Privacy Policy

PRIVACY NOTICE

Last modified: July 17, 2017

AND COUTURE and its affiliates (collectively, " AND COUTURE") respect your concerns about privacy. This Privacy Notice applies to personal information we collect (i) on this website, (ii) at AND COUTURE stores, AND COUTURE Factory Outlet Stores (collectively, the "Stores"), and (iii) through the other channels described below. AND COUTURE is responsible for this website.

The Privacy Notice describes the types of personal information we collect on this site, in our Stores, and in other ways discussed below, how we may use that information and with whom we may share it. The notice also describes the measures we take to protect the security of the personal information. We also tell you how you can reach us to ask us to (i) access, change or not use the personal information you have provided to us, (ii) withdraw any consent you previously provided to us, (iii) tell us to refrain from communicating with you about our products or services, and (iv) answer any questions you may have about our privacy practices.

Information We Collect and How We Use It

Individuals may choose to provide personal information (such as name, contact details and payment information) through this website, in our Stores and through the other channels described below. Here are the ways you may provide the information and the types of information you may submit. We also tell you how we may use the information.

Our Website

Shopping

You may be able to purchase AND COUTURE products and gift cards on this website. To process your purchase, we ask for information such as your name, billing and shipping address, telephone number, email address and payment card information. We use this information to process your purchase, confirm your order and deliver the items to you. If you give us permission, we also may use your contact information to communicate with you about our products, services and promotions.

If you purchase an item or gift card on this site or ask us to deliver your purchase to someone else, we ask for the recipient's name, postal address and email address. We use this information to send the gift card or item to the recipient. If you ask us to do so, we also may use this information to notify the recipient of your gift before it arrives.

Surveys, Sweepstakes and Promotions

On this website, you may be able to participate in surveys, sweepstakes and other promotions. If you choose to participate in these promotions, we may ask you for information such as your name, email address, postal address and telephone number. We use the information you provide to administer our contests, sweepstakes and other promotions. We also may use the information to communicate with you about our products, services and promotions, but only if you have given us your consent to do so.

Electronic Newsletters

You may be able to sign up on this site to receive electronic newsletters and promotional emails from AND COUTURE, including new ideas, special offers and event information. To sign up, we may ask you for information such as your name, email address, postal address, telephone number, age, gender, shopping preferences and email preferences. We use this information to send you communications about our products and services, invitations to specials sales and events at Stores located near you, and notices of new arrivals. We also use this information to tailor our newsletters to reflect your preferences. You can choose at any time not to receive marketing emails from us by clicking on the unsubscribe link within our marketing emails. There is no charge to you to unsubscribe.

Blogs

You may be able to submit comments to blogs we host on this website. You may include personal information in your comment, and you also may submit your name with your comment. We use your name to identify you as a commenter.

Email to a Friend

You may be able to share certain content from this website with your friends. To send information to your friends, we ask for your friends' and your email addresses. We use this information only to fulfill your request. We do not retain the information you provide in connection with this feature, except to send the requested content. We will not include any other advertisements within the messages sent to your friends.

Contact Us

If you communicate with us through the "Contact Us" link on this site, we may ask you for information such as your name, email address, zip code and telephone number. We use this information to respond to and communicate with you about your questions and comments.

Other Site Features

We offer visitors to this website various features for their information and enjoyment, which we may change from time to time. We may ask you to submit certain personal information so we can provide you with these features and send you communications about our products, services and promotions.

Information Collected by Automated Means

We obtain certain information by automated means when you visit our website, such as through cookies, web beacons, and web server logs. The information we collect in this manner includes the IP address of the device you use to connect to the Internet, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, dates and times of website visits and the pages accessed. By collecting this information, we learn how to best tailor our website to our visitors and understand what products and services you might prefer. Both we and others (such as our service providers) may collect personal information about our visitors’ online activities over time and across third-party websites.

