PRIVACY POLICY
PRIVACY POLICY EFFECTIVE FROM DECEMBER 1, 2018
THIS PRIVACY POLICY SETS OUT HOW WE, CIGAR.SHOP COLLECT, STORE AND USE INFORMATION ABOUT YOU WHEN YOU USE OR INTERACT WITH OUR WEBSITE, CIGAR.SHOP (WEBSITE) AND WHERE WE OTHERWISE OBTAIN OR COLLECT INFORMATION ABOUT YOU.
SUMMARY
THIS SECTION SUMMARIZES HOW WE OBTAIN, STORE AND USE INFORMATION ABOUT YOU. IT IS INTENDED TO PROVIDE A VERY GENERAL OVERVIEW ONLY. IT IS NOT COMPLETE IN AND OF ITSELF AND IT MUST BE READ IN CONJUNCTION WITH THE CORRESPONDING FULL SECTIONS OF THIS PRIVACY POLICY.
HOW WE COLLECT OR OBTAIN INFORMATION ABOUT YOU: WHEN YOU PROVIDE IT TO US (E.G. BY CONTACTING US, PLACING AN ORDER ON OUR WEBSITE, SIGN UP FOR OUR EMAIL NEWSLETTER, TAKE A QUIZ, OR CREATE AN ACCOUNT). FROM YOUR USE OF OUR WEBSITE, USING COOKIES AND SIMILAR TECHNOLOGIES, AND OCCASIONALLY, FROM THIRD PARTIES.
INFORMATION WE COLLECT: NAME, CONTACT DETAILS, PAYMENT INFORMATION E.G. YOUR CREDIT OR DEBIT CARD DETAILS, IP ADDRESS, INFORMATION FROM COOKIES, INFORMATION ABOUT YOUR COMPUTER OR DEVICE (E.G. DEVICE AND BROWSER TYPE), INFORMATION ABOUT HOW YOU USE OUR WEBSITE (E.G. WHICH PAGES YOU HAVE VIEWED, THE TIME WHEN YOU VIEW THEM AND WHAT YOU CLICKED ON, THE GEOGRAPHICAL LOCATION FROM WHICH YOU ACCESSED OUR WEBSITE (BASED ON YOUR IP ADDRESS), YOUR ANSWERS TO QUIZZES OR SURVEYS, AND INFORMATION ABOUT YOUR INTERNET CONNECTION.
HOW WE USE YOUR INFORMATION: FOR ADMINISTRATIVE AND BUSINESS PURPOSES (PARTICULARLY TO CONTACT YOU AND PROCESS ORDERS YOU PLACE ON OUR WEBSITE), TO IMPROVE OUR BUSINESS AND WEBSITE, TO FULFIL OUR CONTRACTUAL OBLIGATIONS, TO ADVERTISE OUR GOODS AND SERVICES, TO ANALYZE YOUR USE OF OUR WEBSITE, AND IN CONNECTION WITH OUR LEGAL RIGHTS AND OBLIGATIONS.
DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES: ONLY TO THE EXTENT NECESSARY TO RUN OUR BUSINESS, TO OUR SERVICE PROVIDERS, AND TO FULFIL ANY CONTRACTS WE ENTER INTO WITH YOU, AND WHERE REQUIRED BY LAW OR TO ENFORCE OUR LEGAL RIGHTS.
SELL YOUR INFORMATION: WE DO NOT SELL YOUR INFORMATION TO THIRD PARTIES (OTHER THAN IN THE COURSE OF A BUSINESS SALE OR PURCHASE OR SIMILAR EVENT).
HOW LONG WE RETAIN YOUR INFORMATION: FOR NO LONGER THAN NECESSARY, TAKING INTO ACCOUNT ANY LEGAL OBLIGATIONS WE HAVE (E.G. TO MAINTAIN RECORDS FOR TAX PURPOSES), ANY OTHER LEGAL BASIS WE HAVE FOR USING YOUR INFORMATION (E.G. YOUR CONSENT, PERFORMANCE OF A CONTRACT WITH YOU OR OUR LEGITIMATE INTERESTS AS A BUSINESS). FOR SPECIFIC RETENTION PERIODS IN RELATION TO CERTAIN INFORMATION WHICH WE COLLECT FROM YOU, PLEASE SEE THE MAIN SECTION BELOW ENTITLED HOW LONG WE RETAIN YOUR INFORMATION.
