Privacy policy
PRIVACY POLICY
This Privacy Policy, known as the "Policy," explains how we, as the accountable entity or "data controller," collect, use, and disclose your Personal Information when you interact with us. Personal Information refers to any information that can identify you, either alone or when combined with other information. This includes information we collect when you use our website, answer our surveys, or contact us.
We take your privacy seriously at BOLSINO, and we have developed this Policy to ensure that we protect your Personal Information according to the highest standards. As the data controller, we are responsible for ensuring that we comply with all applicable privacy laws.
This Policy also outlines your rights concerning your Personal Information and how you can exercise them.
Contact Us: Please take the time to read this Policy carefully. If you have any questions or comments, please contact us by phone at +352 661 745158 or via email at info@bolsino.com.
What Personal Information does BOLSINO collect and why?
The types of Personal Information that we may collect about you, and the reasons why we process it, include:
|
Types of Personal Data we collect |
Purposes for which we process your Personal Data |
Legal basis on which we rely to process your Personal Data |
|
Contact details (Name, Surname, Phone number, Email address) Email Preferences (Language Preferences, Region/Country) Shipping address Billing address |
Contract management · Processing and shipping your orders · Enabling you to access your order history with us at all times · Providing you with customer service as may be required |
Contractual necessity: to provide you with our services.
|
|
Contact details (Name, Surname, Phone number, Email address) Order History, Order Number Shipping address IP Address Financial information (Cardholder Name, Card Expiration Date, Card number, CVV or CID) |
Documenting transactions you made on our website |
To protect BOLSINO's proprietary and legal rights. |
|
Contact details (Name, Surname, Phone number, Email address) Email preferences (Language Preferences, Region/Country) Shopping preferences |
Marketing Providing you with exclusive email updates, promotions, and notifications including information about our products or services, sales/products |
Your opt-in consent |
|
Contact details (Name, Surname, Phone number, Email address) Your inquiry and your inquiry history Type of request Messages Order number Billing/Shipping Address |
Customer relationship follow-up · Processing and responding to any inquiry that you may address to us · After-sales service · Handling customer requests and inquiries |
Contractual necessity: to provide you with and improve our services. |
|
Contact details (Name, Surname, Email address) Order History Financial information (last 4 digits of your credit card number, AVS code) Shipping address/Billing address |
Prevention of fraud |
Legal obligation |
|
IP address User account details (Name, Surname, Shipping Address, email, login, password) Shopping preferences Session browsing data and conversion behaviour Search History Email preferences |
Data analytics, statistics and audience measurement to load the Site accurately for you |
To benchmark and evaluate the performance of our Website. |
|
User account details (Name, Surname, Shipping and Billing addresses, Email address) Order History Financial information (last 4 digits of your credit card number and name of the cardholder) |
Management of the data subjects requests rights Enabling you to exercise your rights regarding your personal data. |
Legal obligation |
Please be aware that the information you provide on our website may be essential for contractual purposes and for us to comply with our legal obligations. If you don't provide such information, we may be unable to process your order or respond to your inquiries. It is important that you provide us with accurate and complete information to ensure a smooth and successful transaction.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:
- We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
- We use Shopify Audiences to help us show ads on other websites with our advertising partners to buyers who made purchases with other Shopify merchants and who may also be interested in what we have to offer. We also share information about your use of the Site, your purchases, and the email address associated with your purchases with Shopify Audiences, through which other Shopify merchants may make offers you may be interested in.
- We use Affiliate Marketing Campaigns from Third-Party-Providers.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
- FACEBOOK - https://www.facebook.com/settings/?tab=ads
- GOOGLE - https://www.google.com/settings/ads/anonymous
- BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: https://optout.aboutads.info/.
Who does BOLSINO share your Personal Information with?
We may disclose your Personal Information to the following categories of recipients:
- To service providers to help us provide our services and fulfill our contracts with you, as described above. For example, we use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
- To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- To our auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the Personal Information for any other purpose;
- To any other person if you have provided your prior consent to the disclosure.
How we protect your privacy?
We will handle Personal Information in accordance with the following principles:
(a) Accountability: An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization's compliance with the following principles.
(b) Identifying Purposes: The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.
(c) Consent: The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except when inappropriate.
(d) Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.
(e) Limiting Use, Disclosure and Retention: Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfilment of those purposes.
(f) Accuracy: Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
(g) Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
(h) Openness: An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
(i) Individual Access: Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
(j) Challenging Compliance: An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization's compliance.
Data storage, retention and deletion
- The Personal Information we collect from you is stored in our servers located in Canada.
- We retain Personal Information for as long as necessary to fulfil our contractual and legal obligations (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
- You can ask us to erase your Personal Information via email. For more information on your right of erasure, please see the ‘Your rights’ section below.
Transfers of Personal Information
Your Personal Information may be transferred to, and processed in, countries/province other than the country/province in which you are resident. These countries/provinces may have privacy laws that are different to the laws applicable in your place of residence.
Specifically, our Website servers are located in Canada, and our third party service providers and partners operate around the world. This means that when we collect your Personal Information we may process it in any of these countries.
However, we have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Policy. We only transfer or make your Personal Information available to our third party services providers in third countries/provinces where such transfer is necessary for the performance of a contract between you and BOLSINO or the implementation of pre-contractual measures.
