HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
communicate with you; screen our orders for potential risk or fraud; and
when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information.”
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information for the purpose of trade, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here.
We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here.
We use Paypal as one of our payment options - you can find out more about how your data is used here.
You can opt out of targeted advertising by clicking the links:
FACEBOOK - https://www.facebook.com/settings/?tab=ads
GOOGLE - https://www.google.com/settings/ads/anonymous
BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information. For example, we use a password protected address book to store addresses for label printing. You have the right to request the removal of your address from our label printing system - please contact us at the address at the bottom of this policy if you wish to be removed.
No printed personal data is held however we do store postage receipts showing house number/postcodes - this is in case of issues with our postage service ie missing/delayed parcels, lost parcels resulting in a claim (POP) or in case tax records need to be shown to HMRC. We will hold Proof of Postage receipts for no longer than 7 years from their issue date after which they shall be destroyed in accordance with guidelines.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at firstname.lastname@example.org or by mail using the details provided below:
Gemma Knox, Gembolina's, 26 Rainford Avenue, Liverpool, L20 0AS, United Kingdom
Last updated 24/05/18
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and customers: in other words, where we determine the purposes and means of the processing of that data.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls you can specify whether you would like to receive direct marketing communications. You can access the privacy controls via https://www.gembolinas.com/account/register
1.5 In this policy, "we", "us" and "our" refer to Gemma Knox trading as Gembolina's. For more information including contact details for our data controller see section 13.
2.1 This document was created using a template from SEQ Legal
3. How we use your personal data
3.1 In this section we have set our:
(a) the general categories of personal data that we may process
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data
(c) the purposes for which we may process personal data: and
(d) the legal basis of the processing
3.2 We may process data about your use of our website ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. The usage data may be processed for purposes of analysing the use of the website, Facebook store and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website, Facebook store and services.
3.3 We may process your account and order/contractual data ("account data"). The account data may include your name, address, email address and order history. The source of your account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining backups of our databases and communicating with you. The legal basis of this processing is consent or our legitimate interests, namely the proper the proper administration of our website and business or the the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, gender, date of birth, interests and hobbies and employment details. The profile data may be used for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.5 We may process your personal data that is provided to us in the course of the use of our services ("service data"). The service data may include your name, address, telephone number, email address, gender, date of birth, interests and hobbies and employment details.The source of the service data is you. The service data will be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining backups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.6 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent or your legitimate interest namely the request for goods or service information and communication and our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.8 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your job title or role, your business name, your contact details, and information contained in communications between us and you. The customer data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products or services to customers. The legal basis of this processing is consent or our legitimate interests, namely the proper management of our customer relationships and administration of our business.
3.9 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased good and services and for keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
3.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for the processing is consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.11 We may process information contained in/relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another living person.
3.15 Please do not supply any other person's personal data to us, unless we prompt you to do so.
4 Providing your personal data to others
4.1 We may disclose your personal data to any member of our business insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purpose of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose names, addresses and contact telephone numbers to our subcontractors identified at https://www.royalmail.com
insofar as reasonably necessary for fulfillment of our contract with you. This is solely for the purpose of the delivery of orders placed on the website. You can find out more about Royal Mail and how they use your data at https://www.royalmail.com/privacy-notice
4.4 Financial transactions in relation to our website and services are handled by our payment service providers, Paypal, Stripe and Apple Pay. We will share transaction data with our payment service providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment service providers' privacy policies and practices at:
4.6 In addition to the specific disclosure of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another living person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We have offices in the United Kingdom. The European Commission has made an "adequacy decision" with respect to the data protection laws of this country. Transfers will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted by or approved by the European Commission, a copy of which can be obtained here; https://ec.europa.eu/info/law/law-topic/data-protection_en
5.3 The hosting facilities for our website are situated in the USA and Canada. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses in accordance with the EU-U.S. Privacy Shield Framework, the Swiss-U.S. Privacy Shield Framework, and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).
5.4 Our Email service providers are based in the USA. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses in accordance with the EU-U.S. Privacy Shield Framework.
For more information on how our email services handles your data please see;
5.5 You acknowledge that personal data you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligation in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) personal data will be retained for a minimum period of 1 year and for a maximum period of 7 years from the date of consent/purchase (forming of what is referred to in this policy as a contract).
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of will be determined based on business requirements
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes made to this policy.
7.3 We will notify you of significant changes to this policy by email if you have opted in.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of those rights; https://ec.europa.eu/info/law/law-topic/data-protection_en
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of the personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting
8.4 You have the right to have any inaccurate personal data about you rectified, and taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In the UK this is the ICO.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.
9. About cookies
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
11. Cookies used by our service providers
11.3 We occasionally publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies.
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 This website is owned and operated by Gemma Knox trading as Gembolina's (www.gembolinas.com)
13.2 Our principal place of business is at 26 Rainford Avenue, Liverpool, Merseyside, L20 0AS, UK
13.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by email - email@example.com
14. Data Protection Officer
14.1 For the purposes of EU Data Law our data protection officer as referred to in this policy is Gemma Knox.
Last updated 25/05/2018 by G.Knox