HOW WE SECURE YOUR INFORMATION: USING APPROPRIATE TECHNICAL AND ORGANIZATIONAL MEASURES SUCH AS STORING YOUR INFORMATION ON SECURE SERVERS, ENCRYPTING TRANSFERS OF DATA TO OR FROM OUR SERVERS USING SECURE SOCKETS LAYER (SSL) TECHNOLOGY, ENCRYPTING PAYMENTS YOU MAKE ON OR VIA OUR WEBSITE USING SECURE SOCKETS LAYER (SSL) TECHNOLOGY, ONLY GRANTING ACCESS TO YOUR INFORMATION WHERE NECESSARY AND BY ONLY TRUSTED INDIVIDUALS THAT HAVE BEEN TRAINED AND BRIEFED ON APPROPRIATE HANDLING OF PERSONAL INFORMATION.
USE OF COOKIES AND SIMILAR TECHNOLOGIES: WE USE COOKIES AND SIMILAR INFORMATION-GATHERING TECHNOLOGIES SUCH AS WEB BEACONS ON OUR WEBSITE INCLUDING ESSENTIAL, FUNCTIONAL ANALYTICAL AND ADVERTISING COOKIES.
SENSITIVE PERSONAL INFORMATION: WE DO NOT COLLECT SENSITIVE PERSONAL INFORMATION ON YOU.
IF YOU HAVE ANY QUESTIONS ABOUT THIS PRIVACY POLICY, PLEASE CONTACT US AT INFO@CIGAR.SHOP.COM
WEB SERVER LOG INFORMATION
WE USE A THIRD-PARTY SERVER TO HOST OUR WEBSITE. OUR WEBSITE SERVER AUTOMATICALLY LOGS THE IP ADDRESS YOU USE TO ACCESS OUR WEBSITE AS WELL AS OTHER INFORMATION ABOUT YOUR VISIT SUCH AS THE PAGES ACCESSED, INFORMATION REQUESTED, THE DATE AND TIME OF THE REQUEST, THE SOURCE OF YOUR ACCESS TO OUR WEBSITE (E.G. THE WEBSITE OR URL (LINK) WHICH REFERRED YOU TO OUR WEBSITE), AND YOUR BROWSER VERSION AND OPERATING SYSTEM.
USE OF WEBSITE SERVER LOG INFORMATION FOR IT SECURITY PURPOSES
OUR THIRD-PARTY HOSTING PROVIDER COLLECT(S) AND STORE(S) SERVER LOGS TO ENSURE NETWORK AND IT SECURITY AND SO THAT THE SERVER AND WEBSITE REMAIN UNCOMPROMISED. THIS INCLUDES ANALYZING LOG FILES TO HELP IDENTIFY AND PREVENT UNAUTHORIZED ACCESS TO OUR NETWORK, THE DISTRIBUTION OF MALICIOUS CODE, DENIAL OF SERVICES ATTACKS AND OTHER CYBER-ATTACKS, BY DETECTING UNUSUAL OR SUSPICIOUS ACTIVITY.
UNLESS WE ARE INVESTIGATING SUSPICIOUS OR POTENTIAL CRIMINAL ACTIVITY, WE/WE DO NOT MAKE, NOR DO WE ALLOW OUR HOSTING PROVIDER TO MAKE, ANY ATTEMPT TO IDENTIFY YOU FROM THE INFORMATION COLLECTED VIA SERVER LOGS.
WE IMPLEMENT APPROPRIATE TECHNICAL AND ORGANIZATIONAL MEASURES TO ENSURE A LEVEL OF SECURITY APPROPRIATE TO THE RISK OF OUR PROCESSING OF INFORMATION ABOUT INDIVIDUALS. RECORDING ACCESS TO OUR WEBSITE USING SERVER LOG FILES IS SUCH A MEASURE.
COOKIES AND SIMILAR TECHNOLOGIES
COOKIES ARE DATA FILES WHICH ARE SENT FROM A WEBSITE TO A BROWSER TO RECORD INFORMATION ABOUT USERS FOR VARIOUS PURPOSES.
WE USE COOKIES AND SIMILAR TECHNOLOGIES ON OUR WEBSITE, INCLUDING ESSENTIAL, FUNCTIONAL, ANALYTICAL AND ADVERTISING COOKIES AND WEB BEACONS.
YOU CAN REJECT SOME OR ALL OF THE COOKIES WE USE ON OR VIA OUR WEBSITE BY CHANGING YOUR BROWSER SETTINGS OR NON-ESSENTIAL COOKIES BY USING OUR COOKIE CONTROL TOOL, BUT DOING SO CAN IMPAIR YOUR ABILITY TO USE OUR WEBSITE OR SOME OR ALL OF ITS FEATURES.
EMAIL AND CONTACT FORM
WHEN YOU SEND AN EMAIL TO THE EMAIL ADDRESS DISPLAYED ON OUR WEBSITE WE COLLECT YOUR EMAIL ADDRESS AND ANY OTHER INFORMATION YOU PROVIDE IN THAT EMAIL (SUCH AS YOUR NAME, TELEPHONE NUMBER AND THE INFORMATION CONTAINED IN ANY SIGNATURE BLOCK IN YOUR EMAIL).
