INTRODUCTION

Last updated: May 2019
Fabulous Threads is committed to respecting your privacy and complying with applicable laws and regulations to ensure that the personal information you give us is kept appropriately secure and processed fairly and lawfully.
Fabulous Threads Private Limited is a company incorporated and registered in India referred to in this Policy as "we, "us" and "our").
Your personal information will be held and managed by Fabulous Threads Private Limited. By visiting and using Fabulous Threads website or mobile site (www.talkingthreads.in) (the "SITE") or any Fabulous Threads application ("APPLICATION") that we make available from time to time or by visiting a Talking Threads store for the purchase or sampling of products or for interacting with our content and/or services or by contacting our Customer Services Team, you acknowledge that you have read this Privacy Policy. You must be at least 13 years’ old to use the Site and Applications (14 years’ old if you are a customer in the People’s Republic of China). If you are under 13 (or 14, if you are a customer in the People’s Republic of China) or a minor in your country or state of residence, please ask your parent or legal guardian to provide their information for you. This Privacy Policy covers all personal information about you that we collect, use and otherwise process in connection with your relationship with Fabulous Threads as a customer or potential customer. Fabulous Threads will collect and use your personal information as described in this Privacy Policy and as permitted by applicable laws, including in circumstances where: (i) it is necessary to provide or fulfil a service requested by or for you; (ii) you have given us your express consent; or (iii) it is necessary for one or more of the following legitimate interests pursued by Fabulous Threads

To analyse, profile and monitor customer patterns and better understand the interests and preferences of our key customer audiences so we can consistently improve our products and services.To offer an enhanced customer experience and service, including by ensuring we personalise the Site and Application and (if applicable) Fabulous Threads updates relating to products, services and events to make them more relevant to our customers’ specific preferences.To ensure the proper functioning and security of our services, Site and Application, for example by preventing fraudulent transactions.To analyse the footfall in Fabulous Threads stores and at Fabulous Threads promotions or events for internal reporting purposes and to ensure adequate and appropriate product and resources.To ensure we continue to comply with applicable laws, for example in maintaining the accuracy of our records.

WHAT PERSONAL INFORMATION WE COLLECT AND HOW DO WE USE IT

When you register for an account with us (whether online or in-store), place an order, interact with our digital content on your computer or mobile device, visit a Talking Threads store, request an in-store service or send us an enquiry, we will collect certain information from you. We will indicate whether this collection involves personal information and, if it does, whether providing your personal information is voluntary or mandatory for the service. Please be aware that where collection is mandatory, we may not be able to provide the relevant products or services to you if you do not provide that information to us. Please select from the different sections of this Privacy Policy to learn more about what personal information we collect and how we use it.

ACCOUNT MANAGEMENT AND CUSTOMER PROFILE INFORMATION
We may collect the following information: your name, postal address, phone numbers, e-mail addresses, credit card numbers and other payment information. You acknowledge that we may also obtain information about you as a result of authentication or identity checks (for example in connection with our standard fraud checks when you make a purchase on our Site or Application). We use this information to identify you as a customer, to process your order, to deliver products and services, to process payments, to update our records and to generally manage your account with us under our terms with you. Providing us with personal information is voluntary but we may not be able to process your order and send you the required order acknowledgement and shipping confirmation e-mails if you do not provide us with certain requested information.

Where permitted under applicable laws or with your consent (if so required by applicable laws), we may use information about how you use our Site, Application and any in-store services to personalise our communications to you, tailor the content appearing on our Site and Application and how these appear to you and to personalise our in-store service to you, so as to make the Site, our Application and our services and communications more relevant to you and to enable your use of any interactive features of our services.

If you have a customer account (whether created online or in-store), you acknowledge that we may also collect information about the products you browse online or purchase, where you purchased the products from and other information related to your purchases or which is otherwise relevant to your customer relationship with Fabulous Threads. We may also ask you for your gender, birthday and age (and where you have an in-store customer account we may infer your age bracket based on your engagement with our stores). You may also provide us with information about yourself, your product size preferences and lifestyle interests on our Site or Application or when using interactive content in Talking Threads store or events. We use your customer account and profile information for our internal demographic insights into our customers, to offer you an enhanced service according to your preferences, including by identifying relevant products, services and events which may be of interest to you, personalising your experience with Fabulous Threads and to share with you information about your past purchases.

We may also use your personal information to contact you in relation to service-related matters, including, on occasion, to request and respond to feedback on your experience in-store and/or on our Site and/or Application, and to assist you in relation to prospective purchases on our Site and/or Application, where permitted to do so in accordance with applicable laws or if we have your consent to do so if required by applicable laws.

