LAST UPDATED: 01TH DECEMBER 2020
2. THIRD PARTY WEBSITES
3. WHAT INFORMATION DO I COLLECT, AND HOW?
When you interact with me, whether by using my Website or communicating with me, I may collect the following information about you:
• information you give me: you may give me information about yourself if you sign up for an account on my Website, place an order for services, complete any online forms (such as registration forms, challenges, and workshops), opt-in to receive my newsletters and special offers, enter a competition or promotion, participate in social media functions with my Website, or correspond with me (by email, telephone, instant chat, social media or otherwise). Depending on what you provide, this information can include your name, address or location, phone number and email address, date of birth, gender, purchase information, shopping preferences, images and financial information (including your credit or debit card details, although I do not hold them, mine Payment processing companies do). If you register an account on the Website, then you may choose to give me your picture and nickname. From your account, you can also invite your friends to visit at my Website (including by email, Facebook, or Twitter). Although I will let them know that I received their details from you, please ensure that you have the permission of your friends before sharing their contact details with me and only forward emails to people you know would be happy to receive them.
• information my IT systems collect about you: each time you visit the Website, certain information will be created and automatically recorded by my IT systems. That information includes:
b) device information: the information provided by your device will differ depending on which type of device you are using and the settings on that device, but includes the type of device you have, the device’s IP address, the browser you are using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.
4. WHAT DO YOU USE MY INFORMATION FOR?
a) To register and manage your account in my Website, I collect your name, email, password and other additional details you may wish to add in your account, like phone number, addresses and gender. The legal basis is the performance of a Contract with you.
b) To fulfil the orders you make through my website, I collect your Name, addresses, phone number, Order details, like the services and products you are buying and price. The legal basis is the performance of a Contract with you.
c) To collect payment from you I collect your payment information, which comprises the credit/debit card’s number, holder’s name and CVV I do not store them and only transfer them to my authorized payment providers. The legal basis is the performance of a Contract with you.
d) To provide you with my customer services (including helping you to solve any issue you have with my services, updating you about any change to my terms of service, or contacting you to know how was your experience with me) I collect your name, email, password and addresses and your contact history with me (including phone records of my conversations. The legal basis is the performance of a Contract with you and my legitimate interests in retaining you as a customer.
e) To monitor the quality of my customer services, I collect your name, email, password and addresses and your contact history with me. The legal basis is the legitimate interests in running my business.
f) To administer, maintain and optimise my Website and my services, I collect your device information (such as your device IP address and device type), Cookie identifiers and browsing information. The legal basis is the legitimate interests in running my business.
g) To perform fraud and credit checks and if I can do business with you, I collect your name; email; addresses; credit/debit card details; browsing history; purchase history; date of birth; gender; device information (such as IP address and device type), any national identifiers (like driver’s license or ID cards) and any publicly available information (like social media profiles or news). The legal basis is the legitimate interests to protect BABROUSKAYA YAUHENIYA ALIAKSANDRAUNA and her customers from fraudulent activities and compliance with a legal obligation.
h) To send you marketing communications and personalised offers, I collect your Name; Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behavior; Device information; Cookie identifiers; Internal identifiers; Country. The legal basis is the legitimate interests to electronic direct marketing of similar products and services to that which you have acquired using my Website or, when such is not applicable, your Consent.
i) To provide you with personalised recommendations and enhance your experience, I collect your Name Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behaviour; Device Information; Shopping preferences; Nickname; Cookie identifiers; Internal identifiers; Country; Spent tier level and Wealth. The legal basis is my legitimate interests in running my business and improve my Website and your experience.
j) Carry on research, analysis, enquiries and surveys on your use of my website, I collect your Name; Addresses; Email; Device information, legal basis is my legitimate interests in running my business and improve my Website and your experience.
k) Advertising and retarget advertising of my services and my Partners’ products and services, I collect your email, cookie identifiers and device information. The legal basis is my legitimate interests in running my business.
l) To produce aggregated statistical reports, I use your order history, provided that the result of such reports do not identify you. The legal basis is my legitimate interests in running my business and improve my Website.
5. WHO DO YOU SHARE MY INFORMATION WITH?
To provide the Website and my services, I work with a number of carefully selected third parties. To do this, I may share your information with these third parties in the following limited circumstances:
• Third party service providers for business purposes: to function properly, I rely on a number of carefully selected third parties to provide me with services and products. I permit these companies to use your personal information only to the extent necessary to provide me with their services and products. Below you can find the types of third parties I use: a) Payment providers that I use to process your payment information (including your credit/debit card details) so that I can collect payment from you.
b) Eventually Anti-fraud and credit check providers to keep me and you secure. They have access to and process your information and associated orders in order to check for any fraudulent behaviour.
c) Analytics and search engine providers, like Google, Yahoo, Baidu that I use to assist me in the improvement and optimisation of the website. These providers are based in the United States, in Europe and in China.