WE USE A THIRD-PARTY EMAIL PROVIDER/CUSTOMER SERVICE MANAGEMENT TOOL TO STORE EMAILS AND MESSAGES YOU SEND US.
IF YOU CONTACT US BY MAIL, WE WILL COLLECT ANY INFORMATION YOU PROVIDE TO US IN ANY POSTAL COMMUNICATIONS YOU SEND US.
E-NEWSLETTER
WHEN YOU SIGN UP FOR OUR E-NEWSLETTER ON OUR WEBSITE OR OPT TO RECEIVE NEWS, OFFERS, UPDATES ON OUT-OF-STOCK ITEMS FROM US BY ENTERING YOUR NAME AND EMAIL ADDRESS AND CLICKING SUBSCRIBE OR TICKING A BOX AT CHECKOUT INDICATING THAT THEY WOULD LIKE TO RECEIVE YOUR E-NEWSLETTER, WE COLLECT YOUR EMAIL ADDRESS , INFORMATION ABOUT YOUR BROWSER, INFORMATION ABOUT THE PAGE YOU SIGNED UP ON, AND ANY OTHER ADDITIONAL INFORMATION YOU MAY PROVIDE TO US.
WE USE A THIRD-PARTY SERVICE TO SEND OUT OUR E-NEWSLETTER AND ADMINISTER OUR MAILING LIST.
USE OF WEB BEACONS AND SIMILAR TECHNOLOGIES IN EMAILS
WE USE TECHNOLOGIES SUCH AS WEB BEACONS (SMALL GRAPHIC FILES) IN THE EMAILS WE SEND TO ALLOW US TO ASSESS THE LEVEL OF ENGAGEMENT OUR EMAILS RECEIVE BY MEASURING INFORMATION SUCH AS THE DELIVERY RATES, OPEN RATES AND CLICK THROUGH RATES WHICH OUR EMAILS ACHIEVE. WE WILL ONLY USE WEB BEACONS IN OUR EMAILS IF YOU HAVE CONSENTED TO US DOING SO.
REGISTERING ON OUR WEBSITE
WHEN YOU REGISTER AND CREATE AN ACCOUNT ON OUR WEBSITE, WE COLLECT THE FOLLOWING INFORMATION: EMAIL ADDRESS, IP ADDRESS, AND ANY OTHER INFORMATION YOU PROVIDE TO US WHEN YOU COMPLETE THE REGISTRATION FORM.
IF YOU DO NOT PROVIDE THE MANDATORY INFORMATION REQUIRED BY THE REGISTRATION FORM, YOU WILL NOT BE ABLE TO REGISTER OR CREATE AN ACCOUNT ON OUR WEBSITE.
INFORMATION COLLECTED WHEN YOU PLACE AN ORDER
MANDATORY INFORMATION
WHEN YOU PLACE AN ORDER FOR GOODS OR SERVICES ON OUR WEBSITE, WE COLLECT YOUR NAME, DATE OF BIRTH, EMAIL ADDRESS, BILLING ADDRESS, SHIPPING ADDRESS, COMPANY NAME (IF APPLICABLE), BILLING NAME, AND INFORMATION ABOUT YOUR BROWSER.
DATE OF BIRTH IS REQUIRED BY OUR THIRD-PARTY AGE VERIFICATION TOOLS TO COMPLY WITH FEDERAL, STATE AND OTHER JURISDICTIONS WHICH HAVE AGE RESTRICTIONS FOR TOBACCO PRODUCT.
IF YOU DO NOT PROVIDE THIS INFORMATION, YOU WILL NOT BE ABLE TO PURCHASE GOODS OR SERVICES FROM US ON OUR WEBSITE OR ENTER INTO A CONTRACT WITH US.
OPTIONAL INFORMATION
WE ALSO COLLECT OPTIONAL INFORMATION FROM YOU, SUCH AS YOUR PHONE NUMBER OR INFORMATION ABOUT HOW YOUR EXPERIENCE WAS IN THE FORM OF A SURVEY. WE ALSO ASK YOU IF YOU WOULD LIKE TO RECEIVE MARKETING COMMUNICATIONS FROM US. FOR FURTHER INFORMATION, SEE ‘MARKETING COMMUNICATIONS’ IN THIS SECTION BELOW.
IF YOU DO NOT SUPPLY THE OPTIONAL INFORMATION REQUESTED AT CHECKOUT, SUCH AS PHONE NUMBER. WE WILL NOT BE ABLE TO CONTACT YOU BY PHONE OR SMS.