Like many companies, we use "cookies" on this website. Cookies are bits of text that are placed on your computer's hard drive when you visit certain websites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site. We use cookies, for example, to preserve the contents of your virtual shopping bag between visits. We also use cookies to measure activity on the site and determine which areas and features of the site are the most popular.

Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie and how to disable existing cookies. Without cookies, however, you may not be able to take full advantage of all our site features. For example, if you turn off cookies or refuse them, you will not be able to make purchases on the site.

Certain pages on this website contain "web beacons" (also known as Internet tags, pixel tags and clear GIFs). Web beacons are used for internal purposes, such as to obtain the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, and the type of browser used to view the page. We also retain service providers who use web beacons to assess the effectiveness of our email communications and learn what pages our visitors viewed.

We use information collected through these automated means for purposes such as (i) customizing our users' visits to our website, (ii) delivering content tailored to our users' interests and the manner in which our users browse our sites, and (iii) managing our sites and other aspects of our business. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.

We also may use third party web analytics services, such as those of Adobe Analytics and Google Analytics, to measure the effectiveness of our advertising and determine how visitors use this website. These service providers’ tools, including cookies and web beacons, allow us to collect information such as the state and zip code from which our visitors come and the IP addresses of our visitors' computers. To opt out of aggregation and analysis of data collected by Adobe Analytics and Google Analytics, please click here and here.

Interest-Based Advertising

We may collect information about your online activities on our website to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. This section of our Privacy Notice provides details and explains how to exercise your choices.

You may see certain ads on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites by collecting information through automated means, including through the use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our website and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

You also may opt out of ad network interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/.

Our Stores

Here are some of the ways we collect personal information in our Stores and a description of how we use the information:

Shopping

When you buy products or obtain services in our Stores, we ask you for information we need to process your purchase or provide you with the services you requested. Depending on the payment method you use, and as permitted by applicable law, we may ask for information such as your name, mailing address, telephone number, driver's license or ID number, passport number, checking account information or payment card information. We also collect information about your purchase, such as the items you bought, the price of the items, the payment method you used and if the product was on sale. We use this information to process your transaction.

Customer Registry

You may join our Customer Registry at our Stores. To join, we ask for your name, postal address, email address and mobile and home telephone numbers. You also may choose to provide us with your birth date and gender. We use this information to communicate with you about our products, services and promotions and for other marketing and customer service purposes.

Customer Satisfaction Surveys

When you buy products or obtain services in our Stores, we may ask you to complete a customer satisfaction survey. If you choose to do so, you may provide information such as your name, email address, telephone number, age, gender and other demographic information, in addition to your comments. Providing any of this information is optional. We use the information you provide to improve our products and services, and enhance your shopping experience.

Other Ways We Collect Personal Information

QR Codes

We use QR codes in connection with certain promotions, contests and special events. If you scan our QR code, you will get an invitation on your mobile device to join our mailing list. To sign up, we ask you for information such as your name, mailing address, email address, telephone numbers, and age. We use the information to communicate with you about our products, services and promotions.

Customer Assistance

You may call our customer service line for information about our products or personal shopping advice. If you do so, we may ask you for information such as your name, email address, postal address, telephone number and, if you choose to make a purchase, your payment card information. We use this information to respond to your request and process your transaction.

Department Stores

Our products are available for sale in many department stores. Personal information collected in these department stores is not provided to AND COUTURE. This Privacy Notice does not address the information practices of department stores in which our products are sold. Department stores may have their own privacy notices or policies, which we strongly suggest you review when you provide them with your personal information. We are not responsible for the department stores' personal information practices.

Information We Share

We do not sell or otherwise disclose personal information about our customers, except as described here. We may share the personal information you provide to us with our affiliates, licensees and joint venture partners for the purposes described in this Privacy Notice. We also may share the information with our service providers who perform services on our behalf based on our instructions. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We may disclose information about you (i) if we are required to do so by law or legal process (such as a court order), (ii) in response to a request by law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

Links to Other Sites

This website may contain links to other sites for your convenience and information. These sites may be operated by companies not affiliated with AND COUTURE. Linked sites may have their own privacy policies, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with AND COUTURE, any use of those sites, or the privacy practices of those sites.

