Privacy Policy
This Privacy Policy sets out how we, Essense of Australia, Inc, collect, store and use information about you when you use or interact with our website, truesociety.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from March 2nd, 2020, and last updated on July 9, 2021.
Information We Collect
Information We Collect When You Interact With Our Website
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
What Personal Information We Collect and Why
When you visit our website, sign up for an appointment, submit your bridal story, or request more information about True Society or any bridal shop in our network, we collect information automatically using tracking technologies, like cookies, and through web forms where you type in your information. We collect this information to provide you with what you request through the web form, to learn more about who is interested in our products and services, and to improve navigation experience on our pages.
We collect and process your personal information:
- When you visit our website
- When you schedule an appointment
- When you share your story with us
- When you make a request to receive information about True Society or our products
When you visit our website
Information You Share Directly:
In some places on True Society’s website, you can fill out web forms to schedule an appointment, register for an event, or submit your story to us. The specific personal information requested on these forms will vary based on the purpose of the form. We will ask you for information necessary for us to provide you with what you request through the form (for example, when you schedule an appointment, we will ask you for information like your name, email address, phone number, and other appointment related information, and for your email address if you want to submit your story). If you sign up to receive ongoing marketing communications from True Society, like a newsletter, you can always choose to opt out of further communications through a preferences page which will be linked from any marketing email you receive from True Society. You can also contact us by email at cs.usa@essensedesigns.com and notify us of your choice to opt out.
Information We Collect Automatically:
When you visit our website, including our web forms, we and our service providers acting on our behalf automatically collect certain information using tracking technologies like cookies, web beacons, and similar technologies. We use this information to understand how our visitors are using them and which pages and features of the website are most popular. This helps us understand how we can improve our website and track performance of our advertisements. In addition, we use tracking technologies to help improve the navigation experience on the website. We don’t sell this information to third parties.
When you schedule an appointment
Information You Share Directly:
In order to schedule an appointment on this website, a user must first complete the appointment scheduling form. During the appointment scheduling process, a user is required to give certain information (such as name, phone number, email address, and wedding date). This information is used to reserve the date and time that you have selected in the booking form, to contact you about your appointment in order to confirm or change the date of the appointment, and for communicating anything related to your appointment status, date, and/or time. Once the booking form is submitted, data is transferred to our service partner (Bridal Live) servers, and the store location you have booked at will contact you for appointment confirmations.
Information We Collect Automatically:
When you fill out an appointment booking form, we and our service providers acting on our behalf automatically collect certain information using tracking technologies like cookies, web beacons, and similar technologies. We use this information to understand how our visitors are using the appointment form, which type of appointment is being booked, and the date and time of the booking.
When you share your story with us or when you request to receive information about True Society or our products
You may share personal information, like your contact information, with a member of our support team when you communicate with them. We keep a record of this interaction.
User-generated content: Reviews, comments, communications and other content:
You may choose to provide us with your own original content such as personal photographs, videos, product reviews, comments, text, audio/visual recordings, images, and/or other materials (“User Content”). True Society welcomes you to submit your User Content to us, via our Sites or other means we may permit, such as but not limited to replying to a social media post with a designated hashtag. True Society and/or its designees may also reach out to you through social media, email, apps, or other means to request the use of User Content you have published elsewhere and/or not submitted directly to True Society. By submitting your User Content to us, including via our Sites, or by otherwise allowing True Society to use your User Content, you are agreeing to the following:
You grant to True Society, its retailers, and affiliated partners (including brands, vendors and media sites) a non-exclusive, irrevocable, worldwide, transferable, royalty-free, perpetual, unrestricted, sub-licensable right to use, market and promote your User Content in any manner or media now known or later developed, for any purpose, including without limitation the rights to reproduce, display, publish, perform, translate, transmit, broadcast, modify, adapt, alter, distribute, present, commercialize, create derivative works from your User Content, and exercise all intellectual property and other rights with respect to your User Content, without any compensation or notice to you or any approval from you, with or without your name (whether your legal name or your user name on the applicable platform), including, without limitation, in advertising and promotion of True Society and its brands and/or products. Without limiting the foregoing, you represent that you have all consents and licenses necessary to use and to authorize True Society and our designees to use your User Content in the manner permitted in these Terms. You agree that your User Content is not confidential.
You represent and warrant to True Society as follows: that your User Content is your own original work and/or that you have the right to grant the rights and permissions set forth in the Terms; you have obtained all necessary licenses and permissions from all applicable third parties required for the submission of the User Content and use as permitted in the Terms; you will comply with all FTC disclosure requirements and guidelines relating to your User Content; the posting and/or display and/or other permitted use of your User Content by True Society or those deriving rights through True Society will not violate any provision of any applicable law or regulation, or in any way infringe or violate rights of any third parties, including but not limited to copyright and other intellectual property, privacy or publicity rights; you waive any and all moral rights that exist in your User Content and any derivative works made therefrom.
When you search for one of our stores
Location information.
We may collect your location in order to bring you more relevant information or to save you time while searching for one of our store locations. We also may use this information to determine whether to provide you with content, information, and notices that may be required by law based on your location.
We will request your permission before your location information is collected, and will only use it as described in the preceding paragraph. If you allow location access, your browser or device may gather information about your nearby access points using WiFi and Bluetooth MAC addresses, IP address, RFID, and GSM/CDMA cell IDs. You can learn more about the API that provides scripted access to geographical location information associated with the hosting device by reading the W3C Geolocation specification.