PROCESSING YOUR PAYMENT
AFTER YOU PLACE AN ORDER ON OUR WEBSITE YOU WILL NEED TO MAKE PAYMENT FOR THE GOODS OR SERVICES YOU HAVE ORDERED. IN ORDER TO PROCESS YOUR PAYMENT, WE USE A THIRD-PARTY PAYMENT PROCESSOR AND A FRAUD GATEWAY TO ENSURE THAT YOUR ORDER IS NOT FRAUDULENT AS WELL AS AGE VERIFICATION TOOLS AND SERVICES.
MARKETING COMMUNICATIONS
AT CHECKOUT AND UPON FIRST ARRIVING TO THE SITE YOU WILL HAVE THE OPTION OF RECEIVING MARKETING COMMUNICATIONS FROM US.
YOU CAN OPT-OUT FROM RECEIVING MARKETING COMMUNICATIONS IN RELATION TO OUR GOODS AND WHICH ARE SIMILAR TO THOSE WHICH YOU PURCHASE FROM US, BY TICKING A BOX TO OPT OUT OR CLICKING ‘UNSUBSCRIBE’ IN ANY EMAIL FROM US.
WE WILL SEND YOU MARKETING COMMUNICATIONS IN RELATION TO SIMILAR GOODS AND SERVICES IF YOU DO NOT OPT OUT FROM RECEIVING THEM.
WE USE A THIRD-PARTY SERVICE TO ADMINISTER OUR MAILING LIST. INFORMATION YOU SUBMIT TO SUBSCRIBE FOR OUR E-NEWSLETTER WILL BE STORED ON OUR THIRD-PARTY MAILING LIST PROVIDER’S SERVERS.
USE OF WEB BEACONS [AND SIMILAR TECHNOLOGIES] IN EMAILS
WE USE TECHNOLOGIES SUCH AS WEB BEACONS (SMALL GRAPHIC FILES IN THE EMAILS WE SEND TO ALLOW US TO ASSESS THE LEVEL OF ENGAGEMENT OUR EMAILS RECEIVE BY MEASURING INFORMATION SUCH AS THE DELIVERY RATES, OPEN RATES AND CLICK THROUGH RATES WHICH OUR EMAILS ACHIEVE. WE WILL ONLY USE WEB BEACONS IN OUR EMAILS IF YOU HAVE CONSENTED TO US DOING SO.
WE WILL SEND YOU MARKETING COMMUNICATIONS IN RELATION TO OUR GOODS AND SERVICES ONLY IF YOU OPT-IN TO RECEIVE THEM.
GENERALLY, WE DO NOT RECEIVE INFORMATION ABOUT YOU FROM THIRD-PARTIES. THE THIRD-PARTIES FROM WHICH WE RECEIVE INFORMATION ABOUT YOU WILL INCLUDE PARTNER COMPANIES WHO WE ARE DOING A JOINT PROMOTION WITH.
IT IS ALSO POSSIBLE THAT THIRD PARTIES WITH WHOM WE HAVE HAD NO PRIOR CONTACT MAY PROVIDE US WITH INFORMATION ABOUT YOU.
INFORMATION WE OBTAIN FROM THIRD PARTIES WILL GENERALLY BE YOUR NAME AND CONTACT DETAILS, BUT WILL INCLUDE ANY ADDITIONAL INFORMATION ABOUT YOU WHICH THEY PROVIDE TO US.
SIMILARLY, THIRD PARTIES MAY PASS ON INFORMATION ABOUT YOU TO US IF YOU HAVE INFRINGED OR POTENTIALLY INFRINGED ANY OF OUR LEGAL RIGHTS. IN THIS CASE, WE WILL HAVE A LEGITIMATE INTEREST IN PROCESSING THAT INFORMATION TO INVESTIGATE AND PURSUE ANY SUCH POTENTIAL INFRINGEMENT.
WHERE WE RECEIVE INFORMATION ABOUT YOU IN ERROR
IF WE RECEIVE INFORMATION ABOUT YOU FROM A THIRD-PARTY IN ERROR AND/OR WE DO NOT HAVE A LEGAL BASIS FOR PROCESSING THAT INFORMATION, WE WILL DELETE YOUR INFORMATION.
OUR USE OF AUTOMATED DECISION-MAKING AND PROFILING
WE USE AUTOMATED DECISION MAKING AND PROFILING ON OUR WEBSITE. WE DO NOT CONSIDER THAT THIS HAS ANY LEGAL EFFECT ON YOU OR SIMILARLY SIGNIFICANTLY AFFECTS YOU.
YOU HAVE THE RIGHT TO OBJECT TO OUR USE OF AUTOMATED DECISION MAKING AND PROFILING DESCRIBED IN THIS SECTION. YOU CAN DO THAT BY OPTING-OUT OF COOKIES AND SIMILAR TECHNOLOGIES IN ACCORDANCE WITH THE METHOD DESCRIBED IN THE RELEVANT SECTION BELOW. IF YOU DO NOT WANT US TO PROCESS YOUR ACTUAL IP ADDRESS (USUALLY THE IP ADDRESS ASSIGNED TO YOU BY YOUR INTERNET SERVICE PROVIDER) WHEN YOU VISIT OUR WEBSITE, YOU CAN USE A VIRTUAL PRIVATE NETWORK (VPN) OR A FREE SERVICE AVAILABLE TO YOU.
