Updated May 24th, 2018
Webgenix Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
What data we collect about you, for what purpose and on what ground we process it
Personal data means any information capable of identifying an individual. It does not include anonymized data. We may process the following categories of personal data about you:
- Identity and Contact Data that includes your title, first name, last name, username and login details, email address and telephone number. If you interact with us through social media, this may include your social media username. We process identity and contact data for the purposes of communicating with you, processing your orders, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, the performance of a contract between you and us, to keep records and to establish, pursue or defend legal claims.
- Order Data that includes your billing address, shipping address and details of products or services you have purchased from us. In addition, we collect transaction data that including details about payments to and from you, such as your masked card number (first 6 digits and last 4 digits), the time of the transaction, and your PayPal account email address. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User Data that includes data you post on our website such as product reviews and forum posts that we publish to our website as you request us to. We process this data to operate our website and to ensure relevant content is provided to you and our visitors. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical Data that includes data about your use of our website such as your IP address, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. We use this data to administer our website, to protect our business from malicious activity (such as credit card fraud and spam), to understand the effectiveness of our marketing and to deliver relevant content to you. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
- Marketing and Communications Data that includes your preferences in receiving direct marketing from us through our email service providers and your communication preferences. We process this data to enable you to partake in our promotions and special offers, to notify you of new products, to deliver relevant content and advertisements to you and to measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use the data above to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is consent or legitimate interests which is to grow our business. For more details, see the Marketing Communication section.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We may process your personal data without your knowledge or consent only where this is required or permitted by law. However, we will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We do not collect any sensitive data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.
Data Collected in Aggregate
Some of the above data, as well as other analytics and order data, is collected in aggregate. We may use aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. An example of aggregated data is the number of customers in California who ordered a rubber sheet in a single month.
How we collect your personal data
We use different ways of collecting data from and about you including through:
Direct interactions You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or through chat or social media.
This includes personal data you provide when you:
- Send us an email
- Register with our website
- Sign-up to our newsletter
- Place an order from our website
- Contact our customer service team
- Submit a product review
- Engage with us in social media
- Enter a competition, promotion or survey
Automated interactions As you interact with us, including via our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We may also collect tracking data when you use our website, or when you click on one of our adverts (including those shown on third party websites).
Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:
- Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
- Contact, Financial and Transaction Data from providers of payment and fraud prevention services;
- Identity and Contact Data from service providers; and
- Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
We will not share your personal data with any third party for their own marketing purposes, but if this changes we will get your express consent.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchase data.
Disclosures of your Personal Data
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services, such as:
- website hosting providers who host our web servers and database servers
- our customer support software that we use for customer service emails
- our email provider that we use to send, receive and store our company emails
- our email marketing company that we use to send bulk emails
- payment processors to process your payment
- fraud detection companies that we use to prevent e-commerce fraud
- Logistical partners who provide fulfillment and shipping of orders placed on our website, including US and non-US shipping centers and carriers such as USPS, FedEx, and UPS.
- Professional advisers of our company including subcontracted coaches that help us assist our customers, lawyers, bankers, auditors, and insurers
- Government bodies that require us to report processing activities.
- Third parties to whom we may sell, transfer or merge parts of our business or our assets
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes only and in accordance with our instructions.
For EU customers, we are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
- We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
- Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data (such as to ship your order). They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
In some circumstances, we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Data Protection rights under GDPR
If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:
- The right of access – that’s a right to make what’s known as a ‘data subject access request’ for a copy of the personal data we hold about you;
- The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
- The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
- The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
- The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
- The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
- Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
Third Party Links
This website may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
We cookies and similar tracking technologies with 3rd party services such as Google Analytics. We require these services to anonymize their data where possible so that you cannot be identified from the data they hold about your use of our website.
Our full details are:
- Full name of legal entity: Webgenix Ltd
- Email address: email@example.com
- HQ postal address: Webgenix, PO Box 44, Balzan, BZN 1000, Malta, Europe