DAVID'S BRIDAL, INC.
EU SAFE HARBOR PRIVACY STATEMENT
David's Bridal has elected to self-certify to the Department of Commerce that it adheres to the Safe Harbor Privacy Principles and the Frequently Asked Questions (collectively, the "Safe Harbor Principles") established by the United States Department of Commerce. This EU Safe Harbor Privacy Statement (the "Statement") sets forth the privacy principles followed by David's Bridal in connection with the transfer and protection of Personal Information received from the European Union ("EU").
DEFINITIONS. For purposes of this Statement, the following definitions shall apply:
"Agent" means any third party that collects or uses Personal Information under the instructions of, and solely for, David's Bridal or to which David's Bridal discloses Personal Information for use on David's Bridal behalf.
"David's Bridal" means David's Bridal, Inc. and its subsidiaries and divisions in the United States.
"Personal Information" means any information or set of information that identifies or is used by or on behalf of David's Bridal to identify an individual. Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Information.
"Sensitive Personal Information" means Personal Information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or data concerning health or sex life.
SCOPE. This Statement applies to all Personal Information received by David's Bridal in the United States from the EU in any format, including electronic, written or oral formats.
NOTICE: David's Bridal notifies individuals about the types of Personal Information it collects about them, the purposes for which it collects Personal Information, the types of third parties to which it discloses Personal Information, ways that individuals may limit the use and sharing of Personal Information and how to contact David's Bridal with any inquiries or complaints. This notice will be provided when individuals are first asked to provide Personal Information or as soon thereafter as is practicable, and in any event before David's Bridal uses or discloses Personal Information for a purpose other than that for which it was originally collected.
CHOICE: David's Bridal will offer an individual the opportunity to choose (opt out) whether Personal Information is (a) shared with a non-Agent third party or (b) used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. To opt out of the sharing or use of Personal Information as contemplated by the preceding sentence, an individual should send an email to David's Bridal at Donotcontact@dbi.com stating that the individual does not want David's Bridal to share Personal Information with a non-Agent third party or to use Personal Information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, we will give an individual an affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individual.
ONWARD TRANSFER (TRANSFERS TO THIRD PARTIES): David's Bridal will only transfer Personal Information to an Agent that has provided assurances to provide at least the same level of privacy protection as is required by this Statement or to an Agent which subscribes to the Safe Harbor Principles, is subject to EU Directive 95/46/EC, or is subject to another European Commission adequacy finding. Where we know that an Agent is using or sharing Personal Information in a way that is contrary to this Statement, we will take reasonable steps to prevent or stop such processing. David's Bridal will only transfer Personal Information to a non-Agent third party where consistent with the notice provided to the individuals who are the subject of the Personal Information and with any opt-out choice exercised by those individuals.
ACCESS: Upon written request to David's Bridal, David's Bridal will grant individuals reasonable access to their Personal Information held by David's Bridal. David's Bridal will also take reasonable steps to permit individuals to review their Personal Information for the purpose of correcting it. There are certain limitations to these access rights, as set forth in the United States Department of Commerce Safe Harbor website.
SECURITY: David's Bridal will use reasonable precautions to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
DATA INTEGRITY: David's Bridal collects Personal Information that is relevant for the purposes for which it is to be used. David's Bridal will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.
ENFORCEMENT: David's Bridal has enacted mechanisms to verify ongoing compliance to this Statement. Any David's Bridal employee who violates this Statement will be subject to disciplinary procedures in accordance with David's Bridal's disciplinary policies. In case of disputes, individuals are able to seek resolution of their complaints regarding use and disclosure of their Personal Information in accordance with this Statement. If you feel that David's Bridal is not abiding by this Statement or is not in compliance with the Safe Harbor Principles, you should first contact David's Bridal at its contact information below. If you do not receive acknowledgment of your complaint or you think it has not been satisfactorily addressed, you should then contact the Better Business Bureau ("BBB") at www.bbb.org/us/safe-harbor-complaints. The Better Business Bureau will resolve any complaint that has not been satisfactorily resolved by David's Bridal.
LIMITATION ON SCOPE OF STATEMENT: Adherence to this Statement may be limited to the extent required to meet a legal, governmental, national security or public interest obligation.
CONTACT INFORMATION: Questions or comments about this Statement or complaints or disputes about David's Bridal's use or disclosure of Personal Information should be directed to:
David's Bridal, Inc.
EUSafeHarbor@dbi.com (Email contact is preferred)
CHANGES TO STATEMENT: David's Bridal may amend this Statement from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the privacy pages of David's Bridal's web page at www.davidsbridal.com when this Statement is materially changed. This Statement is effective as of November 2, 2009.