Privacy Policy: Last Updated: April 2020
1. PREFACE
We are the Private Label/Brand Valma (“Valma”, “we”, “us”, “our”), and we are committed to protecting your privacy.
The Valma Privacy Policy explains how we collect, process and protect your personal data when you use our website(s), social media channels and other apps, when you access our information and when you purchase Valma products via our website/app and digital channels (“Website”) as required by the data protection laws in the countries in which we do business and in particular with the EU General Data Protection Regulation (Regulation 2016/679 - “GDPR”).
We have implemented a robust data protection compliance program, which includes the adoption of the high-standard data protection principles of the GDPR at a global level. Our Website can contain links to and from the websites of our suppliers, partner boutiques, retailers and brands (collectively our “Partners”), advertisers, and affiliates, amongst others. If you follow a link to any of these websites, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.
This Privacy Policy sets out the information that we collect, the reasons for which we collect that information, and how we can use and share that information. The Website and the services provided by Valma are not intended to be used by children. If we should nevertheless inadvertently collect such information, the minor's legal representative can exercise the minor’s rights on his/her behalf and on his/her name at any time. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, you can contact us at privacy@valma.li
2. TYPE OF DATA AND INFORMATION WE COLLECT
When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:
2.1 Information provided directly by you.
You may give us information about yourself if you sign up for an account on our Website, place an order for products, complete any online forms (such as registration forms, competitions, and surveys), opt in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions with our Website, or correspond with us (by email, telephone, instant chat, social media or otherwise).
Depending on what you provide, this information can include your name, address or location, phone number and email address, date of birth, gender, purchase information, shopping preferences, images and financial information (including your credit or debit card details, although we do not hold them, our payment processors do).
When you visit Valma personal sales events or Valma PopUp-Stores you may also give us information about yourself in-store if you make a purchase using a credit or debit card, complete a survey or questionnaire, enter a competition or promotion, provide us with feedback or otherwise interact or correspond with us in-store. Where you use a WiFi-enabled device in-store, certain information may be provided by your device, which will differ depending on your device and settings. The information that may be provided is the type of device you have, the device identifier/media access control (MAC) address, the proximity of the device from the access point, location of the device, and where relevant, when and for how long the device is connected to the Wi-Fi network. You can prevent information being provided by turning off the Wi-Fi feature on your device.
2.2. Information we obtain indirectly about you.
Some additional information is collected indirectly about you while you are browsing the website and interacting with us in other ways. This information is technically needed for the proper functioning of the website, to improve your browsing experience or to perform analytics that will enable us to serve you better by personalizing our services for you.
2.2.1. Information our IT systems collect about you: each time you visit the Website, certain information relative to your online profile and website usage data (e.g. behavioral analysis via cookies and similar technologies, your navigation trail of the website, registration of products in the shopping basket) will be created and automatically recorded by our systems. That information includes:
COOKIES: the information provided by cookies that can help us to improve your experience with the Website and make it easier to interact with us. We use the following categories of cookies:
- STRICTLY NECESSARY COOKIES These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided.
- PERFORMANCE COOKIES These cookies collect anonymous information on how you use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. You may opt-in to these cookies using your browser settings.
- FUNCTIONALITY COOKIES These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. You may opt-in to these cookies using your browser settings.
- TARGETING COOKIES OR ADVERTISING COOKIES These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies to provide you with more personalised adverts when visiting other websites. You may opt-in to these cookies using your browser settings.
- SOCIAL MEDIA COOKIES These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and Twitter. Please refer to the respective privacy policies for how their cookies work. If you want to delete any cookies that are already on your computer, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website.
• Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;
• other third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu.
• any other type of cookies, you can clean the cookies through your browser settings.
Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.
DEVICE INFORMATION: the information provided by your device will differ depending on which type of device you are using and the settings on that device, but includes the type of device you have, the device’s IP address, the browser you are using, your mobile network provider, the pages you have visited, your time zone and country location, and crash or download error reports.
