What is this Policy all about?
Welcome to our Privacy Policy! It's great that you'd like to know more about how we keep your information safe. This policy will give you information about how we look after your personal data when you visit or use our services. The Privacy Policy also tells you about your privacy rights and how the law protects you. Finally, this Privacy Policy covers both our online and offline data collection activities, including personal data that we may collect through our various channels such as websites, apps, third-party social networks, points of sales and events.
In other words, if you're looking for more information on how we collect, store, use and share your personal data, this is the place for you!
Your privacy rights
As a data subject, you have the following rights in respect of the personal data we hold on you:
Request access to your personal data. You have a right to access the personal data we are keeping about you. In many cases, this information is already present to you in your online services from us. Your right to access may, however, be restricted by legislation, protection of other persons' privacy and consideration for the Group's business practices, know-how, business secrets and internal assessments.
Request correction of incorrect or incomplete data. If the data we have pertaining to you are incorrect or incomplete, you are entitled to have the data corrected, with the restrictions that follow from legislation.
Request erasure You have the right to request deletion of your data when:
the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw your consent to the processing and there is no other legitimate reason for processing; you object to the processing and there is no justified reason for continuing the processing; or the processing is unlawful.
Please note that, in certain circumstances, we may be required to retain some of your personal data after you have requested deletion to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your personal data to satisfy our business needs.
Limitation of processing of personal data. If you contest the correctness of the data which we have registered about you or lawfulness of processing, or if you have objected to the processing of the data in accordance with your right to object, you may request us to restrict the processing of this data. The processing will be restricted to storage only, until the correctness of the data can be established, or it can be checked whether our legitimate interests override your interests. Even when processing of your data has been restricted as described above, the Group may process your data in other ways if this is necessary to enforce a legal claim or to process previously collected data if you have earlier given your consent.
Object to processing based on our legitimate interest. You can always object to the processing of personal data about you which is based on legitimate interest. If we are processing your data for direct marketing and profiling in connection to such marketing, your objection will always be sustained. For objections to processing for other purposes, we will conduct a legitimate interest balancing test and consider whether to support your objection.
Data portability. You have a right to receive personal data that you have provided to us in a machine-readable format. This right applies to personal data processed only by automated means and on the basis of consent or of fulfilling a contract.
If we change the way we handle your personal data, we will update this Privacy Policy. We reserve the right to make changes to our practices and this Privacy Policy at any time, so please check back frequently to see any updates or changes to our Privacy Policy.
What personal data does the Group collect?
Personal data is any information about a person from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password.
- Purchaser Data includes purchases or orders made by you, your interests, preferences, and feedback or survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, participate in sweepstakes and other prize competitions and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data because this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We use Pseudonymized Data in order to minimize the privacy impact to you.
Pseudonymization is a method that replaces or removes information in the dataset that identifies an individual but permits a data controller or third party to reidentify the personal data with reasonable effort. It is important to be aware that unlike anonymization, pseudonymization does not remove all identifying information from the data but reduces the linkability of a dataset with the identity of an individual.
We do not proactively collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or genetic information, biometric data for identification purposes, or information about criminal convictions and offences.
If you fail to provide necessary personal data to us, we may not be able to provide you with our goods and/or services.
How does the Group collect personal data from you?
We collect personal data from the following sources:
Websites includes any websites operated by or for the Group, including sites that we operate under our own domains/URLs and mini-sites that we run on third-party social networks such as Facebook, E-mail, text and other electronic messages includes electronic communications between you and the Group.
Customer Service includes calls or online chats with our Customer Service personal.
Who will the Group share personal data with?
Our subsidiaries may sometimes need to access your information to provide services to you on our or their own behalf. They need your personal data so we or they can perform the activities listed in the table above, including as an example:
- Deliver products and services you've requested;
- Get in touch with you about your account or transactions;
- Send you information about our sites, applications and policies;
- Send you direct marketing messages;
- Send you product catalogs;
- Process information that the subsidiary is formally contracted to process on our behalf, e.g. carry out a purchase placed by you, manage your Account activity or your account data, and/or manage your preferences in our Preference Center;
- Internal research, analytics and reporting;
- Identify, review and stop any activities that could breach our policies or break the law.
Other uses and disclosures
We will also use and disclose personal data as we believe to be necessary or appropriate: (1) to comply with applicable laws; (2) to respond to requests from public and government authorities; (3) to cooperate with law enforcement; (4) to protect our rights, privacy, safety or property, and that of our affiliates, you or others.
In addition, we will use, disclose or transfer personal data to a third party in the event of any reorganization, merger, sale, joint venture, assignment.