d) Marketing Tools providers that help me to enable my marketing.
e) IT/technology providers that I use to support, maintain and provide my technology and IT infrastructure that supports my Website and the storage of your information.
f) advertisers for marketing purposes: I can provide your information to my advertising and social media partners (including Facebook and Twitter, where you choose) where they require the data to select and serve relevant adverts about my services and my partners’ products and services to you and others;
g) third party service providers to enrich data: I may also enrich, match or combine information I hold about you with data from other sources, for instance by sharing some of your personal data with selected business partners. I do this to better understand your customer profile and interests so that I can deliver customised offers and other personalised services;
h) to comply with legal requests: on occasion I may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. Although I dispute requests wherever suitable, in some cases I may have to share your information with the regulators or law enforcement agencies. Where I consider it appropriate, and provided I are not prohibited from doing so by law or court order, I will attempt to notify you of these legal demands; and
i) aggregated information with third parties: I may aggregate your information with the information of other customers, creating a dataset of information about the usage of my Website, purchase of services and products, and other general, grouped information about my customers on the basis of my legitimate interest to understand the usage of my service and demand for my product. Although this dataset is aggregated and anonymised, meaning it cannot identify you as an individual, it provides a valuable insight into the use of my Website and I may therefore share it with select third parties. These parties may include providers of plugins or similar technologies to help measure traffic, my Partners and other providers to allow them to better stock products, and my investors.
6. TRANSFERS OF YOUR PERSONAL DATA
To provide my Website and my services, in accordance with the purposes set out above, I may transfer and store the personal information that I collect from you to a destination outside of the European Economic Area (“EEA”), mostly to the United States, either to one of my Group Companies, to one of my Partners or to one of the third parties with which I work with, as stated below:
a) When transferring personal information to one of my Group Companies outside the EEA, which may be the USA, Brazil, Russia, Japan, or China, I rely on the Commission’s model contracts for the transfer of personal data to third countries (i.e. the standard contractual clauses) pursuant to Decision 2010/87/EU;
b) I transfer the personal information to one of my Partners outside the EEA, to the extent such transfer is needed to fulfil the contract between you and the Partner which you are ordering the products or services from.
c) When transferring personal information to one of my third party services’ providers set out above, I rely on different adequacy measures, as set out below:
d) Adequacy Decision: I transfer the personal data that I collect from you to conduct fraud checks to Israel, which was found to have an adequate level of protection for personal data under Commission Decision 2011/61/EU of 31 January 2011.
e) Privacy Shield: Some of my third party providers based in the ME, where I transfer your information to, comply with the ME Department of Commerce’s EU-ME Privacy Shield and have certified that adhere to the EU-ME Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. For more information about the EU-ME Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website.
f) Model Clauses: I rely in the Commission’s model contracts for the transfer of personal data to third countries (i.e. the standard contractual clauses) pursuant to Decision 2010/87/EU when transferring your information to my ME service providers who do not adhere to the ME Department of Commerce’s EU-ME Privacy Shield.
I use technology such as “cookies” to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page. I use the following categories of cookies on my Website:
a) CATEGORY 1: STRICTLY NECESSARY COOKIES These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided.
b) CATEGORY 2: PERFORMANCE COOKIES These cookies collect anonymous information on how you use my Website. For example, I use Google Analytics cookies to help myself to understand how customers arrive at my site, browse or use my site and highlight areas where I can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. You may opt-in to these cookies using your browser settings.
c) CATEGORY 3: FUNCTIONALITY COOKIES These cookies remember choices you make such as the country you visit my website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. You may opt in to these cookies using your browser settings.
d) CATEGORY 4: TARGETING COOKIES OR ADVERTISING COOKIES These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, I use third party companies to provide you with more personalised adverts when visiting other websites. You may opt-in to these cookies using your browser settings.
e) CATEGORY 5: SOCIAL MEDIA COOKIES These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and Twitter. Please refer to the respective privacy policies for how their cookies work. If you want to delete any cookies that are already on your computer, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.aboutcookies.org. Please note that by deleting my cookies or disabling future cookies you may not be able to access certain areas or features of my Website.
You can withdraw your consent to these cookies at any time through the following options:
a) Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;
b) other third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu.
c) any other type of cookies, you can clean the cookies through your browser settings.
Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.
Keeping you and your personal information secure is very important to me. I take a number of reasonable steps to try to protect the personal information that you provide, including:
a) requiring you to establish a unique username and password to access your account on my Website;
b) not keeping details of your credit or debit card that would enable any third party to transact using that credit or debit card (such as your CVV number).
9. HOW LONG WILL YOU USE MY INFORMATION FOR?
I retain the data you provide to me for as long as you have your account with me and thereafter for such period as you may have questions or a claim in relation to my services, notwithstanding any superior retention period that I may be obliged to observe in accordance with legal requirements applicable to me. In some circumstances, you can ask me to delete your data as set out below. After you have terminated your use of my services, I may store your information in an aggregated and anonymised format.
