Your privacy is important to us. This Policy describes the personal information we collect about our customers on this Site, how we use it, with whom we may share it, and the choices available to you regarding our use of the personal information. The Policy also describes the measures we take to safeguard the personal information, how long we retain it and how individuals can contact us about our privacy practices and to exercise their rights.
HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
If you choose to register for our news, offers, promotions or other services, participate in a competition, ask us a question through our “Contact us” link or purchase a product through our Site, we will collect certain personal information about you. This will include your name, address, email, phone number, payment card information and information about what you like to receive from us.
If you choose not to provide us with certain information, we may not be able to offer you certain of our products and services, and you may not be able to access certain features of our Site.
We will use your personal information in pursuit of our legitimate business interests to:
• administer our Site and provide customer services;
• allow you to participate in the interactive features of the Site (e.g. accessing social network platforms);
• process your orders;
• manage your account;
• investigate any complaints about our site;
• monitor and analyse the use of any account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime; and
• personalise your experience of our site.
We also use your personal information to fulfil our contractual obligations, by managing and fulfilling orders and completing any contractual arrangements between us and you, and by processing transactions (we use third party providers to process your payments and carry out 3D secure verification checks, and only these entities see your payment card details).
When required, we will also process your personal information in order to meet our legal, regulatory and compliance requirements. We also may use the information we obtain in other ways for which we provide specific notice at the time of collection.
Where required by applicable law, we will ask your consent to use your personal information for certain marketing and market research activities. It is up to you how much or how little information you allow us to use for these purposes. These are:
• to communicate with you from time to time by email and (where you provide us with those details either via the website(s) or elsewhere) by mobile and occasionally by post, with information, offers and other material which may interest you;
• to make your information available from time to time to trusted partners and third parties, for the same purposes as above; or
• to conduct market research, for example to ask you to participate in a survey about topical issues, conducted by us or trusted partners or third parties. We will always try to tell you before you participate in the survey how any information you provide in the survey will be used.
You may withdraw your consent for these activities at any time. This will not affect the lawfulness of processing based on your consent that occurred prior to its withdrawal.
FEEDBACK AND SURVEYS
Occasionally, we may invite you to participate in a survey or poll such as providing feedback on our website content, services or products. Your responses will be anonymous unless you choose to provide your contact details so that we can provide you with additional information regarding the survey or poll.
SOCIAL PLATFORM REGISTRATIONS AND SOCIAL MEDIA PLUGINS
Our site may permit you to use a third party social networking platform. This includes use of social media plugins such as “Like” buttons. We may ask your permission to repost your social media quotes or posts on our Site. If you agree, you grant us the right to use your posts on our site for promotional purposes. You may withdraw your consent for such use at any time. This will not affect the lawfulness of processing based on your consent that occurred prior to its withdrawal.
INFORMATION SHARING AND DISCLOSURE
We may share your personal information with other third parties as described below or otherwise with your consent or where required by applicable law.
We may share your personal information within the business and our affiliates for the purposes set out in this Policy as well as third party service providers that need access to your information to provide operational or other support services for the purposes described by this Policy. This includes companies that assist us with our site, contests and sweepstakes, providing the products and services that you requested, providing our payment processing services, managing reviews for our products, providing us with analytics about use of our Site or for the purposes of improving our marketing or administration. We do not authorise third parties to use or disclose the personal information except as necessary to perform services on our behalf or to comply with legal requirements.
We may share de-identified and aggregated information about how users use our Site to third parties who help us improve our business and services.
We also may disclose personal information about you:
• if we are required to do so by law or legal process (such as a court order or subpoena);
• in response to requests by government agencies, such as law enforcement authorities;
• to establish, exercise or defend our legal rights;
• when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss;
• in connection with an investigation of suspected or actual illegal activity;
• in the unlikely event that we sell or otherwise dispose of some or all of our business to another party (including in the event of a reorganisation, dissolution or liquidation); or
• otherwise with your consent.
INTERNATIONAL DATA TRANSFERS
We may transfer the personal information we obtain about you to recipients in countries other than the country in which the information was originally collected. Some of your personal information may be transferred to or stored at a destination outside the European Economic Area (“EEA”) and may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Those countries may not have the same data protection laws as the country in which you initially provided the information.
We will comply with applicable legal requirements regarding providing appropriate safeguards for the transfer of personal information to recipients in countries for which the European Commission has not issued an adequacy decision, such as the U.S. These safeguards may include data transfer agreements, copies of which may be obtained by contacting us as indicated in the “Contact us” section of this Policy, contacting the Ethics and Compliance group at firstname.lastname@example.org or reliance on a service provider’s Privacy Shield certification.
RETENTION OF PERSONAL INFORMATION
We retain your personal data as long as needed for the purposes for which we obtained it, plus a reasonable period to take into account any applicable statute of limitation period or to comply with mandatory applicable law.
COOKIES AND SIMILAR TECHNOLOGIES
Cookies are text files containing small amounts of information which are downloaded to your device, or more technically, to the browser that you use on that device, when you visit a site. The entity that places cookies on your browser can then read the information on that cookie that it set. Cookies are typically classified as either “session cookies”, which do not stay on your device after you close your browser or “persistent cookies”, which will usually remain on your device until you delete them or they expire.
