Privacy Policy

Arlettie USA LLC (“we”, “us” or “Arlettie”) has created this privacy policy statement in order to demonstrate our firm commitment to your privacy. The following discloses our information gathering, use and dissemination practices solely for the website located at https://www.arlettie.com/us/en (the “Site”). Any customer account, membership, or other account made available through the Site, and related products, services, communications, online private sale features, showroom event registration and access features, membership application and administration features, reseller-screening features, and digital features are collectively referred to as the “Services.”

Arlettie organizes membership-based and invitation-based private sale events and online sales featuring fashion, jewelry, leather goods, accessories, and other products from luxury and other brands. By using or accessing the Services, you signify your assent to our Privacy Policy. Any terms not defined herein shall have the meaning set forth in Arlettie’s Terms of Use and Sale.

The purpose of this Privacy Policy is to detail (i) how personal data of the Site’s users (“User” and/or “Users”) is collected, used, disclosed, retained, and otherwise processed by Arlettie, (ii) the measures that Arlettie implements in order to help protect such data, and (iii) the rights that Users may have under applicable law.

Personal and Non-Personal Information We Collect

Information You Provide

When using the Site and our Services, including when you create an account, apply for or manage a membership, register for or attend a private sale event, request or use showroom access, place an online order, request a return where available, sign up for communications, contact customer service through our contact form, respond to eligibility or verification requests, report or become involved in a showroom or on-site incident, or otherwise interact with us, you may choose to upload, or we may ask you to provide us with, certain personally identifiable information that can be used to contact or identify you (“Personal Information”). Personally identifiable information may include, but is not limited to:

• Identification data (e.g., first and last name, date of birth, and other information used to verify identity or eligibility)
• User contact information (e.g., email address, mailing/physical address, telephone number)
• Account credentials, such as email address and password, and account or membership status information
• Payment information (e.g., payment card type, credit or debit card information, billing address, billing email, and related payment details processed by our third-party payment processors)
• Connection and device data (e.g., logs, IP address, browser type, device information, and internet or other electronic network activity information)
• Data relating to operations carried out through the Site or in connection with our events (e.g., membership application and status, eligibility verification results, registration history, event attendance, showroom access records, order history, purchase history, return requests, and other commercial information)
• Preferences related to the brands, sales, events, memberships, and products offered through the Site or at Arlettie showrooms, including consumer profiles, preferences, purchase-pattern analysis, and inferences regarding consumer interests, purchasing habits, or potential reseller activity
• Demographic data (e.g., age or date of birth, including for eligibility screening)
• Approximate geolocation data derived from IP address or, where permitted, location-related information relevant to event attendance, showroom access, or security administration
• Communications, submissions, and records relating to suspected reseller activity, fraud reviews, chargebacks, account or order verification, or showroom incidents, including messages, supporting documentation, incident reports, witness statements, and related security information

Personal Information

Personal data or personal information generally means information that relates to an identified or identifiable natural person and may include information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, as applicable under law. A natural person is identifiable when he or she can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, or an online identifier. Arlettie collects personal data from users in the following situations:

• When creating a User account on the Site;
• When applying for, verifying eligibility for, activating, administering, renewing, suspending, or terminating a membership or invitation-based access right;
• When registering for or attending an Arlettie private sale event or showroom sale;
• When screening eligibility for event registration or showroom access, checking in at a showroom, using invitations, or responding to security or incident-related matters at a showroom or event;
• When placing an online order through the Site;
• During the payment of an order by the User;
• When the User contacts Arlettie customer service through the contact form available at https://www.arlettie.com/us/en/contact/new/c;
• When the User browses the Site;
• When the User signs into and accesses a User account on the Site;
• When the User requests a return of an online order where returns are available;
• When we review transactions, accounts, memberships, returns, purchasing patterns, or other activity for fraud prevention, reseller detection, abuse prevention, or compliance purposes;
• When the User signs up to receive newsletters, event invitations, brand alerts, marketing emails, or other commercial communications; and
• When personal data is collected through cookies, pixels, web beacons, or similar tracking technologies embedded on the Site or on third-party sites or services in connection with our advertising, analytics, and marketing activities.

Information for which communication to Arlettie is mandatory is identified as such at the time of collection. If you do not provide certain Personal Information, we may be unable to provide some or all of the Services, process your transactions, or respond to your requests.