We may also use your personal information for our internal marketing analysis and demographic studies, together with non-personal information, to analyse, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers. This means that we can offer more personalised and integrated shopping and interactive experiences to our customers across our stores, our Site and Applications.

We may supplement information we collect about you with marketing and demographic information which we receive from affiliated third-party companies, in addition to other information which is available in the public domain or which we are otherwise lawfully permitted to be provided with, in order to ensure the accuracy of our records, better understand the interests and preferences of our key customer audiences and improve our service to our customers. If you don’t want us to use your personal information in this way then you can contact us at any time to ask us to stop (see “Contacting Fabulous Threads " below).

DEVICE AND LOCATION INFORMATION

We collect information about the device you are using to connect to the services on our Site, Application or any interactive content we may provide. This includes the type of device you use, your internet browser, your location based on the unique identifier for your device such as an Internet Protocol address or a code for an Application running on your device. When you attend a Fabulous Threads store or event, we may also use technologies that connect to the functionality on your mobile device (such as Bluetooth and GPS) and collect information based on Wi-Fi, mobile phone masts, beacons and other in-store technology.

We use this information to ensure the proper functioning and security of our Site and Application, to optimise our services to you and to better understand how our content and services are used and their effectiveness. The information collected in-store through your mobile device using these technologies also gives us aggregated and anonymous statistics about footfall traffic in our stores and information about the average gender, size, height, ethnicity and country of origin of our visitors but it is not used for, or available to, Fabulous Threads at an individual visitor level.

Where you request location services provided by us, for example in order to find the nearest store to you or to provide more precise location based content, we will either: (i) do a look up against address information given by you, such as using your postcode to find our nearest store; (ii) look at the country in which you are in according to the unique identifier (e.g. an IP address) for your device; or (iii) if you enable location services on your mobile device, we may establish your real time location relating to the latitude and longitude of your mobile device, through GPS signals, Bluetooth or Wi-Fi connection information including MAC addresses perceived by your device, where this is available. In the case of mobile device location services, you can change your location preferences at any time by managing your device settings.

COOKIES
Cookies are small pieces of information which are issued to your device when you visit a website or some applications and which store and sometimes track information about your use of the website or application. When you enter our Site or Application our web server sends a cookie to your device which allows us to recognize your device. By associating the identification numbers in the cookies with other customer information that you provide when for example you log-in to the Site or Application, then we know that the cookie information relates to you.

We use cookies, local storage, pixel tags and other similar technologies which may place codes on or access information from and/or about your device to elevate your user experience and the quality of our Site, Application and service. This includes keeping track of what you have in your shopping bag, remembering you when you return to our Site or Application, identifying how you navigate around the internet, including where you click, and which website you arrived from. We may also use cookies, pixel tags and other technologies to understand how parts of our Site are used, and may also partner with third party advertising networks who may use cookies in helping us display advertising that is relevant to you on other websites that you visit and to enable us to assess the effectiveness of that advertising.

Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of our Site or Application may not work if you delete or disable cookies. Some of our Service Partners (discussed below) may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.

We use Google Analytics on our Site to collect usage data, to analyze how users use the Site, and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visithttps://tools.google.com/dlpage/gaoptout/We inform you where relevant of our use of cookies and other device identifiers on arriving at our Site, Application or, if required by applicable laws, on entering relevant stores. You acknowledge and agree that by continuing to use our Site or Application or services without managing your cookie and device choices and preferences, that you consent to our cookie and device identifier settings and agree that you understand ourCookies Policy. Please be aware that restricting certain cookies or other device identifiers will impact on your user experience and may prevent you from using part of our Site or Application.

Please see theCookies Policyfor more information about cookies and other technologies which are used on our Site and Application, including information on how you can manage your cookie choices and preferences.

WI-FI USAGE INFORMATION
If you register for our free Wi-Fi service at our stores or events, we will collect certain information about your device, including MAC or IP address, connection date and time and the location(s) at which you connected to our Wi-Fi Service, for the purpose of providing the Wi-Fi service under our terms with you. When you connect to our Wi-Fi service you will be directed to our Site and we may collect and process information using “cookies” and other similar technologies. For more details please see“DEVICE AND LOCATION INFORMATION”and“COOKIES”above.

COMMUNICATIONS WITH FABULOUS THREADS
Please note that your calls with Talking Threads ( Fabulous Threads ) are recorded in order to enable us to better serve our customers, for quality assurance purposes and to ensure an accurate record relevant to any transaction under our terms. Recordings of calls are retained for 90 days.

