DATA PRIVACY NOTICE
(The "Company", "we", "us")
When you use the services provided by us, we will collect, use and share your personal information in accordance with this data privacy notice. This data privacy notice includes the terms about collecting, storing, using, sharing and protecting your personal information. It is suggested that you should read the data privacy notice completely to help you understand the way to protect your privacy. You can contact us through the contact information provided by us, if you are ever in any doubt about the data privacy notice. If you disagree with any content of this data privacy notice, you should immediately stop using the services provided by our platform. Once you continue to use any services provided by us, it means you have already agreed that we can lawfully collect, use, store, and share your information in accordance with this data privacy notice.
- Our Collecting information
1.1 Your personal data – what is it? Personal data relates to a living individual who can be identified from that data. Identification can be by the data alone or in conjunction with any other data in the data controller’s possession or likely to come into such possession.
1.2 What roles do we play in processing your data? We are the data controller with respect to processing your data (contact details below). This means that we decide how your personal data is processed and for what purposes. We know that you care how data about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly.
1.3 When are your personal data collected? Some of your data can, in particular, be collected by us:
- whenever you register to use our online services (each time you log in or each time you use them);
- whenever you use our services and products;
- whenever you contact us via the various channels we offer you;
1.4 Our collection of personal data The personal data we collect include any and all data you provide to us when you enter into contract with us, register an account with us, enter on our website, provide us information on a web form, update or add information to your account, or give us in any other way. You can choose not to provide data to us, but we may then not be able to service you where such services require processing such data. We use the data that you provide for purposes as communicating with you, responding to your requests, customizing your service experience with us, and improving our products and services.
- How do we process your personal data?
We keep personal data up to date; by storing and destroying it securely; by collecting and retaining only the necessary that we need to service you; by protecting personal data from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We use your personal data for the following purposes:
- To deliver our services to you under our contract with you.
- To provide other services requested by you as described when we collect the information.
- To share your contact details with our affiliate offices around the world within our group companies, for the purposes of internal administration and back-office support.
- To maintain the integrity and safety of our data technology systems which store and process your personal data.
- To detect and investigate data breaches, illegal activities, and fraud.
2.1 Necessity to provide us data You are not under any obligation to provide us any personal data. As noted below, the choice is yours. However, please note that without certain data from you, we may not able to undertake some or all of our obligations to you under Terms of Service, or adequately provide you with our full range of services. If you would like to obtain more detail about this, please contact us following the instructions in the Contact Us section below.
2.2 Sharing your personal data Your personal data will be treated as strictly confidential, and will be shared only with the categories of data recipients listed below. We will only share your data with third parties outside of the Company with your consent, and you will have an opportunity to choose for us not to share your data. We may disclose your personal data to:
- Our affiliated entities within our global group of companies worldwide to provide you services such as facilitating order processing and shipping, for internal administration purposes, to detect and deal with data breaches, illegal activities, and fraud, and to maintain the integrity of our information technology systems.
- Government, courts, or law enforcement agencies, to comply with our obligations under relevant laws and regulations of the European Union or a member state of the European Union, enforce or defend our policies or contract with you, respond to claims, or in response to a verified request relating to a government or criminal investigation or suspected fraud or illegal activity that may expose us, you, or any other of our customers to legal liability; provided that, if any non-European Union or non-European Union member state law enforcement agency requests your data, we will attempt to redirect the law enforcement agency to request that data directly from you, and in such event, we may provide your basic contact information to the law enforcement agency.
- Third parties involved in a legal proceeding, if they provide us with a court order or substantially similar legal procedure requiring us to do so.
2.3 How long do we keep your personal data? We keep your personal data for no longer than reasonably necessary for the given purpose for which your data is processed. If you will provide us, or have provided us, consent for us to process your data, we will process your data for no longer than your consent is effective. Notwithstanding the above, we may retain your personal data as required by the laws and regulations of the European Union or a member state of the European Union, as necessary to assist with any government and judicial investigations, to initiate or defend legal claims or for the purpose of civil, criminal or administrative proceedings. If none of the above grounds for us to keep your data apply, we will delete and dispose of your data in a secure manner according to our data protection policy.