If you are under 18 years of age, please do not submit any Personal Information to us. If you are the parent or guardian of a person under 18 years of age who has provided Personal Information to us, please inform us through https://www.arlettie.com/us/en/contact/new/c.

Non-Personal Information

In addition, we may also collect information that does not directly identify you, such as IP addresses (which identify your device), pages viewed, computer type, screen resolution, operating system version, Internet browser type and version, and other data (“Non-Personal Information”). This information may include approximate geolocation information based on IP address, browsing activity, shopping cart activity, interactions with advertisements, event browsing behavior, purchase and return activity patterns, and information collected through cookies, pixel tags, web beacons and similar technologies, whether deployed by us or by our service providers, advertising partners, or business partners. We may use this information to support analytics, personalization, membership administration, fraud prevention, reseller detection, security monitoring, and operational decision-making. To the extent Non-Personal Information is linked or reasonably linkable to you, we will treat it as Personal Information as required by applicable law. We may retain Non-Personal Information for so long as reasonably necessary to fulfill a legitimate business need and as otherwise permitted by applicable law.

Aggregate Information

We may aggregate or deidentify Personal Information so that the resulting information does not personally identify you or anyone else, such as by using Personal Information to calculate the percentage of our customers who live in a particular area (“Aggregate Information”). In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined. We may use and disclose aggregated or deidentified information in a manner that does not identify any individual subject to applicable law.

Use of Information

The processing of Users’ Personal Data is carried out for the purposes listed below:

• The creation of a User Account on the Site;
• The access and management of the User Account of the Users on the Site;
• The application, verification, administration, renewal, suspension, and termination of memberships, invitations, and other eligibility-based access to the Services;
• The registration, administration, and management of private sale events and showroom access;
• The screening of eligibility for memberships, invitations, event registration, showroom entry, and access to particular sales, products, or Services;
• The processing, management, and delivery of online orders placed through the Site;
• The management and monitoring of commercial relations between Arlettie and each User;
• The sending of promotional offers, newsletters, event invitations, brand alerts, and other marketing communications from Arlettie;
• Audience statistics, analytics, and performance measurement for the purpose of improving the commercial and marketing activities of Arlettie;
• Arlettie’s communication with a User through its customer service contact form;
• Prevention, detection, investigation, and fight against fraud, resale activity, bulk purchasing for resale, chargebacks, event-access abuse, use of automated purchasing tools, suspicious purchase-patterns, or other unlawful or unauthorized activity;
• The prevention, investigation, documentation, and response to showroom incidents, safety issues, misconduct, property loss, or other security-related events;
• Litigation management, dispute resolution, and legal compliance;
• The use of automated tools or rules-based assessments to help review accounts, memberships, event registrations, orders, returns, payments, invitations, and access requests for fraud, reseller activity, eligibility, abuse, security, or operational risk, subject to applicable law;
• The personalization of a User’s experience on the Site, including based on browsing behavior, event interests, shopping activity, and preferences;
• The display of advertisements and the measurement of the performance of marketing and advertising campaigns;
• The maintenance of mailing lists and the sending of commercial communications; and
• The protection of Arlettie’s operations, rights, safety, and property, and the use of user information in connection with business assets, corporate transactions, or restructurings, to the extent permitted by applicable law.

Personal Information to Provide Services

We use Personal Information to process and fulfill online orders, register Users for private sale events, manage showroom access, administer memberships and invitations, evaluate eligibility for certain Services, contact you about our products and Services, personalize your experience with us, maintain and service your account, process online returns where available, provide customer support, investigate suspected fraud or reseller activity, document and respond to showroom incidents, and allow you to use, communicate, and interact with the Site. This may include sharing information with third parties that provide us with services such as Site hosting, data analysis, payment processing, order fulfillment, infrastructure provision, information technology services, customer service tools, e-mail delivery services, identity verification, fraud screening, risk scoring, security, event operations, logistics, returns management, training, and other similar services. These third parties may have access to Personal Information necessary to perform their functions on our behalf but may not use it for their own independent purposes except as permitted by applicable law.

Site and Marketing

We may use Aggregate Information to improve and enhance your experience on the Site and for our market research activities. For example, we may share Aggregate Information with unaffiliated third parties, such as business partners, site analytics vendors, and other service providers, in an aggregate or deidentified form, which means that the shared information will not reasonably identify you. We may also disclose your Personal Information to third-party service providers and business partners, and customer acquisition, customer relationship management, advertising, analytics, retail, logistics, membership administration, event operations, fraud-prevention, security, and similar partners, in order to improve our marketing, advertising, event administration, order management, membership administration, purchase-pattern analysis, retail, customer relationship, and business operations, and as otherwise permitted by applicable law.

