Privacy Policy
(hereinafter referred to as “the Policy”)
of the [Streamline Brands Group Ltd] (hereinafter referred to as the “Company”)
Last updated of the Policy: [June, 20th, 2023
This Policy describes the Company policies and procedures on collecting, processing, transferring and storing information when you use the Services and the Software and tells you about privacy rights and how the law protects your Personal Data.
The Website uses your Personal Data provided by you to provide and improve the Company’s Website and buying the Products. By using the Website, you agree to collect and use information following this Policy.
The Policy makes in compliance with Articles 12,13 and 14 of the GDPR and with the CCPA provisions.
I. INTERPRETATION AND DEFINITIONS
Interpretation
The words in which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.
Definitions
For the purposes of this Policy:
“Device” means any device that can access the Website, such as a computer, a telephone, or a digital tablet.
“The Company”, “we”, “our”, and “us” means the company that is an owner of this Website. The name of the company: [Streamline Brands Group, Ltd. 118 Gordon Road, London, SE15 3RP].
“GDPR” means general data protection rules relating to the protection of natural persons about the processing of personal data and rules relating to the free movement of Personal Data.
“Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, location data, an online identifier, etc.
“Processing” means any operation or set of operations that are performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction
“Products” means an eCommerce store that sells our own brand of beauty and cosmetics products in the United Kingdom, including personal care products and skincare products. Purchases are made through our eCommerce website, hosted on the third-party Shopify platform.
“Usage Data” refers to data collected automatically, either generated using the Website infrastructure itself (for example, the duration of a visit, website usage, and the number of users).
“User”, “you”, and “your” means any individual or legal entity who is using the Website from the Company.
“Website” means an eCommerce platform with a domain address: choosebiobalance.com which has our Products for sale.
II. COLLECTING AND USING YOUR PERSONAL DATA
Personal Data:
While using the Website, you may provide certain personally identifiable information that can be used to contact or identify you. Personal Data that we collect may include, but is not limited to:
- Full legal name;
- Email;
- Contact phone number;
- Country of residence;
- Mailing address and legal address;
- Shipping address; and
- Billing address.
The Company has the right, at any time, at its sole discretion, to request you confirm your personal information or any other information related to providing Services.
III. USAGE DATA
Usage Data is collected automatically when using the Website, buying the Products and visiting the Website.
Usage Data may include information, type of the Device, your visit pages, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you visit the Website, the Company has the right to collect, process and transfer the following data:
- the type of Device that is used for vising the Website; and
- the type of internet browser that is used for visiting the Website.
IV. TRACKING TECHNOLOGIES AND COOKIES
The Company uses Cookies and similar tracking technologies to track the activity on the Website and store certain information. Tracking technologies are beacons, tags, and scripts to collect and track information and improve and analyse the Website.
The technologies that the Company uses may include (but are not limited):
- Cookies or Browser Cookies. A cookie is a small file placed on your Device. You can instruct the browser to refuse all Cookies or to indicate when Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of the Website.
- Flash Cookies. Certain features of the Website may use locally stored objects (or Flash Cookies) to collect and store information about your preferences or activity on the Website. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
- Web Beacon. Certain sections of the Website emails may contain small electronic files known as Web Beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count guests who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal Devices when you go offline, while Session Cookies are deleted as soon as you close the web browser.
The Company uses both Sessions and Persistent Cookies for the purposes set out below:
Necessary/Essential Cookies
Type: Session Cookies
Administered by the Company
Purpose: These Cookies are essential for providing you with services available through the Website and enabling you to use some of its features. They help to authenticate users and prevent fraudulent use of your accounts. Without these Cookies, the services that you have asked for cannot be provided, and the Company only uses these Cookies to provide you with those services.
Cookies Policy/Notice Acceptance Cookies
Type: Persistent Cookies
Administered by the Company
Purpose: These Cookies identify if you have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by the Company
Purpose: These Cookies allow the Website to remember the choices you make when using the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter preferences every time you use the Website.
Advertising Cookies
Administered by the Company
Purpose: Those cookies can be turned on and off by the Website to deliver our potential customers the best advertising experience. They do not contain personal information and are based on your actions over the Website.