Different cookies are used to perform different functions, which we explain below:
The data collected will generally be aggregated to provide trends and usage patterns for business analysis, site/platform and product improvement and performance metrics. Our cookies or the resulting analysis may be also shared with our business partners. The type of information we collect includes how many visitors visit our site, how many customers log in, when they visited, for how long and which areas of our site and services and demographic data such as your age or gender but is generally not used to identify you individually. We may also receive similar information about visitors to our partner sites. We use Google Analytics, run by Google Inc., for example, to track website usage and activity.
OUR USE OF WEB BEACONS
We may use and permit select third parties to use web beacons (usually in combination with cookies) to compile information about your website usage and your interaction with email or other communications, to measure performance and to provide content and ads that are more relevant to you. A web beacon (also called a web bug or clear GIFs) is typically a transparent graphic image (usually 1 pixel x 1 pixel) that can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the date and time when you viewed the beacon, and the IP address of your device. For instance, we may include web beacons in our promotional email messages or newsletters to determine whether our messages have been opened or acted upon and whether our mailing tools are working correctly.
YOUR CHOICES REGARDING COOKIES AND SIMILAR TECHNOLOGIES
We require your consent to use all non-essential cookies and other similar technologies.
Note that by disabling certain categories of cookies, you may be prevented from accessing some features of our Site or certain content or functionality may not be available.
To opt out of being tracked by Google Analytics across our Site visit: tools.google.com/dlpage/gaoptout
If you would like to opt out of third party cookies relating to interest based advertising, please go to www.youronlinechoices.eu or www.youradchoices.com. Note that opting out 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 ads tailored to your web preferences and usage patterns. Opting out of cookies and data collection from one browser, device or app will not necessarily opt you out of collection from all browsers, devices or apps.
Some newer web browsers incorporate “Do Not Track” features. Currently, no industry standard exists for handling “Do Not Track” requests, therefore at this time, our Site may not respond to “Do Not Track” requests or headers from these browsers.
You may be able to disable web beacons in email messages by not downloading images contained in messages you receive (this feature varies depending on the email software used on your personal computer). However, doing this may not always disable a web beacon or other similar technologies in the email message due to specific email software capabilities. For more information about this, please refer to the information provided by your email software or service provider. Web beacons may also be rendered ineffective in some circumstances by opting out of cookies or amending your cookie settings as described above.
Subject to applicable law, you are entitled to see the personal information held about you. If you wish to do this, please contact us at email@example.com We may require you to provide verification of your identity to provide a copy of the information we hold. Please note that in certain circumstances we may withhold access to your information where we have the right to do so under applicable data protection legislation. In addition, you may request the personal information that you have provided to us about you, with your consent or based on a contract to which you are party, in a structured, commonly used and machine-readable format. You have the right to have this information transmitted to another company, where it is technically feasible.
Subject to applicable law, you also have the right to ask us to update, correct, amend or erase your personal information, or restrict or object to our use of your personal information. You may withdraw any consent to the processing of your personal information and request an explanation about the processing by contacting firstname.lastname@example.org. You may also amend or update your details by logging into your account. You have the right to make a complaint to the appropriate supervisory authority in your country or seek a remedy through the courts if you believe your rights have been breached.
If you no longer wish to receive any marketing communications from us, please send an email to email@example.com specifying your name, the email address/telephone number you used to register with us and if referring to a web registration, your user name in the email and whether you wish to stop receiving all marketing communications from us or just specific competitions, newsletters or other interactions with us. Alternatively, please follow the unsubscribe options at the bottom of any email we send you. Please note that if you have already requested products or services when you decide to withdraw your consent, there may be a short period of time for us to update your preferences and ensure that we honor your request. Where we require personal information to comply with legal or contractual obligations, then the provision of such data is mandatory: if such data is not provided, then we will not be able to administer our relationship with you. In all other cases, the provision of personal information is optional.
If you have any other questions about privacy issues or concerns, please send us an email to firstname.lastname@example.org.
Our Site is not intended for use by children under the age of 18 and certain products made available on the Site may be subject to age restrictions imposed by law. We are not permitted by law to supply these products to individuals who do not satisfy the relevant age requirement and, if you are underage, you must not attempt to order these products. We do not market any of our products online for children under the age of 18, nor do we design our online applications, advertisements and other features to attract an audience of children under age of 18. We do not knowingly register or otherwise collect personal information from any child under the age of 18 (or other relevant age in the country in which you reside, if applicable).
We have implemented reasonable technical and organisational measures to ensure that your personal information is secure, including limiting the number of people who have physical access to our database servers, as well as electronic security systems and password protections that guard against unauthorised access. However, we cannot guarantee that unauthorised third parties will never be able to defeat those measures or use your personal information for improper purposes.
LINKS TO OTHER WEBSITES
Our site may contain links to other websites operated, controlled and maintained by independent third parties. We do not control the use of information that you may provide to such third parties. If you access other websites using the links provided in our site, the operators of the third-party sites may collect information from you which will then be used by them in accordance with their own privacy policies, not ours. These policies may differ from ours. It is your responsibility to familiarise yourself with privacy policies on our Site and other websites.
CHANGES TO THIS POLICY
As we continue to provide additional services and as the privacy laws and regulations evolve, it may be necessary to revise or update this Policy. We encourage you to review this Policy from time to time as you return to our site, so that you are familiar with any changes. For significant changes, we will notify you either by posting a prominent notice on our site or emailing you and if required by applicable law, we will obtain your consent.
This policy was last updated in November 2020.
VPAS Idea Merchants Limited is the data controller of your personal information. You may contact us in order to submit a request or exercise your rights by emailing us at email@example.com if you have any questions about our Policy or our data practices outlined above.