As Necessary

We may disclose Personal Information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process and lawful requests from courts, regulators, law enforcement, or public and government authorities, including authorities outside your country of residence; (c) to enforce our terms and conditions and other applicable agreements, policies, and standards; (d) to protect our operations or those of any of our affiliates; (e) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; (f) to detect, prevent, or address fraud, security, or technical issues; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. Additionally, we may disclose or transfer Personal Information in connection with any actual or proposed merger, financing, acquisition, bankruptcy, dissolution, reorganization, sale of company assets, or transition of service to another provider, subject to applicable law.

Automated or Rules-Based Review

We may use automated tools, internal rules, and human review to assess account activity, membership applications or status, event registrations, invitations, orders, returns, showroom access requests, and related interactions for purposes such as eligibility screening, fraud prevention, reseller detection, abuse prevention, security, and operational integrity. Depending on the circumstances, these processes may contribute to decisions to approve, deny, flag, hold for review, limit, suspend, terminate, or otherwise restrict an account, membership, invitation, order, return, event registration, or access to a showroom or other Service, subject to applicable law. Where required by law, we will provide any legally required notice, rights, or safeguards relating to such processing.

Retention Policy

Users’ Personal Data is kept by Arlettie for so long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide the Services, maintain User accounts and memberships, verify eligibility, register Users for events, process transactions, manage our business relationship with Users, comply with legal obligations, resolve disputes, detect or prevent fraud or reseller activity, investigate showroom incidents, support rules-based or manual review processes, protect our rights, and enforce our agreements.

Information collected through cookies and similar tracking technologies may be retained for up to one (1) year, subject to applicable law and any shorter periods required by the relevant technology provider or browser settings. Registration, account, membership, transaction, event, showroom access, fraud-review, reseller-screening, and incident-related data may be retained for so long as the User’s account or membership remains active and thereafter for as long as reasonably necessary for operational, legal, compliance, dispute-resolution, fraud-prevention, safety, security, or recordkeeping purposes.

However, at the end of the above-mentioned periods, the Personal Information which has been collected and processed may be subject to an intermediate archiving so that Arlettie may meet its legal obligations of conservation. Certain data may be archived beyond the periods provided herein in the event of litigation, investigation, fraud prevention, or to respond to lawful requests from judicial or regulatory authorities. Following any applicable time limits set forth herein, Users’ Personal Data will be deleted, anonymized, or securely archived, as applicable.

User Rights

Users may have rights under applicable law to access, modify, object to, limit, rectify, port, or delete certain Personal Information. Users may also request information regarding the categories of personal data collected about them, the categories of sources from which such data is collected, the business or commercial purposes for collection, and the categories of third parties to whom such information is disclosed, subject to applicable law. Depending on applicable law, Users may also have rights to correct inaccurate information, opt out of certain sales, sharing, targeted advertising, profiling, or automated decision-making, limit certain processing of sensitive personal information, appeal a denial of a privacy request, and not be discriminated or retaliated against for exercising privacy rights.

Requests should be submitted through the Arlettie contact form available at https://www.arlettie.com/us/en/contact/new/c. We may request information reasonably necessary to verify your identity and authority to make the request, including where a request is submitted by an authorized agent, and to confirm the personal information relates to you. Where the processing is carried out to meet a legal obligation, the right of deletion of a User’s Personal Information may not apply. Where required by applicable law, we will also explain how you may appeal a decision regarding your request.

Arlettie will respond to privacy rights requests within the period required by applicable law. When exercising rights, the User may specify the address or electronic contact method to which the reply should be sent.

Mailing List

In order to maintain our mailing list, we may combine information you give us with information that is publicly available and/or provided by our third-party service providers or another company, to the extent permitted by applicable law. We may use mailing list information to send newsletters, brand alerts, promotional messages, and similar marketing communications relating to our products and services. If you received our marketing materials and do not know why, we may have received your information from another company or from your interactions with our Services or marketing campaigns. If you do not want to receive marketing emails from us, you may use the unsubscribe link in the message or submit a request through https://www.arlettie.com/us/en/contact/new/c. We may continue to send you non-marketing and transactional communications as permitted by law.

