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PRIVACY POLICY

 

Last updated: January 7, 2021

We, at Ashley Stewart, take your privacy seriously. This Privacy Policy
describes the type of information we collect from or about you when you visit
AshleyStewart.com (the "Website"). This Privacy Policy also explains how Ashley
Stewart may process, use, disclose, and retain such information, as well as your
applicable rights and choices.

By using this Website, you agree to the collection, use, and disclosure of your
information in accordance with this Privacy Policy, and agree to the Ashley
Stewart Terms of Use, which are incorporated by reference. If you do not agree,
please do not access or use the Website. If we update our Privacy Policy, we
will post those changes on this page.

This Privacy Policy is categorized under the following headers:

 1.  1.  What Information We Collect
 2.  2.  How we Use your Information and Our Lawful Basis and Why We Collect
     Information
 3.  3.  When We Disclose Information
 4.  4.  How long Your Information is Retained
 5.  5.  International Transfers to the U.S. and Other Jurisdiction
 6.  6.  Your Rights and Choices
 7.  7.  Privacy of Children Who Visit the Website
 8.  8.  Your Rights in Certain Jurisdictions
 9.  9.  Third Party Content, Links, and Plug-ins
 10. 10. Data Security
 11. 11. Changes to this Policy
 12. 12. Questions/Contact Us


1. WHAT INFORMATION WE COLLECT:

Information You Provide

Ashley Stewart collects information from you when you choose to share it with
us.  This may include when you shop at AshleyStewart.com, register or create an
online account with or through the Website, purchase products, request
information from us, sign up for newsletters or our email list, enter into
sweepstakes or other promotion, fill out a survey, request customer support, or
otherwise communicate with or contact us .  The information we collect include
your name, e-mail address, address or zip code, telephone or mobile number,
gender, and birth date.

You may also provide us with certain information in connection with
specification transactions:

Create an Account: If you create an online account, we will collect information
about your purchases and payment methods, as well as the shipping addresses that
you add to your Address Book, in order to make future shopping experiences
faster and more convenient, and to provide you with more relevant content and
advertising on our Website and on other sites.

Information You Provide When You Make a Purchase . If you make a purchase from
us, we collect a payment card number and related financial information (such as
CVV, expiration date, and billing address), or other payment information (such
as via PayPal), depending on the form of payment you choose.  We also may
collect your billing and/or shipping address, and any other information that is
necessary to provide you with the goods or services you ordered.

Information You Provide When You Apply for an Ashley Stewart Credit Card. If you
apply online for an Ashley Stewart credit card, you will be providing your
personal information directly to the issuing bank for the Ashley Stewart credit
card. However, your name, address, phone number, birth date and credit card
account number, as well as any additional information necessary for us to
provide you with the bonuses and benefits of an Ashley Stewart credit card, may
be provided to us by the card issuer.

Information Automatically Collected

Whenever you visit or interact with the Website, we, as well as any third-party
advertisers and/or service providers, may use cookies, pixel tags, web beacons,
clear gifs, JavaScript tags, log files, or other technologies to automatically
or passively collect information about your online activity. For information
about our use of cookies and other similar technologies through the Services,
please read our Cookie Policy.

Please note that we automatically collect the following information about you:

Computer or Device.  We may automatically collect your IP address or other
unique identifier or information from the computer, mobile device, tablet or
other device you use to access the Services, including the browser type, device
type, operating system, software version, hardware model, and mobile network
information, and the domain name from which you accessed the Services. 

Usage Information. We gather navigational information about where visitors go on
the Website and information about the technical efficiencies of our Website and
services (i.e., time to connect to the Website, time to download pages, etc.).
This information allows us to see which areas of our Website are most visited
and helps us better understand our visitors' experiences at AshleyStewart.com.
This helps us improve the quality of the Website by recognizing and delivering
more of the features, areas and services our visitors prefer. We may also create
and use electronic records to compile statistics about how our visitors
collectively interact with our website.  This information is also used to
provide you with more relevant content and advertising on our Website and on
other sites.

Third Party Service Providers.  We may use third party service providers to
support our Website.  Some of these service providers may use technology such as
cookies, web beacons, pixel tags, log files, Flash cookies, or HTML5 cookies to
receive, collect, and store information.