AUTOMATED DECISION MAKING
AUTOMATED DECISION MAKING IS DECISION MAKING BY TECHNOLOGICAL MEANS (I.E. BY A MACHINE) WITHOUT HUMAN INVOLVEMENT.
USE OF AUTOMATED DECISION MAKING FOR DISPLAY ADVERTISING OR RECOMMENDATIONS.
WE AUTOMATE THE DISPLAY ADVERTISEMENTS AND RECOMMENDATIONS CONTAINING OUR PRODUCTS AND SERVICES ON OTHER WEBSITES YOU VISIT, YOU BASED ON THE FACT THAT YOU HAVE VISITED OUR WEBSITE USING COOKIES.
PROFILING
PROFILING IS ANY FORM OF AUTOMATED PROCESSING OF YOUR INFORMATION TO EVALUATE PERSONAL ASPECTS ABOUT YOU, IN PARTICULAR TO ANALYZE OR PREDICT THINGS LIKE YOUR PERFORMANCE AT WORK, ECONOMIC SITUATION, HEALTH, PERSONAL PREFERENCES, INTERESTS, RELIABILITY, BEHAVIOR, LOCATION OR MOVEMENTS.
USE OF PROFILING FOR WEB ANALYTICS
OUR WEB ANALYTICS SERVICES, GOOGLE ANALYTICS AND QUBIT, INC. USE COLLECTS INFORMATION SUCH AS YOUR LOCATION (BASED ON YOUR IP ADDRESS) AND YOUR BEHAVIOR (BASED ON COOKIES) WHEN YOU ACCESS OUR WEBSITE (SUCH AS THE PAGES YOU VISIT AND WHAT YOU CLICK ON) AND HOW MUCH YOU ARE SPENDING ON OUR SITE. WE WILL ONLY PROCESS INFORMATION FROM COOKIES IF YOU HAVE CONSENTED TO US SETTING COOKIES ON YOUR COMPUTER IN ACCORDANCE WITH OUR COOKIES POLICY. INFORMATION COLLECTED ABOUT YOU, ONCE COLLECTED IS ANONYMIZED AND STORED ON AN AGGREGATE BASIS. IP ADDRESSES ARE ANONYMIZED AT THE POINT OF COLLECTION ON OUR SITE.
USE OF PROFILING IN MARKETING EMAILS
WE USE WEB BEACONS IN OUR MARKETING EMAILS TO ANALYZE WHO OPENS OUR EMAILS AND WHAT ACTIONS THEY TAKE (FOR EXAMPLE, WHAT THEY CLICK ON).
YOU MAY OBJECT TO THIS BY OPT OUT BY USING OUR COOKIE CONTROL TOOL IN YOUR BROWSER.
DISCLOSURE AND USES OF YOUR INFORMATION
WE USE A NUMBER OF THIRD PARTIES TO PROVIDE US WITH SERVICES WHICH ARE NECESSARY TO RUN OUR BUSINESS OR TO ASSIST US WITH RUNNING OUR BUSINESS AND WHO PROCESS YOUR INFORMATION FOR US ON OUR BEHALF.
YOUR INFORMATION WILL BE SHARED WITH THESE SERVICE PROVIDERS WHERE NECESSARY TO PROVIDE YOU WITH THE SERVICE YOU HAVE REQUESTED, WHETHER THAT IS ACCESSING OUR WEBSITE OR ORDERING GOODS AND SERVICES FROM US.
WE DO NOT DISPLAY ALL THE IDENTITIES OF ALL OF OUR SERVICE PROVIDERS PUBLICLY BY NAME FOR SECURITY AND COMPETITIVE REASONS. IF YOU WOULD LIKE FURTHER INFORMATION ABOUT THE IDENTITIES OF OUR SERVICE PROVIDERS, HOWEVER, PLEASE CONTACT US DIRECTLY VIA OUR CONTACT FORM OR BY EMAIL AT INFO@CIGAR.SHOP AND WE WILL PROVIDE YOU WITH SUCH INFORMATION WHERE YOU HAVE A LEGITIMATE REASON FOR REQUESTING IT (WHERE WE HAVE SHARED YOUR INFORMATION WITH SUCH SERVICE PROVIDERS, FOR EXAMPLE).
WE DISCLOSE YOUR INFORMATION TO OTHER THIRD PARTIES IN SPECIFIC CIRCUMSTANCES, AS SET OUT BELOW.