2.2.2. Information we receive from other accounts or sources: we can receive information about you from other sources, such as from your other accounts or other websites, including data brokers, our Partners, social media providers like Facebook and Twitter, advertising networks and analytics partners, and payment and delivery service providers.
By logging in to our mobile applications via Facebook or Twitter, or linking your account on our Website to your Facebook or Twitter accounts, you are giving us permission to obtain certain information and content from these accounts. The specific types of information that we may obtain depends on your settings for that account or website and will be subject to their privacy policies.
3. REASONS WHY WE COLLECT YOUR DATA
Our collection and processing of your personal data is based on our obligation to comply with all applicable laws and regulations. It is also based on the necessity to carry out the purchase contract with you, to provide you the website, app or other online services as requested by you or, if legally required, on your consent.
We may also rely on our legitimate interest in the completion of sales and in our commitment to offer you seamless after sales services and a personalized and highly qualitative treatment in the long term. In more detail we collect your data for the following purposes:
We consider that our products should entitle you to personalized client treatment and after-sales services that may last for a lifetime. For this purpose, and to ensure such services, we may need to keep your personal data for as long as it is needed for the provision of such services. In particular your personal data will be retained until your last use or purchase of our services or goods and normally for a period of up to 5 years thereafter, unless shorter or longer retention is required by applicable local law or where we have a legitimate and lawful purpose to do so.
5. DISCLOSURE OF DATA AND INFORMATION
To provide the Website and our services, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:
You have the following rights in relation to the personal data we hold about you:
To exercise the above rights please contact us at privacy@valma.li and communicate the following information: name, surname, e-mail or any other information necessary to confirm your identity in order for us to process the request (such as your postal address).
Finally, you have the right to lodge a complaint with a competent supervisory authority in case of breach of the applicable privacy laws and regulations, in particular the GDPR but also any other national or regional privacy laws applicable to you.If you have any questions or concerns about this Privacy Policy, please contact us at privacy@valma.li
2.2.2. Information we receive from other accounts or sources: we can receive information about you from other sources, such as from your other accounts or other websites, including data brokers, our Partners, social media providers like Facebook and Twitter, advertising networks and analytics partners, and payment and delivery service providers.
By logging in to our mobile applications via Facebook or Twitter, or linking your account on our Website to your Facebook or Twitter accounts, you are giving us permission to obtain certain information and content from these accounts. The specific types of information that we may obtain depends on your settings for that account or website and will be subject to their privacy policies.
3. REASONS WHY WE COLLECT YOUR DATA
Our collection and processing of your personal data is based on our obligation to comply with all applicable laws and regulations. It is also based on the necessity to carry out the purchase contract with you, to provide you the website, app or other online services as requested by you or, if legally required, on your consent.
We may also rely on our legitimate interest in the completion of sales and in our commitment to offer you seamless after sales services and a personalized and highly qualitative treatment in the long term. In more detail we collect your data for the following purposes:
- To register and manage your account in our Website, we collect your name, email, password and other additional details you may wish to add in your account, like phone number, addresses and gender.
- To fulfil the orders you make through our website, we collect your Name, addresses, phone number, Order details, like the products you are buying, the size and price.
- To collect payment from you we collect your payment information, which comprises the credit/debit card’s number, holder’s name and CVV we do not store them and only transfer them to our authorized payment providers.
- To provide you with our customer services (including helping you to solve any issue you have with our services, updating you about any change to our terms of service, or contacting you to know how was your experience with us) we collect your name, email, password and addresses and your contact history with us (including phone records of our conversations.
- To monitor the quality of our customer services, we collect your name, email, password and addresses and your contact history with us.
- To administer, maintain and optimise our Website and our services, we collect your device information (such as your device IP address and device type), Cookie identifiers and browsing information.
- To perform fraud and credit checks and if we can do business with you, we collect your name; email; addresses; credit/debit card details; browsing history; purchase history; date of birth; gender; device information, any national identifiers and any publicly available information (like social media profiles or news)
- To send you marketing communications and personalised offers, we collect your Name; Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behavior; Device information; Shopping preferences; Cookie identifiers; Internal identifiers; Country.