How We Protect Personal Information

We maintain appropriate administrative, technical and physical safeguards to protect the personal information you provide on this website against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use and other unlawful forms of processing. When accessing a secure site, the first characters of the site address change from "http" to "https." If you are using a web browser or firewall that does not permit communications through secure sites, you will not be able to make purchases on our site.

Access and Correction

Subject to applicable law, we provide you with access to personal information we have retained about you and the ability to review, correct, update, block or delete the information where it is inaccurate. Subject to applicable law, we may limit or deny access to personal information where providing such access is unreasonably burdensome or expensive under the circumstances. Please submit your request to the address specified in the "How to Contact Us" section below. Please include your name, email address and postal address in your request.

Your Choices

We offer you certain choices about how we communicate with you and what information we collect from you. You may withdraw any consent you previously provided to us or object at any time on legitimate grounds and free of charge to the processing of your personal information, and we will apply your preferences going forward.

You can choose not to receive marketing communications from us by clicking on the unsubscribe link in our marketing emails or contacting us as specified in the "How to Contact Us" section below. Please include your name, email address and postal address if you send us your request by email or postal mail. Our website is not designed to respond to "do not track" signals received from browsers.

Children's Privacy

This website is not directed to children under the age of thirteen and we do not knowingly collect personal information from children under the age of thirteen on the site. If we become aware that we have inadvertently received personal information from a visitor under the age of thirteen on this site, we will delete the information from our records.

Updates to Our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices or relevant laws. We will post a prominent notice on the site to notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was updated.

How to Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us as indicated below:

Write to:

AND COUTURE
Anthony L. Trullenque, Esq.

Law Offices of Anthony L. Trullenque

7098 Bonita Drive

Miami Beach, Florida 33141

Telephone: (305) 868-3363

PRIVACY POLICY

Effective date: July 17, 2017

AND COUTURE, along with its affiliates, respect your concerns about privacy. This Policy describes how AND COUTURE implements the Privacy Policy for Consumer Personal Data.

For purposes of this Policy:

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

“Consumer” means any natural person, but excludes any individual acting in his or her capacity as a Worker.

“Partner” means any licensing or franchising partner or other third party operating a store under any of the AND COUTURE brands.

“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by AND COUTURE in the U.S., 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, sex life, 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.

“Sites” means www.andcouture.com.

“Store” means a store operated under any of the AND COUTURE brands by AND COUTURE or any of its affiliates or Partners.

“Worker” means any current, former or prospective employee, temporary worker, intern, contractor or other non-permanent employee of AND COUTURE or any of its affiliates.

Types of Personal Data AND COUTURE Collects

AND COUTURE collects Personal Data directly from Consumers through the Sites and in Stores. AND COUTURE obtains, uses, discloses and otherwise processes Personal Data about its Consumers to (i) process transactions they request, including e-commerce and mobile transactions, (ii) improve its Stores, Sites, quality of service, and Consumers’ shopping experience, (iii) send communications about its products, services, campaigns and promotions, (iv) prevent and detect fraud and abuse, (v) process information or claims in connection with incidents at Stores, (vi) enable service providers to perform certain activities on the company’s behalf, and (vii) comply with legal obligations, policies and procedures and for internal administrative and analytics purposes.

Name;
age;
date of birth
gender;
demographic information;
billing and shipping address;
driver’s license or ID number;
passport number;
telephone number;
email address;
payment card information;
checking account information;
shopping preferences and purchase history;
information obtained by automated means when Consumers visit the Sites, such as through cookies, web beacons, and web server logs (including the IP address of the device the Consumer uses to connect to the Internet, domain name, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on the Sites, dates and times of Site visits and the pages accessed); and
any other information Consumers provide or generate on the Sites and in Stores.