GOOGLE ANALYTICS: personal data and information obtained by way of such cookies concern the use that you make of the Website and will be transmitted from your browser to Google Inc., with registered office at 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States of America, and stored on Google’s servers. Google’s norms on privacy, which we kindly invite you to read, are available at the following URL: http://www.google.com/intl/it/privacy/privacy-policy.html.
The information on personal data concerning Google Analytics services is available at the following URL: http://www.google.com/intl/en/analytics/privacyoverview.html.
BROWSING DATA: computer systems and procedures responsible for the correct functioning of the Website automatically acquire, whilst operating, some Personal Data concerning the User's browsing history. For instance, within this category, the Company may find:
• IP addresses;
• Number of accesses to the Website;
• Visited pages;
• Date and time of access;
• Browser type;
• Adopted operating system.
Data voluntarily provided by you
Data freely and optionally provided by you via email to one of the email addresses indicated on the Website or in this Information may be acquired for purposes communicated to you occasionally. Besides email addresses required to answer you, additional Personal Data included within the same communication received by the Company may be processed. Personal Data collected as such will be retained and processed solely to preserve them and send correspondence and for no further purpose.
V. USE OF YOUR PERSONAL DATA
The Company may use Personal Data for the following purposes:
To provide and maintain the Website and the Software, including monitoring the usage of the Website,
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items, or services you have purchased or any other contract with the Company through the Website.
To provide you with news, special offers and general information about services and events that FixWave offers, like those you have already used unless you have opted not to receive such information.
To manage your requests: To attend to and manage your requests to the Website.
For business transfers: the Company may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or another sale or transfer of some or all the Company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by the Company about the Website and the Software users is among the assets transferred.
For other purposes: the Company may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of the Website’s promotional campaigns, evaluating and improving the Website, products, and services, marketing, and your experience.
The Company may share your Personal Data in the following situations:
- With service providers: the Company has the right to share your Personal Data with service providers to monitor and analyse the use of the Website and to contact you.
- For business transfers: the Company may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of the Company’s assets, financing, or acquisition of all or a portion of the Company’s business to another owner.
- With Affiliates: the Company has the right to share your Personal Data with the Company’s affiliates, in which case the Company will require those affiliates to honour this Privacy Policy. Affiliates include the Company’s parent company and any other subsidiaries, joint venture partners or other companies that the Company controls or are under common control with the Company.
- With business partners: the Company has the right to share your Personal Data with business partners to offer you certain products, services, or promotions.
- With your Consent: the Company has the right to disclose your Personal Data for any other purpose only with your advance consent.
VI. RETENTION OF YOUR PERSONAL DATA
The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.
The Company will retain and use your Personal Data to the extent necessary to comply with the Company’s legal obligations (for example, if we are required to retain the Company’s Personal Data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this Personal Data is used to strengthen the security or improve the Website's functionality, or the Company is legally obligated to retain this data for longer periods.
The Company will retain your personal data with [Shopify] database service that will provide the safest and most stable data protection.
VII. TRANSFER OF YOUR PERSONAL DATA
Your information, including Personal Data, processing by the Company’s operating offices and in any other places where the parties involved in the processing are located. This information may be transferred to — and maintained on — computers outside your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
Your consent to this Privacy Policy, followed by submission of such information, represents your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that your Personal Data is treated securely and following this Privacy Policy, and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place, including the security of your Personal Data and other personal information.
VIII. DISCLOSURE OF YOUR PERSONAL DATA
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. The Company will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose your Personal Data in the good faith belief that such action is necessary to:
- Comply with legal obligations.
- Protect and defend the rights or property of the Company.
- Prevent or investigate possible wrongdoing in connection with the Company.
- Protect the personal safety of you, the Website, or the public.
- Protect against legal liability.
IX. CHILDREN’S PRIVACY DATA
The Company’s Website does not address anyone under 18 (eighteen). The Company does not knowingly collect personally identifiable information from anyone under 18 (eighteen). If you are a parent or guardian and are aware that the child has provided the Company with Personal Data, please get in touch with us immediately.
If the Company becomes aware that we have collected Personal Data from anyone under 18 (eighteen) without verification of parental consent, the Company takes steps to remove that Personal Data from our servers or/and any storage used by the Company.
If the Company needs to rely on consent as a legal basis for processing your information and your country requires consent from a parent, the Company may require your parent’s consent before the Company collects and use that information.
