Any personal information you provide to this Website that can be used to identify you is stored securely and confidentially and processed fairly and lawfully in accordance with this Privacy Policy and Articles 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This Website takes all appropriate technical and organisational measures to protect against unauthorised or unlawful processing of your personal information, including encryption of your information in accordance with applicable industry standards.
During your visit to the Website, we may collect certain personal information that is necessary for the delivery of your goods. This Website retains your information only for as long as necessary to process your order, process any applicable refunds, respond to any complaints / feedback, or provide you with information about promotions you have subscribed to.
When you register your details on the Website, you have the option to subscribe to future promotions and special offers. You can unsubscribe at any time by sending an email to the Owner.
This Website will not transfer your information outside the European Economic Area (“EEA”), unless you are a customer located outside the EEA, in which case it may be necessary to transfer your information in order to deliver your goods, process payments / refunds, or send you information about promotions you have subscribed to.
The Website may recognise previous users by using cookies. Cookies personalise your visits to the Website to suit your individual preferences. You can disable Cookies by adjusting your internet settings.
By providing your information to the Website, you acknowledge the risks associated with the Internet and agree that the Website may process your information in accordance with this Policy. You also agree not to hold any member of the Website liable for the loss of your information, unless they have breached their duty of care towards you.
If you have any questions regarding your Personal Data, the purposes for which it is processed and the parties with whom it is shared, or regarding this Privacy Policy in general, please contact the Owner.
Data Controller and Owner
Foliamo Ltd. – 20-22 Wenlock Road, London, England, N1 7GU
Owner’s contact email: [[email protected]](mailto:[email protected])
Types of Data Collected and How It Is Used
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website.
Unless otherwise specified, all Data requested by this Website is mandatory, and failure to provide such Data may make it impossible for the Website to provide its services. Where this Website specifically states that certain Data is not mandatory, Users are free not to provide such Data without any consequences for the availability or functioning of the Service.
Users who are unsure which Personal Data is mandatory may contact the Owner.
Any use of cookies – or other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service requested by the User, in addition to any other purposes described in this document and in the Cookie Policy, if applicable.
Users are responsible for any Personal Data of third parties obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.
The types of Data collected are as follows: first and last name, telephone number, full address (city, postcode, street, region) and email address. All collected Data is used by the Website to provide its services, such as processing your order, processing any applicable refunds, responding to any complaints / feedback, or providing you with information about promotions you have subscribed to.
The Data may also be used for the following purposes:
Marketing or promotions via email, SMS, Viber and other similar chat service providers, remarketing and behavioural targeting, direct mail and other promotional activities.
Contacting the User by telephone and email regarding confirmation of details, delivery of goods, requests for information, quotations, complaints, warranties and returns.
Analytics carried out using analytics software used by this Website to analyse data, enable the Owner to monitor and analyse web traffic, monitor User behaviour, track and examine use of this Website and prepare reports on its activities.
Methods and Place of Data Processing
Methods of Processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, alteration or unauthorised destruction of the Data.
Data processing is carried out using computers and/or IT-enabled tools, following organisational procedures and methods strictly related to the purposes indicated. In addition to the Owner, in some cases the Data may be accessible to certain types of responsible persons involved in the operation of this Website (administration, sales, marketing, legal matters, system administration) or external parties (such as third-party technical service providers, mail service providers, hosting providers, IT companies and communication agencies) appointed by the Owner, where necessary, as Data Processors. An updated list of these parties may be requested from the Owner at any time.
Legal Basis for Processing
The Owner may process Personal Data relating to Users where one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some laws, the Owner may be permitted to process Personal Data until the User objects to such processing (“opting out”), without having to rely on consent or any other of the legal bases below. However, this does not apply where the processing of Personal Data is subject to European data protection law;
- the provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will be happy to help clarify the specific legal basis that applies to the processing and, in particular, whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner’s operating offices and at any other locations where the parties involved in the processing are located.
Depending on the User’s location, the transfer of Data may involve transferring the User’s Data to a country other than their own. To learn more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users also have the right to learn about the legal basis for transferring Data to a country outside the European Union or to any international organisation governed by international public law or established by two or more countries, such as the United Nations, as well as about the security measures taken by the Owner to protect their Data.
If such a transfer takes place, Users can learn more by checking the relevant sections of this document or by contacting the Owner using the information provided in the contact section.
Data Retention Period
Personal Data is processed and stored for as long as required by the purpose for which it was collected.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained for as long as necessary to fulfil those purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be permitted to retain Personal Data for a longer period when the User has given consent to such processing, provided that such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period where required to comply with a legal obligation or by order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the rights to access, erasure, rectification and data portability cannot be enforced after the retention period has expired.
Users’ Rights
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw their consent where they have previously given consent to the processing of their Personal Data. Users may exercise this right by sending an email to the Owner.
- Object to the processing of their Data. Users have the right to object to the processing of their Data where the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. Users may exercise this right by sending an email to the Owner.
- Access their Data. Users have the right to learn whether their Data is being processed by the Owner, obtain information regarding certain aspects of the processing and receive a copy of the Data undergoing processing. Users may exercise this right by sending an email to the Owner.
- Verify and request rectification. Users have the right to verify the accuracy of their Data and request that it be updated or corrected. Users may exercise this right by sending an email to the Owner.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. Users may exercise this right by sending an email to the Owner.
- Have their Personal Data erased or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner. Users may exercise this right by sending an email to the Owner.
- Receive their Data and transfer it to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred to another controller without hindrance. This provision applies where the Data is processed by automated means and where the processing is based on the User’s consent, a contract to which the User is a party, or pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before the competent data protection authority.
