Clarity Mobile App Privacy Policy
Last updated: 03/16/2021
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This Privacy Policy applies to personal information obtained through the Claire’s Clarity mobile application (the “App”), which is operated by Claire’s Stores Inc. and Claire’s Stores Canada Corp. (“Claire’s”, “we”, “us”, “our”). This Privacy Policy explains our practices and governs the use of personal information Claire’s collects from you or about you through the App.
The App is a mobile application designed to help concession merchandisers, such as you, deliver a consistent visit to concession stores. The App enables immediate communication of feedback from you to functional departments within Claire’s to address in-store issues, such as product allocation, marketing, and store fixtures. It also contains key resources to help you fulfil your role, including, display information from in store-presentations, marketing materials, store locations and human resource and operations policies and procedures.
We and/or our service providers may obtain personal information that you provide to us directly, for example, data you submit when you fill out timesheets, complete a survey, complete (or fail to complete) a job, messageother users, take a photo in the App and submit feedback notes. Personal information we collect includes your name, work and break hours, time logs, stock logs, geolocation, username and password, device information such as IP address and device ID, all of the areas within our App that you visit, and the time of the visit.
2. APP PERMISSIONS
Depending on your device or App permission settings, the App may automatically collect the following information from your device:
1) Location (may include precise location and approximate location)
2) Stored information and files (the App may be able to read, modify, or delete the contents of your shared storage)
3) Camera (may allow the App to take pictures)
4) Otherinformation (for example, the App may be able to receive data from Internet through your device, view your network connections, obtain full network access)
Our App may be personalized based on various information we may have about you to provide you with more location-relevant content.
We may use GPS (global positioning systems) software, geo-filtering, and other location-aware technologies to locate you, sometimes precisely, for purposes such as verifying your location and delivering or restricting content based on your location. However, precise geolocation information is collectedfrom the App in limited circumstances such as when you are in a Claire’s store or when the App prepares or calculates a route, and it is not processed on a continuous or on-going basis.
Our “store locator” feature may access and use information about your device location (e.g., based on your IP address) to suggest appropriate store locations.
We may use your information for other various purposes, such as to:
(i) analyze trends and conduct research about improving our products and services;
(ii) provide support and respond to your questions;
(iii) track traffic patterns and App usage;
(iv) address information security and/or privacy issues, network functioning, and troubleshooting;
(v) investigate claims and/or legal actions, violations of our policies and procedures, and compliance with relevant applicable laws and legal process;
(vi) comply with applicable laws, regulations, or legal process as well as industry standards and our company policies;
(vii) prevent, investigate, identify, or take a related action with regard to suspected or actual fraudulent or illegal activity, or any activity that violates our policies;
(viii) respond to legitimate requests for the disclosure of information, made by public authorities, law enforcement or governmental bodies or under a court order;
(ix) measure the effective performance of job duties, including use in disciplinary proceedings;
(x) access location data including GPS to confirm location when you complete a survey;
(xi) calculate mileage and routes;
(xii) manage and develop our users - for example, performance and talent management, training and development and other related services;
(xiii) manage tax, accounting, record keeping and audit.
4. SHARING OF YOUR INFORMATION
We may share information we collect about you with our subsidiaries and affiliates worldwide to, among other matters, administer and manage group functions, to make systems available to you, to manage supply chains and toassess your performance and the performance of Claire’s.
We may use service providers to help us operate our business and the App, or administer activities on our behalf, such as App maintenance. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our Service providersmay be located in the U.S., Canada or other foreign jurisdictions.
We, and our Canadian, US and other foreign subsidiaries, affiliates and service providers, may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Claire’s or as part of a corporate reorganization or other change in corporate control.
5. EXTERNAL LINKS AND FEATURES
We will retain your personal information only for as long as we need it for Claire's legitimate interest in accordance with applicable law, to fulfil your contract or to meet a legal requirement, after which we will take steps to delete your personal information or hold it in a form that no longer identifies you. More specifically, where we process survey data collected from the App, we keep this for 2 years from thedate of collection. Other personal information pertaining to your contract, is kept with your file for the duration of your contract [addition for Hungary only: and for a period in line with the relevant statutory limitation period thereafter that is 3 years in case of employment relationships and 5 years in other relationships. For tax and accounting purposes we retain your personal data for 8 years.]
6. RETENTION
We will store your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as otherwise required to meet legal or businessrequirements. At the end of the retention period we will remove personal information from our systems and records or take appropriate steps to properly anonymize it.
7. ACCESS AND UPDATE
You may update your personal information through your account settings.
Subject to applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody or control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.
8. SECURITY
We maintain appropriate administrative, technical, and physical safeguards designed to help protect personal information collected or received through the App. Although we use reasonable efforts to safeguard information, transmission via the Internet is not completely secure and we cannot guarantee the security of your information collected through the App.Your personal information will be maintained on a confidential basis and will only be accessed by your manager, employees and third party administrators/processors collectively on a “need-to-know” basis.
9. QUESTIONS / CHANGES IN POLICY
If you have questions regarding this Privacy Policy, please contact us atthe Claire’s Support Line: 1-888-285-7783. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy.