INTRODUCTION

At Tory Burch, we respect privacy and your rights to control your personal data.

This Privacy Policy (the “Privacy Policy”) applies to information that we collect through our websites, mobile applications, and connected products and services (collectively, the "Websites"), in our stores, at events, and through our customer service channels. This Privacy Policy describes the personal data we collect, and explains why we collect it, how we use it, and when we share it with third parties. Our Privacy Policy also describes the choices you can make about how we collect and use your personal data.

WHO WE ARE

We are Tory Burch LLC, as well as our family of affiliated companies that operate the brands TORY BURCH and TORY SPORT (collectively “Tory Burch,” “we,” “us,” or “our”).

INFORMATION WE COLLECT FROM YOU

We collect your personal data in a number of ways and for various purposes, including:

Marketing: 
You may sign up on the Websites or in stores to receive promotional emails, texts, and other communications from Tory Burch. When you sign up, we may collect personal data such as your name, mailing address, telephone number, email address, date of birth, and preferences. If you elect to be added to the Tory Burch marketing list, we may use your contact information to communicate with you about products, services, promotions, offers, news, and events from Tory Burch. From time to time, we may also provide information to you about the Tory Burch Foundation.

Customer Care: 
If you call, email or chat with our Customer Service Representative, we may collect personal data such as your name, mailing address, telephone number, and email address. We use this information to assist you.

Surveys, Sweepstakes & Promotions: 
From time to time, you may be able to participate in surveys, contests, sweepstakes and promotions offered by Tory Burch. If you choose to participate in these activities, we may collect personal data such as your name, mailing address, telephone number, email address, date of birth or age, and preferences. We may use this information to communicate with you about our products, services and promotions if you have given us your consent to do so. We may invite you to participate in promotions that are co-marketed with an unaffiliated business partner. If you participate in this type of promotion, we may also share the information you provide to us with our business partner, who may use it if you have provided your consent. If you elect to receive communications from our business partner, your information will be used by that company in accordance with its policies, and this Privacy Policy will not apply to that company’s use of your information. Sometimes the rules, terms and conditions or disclaimers that apply to a particular promotion include information on how we may use the information that you provide to us through your participation in the promotion. If there is a conflict between the rules, terms and conditions that apply to a particular promotion and this Privacy Policy, those applying to the particular promotion will govern. Please review all of the information about a promotion before you provide us (or our business partners) with any personal data.

Public Forum: 
From time to time, you may be able to participate in an online customer forum or other public or private forum on the Websites where you can post comments or other content. In order to participate in such a forum, we may ask for information such as your name, mailing address, telephone number, email address, date of birth, and preferences. We may use the information you provide to us in order to communicate with you about our products, services and promotions if you have provided your consent. If you voluntarily disclose information, personal or otherwise, online in any community area (whether through the Websites or any other services available online), that information can be collected and used by others. Accordingly, you should use caution when sharing any personal data with others in any community area (whether through the Websites or any other services available online).

Social Media: 
You may choose to enable, log into, or sign on to Tory Burch social media websites such as Facebook, Instagram, or Twitter (“Social Networking Services” or “SNS”). When you connect using your SNS accounts, we may collect personal data that you have provided to that SNS. For example, when you log in with your Facebook credentials, with your consent, we may collect personal data from your Facebook profile that is permitted under Facebook’s Terms of Use – such as your email address, profile picture, and friend list. We use this data to provide, enhance, and personalize the services we provide to you. If you do not want us to provide us with this information, please change the privacy settings on your SNS account.

INFORMATION WE COLLECT BY AUTOMATED MEANS

Cookies: Cookies are files that contain information about your general Internet usage, and are stored on the hard drive of your device. From these cookies, we may collect information about your browser, including, where available, your IP address, operating system and browser type, for system administration. Cookies help us to improve our Websites and to deliver a better and more customized service. They enable us to:

· estimate usage numbers and patterns;

· store information about your preferences;

· customize our Websites according to your individual interests;

· speed up your searches; and

· recognize you when you return to our Websites.

You may refuse to accept cookies by activating the setting on your browser that allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Websites or to avail yourself of some of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you log on to our Websites. Additionally, if a browser is set to issue a “do not track” signal, we do not place tracking cookies on that browser. However, some third parties who place cookies on our Websites may not respond to such “do not track” signals, as the online community has not reached a consensus as to Do Not Track standards, implementations and solutions.

Pixel Tags: 
We may also use "pixel tags" (sometimes called “Internet tags”, "web beacons" or "clear GIFS"), which are tiny graphic images, on our Websites. Pixel tags help us measure the effectiveness of our Websites. We work with service providers that help us track, collect, and analyze this information. Pixel tags on our Websites may be used to collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with the Websites. This information may include your device’s IP address, your browser type, your operating system, date and time information, and other technical information about your device.

Mobile Location Analytics Data: 
We may use tracking technology to collect certain information about your Wi-Fi enabled mobile device, including the presence of the device in our stores, its signal strength, its manufacturer, and a unique identifier known as its Media Access Control (“MAC”) address (collectively, “Customer Mobile Device Data”). This Customer Mobile Device Data may be collected for the purpose of determining the amount, location and frequency of customer traffic into our stores. A mobile device’s MAC address identifies a specific device to the surrounding Wi-Fi networks. The MAC address does not disclose the identity or any other personal data of the mobile device user. You may opt-out of having your MAC address recorded by visiting the following link and entering your mobile device’s MAC address: https://optout.smart-places.org/. To learn more about the use of Customer Mobile Device Data and your choices, please visit: www.smartstoreprivacy.com

Other Tracking Technology: 
Pixel tags and cookies in our emails may be used to track your interactions with those messages, such as when you receive, open, or click a link in an email message from us. We may combine the information we collect through cookies and pixel tags with other information we have collected from you. This information may be used to improve our Websites, to personalize your online experience, to help us deliver information to you, and for other internal business purposes.