X. SECURITY OF YOUR PERSONAL DATA
The Company takes all reasonable steps to protect information that is received from you from accidental or unlawful destruction, loss, alteration, and unauthorised disclosure or access. The Company has put in place appropriate physical, technical and administrative measures to safeguard and secure your information, and the Company makes use of privacy-enhancing technologies such as encryption. If you have any questions about the security of your personal information, you can contact us VIA email: [support@choosebiobalance.com]
XI. LINKS TO OTHER WEBSITES
The Company’s Website may contain links to other websites not operated by us. You will be directed to that third party's website if you click on a third-party link. The Company strongly advises you to review every site's privacy policy.
The Company has no control over and assumes no responsibility for any third-party sites or services' content, privacy policies or practices.
XII. CHANGES TO THIS PRIVACY POLICY
The Company may update the Policy from time to time. The Company is not obliged to notify you and any other third parties of any changes by posting the new Policy on this page.
The Company has the right to update the Policy. The Company will let you and any other third parties know via updating the “Last Updated” date at the top of this Policy.
You and any other third parties are advised to review this Policy periodically for any changes. Changes to this Privacy Policy are effective when posted on this page.
XIII. GDPR NOTICE
The legal basis for processing your Personal Data is Art. 6 sec. 1 a) b), f) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals about the processing of personal data and the free movement of such data and repealing Directive 95/46 / MI Laws UE.L.2016.119.1) (GDPR), where the legitimate interest of FixWave is related to providing the Software for you.
Personal Data will be processed until an objection to data processing or termination is made, but no longer than 10 (ten) years.
You have the right to access, correct, delete, or restrict his or her Personal Data or object to the processing, as well as the right to transfer the Personal Data and complain to the supervisory authority.
In the case of obtaining data and processing them based on Art. 6 sec. 1-year a) GDPR – you have the right to withdraw consent at any time, without prejudice to the lawfulness of the processing carried out based on consent to its withdrawal.
Under the GDPR, the Company is a data controller for the Personal Data collected from all categories of data subjects listed above, with the following exceptions: the Company is a data processor of user logs, administrative user logs, and some account settings information. In addition, the Company is a data processor for any of the information provided by you through the Website that transit. Where the Company is a data processor, the Company processes data on behalf of you under your data processing instructions.
XIV. INFORMATION FOR CALIFORNIA RESIDENTS
This section provides additional disclosures required by the California Consumer Privacy Act (or “CCPA”).
Please see Chart “Categories of personal information we collect” below in this Policy for a list of the personal information the Company has the right to collect about California consumers in the last 12 (twelve) months, along with the Company business and commercial purposes and categories of third parties with whom this information may be shared. For more details about the personal information the Company collects, including the categories of sources, please see “Collecting and using Personal Data”.
Categories of personal information we collect
Internets or other electronic network activity, such as browsing behaviour, information about your usage, and interactions with the Website and/or the Software.
Parties with whom the information may be shared
The third parties that provide services to the Company, such as those that assist us with customer support, subscription and order fulfilment, advertising measurement, communications and surveys, data analytics, fraud prevention, cloud storage, bug fix management and logging, and payment processing. The Company advertisers and marketing partners, such as partners, help determine the popularity of the content, deliver advertising and content targeted to your interests and assist in better understanding your online activity.
Subject to certain limitations and exceptions, the CCPA provides California users with the right to request to know more details about the categories and specific pieces of personal information, to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
The Company does not “sell” the personal information we collect (and will not sell it in the future without providing a right to opt-out). The Company does allow our advertising partners to collect certain device identifiers and electronic network activity via the Company Website to show ads that are targeted to your interests on other platforms. To opt-out, you can adjust Device settings to limit ad tracking via the Website.
California users may make a rights request by emailing us at [support@choosebiobalance.com]. The Company will verify your request by asking you to provide information that matches the information the Company has on file about you. You can also designate an authorised agent to exercise these rights on your behalf. Authorised agents should submit requests through the same channels, but the Company will require proof that the person is authorised to act on your behalf and may also still ask you to verify his/her identity with the Company directly.
XV. DISPUTE RESOLUTIONN
If you have an unresolved privacy or data use concern that the Company has not addressed satisfactorily, please contact us via [support@choosebiobalance.com].
XVI. CONTACTS
If you have any questions about this Policy, you can contact us:
- by email: [support@choosebiobalance.com].