties, as well as for marketing and advertising. We may combine that data with information we obtain from our products, services and digital properties, other users, or third parties to enhance your experience and improve our products and services.
  11. Marketing and Advertisers. We may collect your Personal Information and share that information with third party advertisers or sponsors in order to support and grow our business as well as bring you relevant content, information, and advertisements.
  12. Social Media Platforms. If you log into the Services with a social media service or if you connect a social media account with the Services, we may share your information with that social media service. The social media services’ use of the shared information will be governed by the social media services’ privacy policy and your social media account settings. If you do not want your information shared in this way, do not connect your social media service account with your Services.
  13. Events. We may collect or receive your Personal Information when you register for or attend an event hosted or sponsored by us. If the event is in partnership with a third party, we may share your Personal Information with that interested party, for example so they have an attendance list, or if they need to contact you with event details. We will not share your information with them for their marketing purposes without your consent, which may be obtained at the time of your registration or through a supplemental privacy notice, but will not be required in order to attend.
  14. Government Reporting/Audit/Requests Requirements. We may use or share Personal Information in order to satisfy governmental reporting, tax, and other requirements (e.g., import/export), as required by law. This may include having to meet U.S. national security or law enforcement, regulatory, or self- regulatory requirements.
  15. To verify and/or authenticate an identity, access rights, privileges, etc. For example, we may use Personal Information to authenticate and permit online access to user account information. We may also obtain information about you from other companies that have your permission to share information about you, as well as from other online and offline sources. We may combine that information with information that we collect directly and indirectly from you
  16. At your Direction. We may collect and use your Personal Information at your direction or as otherwise needed to fulfill the purposes for which you provided the Personal Information or that were distributed when it was collected.
  17. Other Business-Related Purposes. For other business-related purposes permitted or required under applicable local law and regulation or to enforce our agreements, policies, and terms of service.
  18. As otherwise obligated by law. For example, subpoena or similar legal process compliance, if we have a good faith belief the disclosure is legally necessary for the protection of rights, safety, or fraud investigations, to protect CeCe DuPraz, you, our customers or the public from harm or illegal activities.
  19. Emergency. To respond to an emergency which we believe in good faith requires us to assist in preventing the death or serious bodily injury of any person.
  20. Consent. If we otherwise notify you and you consent to the sharing.
  21. Publicly available sources. We may also obtain information about you from other companies that have your permission to share information about you, as well as from other online and offline sources. We may combine that information with information that we collect directly and indirectly from you.

Thirty Party Personal Information.
Please keep in mind, before you disclose to use the Personal Information of another person, you must obtain that person’s consent to both the disclosure and the processing of that information in accordance with this Privacy Notice. If you choose to provide us with that Personal Information, you represent that you have that other person’s permission to do so.

Change of purpose.
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us, at  bespoke@cecedupraz.com.