Details Regarding the Right to Object to Processing
Where Personal Data is processed in the public interest, in the exercise of official authority vested in the Owner, or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing grounds relating to their particular situation to justify the objection.
Users should, however, be aware that where their Personal Data is processed for direct marketing purposes, they may object to such processing at any time without having to provide any justification. To determine whether the Owner processes Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to Exercise These Rights
All requests to exercise User rights should be sent to the Owner using the contact details provided in this document. These requests are free of charge and will be addressed by the Owner as soon as possible and in all cases within one month.
Cookie Policy
This Website uses Cookies.
Cookies consist of pieces of code installed in the browser that assist the Owner in providing the Service in accordance with the purposes described. Some of the purposes for which Cookies are installed may also require the User’s consent.
Where the installation of Cookies is based on consent, such consent may be freely withdrawn at any time by following the instructions provided in this document.
Technical Cookies and Cookies Serving Aggregated Statistical Purposes
- Activity Strictly Necessary for the Operation of the Service
This Website uses Cookies to maintain the User’s session and carry out other activities that are strictly necessary for the operation of the Website, such as in relation to traffic distribution.
- Preference Saving, Optimisation and Statistics
This Website uses Cookies to save browsing preferences and optimise the User’s browsing experience. These Cookies include, for example, those used to determine language and currency preferences or to manage first-party statistical data used directly by the Owner of the Website.
How to Provide or Withdraw Consent to the Installation of Cookies
In addition to the information provided in this document, the User can manage Cookie preferences directly through their own browser and prevent, for example, third parties from installing Cookies.
Browser settings can also be used to delete Cookies that have previously been installed, including Cookies that may have stored the original consent to install Cookies from this Website.
Users can, for example, find information on how to manage Cookies in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer.
With regard to Cookies installed by third parties, Users can manage their preferences and withdraw their consent by clicking the relevant opt-out link (if provided), using the tools made available in the third party’s Privacy Policy, or by contacting the third party directly.
Notwithstanding the above, the Owner points out that Users can follow the instructions provided by the initiatives linked to EDAA (EU), Network Advertising Initiative (USA), Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to manage their tracking preferences for most advertising tools. The Owner therefore recommends that Users make use of these resources in addition to the information provided in this document.
Data Controller and Owner
Foliamo Ltd. – 20-22 Wenlock Road, London, England, N1 7GU
Owner’s contact email: [[email protected]](mailto:[email protected])
As the installation of third-party Cookies and other tracking systems through the services used on this Website cannot be technically controlled by the Owner, all specific references to Cookies and tracking systems installed by third parties are provided for guidance purposes only. For complete information, Users are kindly requested to consult the Privacy Policy for the relevant third-party services listed in this document.
Given the objective complexity involved in identifying Cookie-based technologies, Users are encouraged to contact the Owner if they wish to receive further information about the use of Cookies by this Website.
Additional Information About Data Collection and Processing
Legal Proceedings
The User’s Personal Data may be used for legal purposes by the Owner in court or during the stages leading to possible legal proceedings arising from improper use of this Website or its related Services.
The User acknowledges that the Owner may be required to disclose Personal Data upon request from public authorities.
Additional Information About the User’s Personal Data
In addition to the information contained in this Privacy Policy, this Website may provide the User with additional and contextual information regarding specific Services or the collection and processing of Personal Data upon request.
System Logs and Maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interactions with this Website (System Logs) or use other Personal Data (such as the IP address) for this purpose.
Information Not Contained in This Policy
Further details regarding the collection or processing of Personal Data may be requested from the Owner at any time. Please refer to the contact information provided at the beginning of this document.
How “Do Not Track” Requests Are Handled
This Website does not support “Do Not Track” requests.
To determine whether any third-party services used by the Website honour “Do Not Track” requests, please refer to their Privacy Policies.
Changes to This Privacy Policy
The Owner reserves the right to amend this Privacy Policy at any time by notifying its Users on this page and, where possible, within this Website and/or – to the extent technically and legally feasible – by sending a notification to Users using any contact information available to the Owner. Users are strongly encouraged to check this page frequently, taking note of the date of the latest modification shown at the bottom.
If changes affect processing activities carried out on the basis of the User’s consent, the Owner shall obtain new consent from the User where required.
Definitions and Legal References
Personal Data (or Data)
Any information that directly, indirectly or in connection with other information – including a personal identification number – allows the identification of a natural person.
Usage Data
Information collected automatically through this Website (or third-party services used by this Website), which may include: the IP addresses or domain names of the computers used by Users accessing this Website, URI addresses (Uniform Resource Identifier), the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server response (successful result, error, etc.), the country of origin, browser characteristics and the operating system used by the User, the various time details for each visit (such as the time spent on each page within the Application), as well as details regarding the path followed within the Application, with particular reference to the sequence of pages visited, and other parameters relating to the device’s operating system and/or the User’s IT environment.
User
The individual using this Website who, unless otherwise specified, is the same as the Data Subject.
Data Subject
The natural person to whom the Personal Data relates.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body that processes Personal Data on behalf of the Controller, as described in this Privacy Policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body that, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures relating to the operation and use of this Website. Unless otherwise specified, the Data Controller is the Owner of this Website.
This Website (or this Application)
The means by which the User’s Personal Data is collected and processed.
Service
The service provided by this Website, as described in the relevant terms and conditions (if any) and on this Website/Application.
European Union (or EU)
Unless otherwise specified, all references to the European Union in this document include all current Member States of the European Union and the European Economic Area.
Legal Information
This privacy statement has been prepared based on the provisions of various laws, including Articles 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This Privacy Policy applies solely to this Website, unless otherwise stated within this document.
Last updated: 9 May 2018.