Last updated: June 2018
This Website is owned, managed and operated by Tommy & Bella (hereinafter “Tommy & Bella”, “we”, “us”, “our”).
At Tommy & Bella, we recognize the importance of protecting the personal data of our customers (e.g. identification data, financial information such as, for instance, credit card numbers) and the information of the users of our Website. For this reason Tommy & Bella adopts specific policies and security measures to comply with applicable data protection laws and to protect your personal data.
SECTION 1 - WHAT DO WE DO WITH YOUR INFORMATION?
When you purchase something from our online store, as part of the buying and selling process, we collect the personal information you give us, such as your name, address and email address.
When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.
With your permission, we may send you emails about our store, new products and other updates.
SECTION 2 - CONSENT
How do you get my consent?
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
How do I withdraw my consent?
If after you opt in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at firstname.lastname@example.org.
SECTION 3 - DISCLOSURE
We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.
SECTION 4 - SHOPIFY
Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you.
Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.
If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. For more insight, you may also want to read Shopify’s Terms of Service (https://www.shopify.com/legal/terms) or Privacy Statement (https://www.shopify.com/legal/privacy).
SECTION 5 - THIRD-PARTY SERVICES
In general, the third party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, certain third party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in, or have facilities that are located in, a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
When you click on links on our store, they may direct you away from our Website. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
SECTION 6 - SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
SECTION 7 - COOKIES
Here is a list of cookies that we use on our Website. We have listed them here so you can choose if you want to opt out of cookies or not.
_session_id, unique token, sessional: Allows Shopify to store information about your session (referrer, landing page, etc);
_shopify_visit, no data held, Persistent for 30 minutes from the last visit: Used by our Website provider’s internal stats tracker to record the number of visits;
_shopify_uniq, no data held, expires midnight (relative to the visitor) of the next day: Counts the number of visits to a store by a single customer;cart, unique token, persistent for 2 weeks: Stores information about the contents of your cart; _secure_session_id, unique token, sessional;
storefront_digest, unique token, indefinite: If the shop has a password, this is used to determine if the current visitor has access.
SECTION 8 - AGE OF CONSENT
By using this Website, you represent that you are at least the age of majority in your country, state or province of residence, or that you are the age of majority in your country, state or province of residence and you have given us your consent to allow any of your minor dependents to use this Website.
If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
QUESTIONS, COMPLAINTS AND CONTACT INFORMATION
If you would like to access, correct, amend or delete any personal information we have about you, submit a complaint, or simply request more information, please contact our Privacy Compliance Officer at email@example.com.
Privacy Notice to Customers
Last updated: June 2018
Privacy notice to the data subjects for the processing of personal data
Pursuant to art. 13 of Regulation (EU) 679/2016, as may be subsequently amended and supplemented, (“GDPR”), and the implementing European laws, as may be subsequently amended and supplemented, (“Applicable Privacy Legislation”), and in relation to your personal data, that we wish to process, we hereby wish to inform you as follows.
1. Data Controller
1.1 – The data controller is Tommy & Bella, with registered office at PO BOX Z5282, 66 ST GEORGES TERRACE, PERTH WA 6000, Australia,
e-mail: firstname.lastname@example.org (“Controller”).
2. Categories of personal data that are processed
In order to be able to provide you with the requested service, and therefore, in order to enable you to purchase and receive our products (“Products”), the Controller shall process your personal data to the extent they are necessary for pursuing the purposes specified in section 3 below, including, without limitation, your personal identification details (name and surname), residence address, e-mail address, and telephone number.
3. Purposes and legal basis of the data processing
3.1 – Your personal data shall be processed for the following purposes:
- To provide the service of sale, shipping, and delivery of the Products;
- To fulfil the obligations provided for by EU and non-EU laws, regulations, rules and policies, by decisions issued by legally empowered authorities or by other supervisory authorities and bodies; and
- To advertise, promote and market new Products developed by the Controller.
3.2 – For the processing of personal data for the purposes specified in paragraphs 3.1 (a) and (b) above, your consent is not necessary, in that such data processing is required to fulfil our legal obligations and to perform the requested service. For the processing of personal data for the purposes specified in paragraph 3.1(c) above, we will request you to provide your consent. For clarity’s sake, in relation to this data processing, your consent is optional, and not compulsory, and shall be given if you wish to receive promotional and/or marketing communications from the Controller.
3.3 - The Controller will not process any personal data, falling within the special categories indicated in art. 9 of the GDPR, that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or genetic data, biometric data aimed at univocally identifying a natural person, or data concerning health or sexual life or sexual orientation of a natural person.
3.4 – Personal data will be processed electronically and/or manually.
3.5 – The supply of your personal data to the Controller is necessary for the performance of the service agreement and/or for the fulfilment of legal obligations; should you refuse to supply your personal data, the Controller will not be able to provide you with the requested Product(s), except for the data processing carried out for the purposes specified in paragraph 3.1(c) above.
3.6 – The data processing shall be carried out in accordance with the principles of proportionality and necessity (i.e. the Controller shall not process or collect personal data that are unnecessary), in accordance with the principles of loyalty and transparency (the Controller shall always give adequate notice to the data subjects of the data processing carried out), and in compliance with the requisite of adequacy of the security measures.
4. Recipients of personal data and other persons authorised to process them
4.1 – In the performance of its activities and for pursuing the purposes under paragraph 3 above, the Controller may disclose personal data to the following categories of persons: suppliers, providers, and shipping companies.
4.2 – The Controller shall process your personal data through its duly authorised staff, only insofar as is necessary and based on the specific instructions of the Controller, guaranteeing secrecy and confidentiality.
5. Personal data retention
All personal data shall be retained as long as necessary for handling the purchase orders and performing the relevant agreement. Upon fulfilment of the orders, only those personal data which are necessary to enable you to receive promotional and marketing communications and updates on the new Products may be retained for 3 additional years.
6. Rights of the data subject
6.1 – Finally, we hereby inform you that, in relation to the personal data that are in our files, you may exercise the rights provided by the Applicable Privacy Legislation. In particular, you may exercise the following rights:
- To obtain from the Controller confirmation of the existence of your personal data, and to be informed of the origin of such data, as well as of the rationale and purposes of the processing, of the categories of persons to whom the data may be communicated, and of the details identifying the data controller and the data processors;
- To access your personal data, and to obtain anonymisation, blocking, rectification, updating, supplementing or erasure of the data, or limitation of the data processing;
- To object to the data processing in the cases contemplated by the Applicable Privacy Legislation;
- To exercise the right to data portability, within the limits specified by art. 20 of the GDPR; and
- To withdraw your consent (where consent is the necessary legal ground of the data processing) at any time without prejudicing the lawfulness of the data processing based on consent given before the withdrawal.
6.2 – The rectification or erasure or limitation of the data processing, carried out upon your request, – unless this is impossible or implies disproportionate efforts – shall be notified by the Controller to each of the recipients to whom your personal data have been disclosed. The Controller shall notify you of the identity of said recipients, should you request so.
6.3 – For the exercise of the rights specified in paragraph 6.1 above, or for any further clarification or information, please contact Tommy & Bella via e-mail at email@example.com.