Updated: 26 November 2024
NOTICE FOR INDIVIDUALS IN ASIA (INCLUDING SOUTH AFRICA, AUSTRALIA AND NEW ZEALAND)
If your Personal Information is subject to the laws of one of the countries identified below, please review the information in the following Supplemental Notices which may apply to you. In the event of a conflict between the other sections of the Privacy Notice and these Supplemental Notices, the provisions of the Supplemental Notices will apply to the extent needed to resolve the inconsistency or conflict.
A list of relevant LS&Co. group companies and local partners which will be the data controller in the respective region is set out below.
Australia
Levi Strauss (Australia) Pty. Ltd.
Indonesia
PT Levi Strauss Indonesia PT Koneksi Niaga Solusindo
Japan
Levi Strauss Japan Kabushiki Kaisha
Malaysia
LS Retail (Malaysia) Sdn. Bhd
New Zealand
Levi Strauss New Zealand Limited
Philippines
Levi Strauss Philippines, Inc. II
Singapore
Levi Strauss Asia Pacific Division, PTE. LTD.
South Africa
South Africa is Levi Strauss South Africa Ltd
Taiwan
Levi Strauss U.S.A. LLC Taiwan Branch
Thailand
Levi Strauss (Thailand) Ltd.
Vietnam
Au Chau Fashion & Cosmetic Company Limited
“LS&Co.” and “we” as used in this Supplemental Notice (“Supplemental Notice for Asia”) means the relevant Levi Strauss entity listed above, which will act as the “data controller” (or such equivalent term as “data collector”, “controller”, “data user” or “owner” under applicable law) shall have responsibility for Personal Information as described in this Privacy Notice and Supplemental Notice.
Retention of Personal Information
Your Personal Information will be processed and kept from the moment it is collected and for as long as you are our customer. This includes purchasing products directly from us or through our partners, engaging with our platforms and reviewing our content. Following the conclusion of our relationship, we may still retain certain information (e.g., transactional information) to the extent required or permitted by law. We keep information on potential customers for not more than 3 years following the date of last contact or such longer period as is permitted or required by applicable law (for example, a period of 5 years for Indonesian residents).
Purpose(s) And Legal Basis for Processing
Our collection, use, disclosure, and other processing (such as recording, analyzing, storage, rectification, combination, access, copying, sharing, transmission, provision, transfer, deletion and destruction) of Personal Information is necessary for the following legal basis (to avoid doubt in addition to those specified in the Privacy Notice):
- performance of the contract between us to provide you with products and services including sending you transactional communications, verifying your identity, assisting you in-store, on the sites, processing payments, returns, exchanges, orders, shipping products, and providing customer service, and to conduct automated decision-making processes in accordance with any of these purposes. For residents in Thailand, if you do not provide any Personal Information that is necessary for entering into a contract with you, or for performance of the contract, we may not be able to establish a legal relationship with you, or enter into a contract with you or perform our obligations (either in whole or in part), or provide you with our products and services, or proceed with your order and the payment;
- for purposes we consider to be in our legitimate interests including improving the functionality and integrity of our platforms and stores, keeping consumers up to date with information about our products and services, completing corporate transactions, understanding consumer preferences, personalizing our interactions and developing our business relationship, as these functions help sustain and grow our business;
- to comply with a legal obligation to which we may be subject, such as complying with orders from government or other legal authorities, detecting and preventing illegal conduct, abuse, spam, fraud (e.g. account takeovers or payment related fraud) security incidents and other harmful activities. For residents in Thailand, if you do not provide any Personal Information that is necessary for compliance with the law which is applicable to us, we and/or you may be unable to comply with the laws, and that may result in the violation of applicable laws.
Where we are required by law to obtain your consent before collecting, using, disclosing or otherwise processing Personal Information, we will rely upon consent as our basis for the collection, use, disclosure or other processing.
Marketing
We will use your Personal Information to send you marketing communication about products, services and memberships that we feel may be of interest to you. We will give you the opportunity to consent to the receipt of marketing by unsolicited electronic communications at the point that you apply or register to receive the products and services. Should you already be considered our existing customer who receives marketing by unsolicited electronic communications from us in relation to the same or similar products and services, we will give you the opportunity to opt out of receiving marketing by unsolicited electronic communications on each occasion thereafter that you receive marketing communications from us. You can also change your marketing preferences at any stage by contacting us.
