EU Privacy Policy

Information you give us: This will depend on how you interact with us. The following are a few examples of when we collect information directly from you:

• when you register to use our websites;
• when you place an online order on our websites;
• when you sign up to receive our newsletter;
• if you enter a competition, promotion or survey;
• if you upload or share a photo or other digital content through one of our websites;
• if you return a product or use a rebate; and
• in connection with your interactions with us as a registered user of our websites (for example, when you use the wish-list or “my hearts” feature).

This information includes, for example, your name, email address, postal address, phone number, credit card number or other payment or financial related information, gender, birthday, your children’s names, and your children’s gender.

Information we collect from you: Where permitted by applicable law, our websites use tracking tools like browser cookies, flash cookies, pixels, and web beacons. Please see “How do we use browser and mobile-based cookies and other tracking technologies?” for more information.

We also collect information about the device you use to access our websites, such as your computer’s or model device’s internet protocol address (“IP address”), your browser type, your operating system, media access control address (“MAC address”), received signal strength indicator (“RSSI”), and other technical information.

In certain circumstances, we also collect information about you from other sources, such as commercially available sources.

We use your personal information in the following ways:

• To process and fulfill your order, including to send you emails to confirm your order status and shipment;
• Where permitted by applicable law, to communicate with you and to send you information by email, postal mail, telephone, text message, or other means about our products, services, contests, and promotions, unless you have directed us not to contact you with promotional communications;
• To administer and fulfill our contests and other promotions;
• To help us better understand your shopping needs and preferences and provide consistent, personalized services and experiences across our brands;
• To help us address problems with and improve our site design, products and services;
• To enhance your shopping experience;
• To analyze trends and statistics;
• To protect the security or integrity of our websites and our business; and
• To otherwise contact you if necessary.

You always have the choice not to receive marketing information or calls from us. For instructions on opting out, please see the section entitled, “How do I make choices about receiving promotional communications?” below.

As you are located in the EEA, we are required to set out in this privacy policy the legal grounds on which we rely in order to process your personal information. Our use of your personal information is permitted by law because:

• it is necessary for taking steps to enter into a contract with you for the products you purchase, or for carrying out our obligations under such a contract. Where we need your personal information in order to fulfil our contract with you, if you do not provide it, provide it inaccurately or require us to delete it, then we may not be able to provide you with the product or service that you have ordered from us;
• it is necessary for our legitimate interests, including to provide and improve services, personalize the services to your shopping habits and to protect the security of our websites. In such cases, we have taken measures to ensure that this processing does not cause unwarranted prejudice to your privacy;
• it is required to satisfy any legal or regulatory obligations that we are subject to; and
• in limited circumstances and if required by applicable law, you have agreed to us processing your personal information.

In certain circumstances, information we collect about you will be shared with our affiliates and subsidiaries.

We also share information about you with our business partners, suppliers and sub-contractors for purposes of providing services to us. For example, when you complete a purchase, we share information about you and your purchase with other companies for the purpose of processing your transaction, including credit card authorization, and order processing and fulfillment. We also share your information with our other service providers who collect, manage, and analyze our customer information on our behalf and perform services on our behalf, such as sending promotions and other communications and conducting contests and surveys.

Certain third-party service providers, such as payment gateways and other payment transaction handlers, have their own privacy policies in respect of the information we are required to provide to them for your purchase-related transactions. Once you leave our websites or are redirected to a third-party website or application, the use of your personal information is no longer governed by this policy. For these providers, we recommend that you read their privacy policies, so you can understand the manner in which your personal information will be handled by these providers.

We may also disclose your personal information to third parties for the following reasons:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
• if all or substantially all of our assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets;
• if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, regulation or in response to a valid subpoena, order, or government request; or
• to enforce or apply our terms of website use (http://www.carters.com/disclaimer.html) or to establish, exercise or defend our rights or the rights of our customers or others.

We retain your personal information in accordance with our detailed Records Management and Retention Policy. We calculate retention periods for your personal information in accordance with the following criteria:

• the length of time necessary to fulfil the purposes described in this policy;
• the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations;
• any limitation periods within which claims might be made; and
• the length of time we are required to retain any information for by law.

You can review and change certain personal information related to your use of our online sites (such as your name and contact information). To access your information at a Carter’s website, simply sign in to your account using your login and password, and you will be able to edit your personal information in your account profile.