Third Party Analytic Technologies.  We may use third parties’ analytics and
tracking tools to better understand who is using the Website, how people are
using the Website, how to improve the effectiveness of the Website and related
content, and to help us or those third parties serve more targeted advertising
to you across the Internet. These tools may use technology such as cookies, web
beacons, pixel tags, log files, Flash cookies, HTML5 cookies, or other
technologies to automatically collect and store certain information. They may
also combine information they collect from your interaction with the Website
with information they collect from other sources. We do not have access to, or
control over, these third parties’ use of cookies or other tracking
technologies. 

To learn more about your advertising choices relating to the collection and use
of your information, please see the Your Rights section below.

Combination of Data

We may combine the information we collect from or about you, including
information you provide to us and information we automatically collect through
our Website, as well as information collected offline, across other computers or
devices that you may use, and from third party sources.

This information may be used to improve our Website, to personalize your online
experience, to tailor our communications with you, to determine the
effectiveness of our advertising, and for other internal business purposes (for
example, to complete a sale or honor any return policy).

--------------------------------------------------------------------------------

 


2. HOW WE USE YOUR INFORMATION AND OUR LAWFUL BASIS

Ashley Stewart is committed to protecting and maintaining the privacy of your
information. Therefore we will use and process your data only in accordance with
applicable data protection law and this Privacy Policy.

We will have a lawful basis to process your data when:

We need to process your information in order to provide you with the products or
service you have requested or to enter into a contract

We have a legitimate interest for processing your data – e.g., for fraud
prevention; network and information systems security; data analytics; enhancing
modifying or improving our services; identifying usage trends; determining the
effectiveness of promotional campaigns; and advertising personalization of the
service using data to make it easier and faster for you to place orders;

You have consented to such processing; or

We are required to do this by law (for example, where it is necessary to retain
it in connection with potential litigation).

We may use the information we collect from and about you for a variety of
business purposes, including the following:

To validate, confirm, verify, deliver, install, and track your order (including
to process payment card transactions, arrange for shipping, handle returns and
refunds, and contact you about your orders, including by telephone), provided
support and responding to questions from customers and Website visitors, and
learn about customers' needs

To enhance your online shopping experience, including as a way to recognize you
and welcome you to the Website

To review the usage and operations of our Website,  develop new products or
services, and conduct analysis to enhance or improve our content, products, and
services

To provide you with customized Website content, targeted offers, and advertising
on the Site, via email or text message, or across other websites, mobile
applications, social media or online services

To contact you with information, newsletters and promotional materials from
Ashley Stewart or on behalf of our partners and affiliates, or for research or
informational purposes

To use your data in an aggregated non-specific format for analytical and
demographic purposes (this processing may involve profiling - for example to
suggest products to you based on your search history, or the search history of
other visitors that viewed similar product)

To protect the security or integrity of the Website and our business, such as by
protecting against and preventing fraud, unauthorized transactions, claims and
other liabilities, and managing risk exposure, including by identifying
potential hackers and other unauthorized users

To use and disclose your credit/debit card information only to process payments
and prevent fraud

If you have an Ashley Stewart credit card, the information we receive from the
issuer of the Ashley Stewart credit card is used by us to deliver information
about our products to you and to provide you with the bonuses and benefits of an
Ashley Stewart credit card, such as contacting you about upcoming in-store
promotions and sending you a mailing during your birthday month

For other purposes disclosed at the time you provide your information or
otherwise with your consent

--------------------------------------------------------------------------------


3.WHEN WE DISCLOSE INFORMATION

We may share your information with the following categories of recipients:

 * Third Party Service Providers:  Ashley Stewart may share your information
   with third party service providers that provide business, professional or
   technical support functions for us (for example, for customer payment
   processing, order fulfillment and shipping services, customer service, and
   other services related to the services provided by us or on our behalf), help
   us operate our business and the Website, or administer activities on our
   behalf.  These vendors have access to your information as is necessary to
   perform such services, but have agreed not to use any customer personal data,
   except in accordance with this privacy policy
 * Select Third Parties: We also may use select third parties to help us provide
   new or better products and services to you.

