PRIVACY POLICY
Last update November 16, 2020
Laurien Testaert and her company ("SCRUBBY™"), "we", "us", "our") are committed to protecting your privacy rights and ensuring that your personal information is protected. This Privacy Policy explains our use of your personal information when you use our websites (the "Sites") and/or interact with us through social media or advertisements and content on third-party websites.
The relevant Laurien Testaert entity responsible for your personal data is the Laurien Testaert entity to which you have provided your personal data; however, as we may share your personal data within our group, other Laurien Testaert entities may also use your personal data in accordance with this Privacy Policy.
For more information on the Laurien Testaert entities acting as data controllers of your personal data, please refer to the list of data controllers section below.
COLLECTION OF INFORMATION
We collect information from you through the Sites in a variety of ways, such as when you provide us with your details to register as a customer on our Sites, subscribe to our newsletter, receive information or mailings, purchase a product or service from us , make a comment or ask a question or contact our Customer Service.
Site visitors: When you visit one of our sites, we collect various types of information such as browser type, IP address, date and time of visit, average time spent on the site, cookie ID , the hyperlinks you clicked on and the websites you visited before arriving at our site. We also collect information such as your name and email address when you contact our customer service team.
Guest Checkout: When you place an order for goods through one of our Sites as a guest, we collect your name, contact information, order information, and prepaid payment information.
Account Holders: When you open an account with us as an account holder and place an order for goods through one of our Sites, we collect your name, contact information, passwords, transaction history and prepaid payment information.
You may also provide us with personal information in other ways, such as when you interact with us through social media or participate in our promotions.
USE OF INFORMATION
Depending on how you interact with the Sites (i.e. depending on the services, products or functionalities you choose), we process your personal data for the following purposes:
Target |
Legal basis |
When you visit the website: |
|
| To provide support and respond to your requests and questions | We have a legitimate interest in responding to your requests and questions for ongoing business administration. |
| To personalize your visit to our Sites and help you use the Sites |
We have a legitimate interest in properly managing and managing our relationship with you and to ensure that we are as effective and efficient as possible... |
| To improve the Sites by helping us understand who uses the Sites |
We have a legitimate interest in properly managing and managing our relationship with you and to ensure that we are as effective and efficient as possible... |
| To prevent and detect fraud and to comply with applicable laws, regulations or codes of conduct | To comply with our legal or regulatory obligations |
| To contact you to tell you about products and services offered by us and about other promotions and competitions, which we think may be of interest to you, unless you advise us not to receive marketing or market research communications from us . | If applicable law requires that we receive your consent before sending you certain types of marketing communications, we will only send you those types of communications after we have received your consent. If you no longer wish to receive marketing or market research communications from us, you can unsubscribe via the link at the bottom of the relevant marketing email or contact us using the contact details below. We have a legitimate interest in conducting direct marketing |
| For tailored advertising on third party sites, either because of the website you are viewing or based on your interests that we have inferred from your information. | With your consent, if required by applicable law. If you no longer wish to see customized advertising, you can adjust your cookie preferences (see section: COOKIES / TRACKING TECHNOLOGY / LOGFILES). |
When you open an account with us and/or buy goods online: |
|
| To provide goods or services to you | |
| To manage and maintain our relationships with you and for ongoing customer service | To administer and perform our contract with you We have a legitimate interest in properly managing and administering our relationship with you and in ensuring that we are as effective and efficient as possible. |
| To enforce or defend our rights, ourselves or through third parties to whom we delegate such responsibilities | |
| Sharing data with police, law enforcement, tax authorities or other government and anti-fraud agencies where we have a legal obligation, including transaction screening, reporting suspicious activity, and following production and court orders. | |
| Reporting tax information to the tax authorities | |
| Investigating and resolving complaints and managing regulatory issues, investigations and lawsuits | To comply with our legal or regulatory obligations |
| Monitoring electronic communications for investigation and fraud prevention, crime detection, prevention and investigation | |
| To comply with any of our applicable legal or regulatory obligations. For example, if you are a corporate customer, we need to process your data to verify your identity and perform the necessary due diligence checks. | |
| The day-to-day business and management of the company, including to: monitor, maintain and improve the processes, information and data, technology and communication solutions and services we use; performing general, financial and regulatory accounting and reporting; compiling or merging personal data into certain data analytics or reports; monitor and record requests for quality, business analysis, training and related purposes to pursue our legitimate interests and improve our services; protect our legal rights and interests; or share such personal data with third parties who acquire all or part of our assets or shares or who follow us in the course of our business; |
We have a legitimate interest in running our business, including for legal, human resources, administrative and management purposes and for the prevention and detection of crime, provided that your interests do not override our interests. To comply with our legal or regulatory obligations |
Your right to object - If you are located in the European Economic Area ("EEA") and/or you are a customer of Laurien Testaert, you have the right to object to the processing of your personal data where that processing is carried out for us legitimate interest or for direct marketing purposes.
Where we need your personal data to comply with legal requirements, failure to provide this information means that we may not be able to accept you as a customer and/or process your purchases. We will tell you when we ask for your information whether it is a legal or contractual obligation to provide us with the information and what the consequences are of not providing the information.
COOKIES / TRACKING TECHNOLOGY / LOGFILES
Like many websites, the Site uses cookies and web beacons (also known as clear GIF technology or "action tags") to speed up your navigation on the Site, recognize you and your access rights, and track your use of the Site.
