Privacy Policy

 USA SSENSE Privacy Policies

Last updated: June 1, 2023

1. About this Policy

1.1 This Privacy Policy (“Policy”) explains how Atallah Group US Inc. (together with our affiliates and subsidiaries, “SSENSE,” “we,” “us,” or “our”) collects, uses and discloses information that, alone or in combination with other information, relates to you (“Personal Data”) when you use our website, ssense.com (the “Website”), the SSENSE mobile app (the “App”), purchase our Products, or otherwise engage with us online and offline, such as when you communicate with our customer service center (collectively, the “Services”).

This Policy is intended for individuals in the United States. If you live outside of the United States, please review our Privacy Policy applicable to all other consumers (click here if you live in the United Kingdom and the European Union, click here if you live in the People’s Republic of China, click here if you live in the Republic of South Korea, click here if you live elsewhere).  

1.2 Please take the time to read this Policy carefully. By using or accessing our Services, you agree to this Policy.  If you have any questions or comments, please contact us by phone [phone] or via email at [e-mail].

2. What Personal Data does SSENSE collect and why?

2.1 We collect several types of Personal Data for several reasons, including:

Categories of Personal Data we collect	Sources	Business or commercial purposes for collecting
Identifiers, including (i) full name and username/password; (ii) contact information such as your phone number, email address, or shipping address; and (iii) Customer ID	You Automatically Service providers	Operational purposes, including administering and maintaining the Services, receiving, processing and fulfilling your order or registration with the Services, communicating with you about your order or account  Operational and quality assurance, including to perform data analytics, statistics and audience measurement, to maintain and improve the Services Commercial purposes, including to provide you with exclusive email updates, promotions, and notifications about our products, the Services, or those of our affiliates  Security and fraud prevention Advertising and marketing purposes Legal purposes
Commercial information, including order history and shopping preferences	You Automatically Service providers	Operational purposes, including administering and maintaining the Services, receiving, processing and fulfilling your order or registration with the Services, communicating with you about your order or account  Operational and quality assurance, including to perform data analytics, statistics and audience measurement, to maintain and improve the Services Commercial purposes, including to provide you with exclusive email updates, promotions, and notifications about our products, the Services, or those of our affiliates  Security and fraud prevention Advertising and marketing purposes Legal purposes
Financial information (Cardholder Name, Card Expiration Date, Card number, CVV or CID), which is collected through our third-party payment processors on our behalf	You	Operational purposes, including administering and maintaining the Services, receiving, processing and fulfilling your order or registration with the Services, communicating with you about your order or account  Security and fraud prevention Legal purposes
Internet and other electronic network activity, such as browsing history, search history, your interaction with the Services and advertisements (such as click or touch stream data, movement, scroll, keystroke activity, pages you visit, links you click, the webpages you visit before and after visiting the Services, and the subject of the ads you click or scroll over)	Automatically Service providers	Operational purposes, including administering and maintaining the Services, receiving, processing and fulfilling your order or registration with the Services, communicating with you about your order or account  Operational and quality assurance, including to perform data analytics, statistics and audience measurement, to maintain and improve the Services Commercial purposes, including to provide you with exclusive email updates, promotions, and notifications about our products, the Services, or those of our affiliates  Security and fraud prevention Advertising and marketing purposes Legal purposes
Technical data collected from your computer or device, including your IP address, device type (such as model and manufacturer), device or mobile advertising identification number, browser (including browser type, language, and preferences), operating system, internet service provider, domain name, and other technical information.	Automatically Service providers	Operational and quality assurance, including to perform data analytics, statistics and audience measurement, to maintain and improve the Services Commercial purposes, including to provide you with exclusive email updates, promotions, and notifications about our products, the Services, or those of our affiliates  Security and fraud prevention Advertising and marketing purposes Legal purposes
Geolocation data (if enabled)	Automatically Service providers	Operational and quality assurance, including to perform data analytics, statistics and audience measurement, to maintain and improve the Services Commercial purposes, including to provide you with exclusive email updates, promotions, and notifications about our products, the Services, or those of our affiliates  Security and fraud prevention Advertising and marketing purposes Legal purposes
Sensory information, such as call recordings	You	Operational purposes, including administering and maintaining the Services, receiving, processing and fulfilling your order or registration with the Services, communicating with you about your order or account  Operational and quality assurance, including to perform data analytics, statistics and audience measurement, to maintain and improve the Services Security and fraud prevention Legal purposes
Inferences drawn from Personal Data collected	Automatically Service providers	Operational purposes, including administering and maintaining the Services, receiving, processing and fulfilling your order or registration with the Services, communicating with you about your order or account  Operational and quality assurance, including to perform data analytics, statistics and audience measurement, to maintain and improve the Services Commercial purposes, including to provide you with exclusive email updates, promotions, and notifications about our products, the Services, or those of our affiliates  Security and fraud prevention Advertising and marketing purposes Legal purposes
User-generated content or feedback that you provide	You	Operational and quality assurance, including to perform data analytics, statistics and audience measurement, to maintain and improve the Services Commercial purposes, including to provide you with exclusive email updates, promotions, and notifications about our products, the Services, or those of our affiliates  Security and fraud prevention Advertising and marketing purposes Legal purposes

