Effective Date: September 7, 2021
Pipes and Shaw LLC dba Veronica Beard (together with its affiliates, “We” or “Our” or “Us”) welcomes you to its web site for Veronica Beard (collectively all elements of the web site in all formats, the “Site”). We collect, use and are responsible for certain personal data about you. When We do so We are subject to the UK General Data Protection Regulation (“UK GDPR”). We are also subject to the EU General Data Protection Regulation (“EU GDPR”) in relation to goods and services We offer to individuals and our wider operations in the European Economic Area (“EEA”).]
Before using the Site or submitting any information to the Site, please read this Policy carefully. If You do not accept and agree to this Policy, You are prohibited from using the Site. Please note that this Policy only applies to information collected by Us on the Site.
If You have questions about this Policy, please contact Us at email@example.com.
1. User Information
In order to access or participate in certain features of the Site, such as purchasing, returning and exchanging products, signing up to create your own account on the Site, signing up to receive e-mail updates relating to Us and/or the Site (e.g., news, marketing), obtaining customer service, and participating in surveys, sweepstakes and promotions (which may be subject to additional terms and conditions), You must provide Us with certain kinds of personal information, which may include Your name, a valid, working e-mail address, Your billing and shipping address, telephone number, payment card information, age, gender, preferences, user name and/or password and responses to surveys, sweepstakes and promotions, as applicable (individually and collectively, “User Information”).
In the event that You contact Us for support through the Site, We may also request that You provide information in addition to User Information relevant to the support requested. From time to time, We may also ask additional questions to determine how We can better serve Users or entities with whom We work. You are under no obligation to provide such information. We cannot guarantee that We can provide support or services in the event that relevant information is withheld. We may retain communications relating to support, and/or information drawn from such communications, for statistical and/or reference purposes.
2. Other Information
Other information (“Other Information”) that does not personally identify You (but may identify Your computer or device) may be collected when You participate in certain features of the Site. We may use standard services, technology and tools, such as cookies (small pieces of data sent from a web site and stored in a user’s web browser or computer), to automatically collect Other Information, which may include, by way of example and not limitation, Your Internet protocol (IP) address, the locality of Your IP address, Your geographic location, the searches You initiated, things You clicked on, Your browser type, Your operating system type, the pages You viewed and requested, and the date and time of Your visit. This information is aggregated and is used for Our business, and may be used to improve the Site, estimate usage numbers and patterns for the Site, store information about Your preferences and allow Us to customize the Site according to Your individual interests, speed up Your searches, and/or recognize You when You return to the Site. If You choose to disable cookies or other functionality or tools, some areas of the Site may not work properly, and You may not be able to access certain services or parts of the Site.
We may use standard tracking tools, such as cookies and web beacons, to gather other information as You view or interact with the Site or various advertisements. For more detailed information on the respective privacy policies of third-party ad networks and servers as well as for instructions on how to opt-out of certain practices, please visit the respective advertising networks directly.
3. How Your Personal Data is Collected
We collect most of Your personal data directly from You, either in person, by telephone, text or email and/or via Our website. However, We may also collect information from publicly accessible sources, e.g.:
- through cell phone beacons via a third party IP address when You use or are in close proximity to such third party’s wifi network; and
- via Our IT systems, e.g.: from door entry systems and reception logs; through automated monitoring of Our websites and other technical systems, such as Our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
4. How and Why we use Your personal data
Under data protection law, We can only use Your personal data if We have a proper reason, e.g.: where You have given consent; to comply with Our legal and regulatory obligations; for the performance of a contract with You or to take steps at Your request before entering into a contract; or for Our legitimate interests or those of a third party.
A legitimate interest is when We have a business or commercial reason to use Your information, so long as this is not overridden by Your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance Our interests against Your own.