Distributors and Other Offers

We may at times share our customers’ email addresses and other relevant Personal Information with logistics providers, customer relationship management providers, event partners, brand partners, payment providers, fraud-prevention providers, analytics providers, membership administration providers, security providers, and/or other service providers or business partners, including partners such as where we believe such sharing supports our retail, event, order management, membership administration, fraud prevention, security, marketing, customer relationship, fulfillment, or business operations and is permitted by applicable law. From time to time, we may give you the opportunity to opt in to participate in special third-party offers that require us to share certain Personal Information with such third parties. We will disclose this anticipated sharing of Personal Information at the time we make such opportunities available to you. If you opt in to participate in such an offer, we may disclose your Personal Information to such third parties for their own purposes, including direct marketing, as disclosed at that time. We recommend that you consult such third parties’ privacy policies in advance if you wish to participate in these offers.

Email and Telephone Communications

We may use “browse abandon” and “cart abandon” tracking functions. For example, if you have provided your email address by logging into your account or entering it during the registration or checkout process and you visit our Site, we may send you an email about the products, events, or sales you viewed or left in your cart, subject to applicable law. If you receive an unwanted marketing email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future marketing emails. We will process your request within a reasonable time after receipt. Note that you may continue to receive transaction-related emails regarding products or services you have requested.

Cookies

“Cookies” are pieces of information that may be placed on your computer or mobile device by a Site for the purpose of facilitating and enhancing your communication and interaction with that Site. These technologies may be used by us and by our service providers, advertising partners, and business partners to support Site functionality, remember user choices, conduct analytics, measure ad performance, and deliver or help deliver interest-based advertising, subject to applicable law. We may use cookies to customize your visit to the Site and for other purposes to make your visit more convenient or to enable us to enhance our Services. For example, cookies allow us to select which ads or offers are most likely to appeal to you, based on your interactions with the Site or other information associated with your browser or device. Cookies also allow us to keep track of items you add to your shopping cart. Many Sites use cookies for these purposes.

There are several types of cookies, including, for example, browser cookies, session cookies, and persistent cookies. We use different types of cookies on our Site. The following is a description of the four categories of cookies and examples of how we use them to provide you the Services:

• Strictly Necessary Cookies – These cookies are essential to enabling you to browse and use the functionality of a website without which the Services cannot be provided. We use these cookies, among other things, to recognize and maintain your logged-in status throughout your visit and manage your shopping cart or event registration.
• Performance Cookies – These cookies collect information about how visitors use the Services, including for analytics and performance measurement. This information does not identify you individually and is used in the aggregate to improve our Services.
• Functionality Cookies – These cookies allow us to remember certain choices you make and provide you a more personalized experience, for example, your shipping country and currency preferences.
• Targeting Cookies – These cookies are used to deliver online advertisements that are relevant to you and your interests and to measure the effectiveness and performance of advertising campaigns. They may be placed on the Services by us or by our advertising partners, subject to applicable law.

You may stop or restrict the placement of certain cookies on your computer or flush them from your browser by adjusting your web browser preferences or, where available, your cookie settings, in which case you may still use our Site, but it may interfere with some of its functionality. Depending on your jurisdiction, certain cookies may be deployed only with your consent. We do not use cookies to retrieve information from your computer for purposes that are unrelated to the Services or your interaction with the Services.

Clickstream

As you use the Internet, a trail of electronic information is left at each Site you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a Site’s server. Clickstream data can tell us the type of computer and browsing software you use and the address of the Site from which you linked to the Site. We may collect and use clickstream data to understand how visitors use the Site, including how much time visitors spend on each page of our Site, how visitors navigate throughout the Site, and how we may tailor our web pages to better meet the needs of visitors. To the extent clickstream data is associated with an identifiable individual, we will treat it as Personal Information as required by applicable law.

Site Analytics

We may work with third-party service providers and partners who use the technologies described in this section to conduct Site analytics and advertising measurements and to help us track and understand how visitors use the Services.

Security

The security of your Personal Information is very important to us. We attempt to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and Arlettie, or information stored on the Services or our servers, will be free from unauthorized access by third parties such as hackers and your use of the Services demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Information.

Where payment information is collected, the full payment card number, expiration date, and security code are transmitted directly to our payment processor in encrypted form and are not stored by us, except to the extent otherwise disclosed by the payment processor or required for transaction records. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us through https://www.arlettie.com/us/en/contact/new/c.

