1. Personal Data We Collect
We also may collect certain other information when you access the Product(s) Text or Images, such as: the type of browser you are using; the URL that referred you to our Product(s) Text or Images; the type of operating system you are using; the IP address or other unique identifier such as a Device Identifier (defined below) of any of your computer(s) or device(s) that are used to access the Product(s) Text or Images; your Device characteristics and certain Device data; the name of your Internet Product(s) Text or Images provider or mobile carrier; all the areas within our Product(s) Text or Images that you visit and your activities there; referring/exit pages; date/time stamp; clickstream data; web beacons; precise geolocation information (with your consent, where required) and information about your interests in and use of various products, programs, and Product(s) Text or Images (collectively described as “Usage Information,” described in greater detail in Section 2(e) below). If you log in via a social media platform, see Section 4 regarding additional information that may be collected. In addition, when you visit the Product(s) Text or Images our servers automatically collect information describing your use of the Product(s) Text or Images, including but not limited to content accessed by you, page/screen visits, length of time viewing a certain page or program, how the content is viewed, etc.
We may on occasion combine your personal data we collect with additional records (including those of our analytics vendors and affiliated companies) to enhance our ability to market to you those products, features, or Product(s) Text or Images that may be of interest to you, to assist us in providing, personalizing and improving our Product(s) Text or Images and other offerings, and for research purposes. Example If you bought this you may like this additional item.
2. How Do We Use the Personal Data Collected
1. To Enable and Improve Access to the Product(s) Text or Images.
In accordance with applicable laws, we may use or share the information you provide about yourself with our vendors, affiliates, partners and distributors to verify your eligibility to access the Product(s) Text or Images, fulfill your requests for our products, programs, and Product(s) Text or Images, to customize your use of the Product(s) Text or Images based on your viewing patterns and areas of interest, verify the status of your account, for analytics, and to provide you with information regarding changes or updates to the Product(s) Text or Images, newsletters, and special offers and promotions.
The information we collect in connection with our online, mobile and in future potential video forums and communities is used to provide an interactive experience. We use this information to facilitate participation in these online forums and communities and, from time to time, to offer you products, programs and Product(s) Text or Images.
If you choose to submit content for publication, we may publish your screen name and other information you have provided to us on the Product(s) Text or Images, on the Internet, or elsewhere. We also may access content posted about our programs and Product(s) Text or Images on various online platforms (such as Twitter hash tags) and post them on our site.
2. To Assist Third Parties Acting on Our Behalf.
We may use vendors to perform certain Product(s) Text or Images on behalf of us, such as hosting the site or application, fulfilling your orders of products and/or Product(s) Text or Images, designing and/or operating the Product(s) Text or Images’s features, tracking the Product(s) Text or Images’s activities and analytics, and enabling ROMANCE BRANDS to send you special offers or performing other administrative Product(s) Text or Images. We may provide these vendors with access to user information, including Device Identifiers and personal data, to carry out the Product(s) Text or Images they are performing for you or for us.
We may use analytics vendors for purposes such as to evaluate and provide us with information about the Product(s) Text or Images and viewing of our content (for more details see also Section (e)). These vendors may set and access their own Tracking Technologies (defined below) on your Device and they may otherwise collect or have access to information about you. Please recognize that ROMANCE BRANDS and/or its vendors (such as mailing houses or customer Product(s) Text or Images vendors) may store this information, and may share this information with third parties as necessary solely to process your transactions and provide access to the Product(s) Text or Images by you. ROMANCE BRANDS may also use this information for internal review and analysis of the Product(s) Text or Images, the customer Product(s) Text or Images process, and consumer comments.
3. To Communicate With You.
We sometimes use this information to communicate with you, such as to notify you when you have won one of our contests, or when we make changes to our user agreements, to provide you with newsletters, promotional information about ROMANCE BRANDS and/or the Product(s) Text or Images, in connection with incentive programs, rewards and consumer engagement activities, to respond to your inquiries about our offerings and provide customer Product(s) Text or Images assistance, to confirm transactions, to offer you other products, programs or Product(s) Text or Images that we believe may be of interest to you, or to contact you about changes to the Product(s) Text or Images or other system requirements, your account, or any customer Product(s) Text or Images requests submitted by you.