2.2 Please note that the information you provide may be necessary for us to provide the Services and comply with our legal obligations. Without such information, we may not be able to provide the Services, including processing your order or answering your queries.

2.3 We combine Personal Data about you from your use of the Services with other Personal Data we obtain about you from third parties. We may aggregate and/or de-identify any information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation to derive possible interests about you or our customers, provide more relevant experiences for you or our customers, improve our Services, analytics, and advertising, and may disclose such data to any third parties.

2.4 “Internet and other electronic network activity” and “technical” information may be collected using our own or third party cookies and similar tracking technology, as explained further in the “Personalized Content, Advertising, and Your Choices” section below and our Cookie Notice, which is available below. Collecting this information enables us to better understand how visitors use the Services, where they come from, and what content is of interest. We use this information for our own operational, commercial, and quality assurance purposes, including internal analytics and to improve the quality and relevance of our Services.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Microsoft Edge, Google Chrome, Mozilla Firefox, or Apple Safari). As stated above, by blocking any or all cookies, you may not have access to certain features or offerings of the Services.

We use third parties to assist us in serving advertisements, tracking site usage statistics, and providing content-sharing services to support the Services. These third parties may also use cookies and similar technologies to collect similar information about your use of the Services. We do not control these third-party technologies, and their use of your information is governed by those parties' privacy policies. For more information about how to opt out of these third parties’ use of your information, please see “Personalized Content, Advertising, and Your Choices” below.

3. To Whom does SSENSE disclose your Personal Data?

3.1 We may disclose your Personal Data to the following categories of recipients:

(a) to our affiliates and group companies under common ownership and/or control for purposes consistent with this Policy, and in particular, so that they may contact you regarding products and services that may be of interest to you. Our group companies include: Atallah Group Inc., Atallah Group Limited, Atallah Hong Kong Limited, Atallah Group US Inc., GAI Services PTY Limited, Atallah International Inc.

(b) to our third party vendors and service providers who provide data processing services to us, or who otherwise process Personal Data for purposes that are described in this Policy or notified to you when we collect your Personal Data. This may include disclosures to service providers we use in connection with the services they provide to us, including to support us in areas such as IT platform management or support services, infrastructure and application services, email and digital marketing, and data analytics. Our third party vendors, service providers and partners include, without being limited to: Zendesk, Klarna, Avalara, SAP, KIBO, StellaConnect, Loqate, Chatdesk, Clearsale, HostedPCI, First Data (Payeezy/IPG), Paypal, Pazien, Google, Facebook, Bing, Commission Junction, Partnerize, Rakuten, Braze, Mandrill, SendGrid, SurveyMonkey, AWS, Talon.One, Stripe, and Worldpay, which privacy policy is available here.

(c) to advertising partners that assist in tailoring and serving advertisements that are relevant to you. We may also allow third-party advertising technologies (e.g., ad networks and ad servers) to use cookies and similar technologies on the Services to deliver relevant and targeted content and advertising to you on other websites you visit and applications you use, as explained further in “Personalized Content, Advertising, and Your Choices” below.  

(d) to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

(e) to our professional advisors, such as auditors, advisors, legal representatives and similar providers in connection with the professional services that they provide to us.

(f) to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition, assignment, transfer, or other disposition of any part or all of our business or assets (including in connection with any bankruptcy or similar proceedings).

(g) to other recipients, with your consent.

4. Personalized Content, Advertising, and Your Choices

4.1 Online Analytics

We may use third-party web analytics services on our Services, such as those of Google Analytics, Braze, Facebook Connect, and others. These service providers use the sort of technology previously described in the “What Personal Data does SSENSE collect and why?” section to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section.  