Other Sites

Our Site may contain links to other Sites not maintained by Arlettie. Other Sites may also reference or link to our Site. The inclusion of a link on the Services does not imply endorsement of the linked Site by us. We are not responsible for the privacy practices of Sites operated by third parties that are linked to or integrated with our Site, or for the privacy practices of third-party Internet advertising companies. We encourage you to be aware when you leave our Site, or surf the Internet, and to read the privacy statements of each and every Site that you visit.

“Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers or mobile operating systems. DNT is a way for users to inform Sites and services that they do not want certain information about their webpage visits collected over time and across sites, applications, or online services. Please note that we do not respond to or honor DNT signals transmitted by web browsers. Where required by applicable law, we will process opt-out preference signals, such as browser-based global privacy controls, for requests to opt out of certain cookies or certain sharing for targeted advertising, in each case to the extent we are able to associate the signal with the relevant browser or device and as required by law.

Privacy of Minors

The Services are not directed to children under the age of 13, and Arlettie does not knowingly collect Personal Information from children under 13 in a manner that would require consent under the Children’s Online Privacy Protection Act (“COPPA”). In addition, the Services are not intended for individuals under 18 years of age, and we do not knowingly permit individuals under 18 to create accounts, place orders, or submit Personal Information through the Services. If we learn that we have collected Personal Information from a child under 13, or from any individual under 18 in violation of this Privacy Policy, we will take reasonable steps to delete such information, unless retention is required by applicable law. If you believe that a child or minor has provided Personal Information to us, please contact us through https://www.arlettie.com/us/en/contact/new/c. We also recommend that parents monitor their children’s Internet activities and learn and employ software or other tools that can help their children enjoy their online experience without compromising their personal safety or allowing them to use the Internet in a manner inconsistent with their parent/guardian’s preferences.

California Privacy Rights

California law permits California residents to request certain information about our collection, use, disclosure, and sharing of their personal information, subject to applicable exceptions and verification requirements. Depending on your relationship with us and as described elsewhere in this Privacy Policy, we may collect, disclose for a business purpose, or share the following categories of personal information: identifiers and profile/contact information; payment information; commercial information; demographic information; geolocation information; internet or other electronic network activity information; account credentials; membership, eligibility, and access-related information; inferences drawn from personal information; sensory or security-related information, such as information relating to showroom incidents where applicable; and other information that you provide to us or that we collect in connection with the Services.

We may collect these categories from you, your devices, our service providers, advertising partners, business partners, analytics providers, and other parties as described in this Privacy Policy. We collect, use, disclose, and share this information for the business and commercial purposes described in this Privacy Policy, including providing the Services, processing orders and returns, maintaining accounts and memberships, eligibility screening, registering Users for events, administering showroom access, customer service, analytics, personalization, marketing, advertising, security, fraud prevention, reseller detection, automated or rules-based review, incident investigation, legal compliance, and business operations. We do not knowingly sell or share the personal information of consumers under 16 years of age.

California residents may have the right to request that we delete personal information that we collected from them and retained, to correct inaccurate personal information, to know the categories and specific pieces of personal information we have collected about them, and to opt out of certain disclosures of personal information that constitute a “sale” or “sharing” under California law, subject to certain exceptions. California residents may also have the right to limit the use and disclosure of sensitive personal information, where applicable, and to receive information about certain profiling or automated decision-making practices if and to the extent required by law. Once we receive and confirm your California privacy rights request, we will process it in accordance with applicable law.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Please submit any California Privacy Rights Request through https://www.arlettie.com/us/en/contact/new/c and clearly state that the request is related to “Your California Privacy Rights.” Please include sufficient detail to allow us to understand, evaluate, and respond to the request, including your name, email address, and any other information reasonably necessary to verify your identity.

We cannot respond to your California Privacy Rights Request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Arlettie is not responsible for a California Privacy Rights Request that is incomplete, incorrectly labeled, or incorrectly sent. Making a California Privacy Rights Request does not require you to create an account with us. We will respond to verifiable consumer requests within the time required by applicable law, which is generally within forty-five (45) days, subject to any extension permitted by law.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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 a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

For avoidance of doubt, you must still abide by our Terms of Use and Terms of Sale available here https://www.arlettie.com/us/en/terms.

Opt Out or Change Your Information

You may be able to change certain account information by logging in to your account using your username and password and accessing the applicable account settings or profile section. To opt out of marketing emails, click the unsubscribe link at the bottom of an email from us or submit a request through https://www.arlettie.com/us/en/contact/new/c.