 * Promotions. If you choose to enter into one of our sweepstakes, contests,
   drawings, contests, or other promotions, we may disclose your information to
   third parties or the public in connection with the administration of such
   promotion, as required by law, as otherwise permitted by the promotion’s
   official rules, or otherwise in accordance with the terms of this Privacy
   Policy.

 * Legal Obligations; Safety: We may access and disclose specific information
   about you if necessary to do so by law, or based on our good faith belief
   that it is necessary to conform or comply with the law (including to respond
   to subpoenas, judicial processes, or government requests and investigations).
   We also may disclose information to prevent fraud to reduce credit risks, to
   cooperate with police and other governmental authorities, or to protect the
   rights, property or safety of visitors to the Website or the public. We may
   disclose your information to protect the security of our Website, servers,
   network systems, and databases. We also may disclose your information as
   necessary, if we believe that there has been a violation of our Terms of Use,
   any other legal document or contract related to our services, or the rights
   of any third party.

 * Sale or Transfer of Business or Assets: We may disclose information about you
   if there is a sale of all or part of our business, or if we go through a
   reorganization or merger.

 * Aggregate or Anonymous Non-Personal Information: We may also share aggregate,
   anonymous, or de-identified non-personal information with third parties for
   their marketing or analytics uses.

 * Other: We also may share your information as disclosed to you at the time of
   collection

--------------------------------------------------------------------------------


4. HOW LONG YOUR INFORMATION IS RETAINED

We’ll hold on to your information for as long as you have your account, or as
long as is needed to be able to provide the services to you, or (in the case of
any contact you may have with our Customer Care team) for as long as is
necessary to provide support-related reporting and trend analysis only.

If reasonably necessary or required to meet legal or regulatory requirements,
resolve disputes, prevent fraud and abuse, or enforce our terms and conditions,
we may also keep hold of some of your information as required, even after you
have closed your account or it is no longer needed to provide the services to
you.

--------------------------------------------------------------------------------


5. INTERNATIONAL TRANSFERS TO THE UNITED STATES AND OTHER JURISDICTIONS

This Site is governed by and operated in, and in accordance with the laws of
the, United States, and are intended for the enjoyment of residents of the
United States. Given that we are an international business, our use of your
information necessarily involves the transmission of data on an international
basis.

If you are located in the European Union, Canada or elsewhere outside of the
United States, please be aware that information we collect may be transferred to
and processed in the United States, where data protection laws may be less
stringent than in the country where you live. When applicable, we only transfer
your personal data subject to suitable safeguards being in place; through the
use of approved standard EU Model Clauses or to companies who are Privacy Shield
certified .  We also make sure that any such transfers are conducted in
accordance with applicable data protection laws.  To find out more about how we
safeguard your information (including obtaining a copy of such safeguards) in
relation to transfers outside the EEA, please contact us via the details
provided in the “Contact Us” section below.

--------------------------------------------------------------------------------


6. YOUR RIGHTS AND CHOICES

Cookies, Tracking Options, and California Do Not Track Disclosures

Certain parts of our Website requires cookies. You are free to set your Internet
browser device system settings to limit certain tracking or to decline cookies,
but by doing so, you may not be able to use certain features on the Site or take
full advantage of all of our offerings. Please refer to your Web browser’s or
operating system’s website or “Help” section for more information on how to
delete and/or disable your browser or operating system from receiving cookies or
controlling your tracking preferences

Our system may not respond to Do Not Track requests or headers from some or all
browsers. We also work with third-party companies that use tracking technologies
to serve advertisements on our behalf across the Internet. These companies may
collect information about your visits to our Website and your interaction with
our advertising and other communications. If you would like more information
about this practice and to know your choices about not having your information
used by these companies, please visit http://www.networkadvertising.org/choices/

Opt-Out Preferences

If you do not wish to receive e-mails about special offers, new fashion trends,
contests and other promotions from AshleyStewart.com, click the unsubscribe link
at the bottom of our emails, or modify your account settings by going to the
“Welcome Login” link at the top of our website, log-in to your account and then
change your settings to indicate that you do not want to receive emails and
other promotional materials.

Updating Your Information

We prefer to keep your personal information accurate and up-to-date. If you
would like to change your contact information, please go to My Account, and log
in with your email address and password.