You do not need to grant permission to use your location information in order to find a store near you. Alternatively, you can select a convenient location from our Locations page or when you use the Book an Appointment page.
Mobile devices often provide users with the ability to adjust settings related to location. If you do not want us to collect specific location information, you may modify the location services on your mobile device’s settings. We have no control over your device’s settings, and adjusting these settings does not completely eliminate the ability of others to develop location information about your device.
When and Why We Share Your Personal Information
Information received from third parties
Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include group companies, affiliates or business partners.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you. Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Transfers of Personal Information Out of the EEA and Switzerland
Your information will be transferred and stored outside the European Economic Area (EEA) in the and/or outside of Switzerland in the circumstances set out below. We will also transfer your information outside the EEA and/or Switzerland or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
Server Log Information
Information collected when you visit our website is transferred outside of the EEA and Switzerland and stored on the servers of our third party hosting company, AWS. You can access their privacy policy here: https://aws.amazon.com/privacy/.
Country of storage: United States. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield.
We use a third party server to host our website called Amazon Web Services, the privacy policy of which is available here: https://aws.amazon.com/privacy/. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
Our server is located in US East (N. Virginia) and, accordingly, if you are in the EU or in Switzerland, your information is transferred outside the European Economic Area (EEA). For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.
Use of website server log information for IT security purposes
We AND/OR our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analyzing log files to help identify and prevent unauthorized access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Use of website server log information to analyze website use and improve our website:
We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser use.
We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.
Google Analytics
Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission and the Swiss data protection authorities also only consider this country to be appropriate under certain conditions.
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome.
Automated Decision Making
We use automated decision making and/or profiling in relation to our website through the use of web analytics, cookies, web beacons and server logs analysis tools (profiling). We use targeting cookies to display advertisements to people who visit our website on other websites around the internet (e.g. using Google Adwords remarketing).
How We Secure Personal Information
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:
- only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;
- verifying the identity of any individual who requests access to information prior to granting them access to information;
- using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website.
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Use of Cookies and Similar Technologies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies and similar technologies on our website to process information including standard internet log information and details of the visitor’s behavioral patterns upon visiting our site. This is done to provide you with a better experience, and to facilitate the use of certain functions.
Cookies are stored on your individual device and you have full control over their use. You may deactivate or restrict the transmission of cookies by changing the settings of your web browser. Cookies that are already stored may be deleted at any time. Should you visit our site with cookies deactivated, you may possibly not be able to use all of the functions on the site to their full extent. You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.
Disclosure and Additional Uses of Your Information
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business. These include the following categories of providers:
- Email providers
- Hosting providers
- Telephone providers
- CRM provider
Our third party service providers are located in the United States. Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority.
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
How Long We Retain Your Information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period. We retain your information for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, and performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
Server log information: we retain information on our server logs for 90 days.
Correspondence and inquiries: when you make an inquiry or correspond with us for any reason, whether by email or by phone, we will retain your information for as long as it takes to respond to and resolve your inquiry, and for 3 further months after which point we will delete your information.
Criteria for Determining Retention Periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
- the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
- whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
- whether we have any legal basis to continue to process your information (such as your consent);
- how valuable your information is (both now and in the future);
- any relevant agreed industry practices on how long information should be retained;
- the levels of risk, cost and liability involved with us continuing to hold the information;
- how hard it is to ensure that the information can be kept up to date and accurate; and
- any relevant surrounding circumstances (such as the nature and status of our relationship with you).
Your Rights in Relation to Your Information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to 15500 W. 113th St. Suite 300, Lenexa, Kansas 66219, or sending an email to cs.usa@essensedesigns.com:
- to request access to your information and information related to our use and processing of your information;
- to request the correction or deletion of your information;
- to request that we restrict our use of your information;
- to receive information which you have provided to us in a structured, commonly used and machine-readable format(e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
- to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
- to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
- https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
- https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: https://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf.
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information. If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your Right to Object to the Processing of Your Information for Certain Purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to 15500 W. 113th St. Suite 300, Lenexa, Kansas 66219, or sending an email to cs.usa@essensedesigns.com:
- to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analyzing or predicting your behavior based on your information) based on any of these purposes; and
- to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
- clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
- sending an email to cs.usa@essensedesigns.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not generally seek to obtain sensitive personal information unless it is volunteered by you. If you inadvertently or intentionally provide sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information.
Examples of sensitive personal data we may request to better serve and meet your needs include:
- Food allergies;
- dietary requirements which may imply or suggest your religion, health or other sensitive personal data;
- observance of religious holidays which may imply your religion;
- mobility requirements;
- disabilities; and
- medical conditions
Such sensitive data is only shared with other members of Essense of Australia Inc. or our third party service providers (e.g. restaurants, accommodation providers) for the purpose of providing the best possible services to you and will not be shared or used by us for any other purposes.
Changes to Our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to cs.usa@essensedesigns.com.
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org.
Your California Privacy Rights
California Civil Code Section 1798.83 permits Users that are residents of California to request certain information regarding True Society’s disclosures of personally identifiable information to third parties for such third parties’ direct marketing purposes. If user is a California resident and would like to make such a request, please email Essense of Australia Inc at cs.usa@essensedesigns.com or write us at 15500 W. 113th St. Suite 300, Lenexa, Kansas 66219.