Customer Care

Data Privacy Framework: Consumer Privacy Policy

Tapestry, Inc.

Data Privacy Framework: Consumer Privacy Policy


Last Updated: August 1, 2024

Tapestry, Inc. ("Tapestry") respects your concerns about privacy. Tapestry participates in the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework (collectively, the "DPF") administered by the U.S. Department of Commerce. Tapestry commits to comply with the DPF Principles with respect to Consumer Personal Data the company receives from the European Union, United Kingdom and Switzerland in reliance on the DPF. This Policy describes how Tapestry implements the DPF Principles for Consumer Personal Data. If there is any conflict between the terms in this Policy and DPF Principles, the DPF Principles shall govern.

"Consumer" means any natural person who is located in the EU, UK or Switzerland, but excludes any individual acting in his or her capacity as an Employee.

"Controller" means a pe­rson or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

"Data Privacy Framework Principles" or "DPF Principles" means the Principles and Supplemental Principles of the DPF.

"Employee" means any current, former or prospective employee, contractor, intern or temporary worker of Tapestry or any related individual whose Personal Data Tapestry processes in connection with an employment relationship, who is located in the EU, UK or Switzerland.

"EU" means the European Union and Iceland, Liechtenstein and Norway.

"Personal Data" means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Tapestry in the U.S. from the EU, UK or Switzerland, and (iii) recorded in any form.

"Processor" means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

"Sensitive Data" means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (including trade union-related views or activities), sex life (including personal sexuality), information on social security measures, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings or the sentence of any court in such proceedings (including administrative proceedings and criminal sanctions).
"UK" means the United Kingdom (and Gibraltar).

Tapestry's certification to the Data Privacy Framework program, along with additional information about the Data Privacy Framework program, can be found at https://www.dataprivacyframework.gov/.

Types of Personal Data Tapestry Collects

Tapestry obtains Personal Data about Consumers in various ways. For example, Tapestry collects Personal Data directly from Consumers when they visit Tapestry's websites, mobile apps, or other online services (collectively, the "Services") or sign up to receive communications or other brand initiatives from the company.

The types of Personal Data Tapestry collects about Consumers include:

  • Name, email address, telephone number, billing and shipping address, and login credentials;
  • Demographic information such as date of birth, racial or ethnic origin and gender;
  • Order information and account data;
  • Commercial information, including records of products or services purchased, obtained or considered, and other purchasing or consuming histories or tendencies of Consumers;
  • Location data, including precise geolocation data;
  • Gift registry and wish list data, such as details regarding the products or services Consumers are interested in;
  • Giveaways or sweepstakes data, which may include Consumers" contact data and the details of the giveaway or sweepstakes Consumers" have voluntarily entered;
  • Social media data, which may include social media interactions with us (e.g., if Consumers" "like" or "share" or "comment" on something they see on our social media platforms) and any information Consumers" actively provide to us for social media marketing purposes;
  • Correspondence data, which Consumers" voluntarily provide to us when booking an appointment or sign up for an event at one of our stores, making inquiries to customer care, comments on our social media, product reviews on our site, survey feedback, interests if Consumers" choose to participate in our clienteling program, and any other information they actively provide to us;
  • Technical data, which includes Consumers" IP address, browser type and version, device identifier, location and time zone setting, network and/or service provider, operating system and platform, page response times, and download errors;
  • Online usage and interaction data, which includes the websites Consumers" visited before and after visiting our website, products Consumers" viewed or searched for on our online services, length of visits to certain online pages, online page interaction information (such as scrolling, clicks, and mouseovers), methods used to browse away from online pages, your interactions with our marketing emails (such as whether and when Consumers" opened an email from us, and whether Consumers" clicked a link in the email or forwarded the email), and Consumers" interactions with our online ads; and
  • Other information Consumers choose to provide, such as through Tapestry's surveys, registrations, reviews, and "Support" and "Contact Us" features.

Tapestry may use this information for the following purposes:

  • To provide our products and services;
  • To fulfill Consumers" requests related to product fulfillment or returns;
  • To communicate with Consumers about product orders or subscriptions;
  • To communicate with Consumers regarding marketing, advertisements, and updates on special offers or promotions, products and services across any of the Tapestry brands (COACH, kate spade, and STUART WEITZMAN) that we believe Consumers may be interested in, or to administer and let Consumers know about our sweepstakes and giveaways;
  • To personalize and optimize your online shopping experience with Tapestry or other personalization services on our websites;
  • To provide customer support;
  • To maintain Consumers" accounts, including for expedited checkout and saving payment and shipping information;
  • To enable Customers to take part in our contests, sweepstakes, competitions, promotions and similar events and initiatives;
  • To interact with Customers through our social media platforms and measure the effectiveness of our social media campaigns;
  • To conduct research and analytics to improve services and product offerings;
  • To maintain the functionality of Tapestry's applications and website;
  • To increase and maintain the safety and security of the Services and prevent misuse;
  • To detect security incidents and prevent or take action regarding malicious or illegal activity;
  • To operate and support Tapestry's core business functions, including maintaining records related to business process management and loss and fraud prevention, and collect amounts owed to Tapestry;
  • To use services by third-party platforms to serve targeted advertisements;
  • To enable a corporate transaction such as a merger or acquisition whereby data assets must be merged or transferred as part of the transaction;
  • To establish or exercise Tapestry's legal rights, including defending against legal claims;
  • To respond to or address enquiries or requests from law enforcement bodies, regulators or other public authorities; and
  • To comply with and enforce applicable legal requirements, relevant industry standards and other Tapestry policies.