Your Data Subject Rights
You may have the following rights with respect to your Personal Information and, upon receiving your request, we will honor it as required under applicable laws:
- Request access to, a copy of, and/or information on the processing of your Personal Information;
- Correction/rectification of your Personal Information where it is inaccurate or incomplete;
- Erasure, deletion or anonymization of your Personal Information in certain circumstances;
- Object to or restrict processing of your Personal Information in certain circumstances;
- Request to discontinue collection, processing or use of your Personal Information;
- Withdrawal of your consent to collection, use, disclosure or other processing of your Personal Information;
- Objection to automated-decision making and profiling (including for marketing purposes);
- De-registration of your account;
- Data portability;
- Lodging a complaint with us or with the relevant data protection authority;
- Claim damages in certain circumstances;
- Have your Personal Information kept confidential.
In addition to the data subject rights above, if you are in Thailand, you may be entitled to request for the disclosure of the source of Personal Information if we have collected it without your consent. If you are in the Philippines, you will be informed if your Personal Information will be used for automated decision-making or profiling.
Contact information for making such a request is set out in the “CONTACT US” portion of this Supplemental Notice for Asia.
Children
Our Asia Pacific Platforms are not intended to address anyone under the age of 18 (or the age of 20 in Thailand; the age of 15 in Vietnam; or the age of 18 in Indonesia) (“Children”). We do not knowingly collect Personal Information from Children. If you are a parent or guardian and you are aware that your child has provided us with Personal Information without your consent, please contact us using information in the “CONTACT US” section below and we will take steps to remove the Personal Information.
International Processing
If you are a resident of Australia, New Zealand, the Philippines, Indonesia, or Thailand, your Personal Information may be transferred outside of your country of residence and/or transferred to people or entities based or incorporated outside of your country of residence, including to Australia, Canada, India, Ireland, Singapore, and the U.S. While these jurisdictions may not have the same data protection laws as where you reside, we will use reasonable endeavours to require those we disclose your Personal Information to, for example our service providers and Affiliates, to protect it in a way that provides comparable safeguards to the laws in your location (such as by way of contractual data protection obligations) or where you expressly authorize us to make such a disclosure. This is to ensure they protect the integrity and security of your Personal Information. Notwithstanding the foregoing, you acknowledge that sometimes overseas recipients of your Personal Information may not be required to protect it in a way that provides comparable safeguards.
Languages Other Than English
If the Privacy Notice and these Supplemental Notices are translated into or appear in a language other than English (as may be required to be in compliance with applicable local language laws to which a party may be subjected to), the English language version shall control.
ADDITIONAL SUPPLEMENTAL TERMS FOR INDIVIDUALS IN SOUTH AFRICA
This Notice applies to the processing of Personal Information entered into a record by a data controller within the Republic of South Africa. If you are a user located in South Africa, the terms set out below apply to you in addition to the terms set out in our Privacy Notice including the Supplemental Notice for Individuals in Asia. If there is any conflict among the Privacy Notice, Supplemental Notice for Asia and these Supplemental Terms for South Africa, these Supplemental Terms for South Africa shall prevail with respect to the relevant issue. For purposes of this Supplemental Notice and where the processing of Personal Information is subject to South African laws, references to the following terms, shall have the corresponding meaning as applicable in the Protection of Personal Information Act, 2013, as amended or replaced from time to time ("POPIA"):
"Data Controller" shall include a "responsible party" as defined in POPIA;
"Data Subject" shall include a "data subject" as defined in POPIA, which shall include living natural persons and existing juristic persons;
"Data Processor" shall include an "operator" as defined in POPIA;
“Information Regulator” shall mean the data protection supervisory authority in South Africa, as established under POPIA;
"Personal Information" shall be as defined in POPIA, which shall include Personal Information in relation to living natural persons and existing juristic persons;
"Process" or "Processing" shall be as defined in POPIA; and
"Sensitive Data" shall include "special personal information" and “personal information” relating to children as defined in POPIA.
Purpose(s) and Legal Basis for Processing
Our collection, use, disclosure and other processing of Personal Information is necessary for the following legal bases:
- where applicable, with your consent in respect of the processing of your Personal Information, (for example, where we are required to obtain your prior consent in order to send you direct marketing communications by electronic means);
- performance of the contract between us to provide you with products and services including sending you transactional communications, verifying your identity, assisting you in-store, on the sites, processing payments, returns, exchanges, orders, shipping products, and providing customer service;
- for purposes we consider to be necessary for pursuing our legitimate interests or the legitimate interests of third parties to whom we disclose your Personal Information to including improving the functionality and integrity of our platforms and stores, keeping consumers up to date with information about our products and services, completing corporate transactions, understanding consumer preferences, personalizing our interactions and developing our business relationship, as these functions help sustain and grow our business;
- to protect your legitimate interests (e.g. where we use the Personal Information provided to us to give effect to your benefit);
- to comply with a legal obligation to which we may be subject, such as complying with orders from government or other legal authorities, detecting and preventing illegal conduct, abuse, spam, fraud (e.g. account takeovers or payment related fraud), security incidents and other harmful activities.
