Last Updated: January 31, 2023
- Important Information and Who We Are
- The Data We Collect About You
- How Is Your Personal Data Collected
- How We Use Your Personal Data
- Disclosures of Your Personal Data
- International Transfers
- Data Security
- Data Retention
- Your EEA/UK Legal Rights
- Your California Privacy Rights
- Your Nevada Privacy Rights
- Your Canadian Privacy Rights
- Do Not Track Policy
1. Important Information and Who We Are
Full name of legal entity: <NAME>
Email address: <EMAIL ADDRESS>
Postal address: <POSTAL ADDRESS.
If you reside in the United Kingdom (UK), you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you reside within the European Economic Area (EEA), you have the right to make a complaint at any time to the appropriate supervisory authority for your country of residence. See ec.europa.eu for these details. If you reside outside the EEA or the UK, we will apply your legal rights as applicable to the data laws in the jurisdiction you are in. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes username or similar identifier.
- Contact Data includes email address.
- Financial Data includes payment card details. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
- Transaction Data includes details about payments from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, cookie ID, 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, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data includes information about how you use our website, products, and services, including the full Uniform Resource Locators (URLs); clickstream to, through, and from our website (including date and time); content you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not 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, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. How Is Your Personal Data Collected?
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service;
- request marketing to be sent to you;
- enter a competition, promotion, or survey; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU, and
- search information providers such as Google based outside the EU.
- Identity, Contact, and Transaction Data from providers of technical, payment, and delivery services such as <PAYMENT PROCESSING COMPANY> based in <COUNTRY NAME>.
- Technical Data from the following parties:
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for Which We Will Use Your Personal Data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
1) To register you as a new customer
Type of data: Identity, Contact
Lawful basis for processing: Performance of a contract with you
2) To process and deliver your order including managing payments, fees, and charges, and Collecting and recovering money owed to us
Type of data: Identity, Contact, Financial, Transaction, Marketing and Communications
Lawful basis for processing: Performance of a contract with you, Necessary for our legitimate interests (to recover debts due to us)
Type of data: Identity, Contact, Transaction, Marketing and Communications
Lawful basis for processing: Performance of a contract with you, Necessary to comply with a legal obligation, Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
4) To enable you to partake in a prize draw, competition, or complete a survey
Type of data: Identity, Contact, Usage, Transaction, Marketing and Communications
Lawful basis for processing: Performance of a contract with you, Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
5) To administer and protect our business and this website including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data
Type of data: Identity, Contact, Technical
Lawful basis for processing: Necessary to comply with a legal obligation, Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise)
6) To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data: Identity, Contact, Transaction, Profile, Usage, Marketing and Communication, Technical
Lawful basis for processing: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy)
7) To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences
Type of data: Identity, Technical, Usage
Lawful basis for processing: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy)
8) To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data: Identity, Contact, Transaction, Profile, Usage, Marketing and Communication, Technical
Lawful basis for processing: Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional Offers From Us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience, or other transactions.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosure of Your Personal Data
We may share your personal data with the parties set out below for the purposes stated in the table (Purposes for which we will use your personal data) above.
- External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
We are based in <COUNTRY NAME>, but our servers are located in <SERVER LOCATION>. We may process, store, and transfer personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. Where we do so, and where we are required to under local law, we will put in place appropriate mechanisms to ensure that your personal data receives an adequate level of protection where it is processed.
Unless you are located in the EEA or the UK, by submitting your personal data or engaging with the website or our application, you consent to this transfer, storing, or processing.
If you reside in the EEA or the UK, your personal data may be processed outside of the EEA or UK, including, for example, in the United States, so processing of your personal data will involve a transfer of data outside the EEA or UK.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that the recipient third party agrees to contractual clauses.
Please contact us at <SUPPORT EMAIL> if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or UK.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your EEA/UK legal rights below for further information.
In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your EEA/UK Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal data. To learn more about your California privacy rights, visit CCPA.
California’s “Shine the Light” law (Civil Code Section 1798.83) permits our users who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make that request, please send an email to <SUPPORT EMAIL>.
Further, if you are a California resident and would like to opt out from the disclosure of your personal data to any third party for direct marketing purposes, please send an email to <SUPPORT EMAIL>. If you opt out from permitting your personal data to be shared, you may still receive selected offers directly from us in accordance with California law.
11. Your Nevada Privacy Rights
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: <SUPPORT EMAIL>. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
12. Your Canada Privacy Rights
We comply with Canadian Federal and Provincial privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act.
We will only use your personal information for the purposes intended and as detailed in this policy unless we have obtained your consent to use it for other purposes.
Residents of Canada are notified that the personal data they provide to us is stored in our databases outside of Canada, including in <SERVER LOCATION>, and may be subject to disclosure to authorized law enforcement or government agencies in response to lawful demand under the laws of that country.
You may withdraw your consent to our personal data collection, use, or disclosure, subject to legal and contractual restrictions.
You have the right to complain about our personal data handling practices.
If you need to contact us about your personal data or believe that we have violated your privacy rights, please contact us at <SUPPORT EMAIL>. You may visit www.priv.gc.ca for more information about your privacy rights.
13. Do Not Track Policy
Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we provide you the ability to opt out. But we do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information, visit www.allaboutdnt.com.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed, and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
- Compliance with Laws. We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to that information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data about how you interact with the Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. For example, we use Google Analytics to help us understand how our customers use the website (you can read more about how Google uses your personal data here: https://www.google.com/intl/en/policies/privacy/). You can also opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Last Modified: January 31, 2023
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Types of Cookies We Use
We may use the following types of cookies:
- Strictly necessary cookies. Our website requires the use of these cookies to properly operate or provide necessary functions relating to the services you request. They include, for example, cookies enabling you to securely log into our website, use a shopping cart, or purchase products or a VIP membership. You can set your browser to block or alert you about these cookies, but some parts of our website may not work then.
- Analytical/performance cookies. These cookies allow us and our third-party service providers to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us improve how our website works by, for example, ensuring that users can easily find what they need on our website. These cookies generate aggregate statistics that are not associated with an individualized profile. If you do not allow these cookies, we will not know when you have visited our website.
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Except for strictly necessary cookies, all first-party cookies set by this site will expire no later than two years after your last website visit. Third-party cookie expiration periods are set by their respective owners.
Cross-Border Data Transfers
The cookies we use may process, store, or transfer personal data in and to a country outside your own, with privacy laws that provide different, possibly lower, protections. You consent to this transfer, storing, or processing when you consent to our cookie use. Our servers are located in the Netherlands. Please review the third-party cookie provider’s policy to learn more about its location.
Your Cookie Choices
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Changes to Our Cookies