If you contact Fabulous Threads by live chat from our Site or Application, by email or phone, Fabulous Threads will collect your personal information and use this information to identify you as a customer, help with your query, process your order, deliver products and services, process payments, update our records and to generally manage your account with us under our terms with you.

INFORMATION ABOUT YOUR FRIENDS
We sometimes run promotions (for example on social media platforms) where you can tell us about a friend or someone else who you have a personal relationship with and two-way communications based on your shared interests, experiences, opinions and any other relevant factors (a “FRIEND”) who may be interested in our products, services, Site or Application. You may only provide us with information about your Friend with their permission. If your Friend gives you their permission to provide us with their details, then we will only use their information for that reason and not to send them any other unrelated offers. We may also mention that it was you who shared their details with us in the message we send to them.

CHILDREN’S PRIVACY
You must be at least 13 years’ old (or 14 years’ old, if you are a customer in the People’s Republic of China) to use our Site and Applications. If you are under 13 or a minor in your country or state of residence, your parent or legal guardian must provide their information and agree to this Privacy Policy on your behalf and you may only access and use our Site and Applications with permission from your parent or legal guardian. We do not knowingly collect personal information from children under the age of 13 or equivalent minimum age depending on jurisdiction. If we become aware that we have inadvertently received personal information from a child under the age of 13 (14 for the People’s Republic of China) or equivalent minimum age depending on jurisdiction, we will delete such information from our records.

ADVERTISING AND ONLINE TRACKING
We may allow third-party companies to serve ads and collect certain anonymous information when you visit our Site. These companies may use non-personally identifiable information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie to collect this information. Our systems do not recognize browser “Do Not Track” signals, but several of our Service Partners who utilize these cookies on our Site enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visitwww.networkadvertising.orgorwww.aboutads.info/choices. We also provide you with additional tools to opt out of marketing from us (see "Unsubscribe from Fabulous Threads updates" below).

RECEIVING AND UNSUBSCRIBING FROM TALKING THREADS ( FABULOUS THREADS ) UPDATES

TALKING THREADS ( FABULOUS THREADS ) UPDATES
We can only send you Talking Threads updates about our products, services and events with your consent. If you have provided your consent, you can withdraw it at any time (use "Unsubscribe" link available at the bottom of our promotional email updates).

If you have consented, we will send you Talking Threads updates through by e-mail, phone or messaging services. If you have enabled push notifications on the Application or your mobile device, we will send you Talking Threads updates on your phone.

We may also obtain personal information where you “like” us, create posts, mention us in public posts or otherwise interact with our pages on social media platforms and may in response, use this information to communicate with you or provide relevant content via those social media platforms about our products, events and promotions where permitted to do so in accordance with applicable laws. Please refer to the privacy policies of the social media platforms for information about how they collect and use your personal information.

UNSUBSCRIBE FROM TALKING THREADS UPDATES

If you have registered to receive Talking Threads updates relating to our products, services and events, and you no longer wish to receive these, you can request that we amend your preferences. You can do that either as indicated in the particular communication, e.g.by using the unsubscribe link which is included on all email updates, or emailing us support@talkingthreads.in. Fabulous Threads will stop sending updates in respect of which you withdraw your consent within a reasonable period and in any event within 28 days of receiving your request, in order to allow sufficient time for the change to be administered. You may opt out of receiving push notifications on your phone by changing through the settings on your mobile device or in the ‘Account Settings’ on the Application.

If you opt out of receiving Talking Threads updates relating to our products, services and events, we may still send you non-marketing communications such as emails about your account or purchases you have made from the Site or Application.

WHO WE SHARE YOUR PERSONAL INFORMATION WITH

In certain circumstances, we may share your personal information with other companies in the Fabulous Threads group (including joint ventures) globally (“AFFILIATED COMPANIES”) and selected service providers (including franchisees and licensees) who sell or promote Fabulous Threads products and services or perform other functions on our behalf such as fulfilling orders, processing payments, and carrying out promotional services or data management as permitted by applicable laws or with your consent (if so required by applicable laws) as further described below (“SERVICE PROVIDERS”). We may also share aggregated or anonymised information that does not directly identify you. Please select from different sections of this Privacy Policy below to learn more about who we may share your information with and when.

