1. 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, and other electronic payment types.), email address, and phone number. We refer to this information as “Order Information”.
2. How do we use your personal information?
We use the Order Information that we collect generally to fulfil 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 optimise 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).
3. Sharing your personal Information
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Wix to power our CRM --you can read more about how Wix uses your Personal Information here: https://www.wix.com/about/privacy. 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: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
4. Behavioural advertising
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by using the links below:
- 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/.
6. 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.
7. European Union (“EU”) General Data Protection Regulation Policy
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 fulfil 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.
8. California Consumer Privacy Act
This section is specifically for individuals residing in California. We intend to comply with California Consumer Privacy Act of 2018 (“CCPA”). CCPA may provide you with additional rights over our use of your personal information, including Personal Data. You may find more information on: https://oag.ca.gov/privacy/privacy-laws. For the purpose of this section, Personal Data shall be part of the definition of “personal information”, meaning information falling under any of the 11 categories listed below which we may collect.
Under the CCPA, personal information does not include information that is publicly available, aggregated consumer information or those not covered by under the CCPA. IRYNE will only collect personal information in accordance with this Policy.
Sale of Personal Information and Persons under 16
IRYNE does not sell personal information we collected or received from third party, although we have de-identified and aggregated certain information for both internal and specific commercial use. Our Sites are not intended for individuals below age of 16, and we will not knowingly collect personal information from such individuals. If you are of age 16 years or older, you may request us to not use certain personal information collected from you for the aforesaid purpose by sending us a message at email@example.com and title your correspondence ‘Attention: CCPA Personal Data Access’.
As stipulated in this Policy, you have the right to choose not to provide certain personal information to us. We will not discriminate you in exercising your rights offered by CCPA. Unless where permitted in CCPA, we will not:
Deny you goods or services;
Charge a different price or rate for goods or services, including the use of discounts, benefits or other penalties;
Provide a different level or quality of goods or services; and
suggest will receive different price or quality of goods or service in exercising rights under law.
Request for Personal Information
Subject to exceptions permitted by law, you have the right to request us to delete your personal information which we may have collected. Upon receipt and confirming your verifiable consumer request, and if exceptions by law do not apply, we will arrange deletion.
To ensure and verify you are the correct and proper person related to the personal information which you want us to delete, upon receiving your request, you must thereafter provide us with the following in order for us to verify:
Date of Birth (Month/Day) if you recall having provided us with;
Details of last activity that you conducted on our Sites (for example, if you last made a purchase, details of that purchase such as date, value, item(s) purchased);
Email address used to conduct your activity on our Sites.
If the information you provided us with is insufficient to verify your identity as the person being related to the personal information requested for deletion, we may request you for supplementary information.
To submit a verifiable consumer request for deleting personal information, you may refer to Clause 10 below for contact details.
Exceptional circumstances where IRYNE can refuse deletion if we or our service provider(s) need to retain personal information in order to:
complete a transaction, perform our contractual obligation which we have entered with you, provide goods or services which you have ordered or is part of our ongoing business relationship;
detect wrongdoings like security incidents, protect against illegal, fraudulent or deceptive acts which are unlawful in nature;
debug, identify and repair errors that may impair existing intended functionality;
exercising free speech, and to ensure the right of free speech of a business or another Californian individual;
comply with California Electronic Communications Privacy Act;
conduct research (whether for public, scientific, historical, statistical) which adheres to other applicable ethical and privacy laws;
internal use which is reasonably aligned with consumer expectations based on consumer’s relationship with IRYNE, or in a lawful manner which aligns with the context and reason for why personal information was provided;
comply with legal obligations.
We may retain personal information in our electronic archival or backup system.
9. Data Retention
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.
The Site is not intended for individuals who are not at least the age of majority in your country, state or province of residence.
12. Contact us
For more information about our privacy practices, if you have questions, or if you would like to request access to and or correct your personal data held by us or make a complaint, please contact us by e‑mail at firstname.lastname@example.org and title your correspondence ‘Attention: Personal Data Access/ Privacy Compliance’.
Last Updated: 25 Aug 2020
Effective on: 25 May 2020