Before collecting and/or using any special personal information (including photographs and video images) or Personal Information relating to Children, we will establish a lawful justification to use that information. This justification will typically be:
- your consent or the consent of a competent person in relation to a child, if applicable;
- the establishment, exercise or defence by us of a right or obligation in law, or to comply with an international public law obligation;
- for historical, statistical or research purposes to the extent that: (i) the purpose serves a public interest and the processing is necessary for the purpose concerned; or (ii) it appears to be impossible or would involve a disproportionate effort to ask for your consent, and sufficient guarantees are provided to ensure that the processing does not adversely affect your privacy to a disproportionate extent;
- you have deliberately made the Personal Information public; or
- a context specific exemption provided for under South African local laws in relation to the processing of special personal information or information relating to Children, such as to identify you when it is essential for that purpose and to comply with laws and other measures designed to protect or advance persons, or categories of persons, disadvantaged by unfair discrimination.
Transfers and Processing
Please be aware that your Personal Information may be transferred to and maintained on servers or databases located outside of South Africa, including to countries and organisations which have not been determined by the South African Information Regulator to have an adequate level of data protection as provided for under POPIA, including the United States.
When we do transfer your Personal Information, we use a variety of legal mechanisms to help ensure your rights and protections travel with your data:
- we ensure transfers within the LS&Co. entities are covered by agreements based on the EU Commission's standard contractual clauses as amended for compliance with South African local laws, which contractually oblige each member to ensure that Personal Information receives an adequate and consistent level of protection wherever it resides within the LS&Co. entities;
- where we transfer your Personal Information outside LS&Co. entities or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your Personal Information based on the standard contractual clauses as amended for compliance with South African local laws; and
- where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.
In addition, if we transfer any special personal information or Personal Information relating to Children to third parties including other LS&Co. entities in countries that do not have adequate data protection laws with data protection principles similar to POPIA, we shall do so only with the requisite prior authorisation of the Information Regulator, in circumstances where required.
Direct Marketing
We will use your Personal Information to send you direct marketing about other products and services that we feel may be of interest to you. We will give you the opportunity to consent to the receipt of direct marketing by unsolicited electronic communications at the point that you apply or register to receive the products and services. Should you already be considered our existing customer who receives direct marketing by unsolicited electronic communications from us in relation to the same or similar products and services, we will give you the opportunity to opt out of receiving direct marketing by unsolicited electronic communications on each occasion thereafter that you receive direct marketing communications from us. You can also change your marketing preferences at any stage by contacting us.
ADDITIONAL SUPPLEMENTAL TERMS FOR INDIVIDUALS IN JAPAN
The local entity acting as the data controller for Personal Information collected in Japan is Levi Strauss Japan Kabushiki Kaisha. If you are a user located in Japan, the terms set out below apply to you in addition to the terms set out in our Privacy Policy including the Supplemental Notice for Asia above. If there is any conflict among the Privacy Policy, Supplemental Notice for Asia, and these Supplemental Terms for Japan, these Supplemental Terms for Japan shall prevail with respect to the relevant issue.
Joint Use Notice
Your Personal Information may be jointly used with our Affiliates in accordance with Article 27.5.3 of the Act on the Protection of Personal Information (“APPI”) within the scope necessary for achieving the purposes described in “YOUR PERSONAL INFORMATION”. Please see above for a list of our Affiliates. The categories of Personal Information jointly used are also described in “YOUR PERSONAL INFORMATION”. Levi Strauss Japan K.K. is responsible for the joint use of Personal Information (please see https://www.levistrauss.co.jp/ for our address and representative director’s name).
Your Data Subject Rights
In Japan, you may also have additional unique rights under the APPI such as:
- To request deletion of or cessation of processing of your Personal Information if your Personal Information has been used beyond the scope necessary to achieve the purpose for which they were collected, processed or obtained by deceit or in violation of the Article 20 of the APPI, if our use of your Personal Information triggers illegal acts, are no longer necessary in relation to the purposes for which they were collected, compromised or otherwise processed in a manner which could harm the rights or legitimate interest of you;
- To request cessation of transferring of your Personal Information if your Personal Information is transferred to a third party in violation of the Article 27.1 or Article 28 of the APPI or the transfer could harm your rights or legitimate interest;
- To request to disclose the following information (we may refuse your request to the extent we are permitted to do so in accordance with APPI):
- data security measures we have implemented;
- your Personal Information that we retain, and
- in cases where your Personal Information has been shared with foreign companies including our Affiliates by way of joint use and external foreign service providers, (i) measures to ensure the data recipients take sufficient data security measures (the “Measures”) and the details of the Measures, (ii) measures and frequency that we audit the data recipients’ implementation of the Measures, (iii) name of the recipient country and rules of the country that could hinder the implementation of the Measures, and (iv) other obstacles that could hinder the implementation of the Measures and measures that we have conducted to solve such obstacles; and
- To request to correct, add, or delete of your Personal Information if your Personal Information is contrary to the fact.
