THIS POLICY DESCRIBES HOW WE TREAT CUSTOMER INFORMATION

This Privacy Policy for assouline.com (the “Site” or “we”) describes information Assouline Publishing Inc. and its subsidiaries and affiliates (collectively, “Assouline”) collect, use, share, and store, including information (i.e., information that personally identifies you, such as your name, email address or billing information, or other data that can be reasonably used to infer this information).

COLLECTING PERSONAL INFORMATION

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. This information is used to provide you with Assouline products and services, to allow Assouline to understand how you navigate the Site, and to provide advertising that is relevant to your interests.

Purchase informationIf you pre-order or purchase Assouline products from our Site, we request you provide your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. The purpose of collection is to provide products or services to you  to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising related to our products or services. Your information is shared with our processor Shopify, Google Analytics, PayPal, Klaviyo.Device informationIf you visit our Site and/or logged into your Assouline account, we record your version of web browser, IP address, time zone, cookie information, what products you view, search terms, and how you interact with the site. We collect this data to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site. Your information is shared with our processor Shopify, Google Analytics, PayPal, Klaviyo.Mailing list informationYou may choose to submit your email address via a submission form located on our Site or when you sign up for an Assouline account. Your email address may be used to send you news about Assouline-related services, surveys, products, or promotions. We may use one or more service providers to administer these messages, but we do not share your email address with spammers or any other third-party without your permission.

ONLINE TRACKING AND YOUR CHOICES

Website use informationLike many websites, we and our third-party partners analyze log file information and other data collected through cookies, web beacons, and other tracking technology, to collect information about your browsing behavior when you visit our Site. Information collected includes: your browser type, domains, page views, IP address, referring/exit pages, information about how you interact with our Site's webpages and third-party links, traffic and usage trends on the service, etc. We use session cookies to keep you logged in while you use features of our Site; these disappear after you close your browser. We also use persistent cookies, which stay in your browser and allow us to recognize you when you return to the Site. We use this to remember your information so you will not have to re-enter it, to better understand how you use our website and products and services, to diagnose and fix technology problems, and otherwise enhance our Site, products, and services. In some of our email messages, we use a "click-through URL" linked to content on the Site. We track this click-through data to help us measure the effectiveness of our customer communications. We also use third-party analytics tools (including Google Analytics) to assist us with analyzing and improving our service. Most internet browsers automatically accept cookies, but you may be able to change the settings of your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you set your browser to reject cookies, parts of our Site may not work for you. Please note, depending on your type of device or browser, it may not be possible to delete or disable all tracking mechanisms on your device.

• Your selection of the "Do Not Track" option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. The only way to completely "opt out" of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device to delete and disable cookies and other tracking/recording tools.
• We permit third-party advertising partners to use cookies and other technology to collect information about your browsing activities over time and across different websites when you use our Site. For example, we use advertising services provided by third-party ad partners, such as Google Display Network, to market our services to you on other websites and online services. Through a process called "retargeting", each service places a cookie on your browser when you visit our Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity. To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when your cookies are set and you could select the "Do Not Track" option on your browser, though we have no control over and cannot confirm whether these third-party ad parties honor the "Do Not Track" browser signal. Additionally, many advertising companies are members of the NAI or DAA and/or provide opt-outs on those industry pages at NAI opt-out or DAA opt-out.

THIRD-PARTY SITES AND FEATURES

Our Site may contain links to other websites operated by third-parties and may include social media features such as Facebook and Twitter buttons (such as "Like," "Tweet" or "Pin"). These third-party sites may collect information about you if you click on a link and the social media sites may automatically record information about your browsing behavior every time you visit a site that has a social media button. Your interactions with these features are governed by the privacy policy of the company providing the feature, not by your privacy policy. We do not control what information these third-parties collect. Please review your privacy settings on your social media sites and think carefully before clicking on links which may take you to a third-party website.

Nextroll and our advertising partners use cookies and similar technologies on this site and around the web that collect and use personal data (e.g. your IP address) in order to select and deliver measurable and personalized advertising from this site. Please find more information on Nextroll's policy here:https://www.nextroll.com/privacy.

MINORS

The Site is not intended for individuals under the age of 13. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

SHARING DATA AND PERSONAL INFORMATION

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:

• We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
• We may share your Personal Information to comply with applicable laws and regulation, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
• We use Google Analytics to help us understand how our customers us the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location). For more information about how targeted advertising works, you can visit the Network Advertising Initiative's ("NAI") educational page at: https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

USING PERSONAL INFORMATION

We use your Personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

Lawful basisPursuant to the General Data Protection Regulation ("GDPR"), if you are a resident of the European Economic Area ("EEA"), we process your personal information under the following lawful basis:

1. Your consent;
2. The performance of the contract between you and the Site;
3. For our legitimate interests, which do not override your fundamental rights and freedoms.

RetentionWhen you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right or erasure, please see the 'Your rights' section below.

Automatic decision-makingIf you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We DO NOT engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.Services that include elements of automated decision-making include:

• Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
• Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.

SELLING PERSONAL INFORMATION

Our Site sells Personal Information, as defined by the California Consumer Privacy Act of 2018 ("CCPA").

• In the past 12 months, we have collected the categories listed below of personal information from California residents ("California Personal Information"): identifiers; payment information, signature, physical characteristics or descriptions; characteristics of protected classifications under California or federal law; internet or other electronic network activity information; commercial information; audio, electronic and visual information; professional or employment-related information; education information, geolocation; and inferences drawn from the categories in this paragraph.
• In the past 12 months, we may have "sold" (as this term is defined in CCPA) the categories (listed below) of California Personal Information to third parties: identifiers (e.g., online identifiers and internet protocol addresses); internet or other electronic network activity information; geolocation information and commercial information. We note that the "sale" of such categories of personal information occurs primarily through exchanging this information with advertising and media companies through our use of cookies and our online advertising practices.

YOUR RIGHTS

GDPRIf you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through emailing customerservice@assouline.com. Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify's GDPR Whitepaper:https://help.shopify.com/en/manual/your-account/privacy/GDPR.

CCPAIf you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the 'Right to Know'), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us via email at customerservice@assouline.com.

COOKIES

A cookie is a small amount of information that's downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don't have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it's their first time visiting or if they are a frequent visitor.We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.

Cookie settingsThe length of time that a cookie remains on your computer or mobile device depends on whether it is a "persistent" or "session" cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your users experience and parts of our website may no longer be fully accessible.Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser's "Tools" or "Preferences" menu.Additionally, please note that blocking cookies may not completely prevent how we share information with third-parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the "Behavioral Advertising" section above.

Cookie list_session_id, unique token, sessional, Allows Shopify to store information about your session (referrer, landing page, etc).

_shopify_visit, no data held, Persistent for 30 minutes from the last visit, Used by our website provider’s internal stats tracker to record the number of visits.

_shopify_uniq, no data held, expires midnight (relative to the visitor) of the next day, Counts the number of visits to a store by a single customer.

cart, unique token, persistent for 2 weeks, Stores information about the contents of your cart.

_secure_session_id, unique token, sessional storefront_digest, unique token, indefinite If the shop has a password, this is used to determine if the current visitor has access.

PREF, persistent for a very short period, Set by Google and tracks who visits the store and from where.

CHANGES

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.

SECURITY

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

CONTACTIf you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer atcustomerservice@assouline.com or by mail at

Assouline
[Re: Privacy Compliance Officer]
3 Park Avenue, 27th Floor
New York, New York US 10016