Other Rights

You may have other rights depending on where you live. Please see below for
additional jurisdictional specific disclosures.

--------------------------------------------------------------------------------

 


7. PRIVACY OF CHILDREN WHO VISIT THE WEB SITE

Ashley Stewart recognizes the importance of children's safety and privacy. The
Website is not designed to attract children, and is not intended for use by any
children under the age of 13. We do not request, or knowingly collect, any
personally identifiable information from children under the age of 13. Children
under the age of 18 may use the Website only under the supervision of a parent
or legal guardian who agrees to be bound by the Terms of Use.


8. YOUR RIGHTS IN CERTAIN JURISDICTIONS

The European Union and the united Kingdom

If you live in the European Economic Area (EEA) or the United Kingdom, you have
a number of rights when it comes to your personal data. If you wish to exercise
these rights with regards to your personal data that we hold, please contact us
using our privacy request form, click here . Further information and advice
about your rights can be obtained from the data protection regulator in your
country. These rights include:

 * The right to be informed about how your personal data is being used (like
   this notice!)
 * The right to access the personal data we hold about you
 * The right to request the correction of inaccurate personal information we
   hold about you
 * You have the right to ‘block’ or suppress further use of your information.
   When processing is restricted, we can still store your information, but may
   not use it further.
 * We keep lists of people who have asked for further use of their information
   to be ‘blocked’ to make sure the restriction is respected in future
 * The right to request that we delete your data, or stop processing it or
   collecting it, in some circumstances
 * The right to request that we transfer or port elements of your data either to
   you or another service provider
 * If you have given your consent to anything we do with your personal data, you
   have the right to withdraw your consent at any time; and
 * You also have the right to lodge a complaint about the way we handle or
   process your personal data with your national data protection regulator .

To make these requests with Ashley Stewart, please submit a request using our
privacy request form, click here.

California

Your California Privacy Rights:

California law permits residents of California to request certain details about
how their personal information is shared with third parties or affiliated
companies for direct marketing purposes. If you are a California resident and
would like to make such a request, please contact us at: CCPA@ashleystewart.com.
You must put the statement “Your California Privacy Rights” in the subject
field. We are not responsible for notices that are not properly labeled or sent,
or for those that do not have complete information.

California residents may also take advantage of the following rights:

Statutory category of personal information (PI) (Cal. Civ. Code § 1798.140) PI
we collect in this category (See Personal information we collect above for
description) Source of PI Business/ commercial purpose for collection Categories
of third parties to whom we “disclose” PI for a business purpose Identifiers
(other than online identifiers)
 * Establishing and developing neighborhoods
 * Setting you up with an account
 * Provide and improve the Services
 * Create and maintain a trusted environment
 * Advertising
 * Research and development

 * You
 * Third parties and public sources

 * Contact details
 * Network details
 * Data from other accounts
 * Payment information
 * Business information
 * Information from third parties and public sources

 * Public
 * Network details
 * Verification partners
 * Legal and safety-related third parties
 * Advertising partners
 * Third party partners
 * Affiliates
 * Business transferees
 * Professional advisors

California Customer Records (as defined in California Civil Code section
1798.80)
 * Establishing and developing neighborhoods
 * Setting you up with an account
 * Provide and improve the Services
 * Create and maintain a trusted environment
 * Advertising
 * Research and development

 * You
 * Third parties and public sources

 * Contact details
 * Network details
 * Data from other accounts
 * Payment information
 * Business information
 * Information from third parties and public sources

 * Public
 * Verification partners
 * Legal and safety-related third parties
 * Advertising partners
 * Third party partners
 * FYI.FYI corporate family
 * Business transferees
 * Professional advisors

Commercial Information
 * Contact details
 * Network details
 * Survey data
 * Payment information
 * Contests, sweepstakes, and prize drawings data
 * Messages and email data
 * Business information
 * Online activity data
 * Information from third parties and public sources

 * You
 * Your browser and device
 * Third parties and public sources

 * Establishing and developing neighborhoods
 * Setting you up with an account
 * Provide and improve the Services
 * Create and maintain a trusted environment
 * Advertising
 * Research and development