Cookies are small pieces of information that your internet browser stores as text files on your computer's hard drive. Most internet browsers are initially set to accept cookies. You can set your browser to refuse cookies from websites or to delete cookies from your hard drive, but if you do so you will not be able to access or use parts of the Site. We need to use cookies to enable you to select products, place them in an online shopping cart and purchase those products. If you do this, we will keep a record of your browsing activities and purchases. THE SITE'S COOKIES DO NOT INFILTRATE INTO A USER'S HARD DRIVE AND CANNOT INFILTRATE THEM TO COLLECT A USER'S CONFIDENTIAL INFORMATION. Our cookies are not "spyware".
Web beacons assist in the delivery of cookies and help us determine whether a web page on the site has been viewed and, if so, how often. For example, any electronic image on the Site, such as an advertising banner, can function as a web beacon.
We may use third-party advertising companies to tailor site content to users or to serve ads on our behalf. These companies may use cookies and web beacons to measure the effectiveness of the advertisements (such as the web pages visited or products purchased and in what quantity). Any information these third parties collect through cookies and web beacons will not be linked to any personal information collected by us.
For example, Facebook collects certain information through cookies and web beacons to determine which web pages are visited or which products are purchased. Please note that any information collected by Facebook through cookies and web beacons will not be linked to the personal information of customers collected by us.
EXCHANGE OF INFORMATION
We may share your personal data within the Laurien Testaert Group in order to enable us to provide our goods and services to you and to market products sold by other entities of the Laurien Testaert Group are sold, including the entities on the Controller List.
We may use trusted third parties to provide services to us (for example, technical support for the Sites, fulfillment of your order, payment processing, marketing, data analytics companies, web hosting companies and support services) that may have access to your personal information. All service providers may only use the data to perform services for us.
We may share your personal data with competent authorities, courts and agencies in response to a court order, subpoena or subpoena, requests from regulatory authorities, or as permitted or required by law, when we reasonably believe it is necessary or appropriate to investigate, prevent, or act upon suspected fraud or situations involving potential threats to the physical safety of any person.
We may also disclose your personal data to third parties who acquire all or part of our assets or shares or who enable us to operate all or part of our business.
INTERNATIONAL TRANSFER OF INFORMATION
If you are located in the EEA and/or you are a customer of Laurien Testaert, please note that some of the recipients mentioned above to which we transfer your personal data are located in countries outside the EEA, including the US, and which are not considered by the European Commission to provide an adequate level of data protection.
When we transfer your personal data to such recipients, we enter into an EU-model data transfer agreement with the recipient or ask the recipient to provide assurances that they have an EU-US Privacy Shield or that they have binding corporate rules.
More details on the transfer mechanisms can be obtained from the contact details at the end of this Privacy Policy.
COMMITMENT TO DATA SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to ensure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. Your personally identifiable information is kept secure and encrypted during the type of transmission.
For payments, we use a certified payment gateway provider. All credit card information is encrypted via the Payment Card Industry Data Security Standard (PCI-DSS). All payment gateways comply with PCI-DSS standards, as administered by the PCI Security Standards Council, which is a joint effort of brands such as Visa, MasterCard, American Express and Discover. We therefore do not see or store your credit card details.
While we use industry standards to protect your personal information, we cannot guarantee complete security. 100% complete security currently does not exist anywhere online or offline.
RETENTION OF INFORMATION
We retain your personal data to the extent necessary for the provision of the goods/services, for internal analytical purposes or to comply with our legal obligations, to resolve disputes and to enforce agreements (e.g. settlement). The criteria used to determine retention periods include:
how long the personal data is needed for the provision of the goods/services and the operation of the business;
the nature of the personal data collected; and
whether we are subject to a legal, contractual or similar obligation to retain the data (for example, mandatory data retention laws, government orders to retain data relevant to an investigation, or data to be retained for the purpose of a lawsuit or dispute).
YOUR RIGHTS
If you are located in the EEA and/or are a customer of Laurien Testaert, and certain requirements are met, you are entitled to:
request access to the personal information we hold about you;
the correction of your personal data when it is inaccurate, outdated or incomplete;
request that we erase your personal data;
unsubscribe from all marketing communications we send you and object to the use/retention of your personal data where we have no valid reason to do so;
request that we restrict the processing of your personal data - i.e. we must secure and retain the data for your benefit, but not use it in any other way;
withdraw your consent at any time; and
the portability of personal data - i.e. ask to provide a copy of your personal data in digital format to you, or to a third party.
Such requests should be made using the contact details below. Please note that if you request that your personal information be deleted, you may not be able to access or use certain parts of the Sites. You can also request to change or delete your account or personal information such as name, surname, address, country of residence and payment card information at any time.
We will answer your request in writing or orally as soon as possible, and in any case within one month of receipt of your request. In exceptional cases we can extend this period by two months and we will tell you why. We may request proof of identification to verify your request. For more information about your rights, including how to exercise them, please contact us using the contact details below.
You also have the right to lodge a complaint about the processing of your personal data with the relevant data protection authority.
LINKS TO OTHER WEBSITES
Our sites may contain links to other websites that are not operated or controlled by us. We have no control over such third party websites or their privacy practices. Any personal information you provide to third party websites is not covered by this Privacy Policy.
CHANGES TO THIS PRIVACY POLICY
We may change this Privacy Policy from time to time. We will notify you of any material changes by email or through a notice on our Sites. Any changes to this Privacy Policy will be effective immediately upon posting. We recommend that you read this privacy policy regularly to stay informed of changes and how we protect your personal data.
MINORS
You must be 16 years of age or older to use the Sites and our other digital offerings. We do not solicit or knowingly collect personal information from children aged 16 and under. If we are notified that we have received such information, or information that violates our policies, we will use reasonable efforts to locate and remove that information from our records.
CONTACT US
If you have any questions regarding this Privacy Policy or our use of your personal data, or if you would like to exercise your rights as a data subject, you can submit a request to Laurien Testaert's data protection officer: support@my-scrubby.com.