In addition, Tapestry may obtain Personal Data, such as contact information and financial account information, of representatives of its vendors. In those limited instances, Tapestry uses this information to manage its relationships with these parties, process payments and carry out Tapestry's contractual obligations.

Tapestry also may obtain and use Consumer Personal Data in other ways for which Tapestry provides specific notice at the time of collection.

Tapestry's privacy practices regarding the processing of Consumer Personal Data comply with the Data Privacy Framework Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

Notice

Tapestry provides information in this Policy about its Consumer Personal Data practices, including the types of Personal Data Tapestry collects, the types of third parties to which Tapestry discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data and how to contact Tapestry about its practices concerning Personal Data.

Relevant information also may be found in notices pertaining to specific data processing activities.

Choice

Tapestry generally offers Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the Data Privacy Framework Principles, Tapestry obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact Tapestry as indicated below regarding the company's use or disclosure of their Personal Data. Unless Tapestry offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy.

Sharing of Consumer Personal Data

This Policy describes Tapestry's sharing of Consumer Personal Data.

Tapestry may share Consumer Personal Data with third-party Processors the company retains to perform services on its behalf, such as delivery and logistical service providers, customer care, marketing, advertising and communications agencies, online payment and fraud prevention service providers, external auditors and advisers, cookie and data analytics, online advertising and storage and website hosting providers. These third-party Processors may use Consumer Personal Data only on Tapestry's behalf and pursuant to Tapestry's instructions for the purpose of providing services to Tapestry such as those described above. Tapestry may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. Tapestry also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

Accountability for Onward Transfer of Personal Data

This Policy describes Tapestry's sharing of Consumer Personal Data.

Except as permitted or required by applicable law, Tapestry provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Tapestry requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Data Privacy Framework Principles, and (iii) notify Tapestry and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Data Privacy Framework Principles.

With respect to disclosures of Consumer Personal Data to third-party Processors, Tapestry (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Data Privacy Framework Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Tapestry's obligations under the Data Privacy Framework Principles, (v) requires the Processor to notify Tapestry if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Data Privacy Framework Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Tapestry remains liable under the Data Privacy Framework Principles if the company's third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Data Privacy Framework Principles, unless Tapestry proves that it is not responsible for the event giving rise to the damage.

Security

Tapestry takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

Data Integrity and Purpose Limitation

Tapestry limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. Tapestry does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes, Tapestry takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Tapestry relies on its Consumers to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact Tapestry as indicated below to request that Tapestry update or correct relevant Personal Data.

Subject to applicable law, Tapestry retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer.

Access

Consumers generally have the right to access their Personal Data. Accordingly, where appropriate, Tapestry provides Consumers with reasonable access to the Personal Data Tapestry maintains about them. Tapestry also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Data Privacy Framework Principles, as appropriate. Tapestry may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer's privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting Tapestry as indicated below.

Recourse, Enforcement and Liability

Tapestry has mechanisms in place designed to help assure compliance with the Data Privacy Framework Principles. Tapestry conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Tapestry makes about its Data Privacy Framework privacy practices are true and that Tapestry's privacy practices have been implemented as represented and in accordance with the Data Privacy Framework Principles.

In compliance with the Data Privacy Framework, Tapestry commits to resolve Data Privacy Framework Principles-related complaints about Tapestry's collection and use of Consumer Personal Data. Consumers with inquiries or complaints regarding Tapestry's handling of Personal Data received in reliance on Data Privacy Framework Principles should first contact Tapestry as specified below.

Tapestry will take steps to remedy issues arising out of its alleged failure to comply with the Data Privacy Framework Principles.

If a Consumer's complaint cannot be resolved through Tapestry's internal processes, Tapestry will cooperate with JAMS pursuant to the JAMS Data Privacy Framework Program, which is described on the JAMS website at https://www.jamsadr.com/DPF-Dispute-Resolution. JAMS mediation may be commenced as provided for in the JAMS rules. The services of JAMS are provided at no cost to the Consumer. Following the dispute resolution process, the mediator or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has investigatory and enforcement powers over Tapestry. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Tapestry's compliance with the Data Privacy Framework Principles.

How to Contact Tapestry

To contact Tapestry with questions or concerns about this Policy or the company's Consumer Personal Data practices, please write to:

Tapestry Privacy Office (Legal Department)
10 Hudson Yards
New York, NY 10001
E-mail: privacy@tapestry.com