Cookies and Other Tracking Technologies on Social Networking Services:
Tory Burch maintains Tory Burch-branded pages on various Social Networking Services.  When you visit these Tory Burch-branded Social Networking Services, the provider of the Social Network Services and other third parties may set cookies and other tracking technologies on your browser or device.

USE OF YOUR PERSONAL DATA

We use the information we collect from our customers for various purposes, including to:

· Send communications to you about our products, services, promotions, offers, news, and events

· Improve our stores, Websites, events, customers shopping experience, and quality of service;

· Determine the amount, location and frequency of customer traffic into our stores;

· Prevent and detect fraud and abuse;

· Process information or claims in connection with incidents at our stores;

· Enable our service providers to perform certain activities on our behalf;

· Respond to requests for information or services;

· Communicate with you about changes to our Websites;

· Comply with our legal obligations, policies, and procedures; and

· Otherwise for internal administrative and analytics purposes.

If you have provided personal data to us through more than one method, for example, in store and online, we may combine such information for the purposes identified above.

We will not sell your personal data to any third party. We may share your information under certain circumstances with business partners that help the Websites function or assist us in fulfilling your order, as well as otherwise detailed below.

OTHERS WITH WHOM WE MAY SHARE YOUR INFORMATION

We may disclose your personal data to companies that help us bring you the products and services we offer. For example, we may disclose your personal data to service providers and vendors that assist us as follows:

· To manage a database of customer information;

· To distribute emails;

· To operate our stores in certain jurisdictions;

· To provide data storage and/or analytics;

· To prevent fraud;

· To provide customer service;

· To provide other services designed to assist us in providing products and services to you.

We require that these vendors agree to keep confidential all information we share with them and to use the information only to perform their obligations in the agreements and in a manner consistent with this Privacy Policy.

We may share data in aggregate form and/or in a form which does not enable the recipient of such data to identify you (for example, for industry analysis).

In the event of a corporate reorganization, asset transfer, or change of control, your personal data may also be transferred. However, use of your personal data will remain subject to this Privacy Policy.

We may also disclose your personal data when legally required to do so, to cooperate with legal proceedings, law enforcement, court orders, laws, regulations, or other legal obligations, or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, for crime-prevention purposes, or to protect against misuse or unauthorized use of our Websites.

REMOVAL FROM MARKETING LIST

To be removed from our marketing list, please email us at cs_asia@toryburch.com, or simply click the unsubscribe button found at the bottom of any of the emails that we send you. Please allow us at least ten (10) business days from when the request was received to complete the removal, as some of our promotions may already be in process before you submit your request.

MAINTENANCE AND PROCESSING OF INFORMATION

Your personal data may be stored, transferred and process in and to the United States and in other countries by our affiliates and/or service providers. The data protection laws in these countries may provide a lower standard of protection for your personal data than your country of residence. We take great care in protecting your personal data and have put in place adequate mechanisms to protect it when it is transferred internationally. We will transfer your personal data in compliance with applicable data protection laws and will implement suitable safeguards to ensure that your personal data is adequately secured by any third party that will access your information.

By using our Websites and providing personal data to Tory Burch, you consent to the terms of this Privacy Policy and the collection, use, maintenance, transfer to and processing of your personal data in the United States or other countries or territories, and, unless otherwise stated in this Privacy Policy, we use this consent as the legal basis for that data transfer.

If you have questions or wish to obtain more information about the international transfer of your personal data or the implemented safeguards, please send us an email to cs_asia@toryburch.com.

SECURITY

Security Measures:
Tory Burch uses commercially reasonable measures to keep your personal data private and safe. We take appropriate physical, electronic and administrative steps to maintain the security of personal data we collect, including limiting the number of people who have physical access to our servers, as well as employing electronic security systems and password protections that guard against unauthorized access. Our customer care center and stores operate over private, secure networks.

Despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we use commercially reasonable means to ensure the security of information you transmit to us, we cannot guarantee that such information will not be intercepted by third parties. We may, however, prosecute any unauthorized or fraudulent transactions to the fullest extent permitted by law.

Spoofing and Phishing:
Spoofing and phishing are common Internet scams. These may occur when you receive an email from what appears to be a legitimate source requesting personal data from you. Please be aware that Tory Burch will never send you an email requesting you to verify payment card or bank information. If you ever receive an email that appears to be from us requesting such information from you, do not respond to it, and do not click on any links appearing in the email. Instead, please forward the email to us at cs_asia@toryburch.com as we will endeavor to investigate all instances of possible online fraud.

Other Websites:
Our Websites may include links to third party websites whose privacy practices may differ from ours. If you provide personal data to any of those third parties, your data is governed by their privacy policies, and we encourage you to read those privacy policies carefully before providing your personal data.

CHILDREN'S PRIVACY

Our Website is not intended for children. We do not intentionally collect any personal data from children under the age of sixteen, and will dispose of any such information if we become aware that it has been provided to us.

CHANGES TO THIS POLICY

Tory Burch may amend this Privacy Policy from time to time. If we change our Privacy Policy, we will post the updated Privacy Policy on this page with an updated date. Under certain circumstances (for example, in connection with certain material adverse changes to this Privacy Policy), we may also elect to notify you through additional means, such as posting a notice on the home page of our Websites or contacting you via email.

HOW TO CONTACT US

If you have any questions about your privacy or security on our Website, please contact us at cs_asia@toryburch.com.