PROVIDING INFORMATION TO THIRD PARTIES SUCH AS GOOGLE INC. GOOGLE COLLECTS INFORMATION THROUGH OUR USE OF GOOGLE ANALYTICS ON OUR WEBSITE. GOOGLE USES THIS INFORMATION, INCLUDING IP ADDRESSES AND INFORMATION FROM COOKIES, FOR A NUMBER OF PURPOSES, SUCH AS IMPROVING ITS GOOGLE ANALYTICS SERVICE. INFORMATION IS SHARED WITH GOOGLE ON AN AGGREGATED AND ANONYMIZED BASIS. TO FIND OUT MORE ABOUT WHAT INFORMATION GOOGLE COLLECTS, HOW IT USES THIS INFORMATION AND HOW TO CONTROL THE INFORMATION SENT TO GOOGLE, PLEASE SEE THE FOLLOWING PAGE: HTTPS://WWW.GOOGLE.COM/POLICIES/PRIVACY/PARTNERS/]
INDICATING POSSIBLE CRIMINAL ACTS OR THREATS TO PUBLIC SECURITY TO A COMPETENT AUTHORITY
IF WE SUSPECT THAT CRIMINAL OR POTENTIAL CRIMINAL CONDUCT HAS BEEN OCCURRED, WE WILL IN CERTAIN CIRCUMSTANCES NEED TO CONTACT AN APPROPRIATE AUTHORITY, SUCH AS THE POLICE. THIS COULD BE THE CASE, FOR INSTANCE, IF WE SUSPECT THAT WE FRAUD OR A CYBER-CRIME HAS BEEN COMMITTED OR IF WE RECEIVE THREATS OR MALICIOUS COMMUNICATIONS TOWARDS US OR THIRD PARTIES.
WE WILL ONLY NEED TO PROCESS YOUR INFORMATION FOR THIS PURPOSE IF YOU WERE INVOLVED OR AFFECTED BY SUCH AN INCIDENT IN SOME WAY.
WE MAY NEED TO USE YOUR INFORMATION IF WE ARE INVOLVED IN A DISPUTE WITH YOU OR A THIRD PARTY FOR EXAMPLE, EITHER TO RESOLVE THE DISPUTE OR AS PART OF ANY MEDIATION, ARBITRATION OR COURT RESOLUTION OR SIMILAR PROCESS.
FOR ONGOING COMPLIANCE WITH LAWS, REGULATIONS AND OTHER LEGAL REQUIREMENTS
WE WILL USE AND PROCESS YOUR INFORMATION IN ORDER TO COMPLY WITH LEGAL OBLIGATIONS TO WHICH WE ARE SUBJECT. FOR EXAMPLE, WE MAY NEED TO DISCLOSE YOUR INFORMATION PURSUANT TO A COURT ORDER OR SUBPOENA IF WE RECEIVE ONE.
HOW LONG WE RETAIN YOUR INFORMATION
THIS SECTION SETS OUT HOW LONG WE RETAIN YOUR INFORMATION. WE HAVE SET OUT SPECIFIC RETENTION PERIODS WHERE POSSIBLE. WHERE THAT HAS NOT BEEN POSSIBLE, WE HAVE SET OUT THE CRITERIA WE USE TO DETERMINE THE RETENTION PERIOD.
ORDER INFORMATION: WHEN YOU PLACE AN ORDER FOR GOODS AND SERVICES, WE RETAIN THAT INFORMATION INDEFINITELY OR UNTIL YOU REQUEST THAT WE DELETE UNLESS THIS CONFLICTS WITH OUR COMPLIANCE OF A LEGAL RESPONSIBILITY.
CORRESPONDENCE AND ENQUIRIES: WHEN YOU MAKE AN ENQUIRY OR CORRESPOND WITH US FOR ANY REASON, WHETHER BY EMAIL OR VIA OUR CONTACT FORM ,WE WILL RETAIN YOUR INFORMATION FOR AS LONG AS IT TAKES TO RESPOND TO AND RESOLVE YOUR ENQUIRY AND INDEFINITELY AFTERWARD UNLESS IT IS REQUESTED TO BE DELETED AND IT DOES NOT INTERFERE WITH OUR COMPLIANCE WITH LAWS AND OUR LEGITIMATE BUSINESS INTEREST.
E-NEWSLETTER: WE RETAIN THE INFORMATION YOU USED TO SIGN UP FOR OUR E-NEWSLETTER FOR AS LONG AS YOU REMAIN SUBSCRIBED (I.E. YOU DO NOT UNSUBSCRIBE) OR IF WE DECIDE TO CANCEL OUR E-NEWSLETTER SERVICE, WHICHEVER COMES EARLIER.