Profiling
In some instances, we may use your Personal Information in order to better understand your preferences and to provide customized products or services to you. Where applicable, we will inform you of the technology used for collecting/using you profiling, locating, identifying information and provide a way for you to activate them. However, we do not make any decisions based solely on automated processing of such data, which either produce legal effects that concern you or similarly significantly affect you. If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making, when that decision-making has a legal effect on you or otherwise significantly affects you.
Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you. Services that include elements of automated decision-making include:
- Temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a small number of hours.
- Temporary blacklist of credit cards associated with blacklisted IP addresses. This blacklist persists for a small number of days.
Minors
The services we provide on this Website are not intended for individuals below the age of 18. If you are under 18, please do not use or register on this Website.
Your privacy rights
You have the following privacy rights:
(a) If you wish to request access, correction, update or deletion of your Personal Information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below. Please note that requests are subject to certain limitations, for example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.
(c) If we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
(d) You have the right to opt-out of marketing communications we send you at any time. You may unsubscribe from our newsletters or marketing notifications at any time by selecting the unsubscribe option in the "Email Preferences" section of your account, or by clicking the unsubscribe link at the bottom of every newsletter email. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided below.
(e) If you have a complaint or concern about how we are processing your Personal Information then we will endeavour to address such concern(s). If you feel we have not sufficiently addressed your complaint or concern, you have the right to complain to a privacy authority about our collection and use of your Personal Information. For more information, please contact your local privacy authority.
We respond to all requests we receive from individuals wishing to exercise their privacy rights in accordance with applicable privacy laws.
Applicable Data Protection laws
At BOLSINO, we are a global business, and we understand the importance of data privacy laws. We want to assure our customers that we comply with all applicable privacy laws, including the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA). Please note that if you reside outside of the European Economic Area (EEA), the data protection laws of your country may differ from those of the EEA. However, this Policy is drafted in line with the GDPR, which sets the highest standard of data protection. We are committed to protecting your privacy and handling your Personal Information in a transparent and secure manner.
Additionally, if you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above.
Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.
If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above.
If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address above.
Linking to other websites
The Website may contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies and we urge you to review them. They will govern the use of Personal Information you submit whilst visiting these websites.
We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
Cookies
A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.
We use the following cookies to optimize your experience on our Site and to provide our services.
[Be sure to check this list against Shopify’s current list of cookies on the merchant storefront: https://www.shopify.com/legal/cookies ]
Cookies Necessary for the Functioning of the Store
|
Name |
Function |
Duration |
|
_ab |
Used in connection with access to admin. |
2y |
|
_secure_session_id |
Used in connection with navigation through a storefront. |
24h |
|
_shopify_country |
Used in connection with checkout. |
session |
|
_shopify_m |
Used for managing customer privacy settings. |
1y |
|
_shopify_tm |
Used for managing customer privacy settings. |
30min |
|
_shopify_tw |
Used for managing customer privacy settings. |
2w |
|
_storefront_u |
Used to facilitate updating customer account information. |
1min |
|
_tracking_consent |
Tracking preferences. |
1y |
|
c |
Used in connection with checkout. |
1y |
|
cart |
Used in connection with shopping cart. |
2w |
|
cart_currency |
Used in connection with shopping cart. |
2w |
|
cart_sig |
Used in connection with checkout. |
2w |
|
cart_ts |
Used in connection with checkout. |
2w |
|
cart_ver |
Used in connection with shopping cart. |
2w |
|
checkout |
Used in connection with checkout. |
4w |
|
checkout_token |
Used in connection with checkout. |
1y |
|
dynamic_checkout_shown_on_cart |
Used in connection with checkout. |
30min |
|
hide_shopify_pay_for_checkout |
Used in connection with checkout. |
session |
|
keep_alive |
Used in connection with buyer localization. |
2w |
|
master_device_id |
Used in connection with merchant login. |
2y |
|
previous_step |
Used in connection with checkout. |
1y |
|
remember_me |
Used in connection with checkout. |
1y |
|
secure_customer_sig |
Used in connection with customer login. |
20y |
|
shopify_pay |
Used in connection with checkout. |
1y |
|
shopify_pay_redirect |
Used in connection with checkout. |
30 minutes, 3w or 1y depending on value |
|
storefront_digest |
Used in connection with customer login. |
2y |
|
tracked_start_checkout |
Used in connection with checkout. |
1y |
|
checkout_one_experiment |
Used in connection with checkout. |
session |
|
checkout_session_lookup |
Used in connection with checkout. |
3w |
|
checkout_session_token_<<token>> |
Used in connection with checkout. |
3w |
|
identity-state |
Used in connection with customer authentication. |
24h |
|
identity-state-<<token>> |
Used in connection with customer authentication. |
24h |
|
identity_customer_account_number |
Used in connection with customer authentication. |
12w |
The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.
Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “What Personal Information does BOLSINO collect and why?” section above.
Do Not Track
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.
Changes
We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.
Complaints
As noted above, if you would like to make a complaint, please contact us by e-mail or by mail using the details provided under “Contact” above.
If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://cnpd.public.lu/de.html