Effective Date: March 1, 2025

1. Introduction

Irene Neuwirth, Inc., and its subsidiaries, affiliates and parent (“Irene Neuwirth,” “Company,” “we,” “our” or “us”) is committed to protecting your privacy and ensuring you have a positive experience when you visit our webpages, interact with us on social media, online, or in our boutiques (the “Services”).

This Privacy Policy (“Policy”) explains what Personal Information Irene Neuwirth collects about you, how we obtain it, how we share it, and how you may limit the ways in which we use your Personal Information. If you have questions about this Policy after you review it, feel free to contact us at hello@ireneneuwirth.com.

2. Scope

This Policy governs ireneneuwirth.com, its subdomains, and all subdomains or portals that link to this Policy (“Site”) or otherwise when you provide Personal Information or interact with us online, including via social media. This Policy also applies to Personal Information that we may collect from you in person at our physical locations (“Boutiques”), via phone calls or other communications with our representatives, or in any other instance when you contact us. For the purpose of this Policy, “Personal Information” means any personal information relating to an identified or identifiable individual that is protected by applicable privacy laws.  Irene Neuwirth, as defined above, is the data controller. 

By using our Site or otherwise using our Services, you agree to our Terms of Service (“Terms”) and the collection of Personal Information as set forth in this Policy.

3. What Information We Collect

As a rule, we limit the Personal Information we collect to that which is adequate, relevant and reasonably necessary for us to provide our Services to you. 

Information That You Provide to Us

As you interact with our Services, we collect the following Personal Information via the online chat function and webforms or inputs/uploads on our Site, and through telephone calls, text messages, letters, emails and other communications with you.

• Contact information such as your first and last name, email address, job title, home or business address, shipping address, telephone numbers, mobile numbers, username and password (for creating and using an Irene Neuwirth account).

• Date of birth (for age-verification and gift reminder use). 

• Financial information such as your business credit card or debit card number, bank account information and your payment, service and purchase history.

• Social media handles, content and other data shared with us through third-party features that you use on our Site or Services (such as tools, payment services, widgets and plug-ins offered by social media services like Facebook, Instagram, Twitter and Pinterest) or posted on social media pages (such as our social media page or other pages accessible to us); and

• Other information that could reasonably be used to identify you personally, including any information you provide voluntarily for customer support.

Information That Is Automatically Collected

Like many businesses, we and our service providers automatically collect and/or store certain information when you visit or interact with the Site (“Usage Information”), including via cookies and other tracking technologies (see Use of Cookies and Other Tracking Technologies section below). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information includes:

• Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;

• Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);

• Referring and exit web pages and URLs; 

• The areas within the Site that you visit and your activities there, including remembering you and your preferences;

• Your Device location or other general location information, including the zip code, state or country from which you accessed the Services;

• Your Device characteristics (such as device type (computer vs. mobile) and ID, operating system, hardware); 

• Certain other Device data, including the time of day you visit our Site or other information used to provide analytics or other usage information;

• Information about your engagement with our emails; and

• Statistical information about how both unregistered and registered users, collectively, use the Site and Services.

Information Collected from Third Parties

The Site includes functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of our Site from third parties, like Google Analytics or Meta, if you have found us through a search on another site. We might also provide links to make it easier to send a communication from the Site, or we may use third parties to make it easier to send emails or post to social media (like a “Share” or “Forward” button). These third parties also use cookies and other tracking technologies to capture information about your interactions with us. 

Irene Neuwirth does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

Information We Infer

We derive information or draw inferences about you based on information we collect about you. For example, based on your browsing or purchases, we may infer your gender, your interest in certain products or materials, or information about your purchasing activities over time.

4. Use of Cookies and Other Tracking Technologies

Our Site uses various methods and technologies to store or collect Usage Information, to recognize your browser or device, learn more about your interests to personalize your experience, and deliver our Site and Services to you (“Tracking Technologies”). These Tracking Technologies allow us to collect information such as your device type, browser type, interactions with our Site, geographic location, your web request, the date and time of your web request, your Internet Protocol address, and the domain name of your Internet service provider and other data. If you can be identified from this information, for example by combination of your IP Address with other pieces of information because you are logged into an account on our website or on another website, then we will treat this information as Personal Information. Tracking Technologies may set, change, alter or modify settings or configurations on your Device. By using our Site, you consent to our use of Tracking Technologies – where required by law, we will collect your affirmative consent before using these Tracking Technologies. 