2.4 Privacy of data subjects under the age of 16 Our products and services are not targeted to persons under the age sof 16. We do not knowingly collect or process personal data from persons under the age of 16. Please note that if you are under the age of 16, you will need to provide us a written signed consent from your parent or guardian indicating that your parent or guardian has consented for us to process your data. Such consent form can be found by contacting our data protection officer (contact details below).
- Your rights and your personal data
You have the following rights with respect to your personal data:
- The right to request a copy of your personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request to erase your personal data where it is no longer necessary for us to retain such data;
- The right to withdraw your consent to the processing at any time, where we rely on your consent to process your data;
- The right to request that we provide you with your data and where possible, to transmit that data directly to another data controller, where the processing is based on your consent or is necessary for the performance of a contract with you, and in either case we process the data by automated means;
- The right, where there is a dispute in relation to the accuracy or the lawfulness of our processing of your personal data, to request that a restriction is placed on further processing of your data;
- The right to object to us using your personal data to engage in direct marketing; the right to lodge a complaint regarding our processing of your data, with the competent authority of the European Union member state where you reside or in which your data is processed.
If you would like to exercise any of the above rights, please do so through email to contact us (contact details below).
After receiving your request, we will evaluate your request and inform you how we intend to proceed on your request. Under certain circumstances in accordance with the GDPR and applicable European Union or European Union member state laws and regulations, we may withhold access to your data, or decline to modify, erase, port, or restrict the processing of your data.
- Other important information
4.1 Transfer of Data Abroad As a globally operating company, we must be able to transmit your data to other countries within our global group of companies, for the reasons set forth above. We will be transferring your personal data to the countries and jurisdictions which are not member states of the European Union. In making such international data transfers outside the European Union, we make sure to protect your personal data by applying the level of security required by European Union legislation. Where we transfer your data outside the European Union to a country that cannot guarantee this level of protection, we have enhanced our IT security measures and have entered into standard data protection clauses adopted by the European Commission with the transferee to require security obligations on the transferee, both of which are intended to increase the protection of my personal data.
4.2 Further processing If we wish to use your personal data for a new purpose not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing such further processing for a new purpose, setting out the relevant new purpose and processing conditions. In such case, we will find a lawful basis for further processing, and whenever necessary we will seek your prior written consent to such further processing.
4.3 Security We protect your data using technical measures to minimize the risks of misuse, unauthorized access, unauthorized disclosure, and loss of access. Some of the safeguards we use are data pseudonymization, data encryption, firewalls, and data access authorization controls. We take our data security very seriously. Therefore the security mechanisms used to protect your data are checked and updated regularly to provide effective protection against abuse. If you believe that the security of your data has been compromised, or if you like more information on the measures we use to protect your data, please contact us following the instructions in the Contact Us section below.
4.4 Our lawful basis for processing your personal data? We generally only store and process your personal data if you provide your explicit consent beforehand, e.g. when establishing contact or obtaining information. This allows you to decide whether you wish to transfer the data you supply when registering or responding to a survey for storage and use by us. If you agree, we can use your data to respond to inquiries or to improve our services and products, for example. We will collect, process and use the personal data supplied explicitly by you only for the purposes communicated to you and will not disclose it to third parties, or only with your permission, unless disclosure is necessary to negotiate and perform a contract with you, is required by law or to comply with a government agency or court orders, is necessary to establish or preserve a legal claim or defense and furthermore, is necessary to prevent misuse or other illegal activities, such as willful attacks on our systems for maintaining data security, or is carried out for any additional purpose that is directly related to the original purpose for which the personal data was collected. We further detail the circumstances of data disclosure to third parties in the section “Sharing your personal data” below.
4.5 Whom should I contact? If you have any question about this Privacy Notice, or if you would like to exercise any of your rights, or if you have any complaints that you would like to discuss with us, please submit a request to the data protection officer at the following address by e-mail [firstname.lastname@example.org]