You can also ask us to update your personal information by contacting us as described in the section entitled, “How do I contact you?” below. We aim to action such requests as promptly as possible.

We want to communicate with you only if you want to hear from us and will only do so where permitted by applicable law. If you prefer not to receive promotional information, such as information about special offers and sales events, from one or more of our brands, you can let us know (“opt-out”) at any time by contacting our customer service as described in the section entitled, “How do I contact you?” below, or you can click on the self-service unsubscribe or follow the unsubscribe instructions provided in each of our promotional messages.

If contacting customer service, please be sure to include your full name and the email address you used when you registered with or made a purchase from us. If you ask us to remove your name and address from promotional lists, we will maintain your name in a “do not contact” file to ensure that we can honor your request.

If you change your mind, you can start receiving promotional communications from us again by logging into your online account and changing your preferences, by signing up when you visit our websites or when you enter a sweepstakes or contest, or by contacting customer service.

Please note that when you make an online purchase from us, we will continue to confirm your order status and shipment by email. We may also need to contact you via telephone, email, or postal mail with questions or information regarding your order.

As you are located in the EEA, you have various additional rights under local law to those set out above in relation to your personal information, such as to:

• request a copy of the personal information we hold about you;
• ask that we correct or remove information you think is inaccurate or incomplete;
• ask that we delete the personal information that we hold about you, or restrict the way in which we use such personal information;
• withdraw consent to our processing of your personal information (to the extent such processing is based on consent);
• object to our processing of your personal information (including for direct marketing purposes); and
• receive your personal information in a structured and commonly used format so that it can be transferred to another data controller (‘data portability’).

If you would like to exercise these rights or understand if they apply to you, please contact us using the details set out at “how do I contact you” below.

Save as described in this policy or provided under data protection laws, there is no charge for the exercise of these rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.

We are concerned about the privacy and safety of children when they use the internet. We will never knowingly request personal information online from anyone under the age of 16 without prior verifiable parental consent. Our websites are general audience sites and are not targeted to or intended for use by children. However, if we learn that we have received information from a child under the age of 16 without parental consent, we will delete that information from our database.

Where permitted by applicable law, our websites use cookies, pixel tags, and other tracking technologies, to help enable you to shop on our websites and are used in a variety of ways to enhance or personalize your online browsing and shopping experience. These technologies are also be used to determine the ads you see on our sites and also on other sites. For information about targeted online advertising and your choices related to it please see the next section.

For more information about the cookies and other tracking technologies we use, and for information about targeted online advertising and your choices related to it, please read our EU Cookie Policy.

If you choose to share certain content on our websites, such as pictures, Carter’s will receive information about you and you will be bound by our “User-Generated Content Terms and Conditions,” which can be found here. As such, we encourage you to review these terms whenever you share content on our websites. If you do not wish us to receive this information, you should share content on our websites.

We do our best to provide you with a safe and convenient shopping experience. We have in place appropriate physical, electronic, contractual, and managerial safeguards to help protect the security and privacy of your personal information.

When you enter your personal information on our websites, we use encryption technology to protect your information as it is transmitted to us.

If for any reason you cannot access the secure server, or if you’re not quite comfortable shopping online at any of our websites, please feel free to place your order with us by telephone at the number listed in the section entitled, “How do I contact you?”, below.

Transfers of my personal information

Your personal information may be transferred to and processed in other countries where laws governing the processing of personal information may be less stringent than the laws in your country (including jurisdictions outside the EEA, such as the USA).

In such cases, where required by local law we will ensure that there are adequate safeguards in place to protect your personal information. This adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. Where we are legally required to do so, further details of these transfers and copies of these agreements are available from us on request.

Our Data Protection Officer, Antonio Robinson, can be contacted at e-mail: carters.legal@carters.com; phone: +1-678-399-1000, and our EU representative, Skip Hop UK Limited, can be contacted at email: ukoffice@skiphop.com, phone: +44 (0) 1582 434250; or mail: Basepoint F22, 110 Butterfield, Great Marlings, Luton, Bedfordshire, LU2 8DL.

In addition, if you are not content with how we manage your personal information, you can lodge a complaint about our processing of your personal information with the data protection regulator in the jurisdiction in which you live or work. A list of national data protection regulators in the EEA can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.