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

In addition, AND COUTURE obtains Personal Data, such as contact information and financial account information, of representatives of vendors and other business partners. AND COUTURE uses this information to manage its relationships with its vendors and business partners, process payments, expenses and reimbursements, and carry out the company’s obligations under its contracts with the relevant organizations.

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

Notice

AND COUTURE provides information in this Policy and the privacy notices on the Sites about its Consumer Personal Data practices, including the types of Personal Data AND COUTURE collects, the types of third parties to which AND COUTURE 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 AND COUTURE about its practices concerning Personal Data.

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

Choice

AND COUTURE 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 Privacy Shield Principles, AND COUTURE obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact AND COUTURE as indicated below regarding the company’s use or disclosure of their Personal Data. Unless AND COUTURE offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy.

AND COUTURE shares Consumer Personal Data with its affiliates and subsidiaries. AND COUTURE 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. AND COUTURE 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 and the privacy notices on the Sites describe AND COUTURE’s sharing of Consumer Personal Data.

Except as permitted or required by applicable law, AND COUTURE provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. AND COUTURE 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 Privacy Shield Principles, and (iii) notify AND COUTURE 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 Privacy Shield Principles.

With respect to transfers of Consumer Personal Data to third-party Processors, AND COUTURE (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 Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with AND COUTURE’s obligations under the Privacy Shield Principles, (v) requires the Processor to notify AND COUTURE if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield 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. AND COUTURE remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless AND COUTURE proves that it is not responsible for the event giving rise to the damage.

Security

AND COUTURE 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

AND COUTURE limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. AND COUTURE 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, AND COUTURE 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, AND COUTURE 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 AND COUTURE as indicated below to request that AND COUTURE update or correct relevant Personal Data.

Subject to applicable law, AND COUTURE 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, AND COUTURE provides Consumers with reasonable access to the Personal Data AND COUTURE maintains about them. AND COUTURE also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate. AND COUTURE 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 AND COUTURE as indicated below.

Recourse, Enforcement and Liability

Consumers may file a complaint concerning AND COUTURE’s processing of their Personal Data. AND COUTURE will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact AND COUTURE as specified below about complaints regarding AND COUTURE’s Consumer Personal Data practices.

How to Contact AND COUTURE

To contact AND COUTURE with questions or concerns about this Policy or AND COUTURE’s Consumer Personal Data practices:

Write to:

AND COUTURE
Anthony L. Trullenque, Esq.

Law Offices of Anthony L. Trullenque

7098 Bonita Drive

Miami Beach, Florida 33141

Telephone: (305) 868-3363

Notice

We notify our Customers and Workers about the purposes for which we collect and use Personal Information, the types of third parties to which we disclose the information (for example, service providers that process Personal Information on our behalf), certain privacy rights of our Customers and Workers (such as the right to access Personal Information and the choice for limiting the use and disclosure of the information), and how to contact us about our practices concerning Personal Information.

Purpose of Collection and Use of Personal Information

AND COUTURE and its affiliates collect Personal Information through their Sites and in their Stores. In addition, Workers submit Personal Information to AND COUTURE and its affiliates in connection with the employment relationship or services performed for AND COUTURE.

We obtain, use, disclose and otherwise process Personal Information about our Customers to (i) process transactions they request, including e-commerce and mobile transactions, (ii) improve our Stores, Sites, quality of service, and Customers' shopping experience, (iii) send communications about our products, services, campaigns and promotions, (iv) prevent and detect fraud and abuse, (v) process information or claims in connection with incidents at our Stores, (vi) enable our service providers to perform certain activities on our behalf, and (vii) comply with our legal obligations, policies and procedures and for internal administrative and analytics purposes.