Users may also contact us through https://www.arlettie.com/us/en/contact/new/c to request access to, correction of, deletion of, or restrictions on the processing of their Personal Information, subject to applicable law.

Visitors From Outside the United States — Cross-Border Transfer

The Site is operated for Arlettie USA LLC. We may collect personal data from users in the United States and other jurisdictions and may make certain online services available internationally. If you are visiting our Site from outside the United States, please note that your Personal Information may be transferred to, stored in, and processed in the United States and other jurisdictions where we or our service providers operate. The United States may not provide the same level of data protection as the laws of your country. Where required by applicable law, we rely on appropriate safeguards for cross-border transfers of personal data, which may include standard contractual clauses approved by the relevant supervisory authority or other legally recognized transfer mechanisms. Your information may be available to government authorities under lawful orders and applicable laws in such jurisdictions.

By using the Services and/or providing Personal Information to us, you acknowledge that your Personal Information may be transferred to, stored in, and processed in the United States and other jurisdictions as described in this Privacy Policy. We will take steps designed to protect the privacy and security of Personal Information according to this Privacy Policy and applicable law, regardless of where it is processed or stored.

General Data Protection Regulation (GDPR) Privacy Rights

If you are a resident of the European Economic Area, United Kingdom, or another jurisdiction with similar data protection rights, you may have certain rights under applicable law. Arlettie USA LLC is the controller of your personal data provided to, collected by or for, or processed in connection with your use of the Services, unless otherwise stated at the time of collection.

As explained above, we process Personal Information in various ways depending upon your use of our Site and Services. We may process Personal Information on the following bases: (1) with your consent, where consent is required; (2) as necessary to perform a contract with you or to take steps at your request before entering into a contract, including fulfilling online orders, administering memberships, and registering you for events; (3) as necessary for our legitimate interests in providing and improving our products and services, maintaining customer relationships, conducting analytics, screening eligibility, protecting our business, preventing fraud and reseller activity, securing the Services and our showrooms, investigating incidents, and delivering relevant advertising where permitted by law; and (4) as necessary to comply with legal obligations.

Subject to applicable law, you may have the right to object to certain processing, request copies of your personal data, request portability of your personal data, request that we correct or delete your personal data, withdraw consent where processing is based on consent, and lodge a complaint with a supervisory authority. To exercise these rights, please submit a request through https://www.arlettie.com/us/en/contact/new/c.

Existence of Automated Decision-Making

We may use automated decision-making processes, rules-based tools, and related human review to personalize the Services, enhance your shopping, event, and consumer experience on our Site (for example, by recommending certain products, events, brands, or sales to you), to send you personalized promotional emails where permitted, and to support eligibility screening, fraud prevention, reseller detection, order review, return review, invitation controls, and showroom or event access controls. These processes may contribute to decisions to approve, deny, flag, hold for review, limit, suspend, or terminate particular transactions, memberships, invitations, registrations, returns, or access requests. We do not use automated decision-making alone to make decisions that produce legal or similarly significant effects concerning users except as permitted by applicable law, and where required by law we will provide any required information or safeguards.

Communications with Arlettie

By providing your email address to Arlettie, you expressly consent to receiving emails from us where consent is required by applicable law. We may use email to communicate with you, to send information that you have requested, to send transactional or service-related communications, to send event invitations or registration information, to send membership, eligibility, verification, security, or incident-related communications, or to send information about products or services developed or provided by us, and in some cases by third parties where permitted by applicable law. If you receive an unwanted marketing email from us, you may use the unsubscribe mechanism included in the message or submit a request through https://www.arlettie.com/us/en/contact/new/c. We also give you the option, subject to applicable law, to request removal of certain personal information from our active marketing lists. We are not responsible for removing your personal information from the lists of any third party who has been provided with your information in accordance with this Privacy Policy, such as a business partner acting for its own purposes.

For questions or concerns relating to privacy, please contact us through https://www.arlettie.com/us/en/contact/new/c.

Changes to Policy

We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time by posting the updated policy here. For material changes, we will endeavor to provide reasonable advance notice, such as via a notice on the Site or by email, where required by applicable law. Your continued use of the Services following the posting of any changes to this policy means you accept such changes. If you are concerned about potential changes in our Privacy Policy, you should check for an updated version each time you use the Services. You are also advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.