 * Public
 * Verification partners
 * Legal and safety-related third parties
 * Advertising partners
 * Third party partners
 * Affiliates
 * Business transferees
 * Professional advisors

Financial Information Payment information You
 * Provide and improve the Services
 * Create and maintain a trusted environment
 * Research and development

 * Legal and safety-related third parties
 * Third party partners
 * Affiliates
 * Business transferees
 * Professional advisors

Online Identifiers
 * Messages and email data
 * Contact lists
 * Geolocation
 * Device data
 * Online activity data
 * Information from third parties and public sources

 * You
 * Your browser and device
 * Third parties and public sources

 * Setting you up with an account
 * Provide and improve the Services
 * Create and maintain a trusted environment
 * Advertising
 * Research and development

 * Verification partners
 * Legal and safety-related third parties
 * Advertising partners
 * Third party partners
 * Affiliates
 * Business transferees
 * Professional advisors

Internet or Network Information
 * Messages and email data
 * Device data
 * Online activity data

 * You
 * Your browser and device
 * Third parties and public sources

 * Setting you up with an account
 * Provide and improve the Services
 * Create and maintain a trusted environment
 * Advertising
 * Research and development

 * Legal and safety-related third parties
 * Advertising partners
 * Third party partners
 * Affiliates
 * Business transferees
 * Professional advisors

Geolocation Data
 * Geolocation
 * Device data

 * You
 * Your browser and device

 * Setting you up with an account
 * Provide and improve the Services
 * Create and maintain a trusted environment
 * Advertising
 * Research and development

 * Legal and safety-related third parties
 * Advertising partners
 * Affiliates
 * Business transferees
 * Professional advisors

Inferences May be derived from your:
 * Contact details
 * Network details
 * Survey data
 * Contests, sweepstakes, and prize drawings data
 * Messages and email data
 * Device data
 * Geolocation
 * Online activity data
 * Information from third parties and public sources

N/A
 * Setting you up with an account
 * Provide and improve the Services
 * Create and maintain a trusted environment
 * Advertising
 * Research and development

 * Legal and safety-related third parties
 * Advertising partners
 * Third party partners
 * Affiliates
 * Business transferees
 * Professional advisors

Professional or Employment Information
 * Business information
 * Information from third parties and public sources

 * You
 * Third party sources

 * Setting you up with an account
 * Provide and improve the Services
 * Create and maintain a trusted environment
 * Advertising
 * Research and development

 * Public
 * Verification partners
 * Legal and safety-related third parties
 * Advertising partners
 * Third party partners
 * Affiliates
 * Business transferees
 * Professional advisors

Sensory Information Photos and videos You
 * Setting you up with an account
 * Provide and improve the Services
 * Create and maintain a trusted environment
 * Advertising
 * Research and development

 * Public
 * Legal and safety-related third parties
 * Third party partners
 * Affiliates
 * Business transferees
 * Professional advisors



Access Categories of Information

You may request the following information about how we have collected and used
your personal information during the past 12 months::

 * The categories of personal information we have collected about you;.
 * The categories of sources from which we collected the personal information;
 * The business or commercial purpose for collecting or selling the personal
   information;
 * The categories of third parties with whom we share the personal information;
 * The specific information related to you that we collected or processed;
 * The categories of personal information that we sold or disclosed for a
   business purpose; and
 * The categories of third parties to whom the personal information was sold or
   disclosed for a business purpose.

You may exercise any of these choices by sending an email to
CCPA@ashleystewart.com or using this form, click here. Please note that most of
your personal information can be accessed directly through your user account.

Deletion

You can directly delete most information we have about you through your account.
You can also request to delete information we have about you by sending an email
to CCPA@ashleystewart.com or using our form, click here.

Opt-out of sales

We use services that help deliver interest-based ads to you, which enable us to
provide the Services and relevant offers to you.

Our use of these services may be classified under the CCPA as a “sale” of your
personal information to the advertising partners that provide the services
because they collect information from our users to help them serve ads more
likely to interest you.

You can request to opt-out of this “sale” of your personal information by
clicking on the “Do Not Sell My Personal Information” link, where you will find
instructions on opting out of the use of your information for interest-based
advertising.