IN ANY OTHER CIRCUMSTANCES, WE WILL RETAIN YOUR INFORMATION FOR NO LONGER THAN NECESSARY, TAKING INTO ACCOUNT THE FOLLOWING: THE PURPOSE(S) AND USE OF YOUR INFORMATION BOTH NOW AND IN THE FUTURE (SUCH AS WHETHER IT IS NECESSARY TO CONTINUE TO STORE THAT INFORMATION IN ORDER TO CONTINUE TO PERFORM OUR OBLIGATIONS UNDER A CONTRACT WITH YOU OR TO CONTACT YOU IN THE FUTURE); WHETHER WE HAVE ANY LEGAL OBLIGATION TO CONTINUE TO PROCESS YOUR INFORMATION (SUCH AS ANY RECORD-KEEPING OBLIGATIONS IMPOSED BY RELEVANT LAW OR REGULATION); WHETHER WE HAVE ANY LEGAL BASIS TO CONTINUE TO PROCESS YOUR INFORMATION (SUCH AS YOUR CONSENT); HOW VALUABLE YOUR INFORMATION IS (BOTH NOW AND IN THE FUTURE); ANY RELEVANT AGREED INDUSTRY PRACTICES ON HOW LONG INFORMATION SHOULD BE RETAINED; THE LEVELS OF RISK, COST AND LIABILITY INVOLVED WITH US CONTINUING TO HOLD THE INFORMATION; HOW HARD IT IS TO ENSURE THAT THE INFORMATION CAN BE KEPT UP TO DATE AND ACCURATE; AND ANY RELEVANT SURROUNDING CIRCUMSTANCES (SUCH AS THE NATURE AND STATUS OF OUR RELATIONSHIP WITH YOU).
HOW WE SECURE YOUR INFORMATION
WE TAKE APPROPRIATE TECHNICAL AND ORGANIZATIONAL MEASURES TO SECURE YOUR INFORMATION AND TO PROTECT IT AGAINST UNAUTHORIZED OR UNLAWFUL USE AND ACCIDENTAL LOSS OR DESTRUCTION, INCLUDING:
ONLY SHARING AND PROVIDING ACCESS TO YOUR INFORMATION TO THE MINIMUM EXTENT NECESSARY, SUBJECT TO CONFIDENTIALITY RESTRICTIONS WHERE APPROPRIATE, AND ON AN ANONYMIZED BASIS WHEREVER POSSIBLE; USING SECURE SERVERS TO STORE YOUR INFORMATION; VERIFYING THE IDENTITY OF ANY INDIVIDUAL WHO REQUESTS ACCESS TO INFORMATION PRIOR TO GRANTING THEM ACCESS TO INFORMATION; USING SECURE SOCKETS LAYER (SSL) SOFTWARE TO ENCRYPT ANY INFORMATION YOU SUBMIT TO US VIA ANY FORMS ON OUR WEBSITE AND ANY PAYMENT TRANSACTIONS YOU MAKE ON OR VIA OUR WEBSITE; ONLY TRANSFERRING YOUR INFORMATION VIA CLOSED SYSTEM OR ENCRYPTED DATA TRANSFERS.
TRANSMISSION OF INFORMATION OVER THE INTERNET IS NOT ENTIRELY SECURE, AND IF YOU SUBMIT ANY INFORMATION TO US OVER THE INTERNET (WHETHER BY EMAIL, VIA OUR WEBSITE OR ANY OTHER MEANS), YOU DO SO ENTIRELY AT YOUR OWN RISK.
WE CANNOT BE RESPONSIBLE FOR ANY COSTS, EXPENSES, LOSS OF PROFITS, HARM TO REPUTATION, DAMAGES, LIABILITIES OR ANY OTHER FORM OF LOSS OR DAMAGE SUFFERED BY YOU AS A RESULT OF YOUR DECISION TO TRANSMIT INFORMATION TO US BY SUCH MEANS.
INFORMATION YOU SUBMIT TO US VIA OUR CONTACT FORM IS STORED ON OUR THIRD-PARTY EMAIL AND CUSTOMER SERVICE SYSTEMS.
INFORMATION YOU SUBMIT TO US WHEN YOU SIGN UP FOR OUR E-NEWSLETTER IS STORED ON OUR THIRD-PARTY MAILING LIST PROVIDER’S SERVERS.
INFORMATION COLLECTED BY GOOGLE ANALYTICS (YOUR IP ADDRESS AND ACTIONS YOU TAKE IN RELATION TO OUR WEBSITE) IS STORED ON GOOGLE’S SERVERS. YOU CAN ACCESS GOOGLE’S PRIVACY POLICY HERE: HTTPS://WWW.GOOGLE.COM/POLICIES/PRIVACY/
INFORMATION YOU SUBMIT TO US BY OUR THIRD-PARTY PAYMENT PROCESSOR IS STORED ON THEIR SERVERS.