10. WHAT ARE MY PRIVACY RIGHTS?
You have certain rights in relation to the personal data I hold about you, which I detail below. Some of these only apply in certain circumstances as set out in more detail below. I also set out how to exercise those rights. Please note that I will require you to verify your identity before responding to any requests to exercise your rights and that can include asking a set of security questions to ensure it is you. When you have appointed someone else to do the request on your behalf, that person and/or organization needs to show a valid power of attorney issued by you. I must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact me at firstname.lastname@example.org or by writing to Data Protection Officer, at Rua 5 de Outubro, 91 9000-216 Funchal, Portugal.
a) Access. You have the right to know whether I process personal data about you, and if I do, to access data I hold about you and certain information about how I use it and who I share it with (including the categories of personal data I share with businesses for their direct marketing uses and the names and addresses of those businesses). You can also request a copy of your information. If you require more than one copy of the data I hold about you, I may charge a reasonable administration fee. I may not provide you with certain personal data if providing it would interfere with another’s rights (e.g. where providing the personal data I hold about you would reveal information about another person) or where another exemption applies.
b) Portability. You have the right to receive a subset of the personal data I collect from you in a structured, commonly used and machine-readable format and a right to request that I transfer such personal data to another party. The relevant subset of personal data is data that you provide me with your consent or for the purposes of performing my contract with you. If you wish for me to transfer the personal data to another party, please ensure you detail that party and note that I can only do so where it is technically feasible. I are not responsible for the security of personal data or its processing once received by the third party. I also may not provide you with certain data if providing it would interfere with another’s rights (e.g. where providing the personal data I hold about you would reveal information about another person or my trade secrets or intellectual property).
c) Correction. You have the right to correct any personal data held about you that is inaccurate. You can request the correction by emailing me. Please note that in some cases I can ask you to explain in detail why you believe the personal data I hold about you to be inaccurate or incomplete so that I can assess whether a correction is required. Please note that whilst I assess whether the personal data I hold about you is inaccurate or incomplete, you may exercise your right to restrict my processing of the applicable data as described below.
d) Erasure. You may request that I erase the personal data I hold about you in certain circumstances. Please scroll down to know what those are:
I) you believe that it is no longer necessary for me to hold the personal data I hold about you;
II) I are processing the personal data I hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which I can process the personal data;
III) I are processing the personal data I hold about you on the basis of my legitimate interest and you object to such processing. Please provide me with detail as to your reasoning so that I can assess whether there is an overriding interest for me to retain such personal data;
IV) you no longer wish me to use the personal data I hold about you in order to send you promotions and special offers;
V) you believe the personal data I hold about you is being unlawfully processed by me. Also, note that you may exercise your right to restrict my processing the data whilst I consider your request as described below. Please provide as much detail as possible on your reasons for the request to assist me in determining whether you have a valid basis for erasure. Please note, however, that I may retain the personal data if there are valid grounds under the law for me to do so (e.g., for the defence of legal claims or freedom of expression) but I will let you know if that is the case. Where you have requested that I erase data that I have made public and there are grounds for erasure, I will use reasonable steps try to tell others that are displaying the data or providing links to the data to erase the data too. • Restriction of Processing to Storage Only. You have a right to require me to stop processing the personal data I hold about you other than for storage purposes in certain circumstances. Please note, however, that if I stop processing the personal data, I may use it again if there are valid grounds under data protection law for me to do so (e.g. for the defence of legal claims or for another’s protection). Please scroll down to know the cases where you may request I stop processing and just store the personal data I hold about you.
a) you believe the personal data is not accurate for the period it takes for me to verify your claim;
b) I wish to erase the personal data as the processing I are doing is unlawful but you want me to retain the personal data for storage but not further process it;
c) I wish to erase the personal data as it is no longer necessary for my purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or
d) you have objected to me processing personal data I hold about you on the basis of my legitimate interest and you wish me to stop processing the personal data whilst I determine whether there is an overriding interest in me retaining such personal data.
• Withdrawal of Consent: You can withdraw your consent at any time by changing your marketing preferences in “My Account” or by unsubscribing at the bottom of each email received or by writing emailing me as set out below.
• by emailing me at email@example.com; or
• by writing to the Data Protection Officer, at Rua 5 de Outubro, 91 9000-216 Funchal, Portugal. This is without prejudice to your right to launch a claim with the Comissão Nacional de Proteção de Dados (CNPD), at Av. D. Carlos I, 134 – 1.º 1200-651 Lisboa, Portugal – Tel: +351 213928400 – Fax: +351 213976832 – e-mail: firstname.lastname@example.org or the data protection supervisory authority in the EU country in which you live or work where you think I have infringed data protection laws.
12. UPDATES TO THIS POLICY