APPLICATION OF NATIONAL LAWS
Some data will be collected automatically by our website, other data will only be collected if you voluntarily submit it and consent to us using it for the purposes set out herein. Automatically collected data includes “(1) Information about the browser type and version used; User information: Frequency, recency, # sessions, page visits, usage details, clicks, traffic data, website navigation paths (2) your operating system; Platform/device (3) your Internet service provider; (4) your system, computer details, and internet connection, IP address; (4) Internal searches: search terms and categories (5) Date and time of access E-commerce transaction details if any (6) Session: Duration, bounce rates (7) Traffic sources (8) Adwords. In the event of abuse, we may block certain IP addresses”
USE OF DATA
a) All personal data is stored securely in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.
b) “We use your data for:” (i) Providing and managing your account; (ii) Providing and managing your access to our website; (iii) Personalising and tailoring your experience on our website; (iv) Supplying our products and services to you; (v) Personalising and tailoring our products and services for you; (vi) Responding to communications from you; (vii) Supplying you with newsletters, alerts etc. via email, that you may have subscribed to and that you may unsubscribe or opt-out at any time by clicking on the unsubscribe link from such emails or from your account profile; (viii) Market research and (ix) Analysing your use of our website and gathering feedback to enable us to continually improve our website and your user experience.
c) In some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you without your consent for us to be able to use such data.
d) With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone, text message, post and/or messaging services with information, news and offers on our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the applicable relevant laws.
f) Legal basis: We will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies: (i) you have given consent to the processing of your personal data for one or more specific purposes; (ii) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract; (iii) processing is necessary for compliance with a legal obligation to which we are subject; (iv) processing is necessary to protect the vital interests of you or of another natural person; (v) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller and/or processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
g) Sensitive Information: Sensitive information as defined under the relevant national data privacy laws, will be used by us only: (i) for the primary purpose for which it was obtained; “and/or (ii) with your consent; or where required or authorized by applicable law.
STORAGE OF DATA
a) We only keep your data for as long as we need to in order to use it as described t.in the above section (Use of Data), and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your data.
b) “Some or all of your data may be stored outside of your country of domicile” You accept and agree to this by using our website and submitting information to us. If we do store outside of your country of domicile, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within your country of domicile.
c) Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our website.
Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting data to us via the internet.
SHARING OF DATA
a) “We may contract with third parties to supply products and services to you on our behalf”. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under applicable relevant law.
b) We may compile statistics about the use of our website including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymized and will not include any personally identifying information. We may from time to time share such data with third parties. Data will only be shared and used within the bounds of the law.
In certain circumstances, we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. we do not require any further consent from you in order to share your data in such circumstances and will comply as required by any legally binding request that is made of us.
a) When you submit information via our website, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and by managing your account preferences).
b) you may also wish to sign up to one or more of the preference services operating in your country. These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.
c) It is important to us that your data is up to date. We will take reasonable steps to make sure that your data is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
RIGHT TO WITHDRAW INFORMATION
a) You may access certain areas of our website without providing any data at all. However, to use all features and functions available on our website you may be required to submit or allow for the collection of certain data.
c) You may withdraw your consent for us to use your personal data at any time by deleting your account or by contacting us using the details set out herein below, and we will delete your data from our systems. However, you acknowledge this may limit our ability to provide the best possible products and services to you.
ACCESS TO DATA
You may access your personal data we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your personal data, please access it through your account.On request by you, we will not charge any fee for your access request but may charge an administrative fee for providing a copy of your personal data, unless otherwise requested by you, the information shall be provided in a commonly used electronic form.In order to protect your personal data, we may require identification from you before releasing the requested information.
AUTOMATED DECISION-MAKING AND PROFILING
a) In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
b) The right described in the section above does not apply in the following circumstances: (i) the decision is necessary for the entry into, or performance of, a contract between you and us; (ii) the decision is authorized by law; or (iii) you have given your explicit consent.
c) Where we use your personal data for profiling purposes, the following shall apply: (i) clear information explaining the profiling will be provided, including its significance and the likely consequences; (ii) appropriate mathematical or statistical procedures will be used; (iii) technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and (iv) all personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
APPLICABLE FOR PERSONS FROM THE EUROPEAN ECONOMIC AREA
a) Legal Framework
It has been concluded by the European Commission that particular countries outside of the European Economic Area (the “EEA” which consists of all European Union member states, plus Norway, Iceland, and Liechtenstein) require to adequately protect personal data. This can be reviewed under European Commission adequacy decision. Where data is being transferred from the EEA to other countries, we shall comply with legal frameworks that ascertain an equivalent level of protection with European Union law.
b) EU-US and Swiss-US Privacy Shield frameworks
We shall comply with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland, respectively.
c) Model Contract Clauses
If, after contacting us, you feel that your concerns have not been addressed to your satisfaction, you can contact our data protection officer (“DPO”) at [email protected]Last updated on 8th July 2020