Privacy Notice for California Residents

This Privacy Notice for California Residents (the “Notice”) supplements the information contained in our privacy policy and applies only if you are resident of the State of California (a “California Resident”).

For purposes of this Notice “Sell,” “Selling,” “Sale,” or “Sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to another business or a third party for monetary or other valuable consideration.

“Verifiable Request” means the identifying information provided by a California Resident in connection with a request matches the personal information of the California Resident already maintained by us. We accept the following identifying information to verify your identity: the email address you used to sign-up for the Site. Be aware that certain requests, such as requests for specific Personal Information or requests to delete Personal Information, may require us to be more selective about the types of identifying information required to fulfill your request. For example, we may require additional information to verify your identity if you submit a request to delete your Personal Information.

“Share”, “Shared,” or “Sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to a third party for Cross-context Behavioral Advertising, whether or not for monetary or other valuable consideration.

“Cross-context Behavioral Advertising” means the targeting of advertising to a California Resident based on that California Resident’s Personal Information obtained from activity across businesses or distinctly- branded websites, applications, or services, other than the business or distinctly-branded website, application, or service with which the California Resident intentionally interacts. (In other words, if we send you an ad based solely on your interaction with us or our Site, this is not Cross-context Behavioral Advertising.)

“Sensitive Personal Information” means Personal Information that is not publicly available and reveals one or more of the following:

• A California Resident’s Social Security, driver’s license, state identification card, or passport number;
• A California Resident’s account log-in, financial account, debit card or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
• A California Resident’s precise geolocation;
• A California Resident’s racial or ethnic origin, religious or philosophical beliefs, or union membership;
• The contents of a California Resident’s mail, email, and text messages unless we are the intended recipient of the communication;
• A California Resident’s genetic or biometric data; or
• Personal Information collected and analyzed concerning a California Resident’s health, sex life, or sexual orientation.

In the past twelve (12) months, Frette has collected the following categories of Personal Information
from California residents:

Users of the Site:

• Browsing data, including IP address, domain names of the computers used by the users connecting with Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user's operating system and computer environment
• Name, surname and contact details submitted to Frette through the Site

Store Customers:

• Name, surname, address, nationality, phone numbers, email address, date of birth

Store Customers and Users of the Site:

• Personal Information sent by post, e-mail, fax sent on a voluntary basis or communicated during a phone conversation

Additionally, in the past twelve (12) months, Frette has not collected Sensitive Personal Information from California Residents.

Frette obtains this Personal Information directly from you, for example, from forms you complete or information you submit to the Site. Frette may also receive information indirectly from you, for example, from information automatically sent by your web browser or from analyzing data about your actions on our website.

Frette may use, or disclose the Personal Information we collect for one or more of the following “Business Purposes:”

• To fulfill or meet the reason you provided the information, such as fulfilling an order you place or responding to your customer service requests;
• To provide, improve, develop, secure, and market our Site and products;
• To communicate with you, including sending marketing messages, by a variety of methods including, mail, email, telephone, SMS, and Cross-context Behavioral
• Advertising;
• To comply with our legal and contractual obligations, and enforce our legal and contractual rights;
• To prevent fraud;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• To respond to your requests under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”);
• For any other purpose described to you when we collect your Personal Information; and
• For any other acceptable purposes as set forth in the CCPA.

Unless we notify you otherwise, we will not collect additional categories of Personal Information, nor use the Personal Information we collect for any other materially different, unrelated, or incompatible purposes.

Frette may disclose Personal Information to our “service providers, “contractors,” and “third parties” (each as defined by the CCPA) for a Business Purpose.

When we disclose Personal Information for a Business Purpose, we enter into an agreement with the receiving party that describes the purpose for sharing the Personal Information, and that requires the receiving party to keep that Personal Information confidential. In the case of disclosures to our service providers, our service providers are obligated not to use the Personal Information for any purpose other than performing the services according to our agreement with them. In the case of our contractors, our contractors are obligated not to use the Personal Information for any purpose unrelated to the Business Purpose for which we engaged them.