Requests by authorized agents.

Your authorized agent may make a request for information, access, and deletion
on your behalf upon our verification of the agent’s identity and our receipt of
a copy of valid power of attorney given to your authorized agent pursuant to
California Probate Code Sections 4000-4465. If you have not provided your agent
with such a power of attorney, you must provide your agent signed permission to
exercise your CCPA rights on your behalf, provide the information we request to
verify your identity, and provide us with written confirmation that you have
given the authorized agent permission to submit the request. Authorized agents
are required by California law to implement and maintain reasonable security
procedures and practices to protect their clients’ information.

Verifying requests for information, access, and deletion.

We will need to verify your identity to process your information, access and
deletion requests and reserve the right to confirm your California residency.

You do not need to create an account with us to exercise your opt-out rights. We
will only use personal information provided in an opt-out request to review and
comply with the request.

Shine the light.

Under California’s Shine the Light law (California Civil Code Section 1798.83),
California users of our Services may ask us to provide the names of third
parties to which they have disclosed certain personal information (as defined
under the Shine the Light law) during the preceding calendar year for their own
direct marketing purposes and the categories of personal information disclosed.
You may send us requests for this information to 150 Meadowlands Parkway, Suite
403, Secaucus, NJ 07094. In your request, you must include the statement “Shine
the Light Request,” and provide your first and last name and mailing address and
certify that you are a California resident. We reserve the right to require
additional information to confirm your identity and California residency. Please
note that we will not accept requests via telephone, email, or facsimile, and we
are not responsible for notices that are not labeled or sent properly, or that
do not have complete information.


9. THIRD-PARTY CONTENT, LINKS, AND PLUG-INS

For your convenience, the Website may contain links to other websites. Ashley
Stewart is not responsible for the privacy practices, advertising, products, or
the content of such other websites. None of the links should be deemed to imply
that Ashley Stewart endorses or has any affiliation with the links.

The Website may also offer you the ability to interact with social plugins from
social media sites, which may allow us and/or the social media site to receive
data from or about you. In some cases, we may know that you clicked on a social
plugin, such as a Twitter Follow button, or receive other information from the
social media sites. Similarly, if you have previously provided personal
information to a third-party operating a plug-in on this Website, then such
third-party may recognize you on this Website. Your use of social network
plugins is subject to each social media site’s privacy policy, which may be
different from ours, so please read these policies carefully to understand their
policies and your options.


10. DATA SECURITY

Ashley Stewart believes in providing a safe and secure experience for all of our
online visitors. To that end, we have implemented security measures at
AshleyStewart.com to protect the information we have collected at the Website.
For example, we limit access to your personal information to select employees
and others with a valid business need for the information. In addition, we hold
our employees responsible for upholding our privacy standards.

We maintain reasonable physical and electronic safeguards designed to limit
unauthorized access to your personally identifiable information, and to protect
you against the criminal misuse of that information.

We use data encryption technology when transferring and receiving your personal
information. For example, in your transactions submitted by you through the
Website, a solid key icon or a locked padlock icon at the lower portion of your
Web browser window confirms the site is secured through Secure Sockets Layer
(SSL). Pages requesting personal information should always have one of these
icons. You can also confirm your data is being encrypted by looking at the URL
line of your browser (the place where you type Website addresses). When
accessing a secure server, the site address will change from "http" to "https".

While we use the foregoing security measures to protect your information, please
note that no data transmitted over the Internet or stored and utilized for
business purposes can be guaranteed to be completely secure. No security
measures are perfect or impenetrable. We cannot guarantee that only authorized
persons will view your information. We cannot ensure that information you share
on the Website will not become publicly available. You can reduce these risks by
using common sense security practices such as choosing a strong password, using
different passwords for different services, and using up to date antivirus
software


11. CHANGES TO THIS PRIVACY POLICY

We may elect to change or amend our Privacy Policy; in such event, we will post
the policy changes in our Privacy Policy on the Website. If you are concerned
about how your personal information is used, please visit our Website often for
this and other important announcements and update.


12. QUESTIONS/CONTACT US

If you have questions or concerns with respect to our Privacy Policy, please
send us an email at customerfeedback@ashleystewart.com for assistance.

 

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