OWNER AND DATA CONTROLLER
Trunkaroo Ltd, 6th Floor, Remo House, 310-312 Regent Street London GB W1B3BS. Owner contact email: firstname.lastname@example.org
SECTION 1 - WHAT DO WE DO WITH YOUR INFORMATION?
- When you purchase something from our store, as part of the buying and selling process, we collect the personal information you give us such as your name, address, order history, telephone number and email address.
- We request the name of the child to put on the box. By submitting the name of a child to be used on a box, you represent to us that you are a parent or guardian of the child and consent to us processing their data or that you have the consent of the relevant person holding parental responsibility to provide us with that personal data for processing.
- When you browse our store, we also 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.
- Email marketing (if applicable): With your consent, we may send you emails about our store, new products and other updates.
- We may also use your data for the following (primarily marketing) purposes: analytics, advertising, traffic optimization and distribution, remarketing and behavioral targeting, hosting and backend infrastructure, heat mapping and session recording, infrastructure monitoring, handling payments, platform services and hosting, managing landing and invitation pages and user database management.
- Complete details on each type of personal data collected are provided by specific explanation texts displayed prior to the data collection, or upon request by emailing email@example.com.
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 email marketing, we will ask you directly for your consent.
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 anytime, by contacting us at firstname.lastname@example.org or mailing us at: Trunkaroo Ltd, 6th Floor, Remo House, 310-312 Regent Street London GB W1B3BS
SECTION 3 - DATA PROCESSING
Methods of processing
- We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data.
- The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In some cases, data may be accessible to certain types of persons in charge, involved with the operation of Trunkaroo (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors. The updated list of these parties may be requested at any time.
Legal basis of processing
- We may process your personal data if one of the following applies:
- You have given consent for one or more specific purposes. Note: Under some legislations we may be allowed to process your data until you object to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of your data is subject to European data protection law.
- provision of data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which twe are subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us as the owner;
- processing is necessary for the purposes of the legitimate interests pursued by usor by a third party.
- In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of your personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
- The data is processed at our office in London, England, and in any other places where the parties involved in the processing are located.
- Depending on your location, data transfers may involve transferring your Data to a country other than your own.
- You are also entitled to learn about the legal basis of data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures we take to safeguard ata.
- If any such transfer takes place, you can find out more by checking the relevant sections of this document or emailing email@example.com to find out more.
- Personal data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal data collected for purposes related to the performance of a contract between Trunkaroo and you shall be retained until such contract has been fully performed.
- Personal data collected for the purposes of the our legitimate interests shall be retained as long as needed to fulfill such purposes. You may find specific information regarding the legitimate interests by contacting us at firstname.lastname@example.org
- We may be allowed to retain your personal for a longer period whenever the you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain your personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
- Once the retention period expires, your personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
SECTION 4 - 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 5 - 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 6 - 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 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.
- When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
SECTION 7 - 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 8 - COOKIES
- Here is a list of cookies that we use. We’ve listed them here so you that 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 9 - AGE OF CONSENT
- By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
- 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.
SECTION 11 - THE RIGHTS OF USERS
You may exercise certain rights regarding your personal data. In particular, you have the right to do the following:
- Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your personal data.
- Object to processing of your data. You have the right to object to the processing of your data if the processing is carried out on a legal basis other than consent. Further details are provided in the relevant section below.
- Access Data. You have the right to learn if data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
- Verify and seek rectification. You have the right to verify the accuracy of your data and ask for it to be updated or corrected.
- Restrict the processing of your data. You have the right, under certain circumstances, to restrict the processing of your data. In this case, we will not process your data for any purpose other than storing it.
- Have your personal data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your data from us.
- Receive your data and have it transferred to another controller. You have the right to receive your data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
- Lodge a complaint. You have the right to bring a claim before your competent data protection authority.
- Details about the right to object to processing: Where your data is processed for a public interest, in the exercise of an official authority vested in us as the Owner or for the purposes of the legitimate interests pursued by us the Owner, you may object to such processing by providing a ground related to your particular situation to justify the objection.
You must know that, however, should your personal data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification.
How to exercise these rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed as early as possible and always within one month.
QUESTIONS AND CONTACT INFORMATION
- If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at email@example.com or by mail at: Trunkaroo, Re: Privacy Compliance Officer, 6th Floor, Remo House, 310-312 Regent Street London GB W1B3BS