A few of the Tracking Technologies used on the Site include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):

• Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies and other types of cookie technology to store information on local storage. 

• Pixels. A pixel is a small graphic file that allows us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site. Like many other companies, we use the Meta pixel and may use other pixels.

• Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.

• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. 

• ETag, or entity tag. An eTag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. We may use tags via Google Tag Manager or Google Analytics. 

• Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

• Recognition Technologies. These technologies, including application of statistical probability to data sets, attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user). 

We may use the following types of cookies:

• Essential/Strictly necessary cookies. These cookies are essential for you to browse the Sites and use its features, such as accessing secure areas of the site. You cannot disable this type of cookie on our Site.

• Functionality cookies. Also known as “preference cookies,” these cookies allow the Sites to remember choices you have made in the past, like what language you prefer, or what your username and password are so you can automatically log in. Disabling these cookies can cause some parts of the Site to not work properly.

• Performance cookies. Also known as “analytics cookies,” these cookies collect information about how you use a website, like which pages you visited, and which links you clicked on. Their purpose is to improve website functions. This includes cookies from third-party analytics services if the cookies are for the exclusive use of the owner of the website visited.

• Targeting and Advertising cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always from third parties.

You can alter the configuration of your browser to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Site. For example, we may not be able to recognize your computer or device, and you may need to log in every time you visit.

You can opt out of non-essential cookies by enabling an opt-out preference signal on your browser or opting-out of cookies in our Site’s cookie preference centers.

You can control the use of cookies on most web browsers, use the links below to modify your web browser’s settings on the most popular browsers:

• Apple Safari

• Google Chrome

• Microsoft Edge

• Mozilla Firefox

You can opt out of Google AdWords Remarketing here.

You can change your Facebook Ad Preferences here.  

You can block Google Analytics from accessing your online activity with a browser add-on here.

Learn more about cookies and similar technologies or to opt out of targeted advertising cookies here. More resources are also available from the Digital Advertising Alliance or the Network Advertising Initiative. We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs.

Other Tracking Technologies may be used that collect comparable information for security and fraud detection purposes.  You cannot disable Tracking Technologies used for security and fraud purposes. 

If you have any questions about cookies or to generally find out more about cookies, visit this site.  Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective. We always do our best to honor your choices, but because some choices are set at the browser or device level, you may have to make these choices multiple times if you use different browsers or different Devices.

5. Why We Collect Information

We use the information we collect about you in a variety of ways, including the following:

To Provide Our Services

We process certain Personal Information when you access or use our services, including to:

• process your purchases of, or requests for, products and services;

• create and verify user accounts;

• deliver gift cards or e-gifts, and any associated personalized messages, in accordance with your instructions;

• facilitate the functionality of our Site, including payment-related functionality; and

• customize experiences and personalization when you are on our Site.

To Communicate with You

We process certain information to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:

• communicate with you about orders, purchases, returns, services, accounts, programs, contests, and promotions;

• respond to your customer service inquiries and requests for information;

• post your comments or statements on our Site;

• send you personalized promotions, content, and special offers;

• communicate with you about our brands, products, events, or other promotional purposes;

• implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives; and

• provide important product safety information.

For Improvement of Our Site or Services

We want to ensure that our Site and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:

• maintain, improve, and analyze our Site or Services; and

• detect, prevent, or investigate suspicious activity or fraud.

To Comply with Applicable Laws

We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

• maintain appropriate records for internal administrative purposes; and

• comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use our Site and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

With Your Consent

We process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your consent.

6. When We Disclose Information

To the extent permitted by law, certain Personal Information about you may be disclosed in the following situations:

• Service providers. To provide information to our affiliates and nonaffiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party which prohibits them from disclosing or using the information other than for the purposes for which it was disclosed. Examples of such disclosures include using a cloud services provider, carriers and couriers, payment processor, customer service provider, email marketing provider, or other service provider. 

• Marketing and advertising. We also may share your information, including your Personal Information, with our affiliates and other third parties, such as companies with whom we have marketing or other relationships, for direct marketing purposes. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described in this Policy. 

• Legal process. To comply with a validly issued and enforceable subpoena or summons or as a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, including detecting or preventing fraud, security or technical issues, or to protect against harm to the rights, property or safety of Irene Neuwirth, our users, or the public as required or permitted by law. 