IV. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

Except as set out in this privacy notice or as required by law we do not sell, license, rent, or swap your Personal Information without your permission. We may have to share your Personal Information with the categories and types of parties set out herein for the purposes set forth herein. For example, we may share your Personal Information with our service providers and vendors, with our advertising and Marketing Partners, social media platform providers, or research and analytics solution providers. We require all third parties to respect the security of your Personal Information and to treat it in accordance with the applicable law. Here are some examples of how we may share your information:
  1. Service Providers and Vendors. Service Providers. We contract with service providers to help us with credit card and bill processing, shipping, email distribution, list processing, analytics and promotions management, and ad serving. We provide service providers only with the information they need to perform their services. We prohibit them from sharing, reselling, or using our data for their own marketing purposes. Other service providers may help us with delivering or shipping to you our products you may order, and to ensure fulfillment of your orders and purchases. Another we may share, or facilitate the sharing of, your Personal Information is with third party retail or payment processing platforms or vendors in order to process and confirm payment. Or, we may share your Personal Information with third party customer service providers and vendors that allow us to assist in answering consumer inquiries and complaints and address our users’ technical issues, as well as to receive and collect user feedback on our Services, etc. We may also engage service providers to collect and analyze information about our users’ use of our Digital Properties in order for us to improve our Services and grow our business.
  2. Social Media Platforms. We may use widgets and tools from third party social media platforms on our Digital Properties to enable sharing and other functions through social media platforms, which facilitates the collection and sharing of your Personal Information by these social media platforms.
  3. Promotions, Contests, Surveys, and Events. We may facilitate the collection of, or share your Personal Information with a third party service provider, vendor, co-host, co-sponsor, or the like when we conduct, administer, host, or co-sponsor promotions, contests, surveys, or events.
  4. Marketing and Advertising Partners. We share personal data with third parties for marketing and advertising, such as Google and Facebook, so they can assist us in promoting our Services on and off our Digital Properties to current and future customers through targeted advertisements.
  5. Third Party Advertisers. We may share your Personal Information with third party advertisers. Generally we will only share aggregated statistical, demographic and marketing analyses of customers and their browsing and purchasing patterns to inform advertisers about the nature of our customer base, which does not contain Personal Information.
  6. Merger or Acquisition Partners. We may share your Personal Information with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this privacy notice.
  7. With other third parties, as required for legal compliance, law enforcement, public safety, or security purposes. For example, we may disclose your Personal Information if we have a good faith belief that disclosure is necessary to comply with the law or with legal process, such as to comply with a subpoena, protect and defend our rights and property, to protect against misuse or unauthorized use of our websites, or to protect the personal safety or property of our users or the public. For example, we may release Personal Information to comply with a court order or subpoena. Or, if you provide false information or attempt to pose as someone else, we may release Personal Information as part of any investigation into your actions.
California Privacy Rights.
If you are a California resident, you have the right, under California Civil Code Section 1798.83, to request and obtain from us, once a year and free of charge, a list of the third parties to whom we have disclosed Personal Information for their direct marketing purposes in the prior calendar year. Please email requests for such information to bespoke@cecedupraz.com.


V. INTERNATIONAL TRANSFERS (EU/EEA, UK, AND OTHER APPLICABLE JURISDICTIONS)

Cece DuPraz is headquartered and operates in the United States, and many of our external third parties are based outside the EU/EEA. In order to perform our contractual obligations with you, if any, as well as for operational and other legitimate interest reasons, we may process, store, and transfer Personal Information in a country which may be outside of your own, such as the United States. By providing us with your Personal Information you acknowledge such transfer of information out of your jurisdiction. If you do not wish for certain Personal Information to be so transferred, please do not provide your Personal Information to us and/or take such steps described herein to prevent the collection of your Personal Information. Please note in your doing so, and without such information, we may be unable to provide this Service to you. If you have any questions, please contact us.


VI. DATA INTEGRITY AND SECURITY

We have put in place commercially appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed, and to maintain its accuracy and integrity. While no security is impenetrable, we implement and maintain commercially appropriate technical, physical, administrative and organizational measures to ensure a level of security appropriate to the risk for our use of the Personal Data, taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing.


VII. MINIMIZATION, RETENTION, AND DELETION OF PERSONAL INFORMATION

We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including, for example, for so long as we provide you with Services, and for the purposes of satisfying any legal (including but not limited to enforcement of agreements or resolving disputes), accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.


VIII. ACCEPTANCE AND CHANGES TO THIS POLICY

This Privacy Notice may be amended from time to time, consistent with the applicable data protection and privacy laws and principles. We will make you aware of changes to this Privacy Notice either by posting on our site, through email, or other means. We will post those changes on our websites and in our apps so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. We reserve the right to modify this Privacy Notice at any time, so please review it frequently. We will also notify you by email or a means of a notice on our websites and apps prior to the changes becoming effective, if we make changes that materially affect the way we handle Personal Information. If you do not wish your information to be subject to the revised Privacy Notice, you will need to deactivate with us and stop using our Digital Properties and Services. Your use of our Digital Properties and Services after the posting of such changes will constitute your consent to such changes

By using the our Services and our Digital Properties, and/or submitting any of your Personal Information to us, you agree to the terms of this Privacy Notice. Please do not send us any Personal Information if you do not want that information used in this way.


IX. WHO SHOULD YOU CONTACT IF YOU HAVE QUESTIONS?

For questions or concerns about this Privacy Notice or our security practices: We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice and our security practices. If you have any questions or concerns about this privacy notice, or seeking to exercise any of your statutory rights, please contact the data privacy manager using the details set out below.

Email: bespoke@cecedupraz.com
Phone: 781.990.3425 (between 9:00am and 5:30pm EST)
Mail: 89 Front Street, Unit 102 Marblehead MA 01945 Attention Privacy Manager