4.2 Tailored Online Advertising

We may personalize the content and advertising that you see when using the Services through the use of third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as other websites you visit and other applications you use. These third-party advertising technologies may include Google AdWords Conversion, Google Dynamic Remarketing, Naver, ClearSale, and others. The ads may be based on various factors such as the content of the page you are visiting, information you provide such as your searches, demographic data, and other information we collect from you. These ads may be based on your current activity or your activity over time and may be tailored to your interests.

Also, third parties whose products or services are accessible or advertised via the Services may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of our Services. We also may disclose a hashed version of your email address with third-party advertising partners for purposes of delivering tailored advertising. 

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs.  You can also use the options below in the "Your Data Rights and Choices" section.  Please note that you may still receive advertisements even if you opt out of tailored advertising. In that case, the ads will just not be tailored. 

5. Your Data Rights and Choices

5.1 Marketing Communications

In accordance with applicable law, we may send you marketing and promotional emails. If you would like to opt out of email marketing, notify us at [e-mail] or follow the unsubscribe instructions in the email.  It may take some time, consistent with law, for us to process your request. Please note that even though you may opt-out of receiving marketing-related communications from us, we may still send you important administrative and transactional messages (e.g., notifications regarding updates to our legal terms).

5.2 Rights Regarding Your Information

You may have the right, in accordance with applicable U.S. law, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to: 

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
• Provide you access to and/or a copy of certain personal information we hold about you.
• Correct or update personal information we hold about you.
• Delete certain personal information we have about you.
• Provide you with information about the financial incentives that we offer to you, if any.
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable. 

You may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising” as described below. If you are a California resident, please see the “Notice to California Residents” section below for more information about your rights under California law.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information to provide our Services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify your identity, we may be unable to respond to your requests. 

To exercise any of these rights, you can contact us at [e-mail] with your name and type of request you are making.

You may be able to designate an authorized agent to make requests on your behalf. For an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.  

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

6. Notice to California Residents

If you are a California resident, the California Consumer Privacy Act, as amended (“CCPA”) requires us to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. 

We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities with which we disclose such information in the “What Personal Data does SSENSE collect and why?” and “Who does SSENSE disclose your Personal Data with?” sections of this Policy.  

6.2 Additional Privacy Rights

In addition to the rights set forth in the section above on “Your Choices Regarding ‘Sharing’ and ‘Selling,’” California residents may make certain requests about their personal information under the CCPA as set forth in the section above on “Rights Regarding Your Information.”

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note, in the limited circumstances that we process sensitive personal information (such as usernames in combination with passwords) as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA. We ask that users not include sensitive information in your correspondence with or any submissions to us.   

If you are a California resident and would like to exercise any of your legal rights under the CCPA, you can contact us at [e-mail] with your name and type of request you are making.

6.3 Shine the Light

California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

6.4 Do Not Track 

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Except as otherwise described herein with respect to legally required browser based opt outs, we do not recognize or respond to browser-initiated DNT signals, as there is no industry-wide framework for DNT signals. 

          7. Data security, retention and deletion

7.1 We use a variety of technical and organizational measures to protect your Personal Data. The measures we use are designed to provide a level of security appropriate to the sensitivity of your Personal Data, including physical measures, such as secure areas, technical measures, and organizational measures such as employee security through vetting and supervision. Although we maintain the controls listed herein, transmission of data is not without risk and the complete security of your Personal Data cannot be guaranteed.

7.2 We retain your Personal Data where we have an ongoing legitimate business need to do so, for example, to provide you with a product you have requested and honor return and chargeback periods, or to comply with applicable legal, tax or accounting requirements.

          8.    Minors

The Services are directed to individuals who are permitted to share their Personal Data without parental consent. If you are under age 16, please do not use or register on the Services. If you are the parent of a minor under age 16, and believe your child has provided us with Personal Data, please contact us as directed below in the “Contact us” section.

                                  9.    Linking to other websites

The Services may contain hyperlinks to sites owned or operated by third parties. These links are provided for your convenience only. Your use of third-party sites is subject to the terms and policies applicable to those sites and not this Policy. 

                                  10.   Updates to this Policy

We may update this Policy from time to time.  You can see when this Policy was last updated by checking the “last updated” date displayed at the top of this Policy. If we make a material change to the Policy, we will provide you with appropriate notice in accordance with legal requirements. To the extent permitted by law, your continued use of the Services constitutes your agreement to the Policy. 

          11.  Contact us

If you have any questions about this Policy, please contact us via email at [e-mail]. You can also write to us at:

SSENSE 

Data Protection 

333 Chabanel Street W #900 

Montreal QC H2N 2E7 

Canada