SERVICE PARTNERS
We may share information about you with companies we have chosen to handle our order dispatch service, any delivery company that we may use from time to time and with other companies that provide support services to us, including website hosting companies. We may also share your information with other companies who sell or promote Fabulous Threads products and services in order to provide you with an enhanced customer experience. In addition, we may also share certain limited information with companies who assist Burberry with other services, for example, in analysing our customer data in order to better understand, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers. In each case, we will only provide these companies with the information which they need to carry out their services and they will not be permitted to use the information for other purposes. They will only be allowed to use your information in the way in which we instruct them and as permitted by applicable laws.

FINANCIAL INSTITUTIONS AND PAYMENT PROCESSING PARTNERS
Payments using our Site or Application are made through our payment solutions providers. You will be providing credit or debit card information direct to our providers who process payment details further.

LEGAL DISCLOSURES
In certain circumstances (where required or permitted under applicable laws or with your consent (if so required by applicable laws), we may disclose personal information relating to you to third parties in other jurisdictions in order to conform to any requirements of law, to comply with any legal or regulatory process, for the purposes of obtaining legal advice, for the purposes of credit risk reduction, to prevent and detect fraud and/or to protect and defend the rights and property of Fabulous Threads and other members of the Fabulous Threads group. At all times where we disclose your information for the purposes of credit risk reduction and fraud prevention we will take all steps reasonably necessary to help ensure that it remains secure.

BUSINESS OR PROCESS CHANGE PARTNERS
In the event that we or a part of our business undergo re-organisation or are sold or licensed to a third party, any personal information we hold about you may be transferred to that re-organised entity, licensee or third party.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

You may have the right under applicable laws to ask for details of the personal information we hold about you, to amend, limit or delete your personal information, or ask for a copy of the personal information you gave us. You can also withdraw any consent you give to us at any time and object to us using your personal information for Fabulous Threads legitimate purposes (as described inFABULOUS THREADS AND THIS PRIVACY POLICY’).
If you would like to exercise any of these rights in relation to the personal information we hold about you or wish to change your preferences at any time, please contact our Customer Service Team atsupport@talkingthreads.inPlease note that we may require you to verify your identity before allowing you to access your personal information.
If you have an online customer account, you can also access, amend or update your information by logging into My Account on the Site or Application and amending your details as appropriate. If you have created a customer profile in a Talking Threads store, you can also access, amend or update your information by visiting a store and speaking to one of our sales associates.

RETENTION AND DELETION OF PERSONAL INFORMATION

We will only keep your information as long as you remain an active customer and for 5 years afterwards or otherwise as required for our business operations or by applicable laws. We may need to retain certain personal information even once a customer account has been closed or deleted to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping purposes. We may also retain a record of any stated objection by you to receiving Talking Threads updates for the purpose of ensuring we can continue to respect your wishes and not contact you further. Your personal information will be deleted or destroyed in a manner that cannot be restored or reproduced.

SECURITY AND THIRD PARTY LINKS

We take reasonable steps to protect your personal information against unauthorized or accidental access, processing, erasure, loss or use. Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information submitted to us and any transmission is at your own risk.

We do however use strict procedures and security features to try to prevent unauthorized access wherever possible. Personal information may be accessed by persons within our organization, or our third-party service partners, who require such access to carry out the purposes indicated above, or such other purposes as may be permitted or required by the applicable law.
Personal information provided to Fabulous Threads via the Site, Application and online credit card transactions are transmitted through a secure server using Secure Socket Layering (SSL), encryption technology. When the letters "http" in the URL change to "https," the "s" indicates you are in a secure area employing SSL; also, your browser may give you a pop-up message that you are about to enter a secure area or display a padlock image. The Site and the Application use this encryption technology to protect your information during data transport. SSL encrypts ordering information such as your name, address and credit card number. Our customer service center and stores also operate over a private, secure network. Please note that e-mail is not encrypted and is not considered to be a secure means of transmitting credit card information.

The Site and/or Application may from time to time contain links to other websites not controlled by us. We do not accept responsibility or liability for the privacy practices, data collected or the content of such other websites. The operators of these linked websites are not under a duty to abide by this Privacy Policy. If there are terms and conditions, other privacy statements or policies appearing on those websites, you should also review them carefully as your use of those sites may be subject to them.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The amended Privacy Policy will be posted on the Site or Application. Please check this page regularly for changes to this Privacy Policy. If we make any material changes to this Privacy Policy we will notify you before they take effect either through the Site or Application or by sending you a notification. Any such material changes will only apply to personal information collected after the revised Privacy Policy took effect.

CONTACTING TALKING THREADS

You can contact us if you have any questions about the way in which your personal information is being collected or used which are not answered by this Privacy Policy. Please contact us atsupport@talkingthreads.in