• Business transactions. In conjunction with a prospective purchase, sale, acquisition, merger, restructuring or change in control involving all or part of our business or assets, including in connection with bankruptcy or similar proceedings.

Finally, we may aggregate, de-identify, and/or anonymize any information collected through the Site or Services such that such information is no longer linked to your Personal Information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

7. Ads and Information About You 

You may see certain ads on our Site because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites and online services by collecting information through automated means, including through the use of the Tracking Technologies described above, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our Site, such as the pages you have viewed. This collection and ad targeting takes place on our Site and on third-party websites that participate in the ad network. This process also helps us track the effectiveness of our communications and marketing efforts. You may be able to adjust some of these tracking settings in your browser, or by using the tools outlined in our “Use of Cookies and Other Tracking Technologies” section above. 

8. Retention of Personal Information

Irene Neuwirth will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

We utilize the following criteria to determine the length of time for which we retain Personal Information:

• How long we have had a relationship with you or provided our Services to you

• The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;

• Whether we are required to retain the information, or the information is otherwise necessary, in order to: comply with legal obligations or contractual commitments: defend against potential legal claims: detect or prevent potential illegal activity or actions in violation of our policies and procedures; secure our systems and online environment; or protect health and safety;

• The privacy impact on individuals of ongoing retention; and

• The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

9. Your Choices About the Information We Collect

Communications Preferences

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us using the information in the Contact Us section below. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). 

You can opt out of receiving marketing emails from us at any time. You will still receive transactional messages from us. To manage your email preferences with us, please click on the Unsubscribe link in any email you receive from us or contact us using the information in the Contact Us section below. Your choice will not affect our ability to share information in the other ways described in this Policy.

Controlling Your Cookies 

You can opt out of cookies by enabling an opt-out preference signal on your browser or opting-out of cookies in our Sites’ cookie preference centers.  For more information, please see our “Use of Cookies and Other Tracking Technologies” section above.  

Do Not Track

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here. 

10. Children’s Privacy

Our Site is not intended for use by children under the age of 16. We do not request, or knowingly collect, any Personal Information from children under the age of 16. If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please contact us using the information in the Contact Us section below to request the deletion of that information.

11. Visitors to the Site Outside of the United States

Please note that our Boutiques are only in the United States at this time. If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. If you are a resident of the United Kingdom or the European Economic Area (“EEA”) and your Personal Information is transferred outside of the UK or EEA, we will implement appropriate safeguards to protect your Personal Information, including transferring it in accordance with the applicable transfer mechanism, including the European Commission’s Standard Contractual Clauses or the UK International Data Transfer Agreement. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States, as set forth in this Policy.

12. Links

For your convenience, the Site and this Policy may contain links to other websites. Irene Neuwirth is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that Irene Neuwirth endorses or has any affiliation with the links.

13. Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Site, and you provide us with your information at your own risk. 

14. Your California Privacy Rights

This section of the Policy applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

California residents have the following rights:

• To know the categories of Personal Information being collected about you, the purposes for which the categories of Personal Information are collected or used, and whether that information is sold or shared;

• To know the length of time we intend to retain each category of Personal Information; 

• To know whether your Personal Information is sold or disclosed and to whom;

• To access your Personal Information;

• To delete the Personal Information you have provided to us, with certain exceptions; 

• To correct your Personal Information;

• To opt out of the sale of Personal Information; 

• To know if Sensitive Personal Information (“SPI”) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared; 

• To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and

• Not to be discriminated against, even if you exercise your privacy rights.

Request for Information, Correction, or Deletion

California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:

• The categories of Personal Information collected about you;

• The categories of sources from which the Personal Information is collected; 

• The business or commercial purpose for collecting, selling or sharing Personal Information;

• The categories of third parties to whom the business discloses Personal Information; and

• The specific pieces of Personal Information collected about you.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information. 

Personal Information Collected 

We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Information related to how long we retain each category of Personal Information is included in the Retention of Personal Information section above. 

Personal Information Sold or Shared

We have sold or shared (as those terms are defined in the CCPA) to third parties the following Categories of Personal Information in the last twelve (12) months:

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

Personal Information Disclosed for Business Purposes

We have disclosed the following categories of Personal Information for business purposes in the last twelve (12) months:

Do Not Sell My Personal Information

As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. We do not sell Personal Information, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt-out of this, you may modify your cookie preferences, or click on the “Do Not Sell” link in our footer. 

