Privacy and Data Protection Policy

 

1. Introduction

 

This document tells you how we at Cindy Giovagnoli, LLC use your data when you use our website, interact with us and buy our goods or services.

This policy also tells you about your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.

This Privacy and Data Protection Policy was last updated on May 23rd, 2018, and can be edited without prior notice. This document is compliant with most recent privacy regulations.

For more questions regarding the contents of this policy, feel free to get in touch with us at staycurious@cindygiovagnoli.com.

 

2. Who is Cindy Giovagnoli?

 

Cindy Giovagnoli is represented by her website CindyGiovagnoli.com and related platforms including ConvertKit and social networks [Instagram, Facebook, Pinterest]. None of the resources managed and presented by Cindy Giovagnoli are intended for children and we do not knowingly collect any data relating to children.

Cindy Giovagnoli, LLC is the data control responsible for handling any personal data carried through CindyGiovagnoli.com. Any data carried through other platforms, like ConvertKit, Facebook, Instagram or Pinterest is the responsibility of the relative platform.

 

3. What data do we collect?

 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect a variety of information about our wonderful customers (you!) and visitors to the Cindy Giovagnoli website. This personal data falls into these categories:

Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website, products and services.

Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.

Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We also collect, use and share 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 in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We do NOT collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offenses.

 

4. How is your personal data collected?

 

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact details 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:

  • sign up to receive the Cindy Giovagnoli newsletters;

  • make enquiries or request information be sent to you;

  • create an account on our website;

  • order our products or services;

  • engage with us on social media;

  • enter a competition, promotion or survey;

  • contact customer services; or

  • leave comments or reviews on our products or services.

Automated technologies or interactions. As you interact with us, including via the CindyGiovagnoli.com 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 and Transaction Data from providers of payment and fraud prevention services;

Identity and Contact Data from data partners; 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. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

5. How we use your data

 

Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening as part of the check-out process.

Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.

 

6. Advertising, marketing and your communications preferences

 

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and tell you about them.

We normally carry out direct marketing via email or email newsletter blasts.

On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to our newsletter or as part of creating an account or the purchase journey – and you have a right at any time to change your mind and opt out. The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.

We work with ConvertKit to send out our blasts, so we strongly advise you to review their data protection policy.

Our partner for getting tracking data is Google Analytics. In particular we use cookies to collect anonymous tracking data. We also use cookies for our checkout process, this helps products to remain in your cart through out the process as well as it keeps you logged into your account.

See more about cookies below:

 

7. Cookies

 

Cookies help CindyGiovagnoli.com work better and provide lots of help in the background to make the process of being a CindyGiovagnoli.com customer a lot easier. You’d miss a lot of these things if they were gone – like it being easy to log in and move from page to page, and things staying in your cart while you go off and look at other pages.

Other cookies collect information about how visitors use CindyGiovagnoli.com, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how CindyGiovagnoli.com works.

When you use CindyGiovagnoli.com, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It's important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

8. Disclosures of your personal data

 

We will not share or disclose any of your personal data with no other third party except government, regulators and law enforcement should this data be requested through written documents.

 

9. Payment information

 

CindyGiovagnoli uses third party payment processors Stripe and PayPal/Braintree to process payments made for products and services via the CindyGiovagnoli.com. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors - Cindy Giovagnoli never sees your full Permanent Account Number (PAN).

For PayPal we only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.

 

10. Data security

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

11. Third-party links

 

This website may include links to third-party websites, plug-ins and applications (for example, the ability to sign in with Facebook). 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 policy of every website you visit.

 

12. Data retention

 

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

13. Your legal rights

 

If the General Data Protection Regulation (GDPR) 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 to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing that in this privacy policy);

  • The right of access – that’s a right to make what’s known as a ‘data subject access request’ for 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 contact us. 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 and keep you updated.

 

14. How to contact us about privacy

If you have any questions about our privacy policy or would like to exercise any of your right feel free to contact us at staycurious@cindygiovagnoli.com

 

15. Changes to this privacy policy

The General Data Protection Regulation is new and the ICO is still issuing new bits of guidance about how businesses should follow it. So, you may see little updates to our privacy policy over the coming months.