We obtain, use, disclose and otherwise process Personal Information about our current, former and prospective Workers to (i) carry out and support our human resources functions and activities, (ii) carry out our obligations under employments contracts and employment and benefits laws, (iii) administer employee participation in benefits, compensation, human resources and training plans and programs, (iv) manage employee purchases from AND COUTURE, (v) manage employee performance, (vi) implement compliance and discipline procedures, and investigate and report on employee compliance and discipline, (vii) comply with our legal obligations, carry out investigations and for internal administrative and analytics purposes, and (viii) manage and conduct AND COUTURE's business activities. AND COUTURE obtains, uses, discloses and otherwise processes Personal Information about its Contractors to (i) carry out and support AND COUTURE's procurement functions and activities, (ii) carry out AND COUTURE's contractual and legal obligations, (iii) manage Contractors' performance, (iv) implement compliance procedures, and investigate and report on Contractor compliance, (v) comply with AND COUTURE's legal obligations, carry out investigations and perform internal administrative and analytics activities, and (vi) manage and conduct AND COUTURE's business activities.

We obtain, use, disclose and otherwise process Personal Information about Workers' emergency contacts and other individuals (such as dependents and beneficiaries) to the extent our Workers provide the information to us. We process this information to comply with our legal obligations and for internal administrative purposes. To the extent necessary or appropriate for compliance with relevant legal or contractual obligations, we process Sensitive Information about our Workers, including for purposes of managing attendance and Worker records, and organizing elections of employees' union representatives, and to protect the health and safety of our Workers.

Choice

We do not use Personal Information for purposes incompatible with the purposes for which we originally collected the information without notifying the relevant individuals of such uses and offering an opportunity to opt out.

We may disclose Personal Information without offering individuals an opportunity to opt out (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We also reserve the right to transfer Personal Information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use Personal Information you have provided to us in a manner that is consistent with our Privacy Notice.

Onward Transfer of Personal Information

We may share Personal Information with service providers we have retained to perform services on our behalf. We require service providers to whom we disclose Personal Information and who are not subject to laws based on the Swiss Federal Data Protection Act (DPA), to contractually agree to provide at least the same level of protection for Personal Information as is required by the relevant Safe Harbor principles.

Access to Personal Information

AND COUTURE provides Customers and Workers with reasonable access to the Personal Information maintained about them. We also provide a reasonable opportunity, as required by applicable law, to correct, amend or delete that information where it is inaccurate. We may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances or as otherwise permitted by the Safe Harbor principles. To obtain access to Personal Information, Customers may contact AND COUTURE as specified in the "How to Contact Us" section of this Policy. Workers should submit requests for access to their Personal Information to Human Resources representative.

Security

AND COUTURE maintains reasonable administrative, technical and physical safeguards to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity

AND COUTURE takes reasonable steps to ensure that Personal Information the company collects is relevant for the purposes for which it is to be used and that the information is reliable for its intended use and is accurate, complete and current. We depend on our Customers and Workers to update and correct their Personal Information, or ask us to do so, whenever necessary or appropriate.

Enforcement

Customers and Workers may file a complaint with AND COUTURE in connection with the processing of their Personal Information under the Safe Harbor principles. We will also cooperate with the following dispute resolution bodies to address individuals' complaints regarding privacy issues: (i) for Customer complaints, we cooperate with JAMS in accordance with the JAMS Safe Harbor Program, which is described on the JAMS website at http://www.jamsadr.com/safeharbor/; (ii) for complaints concerning our handling of Worker Personal Information, we will take steps to remedy any issues arising out of a failure to comply with the Safe Harbor principles. Please contact us as specified below to address any complaints regarding our Personal Information practices

How to Contact Us

Please address any questions or concerns regarding our Privacy Policy or our practices concerning Personal Information by:

Anthony L. Trullenque, Esq.

Law Offices of Anthony L. Trullenque

7098 Bonita Drive

Miami Beach, Florida 33141

Telephone: (305) 868-3363

Facsimile: (305) 864-3379