VERIFYING YOUR IDENTITY WHERE YOU REQUEST ACCESS TO YOUR INFORMATION
WHERE YOU REQUEST ACCESS TO YOUR INFORMATION, WE ARE REQUIRED BY LAW TO USE ALL REASONABLE MEASURES TO VERIFY YOUR IDENTITY BEFORE DOING SO.
THESE MEASURES ARE DESIGNED TO PROTECT YOUR INFORMATION AND TO REDUCE THE RISK OF IDENTITY FRAUD, IDENTITY THEFT OR GENERAL UNAUTHORIZED ACCESS TO YOUR INFORMATION.
WHERE WE POSSESS APPROPRIATE INFORMATION ABOUT YOU ON FILE, WE WILL ATTEMPT TO VERIFY YOUR IDENTITY USING THAT INFORMATION.
IF IT IS NOT POSSIBLE TO IDENTITY YOU FROM SUCH INFORMATION, OR IF WE HAVE INSUFFICIENT INFORMATION ABOUT YOU, WE MAY REQUIRE ORIGINAL OR CERTIFIED COPIES OF CERTAIN DOCUMENTATION IN ORDER TO BE ABLE TO VERIFY YOUR IDENTITY BEFORE WE ARE ABLE TO PROVIDE YOU WITH ACCESS TO YOUR INFORMATION.
WE WILL BE ABLE TO CONFIRM THE PRECISE INFORMATION WE REQUIRE TO VERIFY YOUR IDENTITY IN YOUR SPECIFIC CIRCUMSTANCES IF AND WHEN YOU MAKE SUCH A REQUEST.
SENSITIVE PERSONAL INFORMATION
‘SENSITIVE PERSONAL INFORMATION’ IS INFORMATION ABOUT AN INDIVIDUAL THAT REVEALS THEIR RACIAL OR ETHNIC ORIGIN, POLITICAL OPINIONS, RELIGIOUS OR PHILOSOPHICAL BELIEFS, OR TRADE UNION MEMBERSHIP, GENETIC INFORMATION, BIOMETRIC INFORMATION FOR THE PURPOSE OF UNIQUELY IDENTIFYING AN INDIVIDUAL, INFORMATION CONCERNING HEALTH OR INFORMATION CONCERNING A NATURAL PERSON’S SEX LIFE OR SEXUAL ORIENTATION.
WE DO NOT KNOWINGLY OR INTENTIONALLY COLLECT SENSITIVE PERSONAL INFORMATION FROM INDIVIDUALS, AND YOU MUST NOT SUBMIT SENSITIVE PERSONAL INFORMATION TO US.
CHANGES TO OUR PRIVACY POLICY
WE UPDATE AND AMEND OUR PRIVACY POLICY FROM TIME TO TIME.
WHERE WE MAKE MINOR CHANGES TO OUR PRIVACY POLICY, WE WILL UPDATE OUR PRIVACY POLICY WITH A NEW EFFECTIVE DATE STATED AT THE BEGINNING OF IT. OUR PROCESSING OF YOUR INFORMATION WILL BE GOVERNED BY THE PRACTICES SET OUT IN THAT NEW VERSION OF THE PRIVACY POLICY FROM ITS EFFECTIVE DATE ONWARDS.
WHERE WE MAKE MAJOR CHANGES TO OUR PRIVACY POLICY OR INTEND TO USE YOUR INFORMATION FOR A NEW PURPOSE OR A DIFFERENT PURPOSE THAN THE PURPOSES FOR WHICH WE ORIGINALLY COLLECTED IT, WE WILL NOTIFY YOU BY EMAIL (WHERE POSSIBLE) OR BY POSTING A NOTICE ON OUR WEBSITE.
WE WILL PROVIDE YOU WITH THE INFORMATION ABOUT THE CHANGE IN QUESTION AND THE PURPOSE AND ANY OTHER RELEVANT INFORMATION BEFORE WE USE YOUR INFORMATION FOR THAT NEW PURPOSE.
WHEREVER REQUIRED, WE WILL OBTAIN YOUR PRIOR CONSENT BEFORE USING YOUR INFORMATION FOR A PURPOSE THAT IS DIFFERENT FROM THE PURPOSES FOR WHICH WE ORIGINALLY COLLECTED IT.
CALIFORNIA DO NOT TRACK DISCLOSURES
“DO NOT TRACK” IS A PRIVACY PREFERENCE THAT USERS CAN SET IN THEIR WEB BROWSERS. WHEN A USER TURNS ON A DO NOT TRACK SIGNAL IN THEIR BROWSER, THE BROWSER SENDS A MESSAGE TO WEBSITES REQUESTING THAT THEY DO NOT TRACK THE USER. FOR INFORMATION ABOUT DO NOT TRACK, PLEASE VISIT WWW.ALLABOUTDNT.ORG