LAST UPDATED: October 2020
YOLOSTRATEGY SRL is the controller for the purposes of the General Data Protection Regulation (the “GDPR”) a company registered in Romania, and our registered office is located in Sibiu, Str. Oncesti, Nr. 15 Ap.20 550305. We are registered under number J32/687/15.05.2017 with identification number 37578900, and with managing director: Landiana Cerciu, phone number 0040743102331, firstname.lastname@example.org
WHAT INFORMATION DO WE COLLECT, AND HOW?
When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:
you may give us information about yourself if you sign up for an account on our Website or place an order for products, opt in to receive our newsletters and special offers, 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).
We supplement the data you provide to us with data from data append services such as public or social graph data in order to better serve you with content or promotions. We will append this data to our existing customer account information to better understand customers’ interests and to provide more relevant product recommendations and advertising, to increase our customer’s security when using our Website and to comply with our legal obligations, such as sanctions laws. This information may include household size, household income, or profession. This information can be associated with your personal information such as name, email, address, physical address or phone number.
Information our IT systems collect about you: each time you visit the Website, certain information will be created and automatically recorded by our IT systems. That information includes:
WHAT DO YOU USE MY INFORMATION FOR?
To provide you services and the Website, including to allow you to order and receive products using our Website and to optimize your experience we need to use the information that we collect in a number of different ways.
We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications or when you have made a purchase using our services, we will use your personal information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information to tailor these messages to you. You may unsubscribe from our email marketing communications by following the opt out instructions in the promotional emails that are sent to you.
We also carry out research, analysis, and surveys on your use of our Website, and views. We keep tracking of your spend on our Website. Finally, we use your information to confirm your identity and perform credit checks or anti-fraud checks, in order to ensure your, and our financial security. Please scroll down to find out the detailed purposes for which we collect your information, what specific information is collected and the legal basis for which we purpose that data.
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. The legal basis is the performance of the Agreement made with you.
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. The legal basis is the performance of the Agreement made with you.
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. The legal basis is the performance of the Agreement made with you.
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. The legal basis is the performance of the Agreement made with you and our legitimate interests in retaining you as a customer.
To monitor the quality of our customer services, we collect your name, email, password and addresses and your contact history with us. The legal basis is the legitimate interests in running our business.
To administer, maintain and optimize our Website and our services, we collect your device information (such as your device IP address and device type), Cookie identifiers and browsing information. The legal basis is the legitimate interests in running our business.
To send you marketing communications and personalized 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. The legal basis is the legitimate interests to electronic direct marketing of similar products and services to that which you have acquired using our Website or, when such is not applicable, your Consent.
To provide you with personalized recommendations and enhance your experience, 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; Spent tier level and Wealth. The legal basis is our legitimate interests in running our business and improve our Website and your experience.
Carry on research, analysis, enquiries and surveys on your use of our website, we collect your Name; Addresses; Email; Device information, legal basis is our legitimate interests in running our business and improve our Website and your experience.
Advertising and retarget advertising of our and our Partners’ products and services, we collect your email, cookie identifiers and device information. The legal basis is our legitimate interests in running our business.
To produce aggregated statistical reports, we use your order history, provided that the result of such reports do not identify you. The legal basis is our legitimate interests in running our business and improve our Website.
WHO DO YOU SHARE MY INFORMATION WITH?
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:
Third party service providers for business purposes: to function properly, we rely on a number of carefully selected third parties to provide us with services and products. 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.
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 behavior.
Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimization of the website. These providers are based in in Europe.
Marketing Tools providers that help us to enable our marketing.
Performance Marketing and Recommendations Providers that help us deliver advertising and recommendations of Apoldist products tailored to your interests and needs.
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.
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. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands;
Advertisers for marketing purposes: we can provide your information to our advertising and social media partners (including Facebook and Instagram, where you choose) where they require the data to select and serve relevant adverts about our products and services to you and others;
Aggregated 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 anonymized, 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, our Partners and other providers to allow them to better stock products.
We use technology such as "cookies" to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.
We use the following categories of cookies on our Website:
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 your 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, color 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 anonymized 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 personalized 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 Instagram. 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.
You can withdraw your consent to these cookies at any time through the following options:
• Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;
• other third party cookies relating to behavioral 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.
Keeping you and your personal information secure is very important to us. We take a number of reasonable steps to try to protect the personal information that you provide, including:
- requiring you to establish a unique username and password to access your account on our Website
- not keeping details of your credit or debit card that would enable any third party to transact using that credit or debit card (such as your CVV number); and
- regularly monitoring our servers and IT systems for possible vulnerabilities and attacks. Unfortunately, despite this, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal data transmitted to or through our Website, and any such transmission is at your own risk. In particular, please keep in mind that if you voluntarily disclose personal information through other means of communication than the Website in a non-protected environment (such as through email, sms, online messages) then that information can be collected and used by others outside of our or your control.
WHAT ARE MY PRIVACY RIGHTS?
You have certain rights in relation to the personal data we hold about you, which we detail below. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights.
You may request that we erase the personal data we hold about you in the certain circumstances. Please scroll down to know what those are:
you believe that it is no longer necessary for us to hold the personal data we hold about you;
we are processing the personal data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the personal data;
we are processing the personal data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such personal data;
you no longer wish us to use the personal data we hold about you in order to send you promotions and special offers;
you believe the personal data we hold about you is being unlawfully processed by us.
Also note that you may exercise your right to restrict our processing the data whilst we consider your request as described below.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note, however, that we may retain the personal data if there are valid grounds under law for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case.
Where you have requested that we erase data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the data or providing links to the data to erase the data too.
Restriction of Processing to Storage Only. You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defense of legal claims or for another’s protection).
Please scroll down to know the cases where you may request we stop processing and just store the personal data we hold about you.
you believe the personal data is not accurate for the period it takes for us to verify your claim;
we wish to erase the personal data as the processing we are doing is unlawful but you want us to retain the personal data for storage but not further process it;
we wish to erase the personal data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defense of legal claims; or
you have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.
You also have the right to object to our processing of data about you and we will consider your request in other circumstances as detailed below:
We are processing the data we hold about you (including where the processing is profiling) on the basis of our or a third party’s legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the data whilst we make the assessment on an overriding interest;
Withdrawal of Consent: You can withdraw your consent at any time by unsubscribing at the bottom of each email received or by writing emailing us as set out below.
• by emailing us at email@example.com; or
• by writing to the following address: Str. Oncesti, Nr. 15 Ap. 20 Sibiu, Romania 550305
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.
UPDATES TO THIS POLICY
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: Str. Oncesti, Nr. 15 Ap. 20 Sibiu, Romania 550305