We may use Your personal data for the following purposes:
- To process product purchases and other transactions upon Your request
- To validate Your registration with the Site
- To setup and manage Your account and preferences
- To provide You with e-mail updates relating to Us and/or the Site (e.g., news, marketing)
- To verify information that You have provided to Us
- To send information to You or Your designees (e.g., friends) about issues related to the Site and/or Us
- To customize Materials and advertising provided to You by Us or via the Site
- To fulfil Your requests for products and services, including customer service
- To participate in surveys, sweepstakes, and promotions (which be subject to additional terms, conditions and limitations, as may be further described therein)
- To analyze Your interactions with the Site and improve the Site and Our products and services
- For the setup and management of Your account and preferences
- For the setup, management and operation of the Site (including upgraded and future versions thereof)
- To identify and protect against fraudulent transactions and misuse or unauthorized use of the Site
- To initiate or to respond to a subpoena, investigative demand, or other discovery request that is properly served pursuant to applicable law
- To comply with our legal obligations, policies and procedures, and for internal administrative and analytics purposes
- To take actions to protect and/or to defend Our rights and property (including intellectual property)
5. Who we share Your personal data with
We may transfer and share User Information and Other Information with:
- Third party service providers that We use to process, host, collect, store or manage User Information and/or Other Information
- Third parties with whom we work to host, update, and otherwise operate the Site
- Third parties with whom We work to market, advertise and/or enhance the Site or the products or services that We offer
- Third parties with whom We work to place, process, ship, return and otherwise transport orders placed using the Site
- Third parties with whom We work to provide customer service to You and other users of the Site
- Other businesses and media entities with whom We work to offer or customize products and services
- Government agencies (including courts and law enforcement agencies)
- Parties to civil or criminal litigation or arbitration (including arbitrators and/or mediators involved in litigation or arbitration)
- Other third parties under special circumstances, such as complying with legal requirements, preventing fraud, or protecting the safety of our Users
- Our current and future parents, subsidiaries, affiliates, joint ventures or any other entities under a common control, including in the event that We, Our business or assets are acquired by another entity
We only allow third parties to handle Your personal data if We are satisfied they take appropriate measures to protect Your personal data. We also impose contractual obligations on service providers to ensure they can only use Your personal data to provide services to Us and to You.
The Site may contain links to other web sites, including embedded content and forms (individually and collectively, “Other Sites”). Please be aware that this Policy does not apply to those Other Sites, and We are not responsible for, nor do We have any control over, the practices or policies of Other Sites or other parties. We encourage You to be aware when You leave the Site to read the privacy statements and terms of each and every web site that collects personally identifiable information. The Policy applies solely to information collected directly by Us.
Other Sites may have their own policies which describe how they use and disclose User Information and Other Information. Those policies will govern the use, handling and disclosure of Your User Information and Other shared with those third parties, as described in this Policy. We do not control third parties, and We assume no liability in the event that a third party breaches its promises regarding privacy or confidentiality. If You want to learn more about any third party’s privacy practices, We encourage You to visit the websites of those third parties. We encourage You to contact us at firstname.lastname@example.org if You suspect that Your User Information has been compromised by a third party.
We may use Your personal data to send You updates about Our products, including exclusive offers, promotions or new products. We have a legitimate interest in using Your personal data for marketing purposes. This means we do not usually need Your consent to send You marketing information. However, where consent is needed, We will ask for this separately and clearly.
If You do not wish to be contacted by Us, You can follow the unsubscribe instructions that accompanies any contact e-mail. If You opt-out of certain contacts, We may still contact You about any problems or issues with Your account, profile, or any purchases You have made on the Site or from Us. Please allow Us ten (10) business days from when the request to unsubscribe was received to complete the removal, as some of Our promotions may already have been in process before You submitted Your request.
We may ask You to confirm or update Your marketing preferences if You ask us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business. We will always treat Your personal data with the utmost respect and never sell or share it with other organisations outside Our group for marketing purposes.
7. Where Your personal data is held
User Information is stored in servers physically located in United States of America. We make no representations that the Site is appropriate or available for use in other locations. Users who access or use the Site from other jurisdictions do so on their own initiative and are responsible for compliance with all applicable laws.
To the extent that You provide User Information or Other Information to Us concerning third parties, that information will be subject to the same conditions as set forth above.
Your personal data may also be held at the offices of third party agencies, service providers, representatives and agents as described above. Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard Your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
8. Transferring Your personaL DATA OUTSIDE OF THE uk/eea
It is sometimes necessary for us to share Your personal data outside the UK/EEA, e.g.: with Our service providers located outside the UK/EEA; or where there is a European and/or international dimension to the services we are providing to You. Under data protection law, we can only transfer Your personal data to a country or international organisation outside the UK/EEA where:
- the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law
These are explained below.
We may transfer Your personal data to certain countries, on the basis of an adequacy decision. These include: all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’); or the UK; Gibraltar; Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland or Uruguay. The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists. Other countries We may transfer Your personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but We must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, We may transfer Your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects. The safeguards will usually include using legally-approved standard data protection contract clauses.
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, We may transfer Your personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g.: You have explicitly consented to the proposed transfer after having been informed of the possible risks; the transfer is necessary for the performance of a contract between You and Us or to take pre-contract measures at Your request; the transfer is necessary for a contract in Your interests, between You and Us and another person; or the transfer is necessary to establish, exercise or defend legal claims. We may also transfer information for the purpose of Our compelling legitimate interests, so long as those interests are not overridden by Your interests, rights and freedoms. Specific conditions apply to such transfers and We will provide relevant information if and when we seek to transfer Your personal data on this ground.