We may disclose your Personal Information with the following categories of third parties: service providers, contractors, and advertisers.

We retain each category of your Personal Information for no longer than is reasonably necessary for one or more Business Purposes, subject to your right to request we delete your Personal Information. We intend to retain your Personal Information for the shorter the time required for the applicable Business Purpose or the retention period required by applicable law.

In the past twelve (12) months, Frette has not Sold any Personal Information about its California Residents.

Unless we update this Notice or notify you otherwise, we will not collect additional categories of Personal Information, nor use the Personal Information we collect for any other materially different, unrelated, or incompatible purposes.

If you are a California Resident, you may request information about our collection, use, disclosure and Sale of your Personal Information over the past twelve (12) months, whether or not it was collected electronically. If you submit a Verifiable Request, we will provide you with information regarding:

(a) the categories of Personal Information we have collected about you; the categories of sources from which your Personal Information was collected; our Business Purpose for collecting, Selling, or Sharing your Personal Information; the categories of third parties with whom we disclose that Personal Information; and the specific pieces of Personal Information we collected about you; and

(b) if we Sold, Shared, or disclosed your Personal Information for a Business Purpose: what categories of Personal Information we Sold, Shared or disclosed, and to which categories of recipients we Sold, Shared or disclosed it to; and what categories of Personal Information we disclosed for a Business Purpose, and to which categories of recipients we disclosed it to.

You also have the right to request a copy of your Personal Information, and/or to request that we transmit your Personal Information to another entity. To the extent technically feasible, we will comply with your request and provide and/or transmit your Personal Information in a structured, commonly used, machine-readable format.

You also have the right to request that we delete any of your Personal Information that we collect or maintain by submitting a Verifiable Request. We may deny your deletion request if retaining your Personal Information is necessary for us or our service providers or contractors to:

• Complete the transaction for which we collected your Personal Information, provide goods or services 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 illegalactivity, 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 California Resident to exercise their right of free speech, 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 achievement of such research, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with California Resident expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

You further have the right to request that we correct any of your Personal Information that is inaccurate by submitting a Verifiable Request. We will correct any inaccurate Personal Information pursuant to
your request to the extent possible using commercially reasonable efforts. We may deny your correction request if the Personal Information is accurate. We may also delete your Personal Information instead of correcting it to the extent such deletion would not negatively impact you.

If you choose to exercise a privacy right under the CCPA, you have the right not to receive discriminatory treatment.

You may submit a Verifiable Request for the information listed above, or exercise any of your rights enumerated under this Notice, by calling us at 212.299.0400 Ext 1, or by email to privacy@frette.com. You may also submit a Verifiable Request on behalf of your minor child. After we receive your Verifiable Request, we will provide to you, in writing and free of charge (unless your request is excessive, repetitive, or manifestly unfounded), the requested information for the 12- month period preceding your request (unless you specifically request disclosure beyond such 12-month period, in which case, we will process your request with respect to Personal Information we have collected during the time period you specify, provided that (a) the earliest date that your request may apply to is January 1, 2022, and (b) processing your request does not require disproportionate effort). You may choose to have this information delivered to you by postal mail, or electronically. We will try to respond to your verified request within forty-five (45) days of receipt, but if we require more time (up to another forty-five (45) days) we will inform you of the reason and extension period in writing. Please note that we are not required to comply with your request for information more than twice in any 12- month period. If applicable, our response will explain the reasons why we cannot comply with your request.

If you are 16 years of age or older, you will have the right to direct us to stop Sharing your Personal Information at any time. You may opt-out here. However, if you change your mind, you may opt-in to Personal Information Sales at any time by re-registering for the Site. Frette does not and will not, without first obtaining your consent, Sell Personal Information.

If you choose to exercise any of the rights enumerated under this Notice, 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; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, it may be a functional necessity for our Site to have Personal Information about you in order to operate, and we may not be able to provide some or all of our Site to you if you direct us to delete your Personal Information.