Right to Limit Use of Sensitive Personal Information

California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Please note that we only keep your Sensitive Personal Information for a limited time, and only for the transaction for which it is required. Currently, we do not provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to you. 

Right Not to Be Discriminated Against

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you with a different level or quality of goods or services.

• Suggest that you receive a different price or rate for goods or services or a different level or quality of goods or services.

Notice of Financial Incentives

We do not offer financial incentives for providing your Personal Information to us.  

Third Party Marketing

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Except as stated otherwise for partners or co-branded events with your express consent, we do not currently disclose Personal Information protected under this section to third parties for their own direct marketing purposes. 

Exercising Your California Privacy Rights 

You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information by contacting us using the information in the Contact Us section below. 

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

15. Your Privacy Rights under Other US State Laws

If you live in certain other U.S. states, such as Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have rights under applicable privacy laws once those laws have become effective.  

Based on the applicable law in the state where you live, you may have the following rights with respect to your Personal Information:

• To confirm whether or not a controller is processing your personal data and to access such personal data; 

• To know the categories of Personal Information we collect about you, the purposes for the collection, how long we retain your Personal Information, and whether that information is sold or shared or disclosed and to whom;

• To correct inaccuracies in your personal data; 

• To delete your personal data; 

• To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means; 

• To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. 

• Not to discriminate against you because you have exercised any of these rights, including by:

• denying you Services;

• charging different prices or rates for our Services, including through the use of discounts or other benefits or imposing penalties;

• providing you a different level or quality of Services; and/or

• suggesting that you will receive a different price or rate for Services, or at a different level or quality of Services.

To exercise any of these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by using the links in our footer or contacting us using the information in the Contact Us section below.

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period. 

Right to Opt Out 

You may have the right to opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. To exercise your right, please click on the Cookie symbol on the bottom of the webpage where your information is being collected or write to us using the information in the Contact Us section below.

Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

Appeals of Our Decisions

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of your choices described above. In order to appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. 

If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to your state Attorney General.

16. Your Rights Under the General Data Protection Regulation 

This section of the Policy applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this section. 

Under applicable law, we are considered the “data controller” of the Personal Information we handle under this Policy. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law.

We want to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information by logging into your own Irene Neuwirth account if any changes have occurred. We have listed below the rights that you may be able to exercise with respect to the processing of your Personal Information, subject to applicable law. We take reasonable steps to ensure that the Personal Information that we process is limited to the Personal Information that is required in connection with the purposes set out in this Policy.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

• The right to access, update or delete the information we have collected from you. 

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object. You have the right to object to our processing of your Personal Information.

• The right of restriction. You have the right to request that we restrict the processing of your Personal Information.

• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

Legal Basis for Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

• Contract: To conclude or perform a contract with you; for example:

• To manage and fulfill orders, facilitate delivery, and to provide other Services;

• To manage our accounts and records;

• To handle your inquiries and requests;

• Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent, or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:

• To respond to your customer service inquiries and requests for information;

• To maintain, improve, and analyze our Site, ads, and Services we offer;

• To conduct marketing activities;

• To detect, prevent, or investigate security breaches or fraud; and

• To facilitate the functionality of our Site;

• Legal Compliance: To comply with our legal obligations; for example:

• To respond to legal process or defend ourselves in legal proceedings; 

• To maintain appropriate records for internal administrative purposes and as required by applicable law, and

• To provide important product information.

• Consent: We will send you information by email on our Services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.

How to Exercise Your Rights Under the GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the Contact Us section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time. 

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority for the member state in which you reside; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by using the information in the Contact Us section below.  

17. Your Rights Under the UK GDPR 

If you are based in the United Kingdom, the following provisions also apply:

If we share your personal data within Company or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.

You have the same data subject rights as those for the EU listed above, except that references to the "GDPR" should be read as references to the "UK GDPR" and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.

18. Changes to This Privacy Policy

We may change this Privacy Policy at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified policy’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy policy. If required by the applicable law, we will notify you of the changes. 

By continuing to use the Site or our Services or providing us with information following such a replacement Policy being uploaded, you agree that you will be bound by the Privacy Policy as changed.

19. Contact Us

If you have any questions or suggestions regarding this Policy, please contact us as follows:

Irene Neuwirth, Inc.
8458 Melrose Place
West Hollywood, CA  90069

Email: hello@ireneneuwirth.com 

Contact number: 310.566.6660