9. Information Obtained from Children To use the Site
You must be age 13 or older to access the Site. The Site is not directed to children under the age of 13. We do not knowingly collect, use or disclose any User Information from children under 13 years of age. By using the Site, You represent and warrant that You are at least 13 years old. If We discover that a child under the age of 13 has provided the Site with User Information, We will take appropriate steps to delete this information. If You believe that We might have any User Information from a child under the age of 13, please contact us at email@example.com. If You are under the age of 18, You may not use the Site, or make any submissions of User Information to the Site, except with the involvement and verifiable consent of Your parent or legal guardian.
10. Your rights
If You provide us with Your personal data, You may have the following rights with respect to that information:
- Access - To be provided with a copy of the personal data that You have supplied to Us.
- Rectification - To request that We correct any errors, outdated information, or omissions in personal data that You have supplied to Us.
- Erasure (also known as the right to be forgotten) – The right to require Us to delete Your personal data in certain situations.
- Restriction of processing - The right to require Us to restrict processing of Your personal data in certain circumstances, e.g. if You contest the accuracy of the data.
- Data portability - The right to receive the personal data You provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations.
- To object - The right to object: at any time to Your personal data being processed for direct marketing (including profiling); in certain other situations to Our continued processing of Your personal data, e.g. processing carried out for the purpose of Our legitimate interests.
- Not to be subject to automated individual decision making - The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning You or similarly significantly affects You.
If You request that Your User Information be deleted from Our records, there may be a reasonable delay in processing that request, while We or Our designee verifies that the request is valid and originates from You, and a copy of some or all of the User Information may be retained for legal compliance purposes. If You request that Your User Information be deleted, We reserve the right to terminate and/or limit Your access to the Site. To exercise any of these rights, please contact Us at firstname.lastname@example.org, and We will use commercially reasonable efforts to honor Your request.
11. Data Retention
We retain User Information and Other Information to provide You with access to the Site or certain features thereof. For example, in order to create Your own account on the Site, You must provide Us with Your name and Your valid, working e-mail address; and You hereby authorize Us to store Your name and e-mail address. Should You elect to do so, You may also provide, in Your account, Your telephone number, payment card information, and shipping and billing addresses. If You choose to provide Us with such additional information, then You are also authorizing Us to store such information until such time as You request to change or delete it and such request is reasonably processed.
12. Security Measures
We have appropriate security measures to prevent Your personal data from being accidentally lost, or used or accessed unlawfully. We limit access to Your personal data to those who have a genuine business need to access it. Those processing Your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify You and any applicable regulator of a suspected data security breach where we are legally required to do so.
We may use a variety of security technologies and procedures that We deem reasonable and appropriate to help protect User Information and Other Information from unauthorized and improper access, use, disclosure, modification, and destruction. We take appropriate physical, electronic and administrative steps to maintain the security and accuracy of User Information we collect, including employing electronic security systems and password protections that guard against unauthorized access. In addition, it is Our policy to never send Your payment card number via e-mail. Please note that e-mail is not encrypted and is not considered to be a secure means of transmitting payment card information. [We use Transport Layer Security (TLS), the industry standard in transferring information to process your orders. The TLS encrypts, or translates, Your order information into a highly indecipherable code, for secure delivery. All payment card transactions occur in a secure area of the Site, to protect You from any loss, misuse or alteration of information collected. When You have finished shopping and begin the checkout process, You will move into the secure area of the Site. Once You have entered the secure area, the page address (URL) will change from http to https, to let You know You are in a secure area. Also, a key or a closed lock will appear in the lower right hand corner of Your screen to notify You of this change. You will remain in this secure zone for the entire checkout process.]
Unfortunately, the transmission of data over the Internet cannot be guaranteed to be 100% secure, and no method of safeguarding information is 100% secure. Therefore, We do not and cannot guarantee that these technologies or procedures will be effective, that User Information or Other Information will remain private or secure, or that User Information or Other Information will not be intercepted by third parties.
If You ever use a public computer to log in to Your account on the Site, We strongly encourage You to log out of Your account at the conclusion of Your session.
13. California Privacy Rights
If You are a resident of California, You may submit a written request to Us about how We have shared Your User Information with select third parties for their direct marketing purposes. In response to your written request, We will identify the categories of information shared, if any, and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. Please submit a written request to email@example.com.
14. Changes to The Policy
We reserve the right to modify, alter or otherwise update this Policy at any time, without prior notice, by posting any such modified, altered or updated version of this Policy on the Site. We encourage You to check this page each time You use the Site.
15. How to complain
Please contact Us if You have any query or concern about Our use of Your information (see below ‘How to contact us’). We hope We will be able to resolve any issues you may have. You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
YOUR CONTINUED USE OF THE SITE CONSTITUTES YOUR AGREEMENT TO THIS POLICY AND ANY UPDATES TO THIS POLICY.