- To provide you with personalised recommendations and enhance your experience, we collect your Name Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behaviour; Device Information; Shopping preferences; Nickname; Cookie identifiers; Internal identifiers; Country; Spent tier level and Wealth.
- Carry on research, analysis, enquiries and surveys on your use of our website, we collect your Name; Addresses; Email; Device information
- Advertising and retarget advertising of our and our Partners’ products and services, we collect your email, cookie identifiers and device information
- To produce aggregated statistical reports, we use your order history, provided that the result of such reports do not identify you
We consider that our products should entitle you to personalized client treatment and after-sales services that may last for a lifetime. For this purpose, and to ensure such services, we may need to keep your personal data for as long as it is needed for the provision of such services. In particular your personal data will be retained until your last use or purchase of our services or goods and normally for a period of up to 5 years thereafter, unless shorter or longer retention is required by applicable local law or where we have a legitimate and lawful purpose to do so.
5. DISCLOSURE OF DATA AND INFORMATION
To provide the Website and our services, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:
- our suppliers and third party service providers for business purposes: to function properly, we rely on a number of carefully selected third parties to provide us with products, services and the opportunity to present our items at special sales events. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products. Below you can find the types of third parties we use:
- Courier companies, that we use in order to deliver the products to you and, as such, they need to have access to your order information, including your name and address. These providers have a global outreach, with many local companies that can be engaged depending on your shipping address
- Payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. These are based in the European Union, United States and China and are engaged depending on your location
- Anti-fraud and credit check providers to keep us and you secure. They have access to and process your information and associated orders in order to check for any fraudulent behaviour
- Marketing Tools, Analytics and search engine providers that help us to deliver advertising and recommendations of products tailored to your interests and needs; carry out surveys regarding your use of our Website and Services. These providers are mostly based in Europe or in the United States.
- IT/technology providers that we use to support, maintain and provide our technology and IT infrastructure that supports our Website and the storage of your information
- advertisers for marketing purposes: we can provide your information to our advertising and social media partners (including Facebook and Twitter, where you choose) where they require the data to select and serve relevant adverts about our and our partners’ products and services to you and others
- to comply with legal requests: on occasion we may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process
- aggregated and anonymised information with third parties: we may aggregate your information with the information of other customers, creating a dataset of information about the usage of our Website, purchase of products, and other general, grouped information about our customers on the basis of our legitimate interest to understand the usage of our service and demand for our product. Although this dataset is aggregated and anonymised, meaning it cannot identify you as an individual, it provides a valuable insight into the use of our Website and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies to help measure traffic
You have the following rights in relation to the personal data we hold about you:
- A right of access and information: you have the right to be informed in a concise, transparent, intelligible and easily accessible form of the way in which your personal data is processed. You also have the right to obtain (i) confirmation as to whether or not personal data concerning you are being processed, and, where that is the case (ii) to access such personal data and obtain a copy thereof.
- A right to rectification: you have the right to obtain the rectification of your personal data. You also have the right to have incomplete personal data completed.
- A right to erasure: in some cases, you have the right to obtain the erasure of your personal data. However, this is not an absolute right and Valma may have legal or legitimate grounds for keeping such personal data.
- A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
- A right to data portability: you have the right to receive your personal data which you have provided to Valma, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from Valma. This right only applies when the processing of your Personal Data is based on your consent or on a contract and such processing is carried out by automated means.
- A right to object to processing: you have the right to object at any time to the processing of your personal data for marketing purposes.
To exercise the above rights please contact us at privacy@valma.li and communicate the following information: name, surname, e-mail or any other information necessary to confirm your identity in order for us to process the request (such as your postal address).
Finally, you have the right to lodge a complaint with a competent supervisory authority in case of breach of the applicable privacy laws and regulations, in particular the GDPR but also any other national or regional privacy laws applicable to you.If you have any questions or concerns about this Privacy Policy, please contact us at privacy@valma.li