4. To Improve the Product(s) Text or Images.
We sometimes use the information that we collect to improve the design and content of our Product(s) Text or Images and to enable us to personalize your experience in using our Product(s) Text or Images. We also may use this information to analyze usage of the Product(s) Text or Images in the aggregate, to provide user ratings and other information to email subscribers generally, to offer you products, programs, or Product(s) Text or Images that we think you might enjoy, and to better assist with customer Product(s) Text or Images.
5. Cookies and Usage Data Collected as You Access and Use the Product(s) Text or Images.
In addition to any personal data or other information that you choose to submit to the Product(s) Text or Images, we and our vendors may use a variety of technologies that automatically or passively collect certain Usage Information whenever you visit or interact with the Product(s) Text or Images, which technologies may be downloaded to your Device (defined below) and may set or modify settings on your Device. We also may collect precise geolocation in real time from your Device with your consent where required. We may use Usage Information for a variety of purposes, including to assess, enhance or otherwise improve the Product(s) Text or Images or our activities in connection with it, for analytics or for marketing purposes. In addition, we may collect your IP address or other identifier (“Device Identifier”) for your computer or other device used to access the Product(s) Text or Images (any, a “Device”). We will only do so in accordance with applicable data protection laws.
A Device Identifier is an identifier that is automatically assigned to your Device used to access the Product(s) Text or Images, and our computers identify your Device by its Device Identifier. We may access and use Device Identifiers that have already been associated with your device.
We may use various new and hereafter developed technologies to collect Device Identifiers, Usage Information and demographic information about you (“Tracking Technologies”). A few of the methods that may be used to collect Usage Information include, without limitation, the following (and subsequent technology and methods hereafter developed):
A browser cookie is a data file placed on a Device when it is used to visit the Product(s) Text or Images. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to and activities in connection with the Product(s) Text or Images. The Product(s) Text or Images also may use locally stored objects to provide certain content, such as video on demand, video clips, or animation. Adobe's Flash player and similar applications use this technology to remember settings, preferences, and usage similar to browser cookies. Most cookies may be disabled or removed or blocked using tools and settings on commercial browsers. However, some cookies, such as Flash cookies or HTML5 cookies, may not be disabled through your browser. For information on disabling Flash cookies, go to Adobe’s website at www.adobe.com. Please be aware that if you disable or remove cookies some parts of our Product(s) Text or Images may not work and that when you revisit our Product(s) Text or Images, your ability to limit cookies is subject to your browser settings and limitations.
6. Additional Uses.
ROMANCE BRANDS may on occasion combine your information we collect with additional records (such as publicly available information, including on social media sites, and those of our analytics vendors and affiliated companies) to enhance our ability to market to you those products, features, or Product(s) Text or Images that may be of interest to you, for analytics purposes, and to assist us in providing, personalizing and improving our Product(s) Text or Images and other offerings.
ROMANCE BRANDS has not implemented a response to browser-based Do Not Track signals. Because of the current lack of consensus with respect to the Do Not Track standard from both a compliance perspective and a technical perspective, we have not yet determined how or if we would implement a response to Do Not Track signals; we will continue to evaluate in the event a uniform standard is adopted.
3. When We Share Your Personal Data
1. Administrative and Legal Reasons.
2. Sale of Assets or Change of Control.
In the event of a sale of assets or change in ownership, we may transfer such information to a successor of ROMANCE BRANDS or any person or entity that acquires ownership or control of ROMANCE BRANDS or the Product(s) Text or Images via any means.
