Date: January 2020
1.1. Crowd Media B.V., organised under the laws of the Netherlands, having its place of business at Piet Heinkade 95B, 1019 GM, Amsterdam, registered with the Chamber of Commerce in Amsterdam under number 68741839, (herein referred to as the “data controller”, “we,”, “us” or “our”) provides and makes available certain websites, including, without limitation, www.thelondonlabs.com (collectively, the “Site”), pursuant to which we offer hair care advice and tips on trends and practices (the “Company Services”), as well as making available London Labs’ unique hair care products for purchase (the “Products”) to our Site visitors (“you”, “your”).
1.5. In case any Personal Data you provided us with will be identified as being “Sensitive Data” (such as, but not limited to, information with respect to your racial or ethnic origin, political opinion, sexual preference or religion), we will ask your explicit consent for the use of such Personal Data in case such is legally required.
2. PERSONAL DATA WE COLLECT
When you interact with us through the Site, we may collect Personal Data and other information from you, as further described below:
2.1. Personal Data that you provide
When you purchase Products on our Site, you will provide us, at least, with your name, shipping address, email address and, depending on the selected payment method, with other Personal Data such as your bank account or credit card details. Additionally, you may also provide us with, without limitation, your birth date, (mobile) phone number, likes, dislikes or any other information you voluntarily share with us. Furthermore, we will need your Personal Data in case we are in postal, phone or electronic mail contact with you (for example because of a refund you are requesting).
Also, when you create an account with us, we will keep your first and last name and email address as well as your home address, phone number, shipping address, billing address, banking details, order history and wish list. We will store the data in your account for as long as you are a customer. In case you did not use your account for 7 years all data will be deleted. You can delete your account at any time, however, we may need to keep certain Personal Data to comply with legal obligations to which we are subject.
2.2. Browsing information
2.3. Aggregated Personal Data
In an ongoing effort to better understand and serve the users of our Services, we often conduct research on our customer demographics, interests and behaviour based on the Personal Data and other information provided to us. This research may be compiled and analysed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
3. OUR USE OF YOUR PERSONAL DATA
3.2. We collect and use your Personal Data for the purposes set out below:
- a) For the performance of our agreement with you:
- Provision of the Services you requested and delivery of the Products purchased;
- Provision, billing and performance of our Site and our services contained therein/available through it;
- Provide you with an account;
- Provide customer support; and
- Ensuring the technical functioning of our Site, our services contained therein/available through it and our network responsible for allowing us to provide our services to you.
- b) To comply with a legal obligation to which we are subject:
- Any information referred to above in section 2 may be used to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.
- c) For our legitimate commercial interests:
- Developing new Services, such based on your use of our Services;
- Auditing, research and (statistical) analysis in order to maintain, protect and improve our Site and our Services contained therein/available through it;
- Advertising and marketing of our Services;
- We will use your Personal Data for direct marketing purposes. In this context, from time to time, we will send you an email in which we will inform you about our Service. At any time and in accordance with your rights described in this Policy, you will find instructions permitting you to “opt-out” of receiving future communications to stop any further direct marketing messages;
- If you subscribe to our newsletter, we will send it to you via email, in order to inform you regularly about our offers, events, articles etc.
- Protecting our (intellectual) property rights (including content that has been licensed to us) or other property of our users (e.g. your Personal Data);
- In order to be able to create and update a personal profile of you, we may combine all your Personal Data we have collected from you; and
- The Personal Data referred to above in section 2 may also be used by us:
- to generate aggregated statistics about the users of our Products and Services;
- to assist in security and fraud prevention;
- for system integrity purposes (preventing hacking, cheats, spamming, etc.);
- to facilitate our business operations, to operate company policies and procedures;
- to enable us to merge, sell, acquire, or transfer assets; and
- for other legitimate business purposes permitted by applicable law.
4. DISCLOSURE OF YOUR PERSONAL DATA AND OTHER INFORMATION
- Corporate Transaction
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, re-organisation, dissolution, bankruptcy or similar event, Personal Data may be part of the transferred assets.
- Service Providers
We may engage third party vendors, suppliers, agents, service providers, and affiliated entities to provide services to us, such as shipping, fulfilment or billing services and support. In providing their services, they may access, receive, maintain or otherwise process personal data on our behalf. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your personal data and only process it in accordance with our instructions. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
- Third parties in case of legal requirement
We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or our property, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
7. INTEGRATION OF THIRD-PARTY CONTENT
7.1. Third Party Sites
7.2. Social Media Services
Protecting your Personal Data is important to us. We use industry standard technology to protect your Personal Data. We will take reasonable steps to ensure that your personal data are properly secured using appropriate technical, physical, and organisational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss. Unfortunately, no data transmission over the Internet and via mobile communications networks can be guaranteed to be 100% secure. As a result thereof, while we are committed to protecting your Personal Data, we cannot ensure or warrant the security of any information you transmit to or through us.
9. DATA TRANSFER
Your Personal Data may be transferred to -and maintained on- computers located outside of your state, province, country or governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Where we are legally required to do so, we have legally acceptable mechanisms in place that ensure an adequate level of protection for the transfers of Personal Data to parties outside your jurisdiction. For example, for data transfers from EU/EEA to countries outside this region, we have European Commission-approved Standard Contractual Clauses or similar safeguards in place, allowing such data transfers.
10. YOUR RIGHTS IN REGARD TO YOUR PERSONAL DATA
10.1. In the following you will find a list with all individual rights you have in regard to the Personal Data we hold about you:
- Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). Please note that you might need to send us a copy of your passport ID or any other legal document that may verify your identity, too; this verification procedure is necessary in order to protect your Personal Data from unauthorised access through any other person.
- Your right to rectification
You are entitled to request to have it rectified, if the personal information we hold about you is inaccurate or incomplete, by sending us an email in the contact details at section 11. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to erasure
In certain circumstances you can ask us to delete or remove your personal information such as where we no longer need it or if you withdraw your consent (where applicable), provided there is no overriding legitimate interest for continuing the processing. If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to restrict processing
In certain circumstances you can ask us to ‘block’ or suppress the processing of your personal information, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to data portability
In certain circumstances you have the right, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format such as Microsoft Excel) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
- Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are:
- relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal information for direct marketing purposes.
- Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
10.2. Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process.
10.5. You have, at any time moving forward and in any case, the right to lodge a complaint with your
respective applicable (local and/or national) data protection authority if you think that we have violated your rights and/or are not in compliance with any applicable Personal Data protection regulation.
10.6. In regard to any respective request as described above that you may place, we have one month from the date of your request to fulfil said request.
12. OUR CONTACT INFORMATION
For questions regarding your privacy please send an e-mail to: privacy[at]crowdmedia.com.
For general inquiries or complaints please contact us at email@example.com.