Commitment to Privacy

TSMI LTD., as the operator of the THOMAS SABO Online Shop (“TSMI”), values its customers and respects their privacy. We have adopted appropriate measures to ensure the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used

This privacy policy (this “Policy”) describes the personal information we may collect from you, the purposes for which we collect it, how we use it and when we may share it with third parties. This Policy also describes the choices you can make about how we collect, use and disclose your information. TSMI will not collect, use or disclose your personal information other than in compliance with this Policy.

By using the www.shop.thomassabo.com website and/or making online purchases of products, you agree to the terms and conditions of TSMI's Policy. If our Policy changes in the future, we will notify our customers and website users of any such changes by posting an updated policy on our website.

Following the posting of such changes, your continued use of the www.shop.thomassabo.com website will constitute your acceptance of these changes and you will be bound by such changes. If you do not continue to use the www.shop.thomassabo.com website following a change to our Policy but take no other action with respect to your personal information, our use of that information will remain subject to our Policy as it was in effect prior to the change. You are responsible for regularly reviewing this Policy and any changes thereto.

Information Collected by TSMI

We may collect personal information from you when you save or otherwise provide your personal information to us, such as by setting up a user account and password, logging in as a registered user of www.shop.thomassabo.com, searching for a product, making an order for a product, providing information in your account (and you might have more than one, if you've used more than one e-mail address when shopping with us), communicating with us by e-mail, or otherwise. As a result of these actions, you might supply us with personal information such as your name, e-mail and postal addresses, phone numbers, credit card information, product interest information and financial information and, in certain circumstances, your opinions and individual preferences.

TSMI's website is directed for use by adults. TSMI does not knowingly collect any personal information from children under the age of 13. Those under age 13 should not use TSMI's website to provide TSMI with any personal information.

Collection Purposes

TSMI may use your personal information to

1. process your order and to answer questions about the status of your order;
2. send you products that you have ordered;
3. send you products that you have ordered;
4. communicate with you (via e-mail, post or otherwise) and provide you with promotional materials and additional information regarding our products, services, promotions and special offers;
5. communicate with you (via e-mail, post or otherwise) and provide you with promotional materials and additional information regarding our products, services, promotions and special offers;
6. help us learn more about your shopping preferences;
   
   and
7. conduct marketing and performance research to assist us in measuring our customer service, benchmarking our performance and to help us improve our shopping experiences and product offerings.

Provided below, you may always choose not to receive promotional materials or marketing information.

Sharing of Information with Third Parties

We do not sell or rent your personal information to non-affiliated third parties except as permitted by law. However, in the event of the sale of all or substantially all of our business or another similar transaction, we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information for the purposes of evaluating the proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in this Policy.

We may transfer personal information to non-affiliated third parties for processing pursuant to agreements that prohibit the third parties from using or disclosing the personal information other than for the purpose of processing and which impose security safeguards appropriate to the sensitivity of the information. Furthermore, we may forward your data to business information services and collection agencies for the purpose of credit and identity assessment, credit monitoring and direct debit processes. This is designed to prevent any payment difficulties and to counteract any damages arising from such matter.

We reserve the right to disclose your personal information as required by law, in response to legal process and law enforcement requests, and as necessary to protect the property, interest and rights of TSMI.

TSMI's website may contain links to websites operated by third parties. These websites may collect your personal information. This Policy does not apply to the practices of third parties and TSMI does not assume any responsibility for, and by using this website and/or accessing a third party's website from this website, you release TSMI from any responsibility for, the actions, practices and omissions of third parties. Please check the privacy policy of each site you visit.

Cookies

We use cookies (small text files stored on your computer's hard drive) to simplify navigation for you. Only these session cookies permit you to use, and comfortably read, the webpage-wide shopping basket displayed to ascertain how many articles you have in your shopping basket, and what the current shopping total is, at any given time. If you do not wish to use cookies, set your browser to block cookies. However, we would like to point out that this will also block the use of the shopping basket function.

Remarketing

We use Google Remarketing, a service offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (hereinafter “Google”).

Here, Google collates information relating to your visit to our Website. For this, Google uses cookies, which are text files that are stored on your computer. Within the context of remarketing, such cookies are used – on the basis of your visit to our Website – to show you online advertising for our products and services when you visit other Websites.

Processing of the data may, under certain circumstances, also take place in the USA. Google has committed itself to adhering to the US Safe Harbor Framework with the European Union and Switzerland for the collation, utilisation and storage of personal data from Switzerland and the European Union member states. The US Safe Harbor Framework was initiated by the US Department of Commerce. With its certification, Google documents that it adheres to the US Safe Harbor data protection agreements regarding the disclosure, options, data security, security, access and implementation. You can find the Google data protection terms and conditions here.

You can deactivate the use of cookies with Google. For detailed information on deactivating cookies, go to the Google ads deactivation page. Alternatively, users can have the utilisation of cookies deactivated by third parties by logging on to the Network Initiative deactivate page. However, you will then not be able to fully use all the functions on our Website. For further tips and information, click here.

Access or Change to Personal Information, Consent and Inquiries or Complaints

TSMI will ensure that the personal information it collects is as accurate, complete and up to date as is necessary for the purposes for which it is to be used. You are entitled to request access to in correction of your personal information collected by us. In order to make such a request, or if you have any questions or to make any complaint in relation to this Policy and TSMI's privacy practices, please contact our Privacy Officer by writing to:

Privacy Officer
TSMI LTD.
1651 St-Regis
Dollard-des-Ormeaux, QC H9B 3H7
CANADA

However, this does not apply to the data required for processing your orders. Once we have received your written withdrawal, we will not use, process or forward the relevant data for purposes other than processing your orders and we will discontinue sending you marketing materials, including our catalogues.

Retention of Personal Information

We will keep your personal information only as long as is reasonably necessary for the purposes described in this Policy or such longer period as may be required by applicable law.

Security

We have adopted appropriate measures to ensure the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used.

Status: December 2011