3. For Affiliate Use.
ROMANCE BRANDS is a Open Management Ltd company, and as such, has affiliate sibling companies and third party partners. In accordance with applicable law, we may share your personal data with our affiliates and/or third party partners to identify products and Product(s) Text or Images that may be of interest to you, for research, analysis and to assist in the improvement of our Product(s) Text or Images or those of our affiliates and/or third party partners, and in connection with promotions conducted by us, by our affiliates or by our third party partners, or jointly. Below is a list of some of the Open Management Ltd companies that are affiliated with ROMANCE BRANDS and with whom we may share information we collect at our sites. In the event we will be sharing your personal data with any of our third party partners for this purpose, this will be made clear to you at the point of data collection.
Open Management Ltd
Distribution companies to enable delivery of your order or orders.
4. Co-Branded Opportunities.
We sometimes may offer content (e.g., contests, sweepstakes, or promotions) that is sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties may obtain personal data that visitors voluntarily submit as a result of participation in such content or activities. We have no control over these parties' use of this information. We will notify you at the time your personal data is requested whether such information will be shared with these parties.
4. Social Networks and Personal Data Sharing
5. Collection of Personal Data by Third Parties
We only have access to your email address, and delivery details. These details will be shared with delivery companies to facilitate the delivery of your order or deal with customer Product(s) Text or Images questions. We are not liable for how these distribution companies, treat your details. We can provide contact details for the delivery company used for your delivery.
6. Storage and Security
We and/or our vendors (such as mailing houses, customer Product(s) Text or Images vendors or cloud Product(s) Text or Images) may store your information. When we store your information, we do so for as long as necessary to (i) fulfill the specific purposes for which your personal data was collected and (ii) comply with our legal obligations or enforce our legal rights.
We take information security seriously and use reasonable physical, electronic, and managerial procedures to help prevent unauthorized access, maintain data security, and correctly use the information we collect online. For example, ROMANCE BRANDS and its vendors secure any financial information, including credit card numbers, with encryption technologies to PCI Level 1 compliance. We incorporate commercially reasonable safeguards to help protect and secure your personal data.
7. What Legal Basis We Rely On To Process Your Data
On some occasions, ROMANCE BRANDS processes your data with your consent. For example, we rely on your consent for third parties to market their products and services to you.
On other occasions, ROMANCE BRANDS processes your data when we need to do this to fulfil a contract with you, such as to complete transactions with you, or where we are required to do this by law, such as when we receive a law enforcement request.
ROMANCE BRANDS also processes your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, ROMANCE BRANDS has a legitimate interest in ensuring the security and integrity of our Product(s) Text or Images and in ensuring that our websites and apps operate effectively.
8. How You can Access or Correct Personal Data, or Opt Out
You can access much of the personal data that you have provided to the Product(s) Text or Images online, or correct factual errors in such information, by contacting us at the email address provided on the website or by following the instructions provided at the time you sign up to the Product(s) Text or Images.
To help protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections or deletions to any personal data.
If at any time you wish to stop receiving promotional materials related to the Product(s) Text or Images, we will provide an unsubscribe link at the bottom of each promotional e-mail you receive. In most cases, you can also log in to your account to opt out of newsletters and other promotional e-mails. Please keep in mind that opting out of promotional e-mails will not prevent you from receiving transactional e-mail correspondence related to, without limitation: the Product(s) Text or Images, your profile, and/or account.
In some instances, certain information or Product(s) Text or Images can be provided to you only if personal data is provided. If you elect not to provide such information, you may not be able to access certain content or information.
You may ask ROMANCE BRANDS for a copy of your information, to correct it, erase it or to transfer it to other organizations at your request. You also have rights to object to some processing and, where we have asked for your consent to process your data, to withdraw this consent. Where we process your data because we have a legitimate interest in doing so, you also have a right to object to this. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement or compelling interest to process your data.
Should you wish to exercise these rights, please contact us at the address indicated in Section 9 below. We hope that we can satisfy queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities.
9. How to Contact Us
10. Data Transfer to the United States
ROMANCE BRANDS is located in the United States, which has different data protection standards than those that apply in the European Economic Area (EAA). You consent to transfer your personal data to ROMANCE BRANDS and/or its TW affiliates (as such term is defined in Section 3c).
Effective Date 30/05/2018