Other Covered Entities

Club Monaco US, LLC

Industries

  • Consumer Goods
  • Apparel

Participation

EU-U.S. Privacy Shield Framework: Active

Original Certification Date: 12/2/2016
Next Certification Due Date: 12/21/2018
Data Collected: HR, NON-HR

Purpose of Data Collection

Ralph Lauren Corporation and its affiliate Club Monaco US, LLC (collectively, "Ralph Lauren") obtain personal data directly from consumers located in the EU and Switzerland through Ralph Lauren's websites and in stores. Ralph Lauren obtains relevant personal data about its consumers to (1) process transactions they request, including e-commerce and mobile transactions, (2) improve its stores, websites, quality of service, and consumers' shopping experience, (3) send communications about its products, services, campaigns and promotions, (4) prevent and detect fraud and abuse, (5) process information or claims in connection with incidents at stores, (6) enable service providers to perform certain activities on the company's behalf, and (7) comply with legal obligations, policies and procedures and for internal administrative and analytics purposes. The types of relevant consumer personal data Ralph Lauren obtains include (1) name; (2) age; (3) gender; (4) demographic information; (5) billing and shipping address; (6) driver's license or ID number; (7) passport number; (8) telephone number; (9) email address; (10) payment card information; (11) checking account information; (12) information obtained by automated means when consumers visit the company's websites, such as through cookies, web beacons, and web server logs (including the IP address of the device the consumer uses to connect to the Internet, domain name, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on the company's websites, dates and times of website visits and the pages accessed); and (13) any other information consumers provide or generate on the company's websites and in stores. In addition, Ralph Lauren obtains personal data, such as contact information and financial account information, of representatives of vendors and other business partners located in the EU and Switzerland. Ralph Lauren uses this information to manage its relationships with its vendors and business partners, process payments, expenses and reimbursements, and carry out the company's obligations under its contracts with the relevant organizations. Ralph Lauren also obtains personal data about workers and the workers of its affiliates, located in the EU and Switzerland, to carry out and support human resources functions and activities. Ralph Lauren also obtains relevant personal data about workers' emergency contacts and other individuals (such as dependents and beneficiaries) to the extent workers provide the information to the company. Ralph Lauren processes this information to comply with its legal obligations and for internal administrative purposes. To the extent necessary or appropriate for compliance with relevant legal or contractual obligations, the company processes relevant sensitive information about its workers, including for purposes of managing attendance and worker records, managing the performance of workers, organizing elections of workers' union representatives, and to protect the health and safety of workers. Ralph Lauren may disclose the relevant personal data to recipients such as (1) the company's affiliates and subsidiaries, (2) third-party controllers and (3) third-party processors the company has retained to perform services on its behalf and pursuant to its instructions. Ralph Lauren also may disclose the relevant personal data if it is required to do so by law or legal process or in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements.

Privacy Policy

HR Data

Ralph Lauren EU/Swiss-U.S. Privacy Shield Worker Privacy Policy
Description:

The Ralph Lauren EU/Swiss-U.S. Privacy Shield Worker Privacy Policy describes how the company implements the Privacy Shield Principles for relevant worker personal data. The Policy is available to employees on the Company’s intranet.

Effective Date: 9/28/2016

Non-HR Data

Description:

The Ralph Lauren EU/Swiss-U.S. Privacy Shield Consumer Privacy Policy describes how the company implements the Privacy Shield Principles with respect to the personal data of certain individuals who are covered by the company’s Privacy Shield certification.

Effective Date: 9/28/2016

Verification Method

Self-Assessment

Dispute Resolution

Questions or Complaints?

If you have a question or complaint regarding the covered data, please contact Ralph Lauren Corporation at:

Cy Fenton
Chief Privacy Officer
Ralph Lauren Corporation
625 Madison Avenue, 5th Floor, New York, NY 10022
650 Madison Avenue
New York, New York 10022

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response from Ralph Lauren Corporation to your question or complaint, please contact the independent recourse mechanism listed below


NON-HR RECOURSE MECHANISM



Appropriate statutory body with jurisdiction to investigate any claims against Ralph Lauren Corporation regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission