• Preface
• What Information About You Is Collected and Stored?
• How We Collect the Data
• Is Information Collected From Children?
• How We May Share Information
• What Steps Are Taken To Keep Personal Information Secure?
• How Can You Access, Correct and Update Personal Information?
• How Can You Indicate Whether or Not You Want To Receive Promotional Communications?
• What Happens When You Link To or From Another Web Site?
• How Will You Be Informed About Changes Regarding This Privacy Policy?
• Your Use of the Web Site and Brochures Signifies Your Acceptance of These Terms

PLEASE READ CAREFULLY. YOUR USE CONFIRMS YOUR UNCONDITIONAL ACCEPTANCE OF THIS PRIVACY POLICY. YOU SHOULD CHECK THIS PRIVACY POLICY REGULARLY TO SEE IF ANY CHANGES HAVE OCCURRED.

Preface
FREY WILLE USA, Inc., a California corporation ("FWUSA" or "we"), recognizes the rights to privacy of the users and customers ("you") of the freywilleusa.com online store and the frey-wille.com international web site (together, the "Web Site"), as well as the FREY WILLE promotional materials in print for U.S. customers (the "Brochures"). You care how information about you is used and shared, therefore . we have created this Privacy Policy to inform you of our information collection, use and sharing practices for the Web Site and Brochures.
Please be advised that the practices described in this Privacy Policy apply only to information gathered through the Web Site or Brochures and our related Customer Service Department, and do not necessarily reflect our practices with respect to information gathered through other off-line means.
If you have any questions regarding this Privacy Policy, you should contact our Customer Service Department by email at This email address is being protected from spam bots, you need Javascript enabled to view it


What Information About You Is Collected and Stored?
We collect and store information that you enter into the Web Site or that you provide to our Customer Service Department. For example, when you register on freywilleusa.com, we collect and store some or all of the following information that you provide: name, billing address, shipping address, email address, telephone number, credit card number and expiration date, as well as the quantity, prices and types of products you have purchased. This information is used to provide the products and services that you have ordered or requested, to process and ship orders, to send order and shipping confirmations and to provide customer service. Unless you have specifically opted out, this information also may be used to contact you about sales, new products and announcements, changes to our Web Site or policies, and special offers and promotional communications, including by email.
If you purchase online without registering, we will utilize the information you give to us only to authorize the charge to your credit card, to provide the products and services that you have ordered or requested, to process and ship orders, to send order and shipping confirmations and to provide customer service.
We collect and store certain other information automatically whenever you interact with the Web Site. For example, we collect your IP address, operating system information, browser information, reference site domain name, date and time every time you visit the Web Site. We also collect information regarding customer traffic patterns, referrers and site usage. This information is used to analyze and improve the Web Site and to help us provide our customers with a fulfilling shopping experience.
We also may collect and store information about you that you may voluntarily provide or that we may obtain from other sources , to enable us to update and correct the information contained in our database and to provide product recommendations and special offers that we think may interest you.


How We Collect the Data:
We gather personally identifiable data about you from a variety of sources, including from the following:

1. Active Means of Collecting Information: We may actively solicit information about you on our website(s), websites operated by others, via telephone calls, as well as information you fill out when you register on freywilleusa.com, submit an inquiry, or make a purchase in a FREY WILLE boutique.


2. Passive Means of Collecting Information: In addition to actively obtaining information about you, we may also collect information passively through electronic means, including:
   
   
   1. Use of Cookies: One way we collect information about you when you use our websites is through the use of cookies. A "cookie" is a set of data that a website server stores on your computer. Cookies enable websites to recognize your computer and to "remember" your entries as you move from page to page, or even when you revisit the site from time to time using the same computer. Cookies stored on your computer by our websites are encrypted. This means that they cannot easily be read by anyone other than us.
      We use two different types of cookies in our websites:
      "Session cookies" track the user's progression through our sites in a single visit.These cookies enable us to remember things as the user progresses from one page to another. Your session cookies are deleted as soon as you close your browser. In addition, if you leave your browser open for a prolonged period, they are set to automatically erase themselves after a short period (typically less than one hour).
      "Persistent cookies" remember a user at the user's next visit. Your persistent cookies are not automatically erased, and they remain on your computer until you erase them. (If you do not want these cookies to remain on your computer, you can erase them through use of your browser settings.)
      Your browser or other software you install may permit you to restrict the use of session cookies, persistent cookies or all cookies. If you elect not to permit the use of session cookies, you will not be able to use our website. If you elect not to permit the use of persistent cookies only, you may still enjoy the full functionality of our website; however, if you do so, you will need to re-enter some data when starting a new session.
   
   
   2. Use of Log Files: We may collect information in the form of logs, i.e., files that record website activity and gather statistics about web user’s browsing habits. This information helps us determine, among other things, how many and how often users have visited our website, which pages they visited, and other similar navigational data. We also use the log file entries for our internal marketing demographic studies, so that we can improve the online services that we provide you.
      

Is Information Collected From Children?
We do not sell or ship any items ordered through the Web Site directly to anyone who we know to be under the age of 18, nor do we collect any personal information from anyone who we know to be under the age of 18. If you are under the age of 18, you should use the Web Site only with the involvement of a parent or guardian and should not submit any personal information to us.


How We May Share Information
We may share personal information that you provide to us through the Web Site, brochures, or through our Customer Service Department, or any other means with our parent, subsidiary or affiliatesd companies and with our:

• Payment service provider and merchant account bank;
• Delivery service provider;
• Web site programmers and internet service providers; and
• Point-of-sale system providers

In turn, such service providers may engage affiliates or third parties to perform services in connection with the operation of our business. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfillment and shipping, marketing and promotional material distribution, Web Site evaluation, data analysis and, where applicable, data cleansing. Our service providers may provide personal information to these third parties, but we authorize them to use this information only in connection with the services they perform for us and our Web Site and Brochures.

We may release personal information if we believe in good faith that: the law or legal process requires it; we have received a valid administrative request from a law enforcement agency; or such release is necessary to protect the rights, property or safety of FREY WILLE, our respective affiliates, service providers, licensees, franchisees, business partners, customers or others.

We may share non-personal information with our marketing partners, advertisers and others from time to time. Examples of such non-personal information include the number of users who visited the Web Site during a specific time period or purchased a specific product through the Web Site. Non-personal information is shared in an aggregated form.

As with any business, it is possible that as FREY WILLE’s business develops, it might sell or buy online stores or other assets. In such transactions, information about customers often is among the transferred assets. Accordingly, in the unlikely event that FREY WILLE, or substantially all of its assets related to the Web Site, is acquired by a third party, such information may be one of the transferred assets. Under such circumstances, FREY WILLE would to the extent possible require the acquiring party to follow the practices described in this Privacy Policy as it may be amended from time to time.


What Steps Are Taken To Keep Personal Information Secure?
We use various security measures, including Secure Socket Layer (SSL) encryption technology, to protect personal information that we collect. If you place an order through the Web Site, you will be asked to set up an account and provide an email address and password. You must provide an appropriate email address and password in order to access account information. In order to help protect your personal information further, you should be careful about providing your password to others. If you wish to cancel or change your password, or if you become aware of any loss, theft or unauthorized use of a password, please contact our Customer Service Department by email at This email address is being protected from spam bots, you need Javascript enabled to view it




How Can You Access, Correct and Update Personal Information?
You can access, correct and update certain personal information that you have provided to us by clicking on " Change/remove my profile " within the “My Jewelry Box” or the “Service” area of the Web Site.
Alternatively, you may contact us by post, fax or e-mail to access, change or demand removal of your personal information from our records:

FREY WILLE USA, Inc.
219 Arizona Avenue
Santa Monica, CA 90401-1203
Telephone: (310)260-2639
Fax: (310)393-089
e-mail: This email address is being protected from spam bots, you need Javascript enabled to view it




How Can You Indicate Whether or Not You Want To Receive Promotional Communications?
There are several ways in which you can tell us whether or not you want to receive promotional communications from us. When you set up an account, or click on " Change/remove my profile " within the “My Jewelry Box” or the “Service” area, or place an order, you will have an opportunity to make or change your selections in this regard. You also will have an opportunity to change these selections by notifying us in writing by e-mail, fax, or by post. Such changes may take effect in up towithin ten (10) business days.




What Happens When You Link To or From Another Web Site?
The Web Site may contain links to other web sites operated by parent, subsidiaries or affiliated companies of FWUSA or third parties. FWUSA is not responsible for the privacy policies, practices or contents of such other web sites. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these other web sites. We encourage you to be aware of when you leave the Web Site. You are responsible for reviewing the privacy policies and practices of each and every web site that you visit.




How Will You Be Informed About Changes Regarding This Privacy Policy?
FWUSA reserves the right to modify this Privacy Policy at any time. If we make any changes to this Privacy Policy, we will post the revised Privacy Policy at the Web Site. In some cases, we also may choose to post a notice on the Web Site notifying users of the changes, or to send an email notifying users of the changes, but we are not required to do so. You should check the Web Site regularly to see if any recent changes to this Privacy Policy have occurred.
This Policy was last changed on November 2, 2006:





Your Use of the Web Site and Brochures Signifies Your Acceptance of These Terms
By visiting the Web Site, you signify your acceptance of this Privacy Policy with respect to non-personal information. By providing personal information to us, either through the Web Site, the Brochures, or our Customer Service Department, or otherwise, you signify your acceptance of this Privacy Policy with respect to personal information. If you do not agree with anything described in this Privacy Policy, you may discontinue use of the Web Site and Brochures. Your continued use of any portion of the Web Site or Brochures following notification or posting of changes to the Privacy Policy will constitute your acceptance of these changes.

©FREY WILLE 2006