ADDITIONAL SUPPLEMENTAL TERMS FOR INDIVIDUALS IN VIETNAM
This Supplemental Notice applies to the processing of Personal Information by a data controller within Vietnam. If you are a user located in Vietnam, the terms set out below apply to you in addition to the terms set out in our Privacy Notice including the Supplemental Notice for Individuals in Asia. If there is any conflict among the Privacy Notice, Supplemental Notice for Asia and these Supplemental Terms for Vietnam, these Supplemental Terms for Vietnam shall prevail with respect to the relevant issue.
Safeguarding Your Personal Information
No data collection, storage, or transmission, including over the Internet or other network can be
guaranteed to be 100% secure, so despite our efforts we cannot and do not guarantee the security
of any data you transmit to us, including on, or through, our Platforms. In the case of any incident involving your Personal Information, you may experience anxiety, emotional distress, increased vulnerability to identity and financial fraud.
Your Data Subject Rights
In addition to the data subject rights above, you may be entitled to self-protection subject to the following obligations:
- To protect your own Personal Information and the one of others;
- Fully and accurately provide your Personal Information when you consent to our processing;
- Participate in the dissemination of personal data protection skills;
- Comply with personal data protection regulations.
Contact Us (Supplemental Notice For Asia)
Australia and New Zealand: If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or, depending on your jurisdiction, contact the Office of the Australian Information Commissioner (www.oaic.gov.au) or the Office of the Privacy Commissioner (New Zealand) (www.privacy.org.nz) for guidance on alternative courses of action which may be available.
Malaysia: If you have any questions, complaints or concerns about the Levi Strauss & Co. Privacy Policy or our data protection practices, or if you wish to exercise your data subject rights, please call us at +600376800800, send an email to privacy@levi.com or to the attention of:
Lim Horng Dar
Manager, Global Security & Resilience
11 North Buona Vista Drive
#14-09 Metropolis Tower 2
Singapore 138589
Other APAC or SAMEA countries: If you have any questions, complaints or concerns about the Levi Strauss & Co. Privacy Policy or our data protection practices, or if you wish to exercise your data subject rights, please send an email to privacy@levi.com or to the attention of:
Lim Horng Dar
Manager, Global Security & Resilience
11 North Buona Vista Drive
#14-09 Metropolis Tower 2
Singapore 138589
Philippines: If you have any questions, complaints or concerns about the Levi Strauss & Co. Privacy Policy or our data protection practices, or if you wish to exercise your data subject rights, please send an email to privacy@levi.com, call us at +63284242958, or write to the attention of:
Levi Strauss Philippines, Inc. II
20/F, Tower 2,
The Enterprise Center,
Paseo De Roxas,
Makati City 1229, Philippines
South Africa: You have the right to lodge a complaint with the South African Information Regulator. You may contact the office at: complaints.IR@justice.gov.za and at +27 (0) 10 023 5200 or 33 Hoofd Street Forum III, 3rd Floor Braampark, South Africa, Braamfontein, Johannesburg.
Thailand: If you have any questions, complaints or concerns about the Levi Strauss & Co. Privacy Policy or our data protection practices, or if you wish to exercise your data subject rights, please send an email to privacy@levi.com or call us at +66020385833 to the attention of:
Levi Strauss (Thailand) Ltd.
690 UOB Plaza Bangkok, 11th Floor,
Sukhumvit Road, Khlong Tan, Khlong Toei,
Bangkok, 10110 Thailand
Vietnam: If you have any questions, complaints or concerns about the Levi Strauss & Co. Privacy Policy or our data protection practices, or if you wish to exercise your data subject rights, please send an email to privacy@levi.com, call us at +8439397999, or write to the attention of:
Au Chau Fashion and Cosmetics Co., Ltd.
Level 6 – Saigon Royal Building, 91 Pasteur Street
Ben Nghe Ward, District 1
Ho Chi Minh City, Vietnam