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Our Data Promise

YOUR PRIVACY IS IMPORTANT

Introduction

1.1 Kiyana London Limited (the “Company”, “we”, “us” or “our”) respects your privacy and is committed to treating any information that we obtain about you with as much care as possible and in a manner that is compliant with all applicable data protection legislation including the EU General Data Protection Regulation 2016/679 (“GDPR”) and any national implementing laws in relation to the same (collectively, “Data Protection Legislation”). In this privacy policy, Kiyana London Limited means Kiyana Wraps. 

It is Kiyana Wrap’s policy to respect your privacy regarding your personal data.  We may collect this data while operating our website or via any other means (such as over email), when you make an inquiry with us. Accordingly, we have developed this Privacy Policy in order for you to understand how we collect, use, communicate, disclose and otherwise make use of your personal data. We have outlined our privacy notice below.  This privacy notice supplements the other notices and is not intended to override them.

1.2 This document (the “policy”) is our Data Promise to you. Please read it carefully. Among other things, it explains:

1.2.1 what personal data we may collect about you in connection with: (i) providing you with our goods and services; (ii) your online interaction with us (including via our website(s), email or social media channels); (iii) any other channels related or ancillary to the foregoing (collectively, the “Channels”);

1.2.2 how we collect, store, disclose, transfer, protect and otherwise process that information and for what purposes; and

1.2.3 other important information, such as the lawful bases by which we process your personal data, how long we might retain your personal data, and the rights you have in relation to personal data we hold about you.

1.4 In this policy, terms defined in the GDPR, including “data subject”, “personal data”, and “processing”, have the same meaning when used in this policy. The words “include”, “including”, “such as” and similar words and phrases shall be construed to mean “including without limitation”.

1.5 This policy is intended to be communicated to you in a concise, transparent, intelligible and easily accessible manner, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please email admin@kiyanawraps.com or write to [Data Protection Enquiries, 202 Hammersmith Road, London, W6 7DN, United Kingdom ] and we will endeavour to respond as soon as possible.

1.6 The Company reserves the right to make changes to this policy in order to reflect any changes in Data Protection Legislation and best practices from time to time. The Company will endeavour to notify you of such changes but you are advised to check for an updated version of this policy at Our Data Promise each time you interact with us through the Channels,

 


 

The personal data we process

 

2.1 We collect personal data about you through the Channels when you:

2.1.1 access and use our websites (including by way of cookies – please refer below for more information);

2.1.2 register for newsletter or subscribe for other services, contests, special events or our mailing list;

2.1.3 create an account;

2.1.4 purchase a product from us;

2.1.5 request technical support or other customer care support;

2.1.6 participate in polls, surveys and questionnaires;

2.1.7 contact us (whether in writing, by email, by telephone or otherwise);

2.1.8 post content on our social media pages; or

2.1.9 otherwise interact with us through the Channels.

2.2 The type of personal data we process may include (if and as applicable):

2.2.1 information obtained through the use of cookies when you use the site (please refer to information below for more information);

2.2.2 your name, user name, password, email address, postal address, telephone number and other information provided by you;

2.2.3 information relating to your purchase history

2.3 Payment (such as credit card) information you use to pay for purchases is processed only to the extent, and for the duration, necessary to enable our third party payment processors (see more information on the third party processors we use) to process the relevant payment. No such payment information is retained or stored by us.

 


 

The purposes for which we process your personal data

 

3.1 We use the personal data referred to in paragraph 2 above for the purposes of (if and as applicable):

3.1.1 personalising content on the Channels;

3.1.2 sending you promotional and marketing materials, notifications, updates and exclusive news;

3.1.3 providing you with access to our products and services and fulfilling product orders;

3.1.4 internal training and other internal uses to improve our services and customer experience (including improving our marketing and promotional efforts, analysing channel usage statistics, improving content and product offerings and customising the content and layout of our stores and online websites);

3.1.5 responding to any correspondence from you including enquiries, comments, complaints and technical problems;

3.1.6 administering any polls, services, questionnaires, contests, or special events which you may have subscribed for;

3.1.7 recording your purchase history and administering your account with us;

3.1.8 market research and demographic studies; and

3.1.9 carrying out our business activities in circumstances where you ought reasonably to have an expectation that we will process your personal data for a particular purpose (including as may be provided for in our Terms of Use or other arrangement between us).

3.2 We may process your personal data for the purposes set out in paragraph 3.1 ourselves or in conjunction with our third party service providers.

 


 

The purposes for which we process your personal data

 

3.1 We use the personal data referred to in paragraph 2 above for the purposes of (if and as applicable):

3.1.1 personalising content on the Channels;

3.1.2 sending you promotional and marketing materials, notifications, updates and exclusive news;

3.1.3 providing you with access to our products and services and fulfilling product orders;

3.1.4 internal training and other internal uses to improve our services and customer experience (including improving our marketing and promotional efforts, analysing channel usage statistics, improving content and product offerings and customising the content and layout of our stores and online websites);

3.1.5 responding to any correspondence from you including enquiries, comments, complaints and technical problems;

3.1.6 administering any polls, services, questionnaires, contests, or special events which you may have subscribed for;

3.1.7 recording your purchase history and administering your account with us;

3.1.8 market research and demographic studies; and

3.1.9 carrying out our business activities in circumstances where you ought reasonably to have an expectation that we will process your personal data for a particular purpose (including as may be provided for in our Terms of Use or other arrangement between us).

3.2 We may process your personal data for the purposes set out in paragraph 3.1 ourselves or in conjunction with our third party service providers.

 


 

The lawful bases by which we process your personal data

 

4.1 Your consent

By accepting the terms of this policy, you give the Company your express, freely given consent to process any of your personal data in accordance with the terms of this policy. You may withdraw your consent given under this paragraph (in whole or in part) at any time by contacting admin@kiyanawraps.com. You can also unsubscribe from different types of emails by following the unsubscribe link. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds as set out below.

 

4.2 Other lawful grounds

Without prejudice to the consent given by you under paragraph 4.1 above, the Company may process your personal data in any circumstances where such processing is necessary:

4.2.1 in order to perform any agreement between us (including pursuant to our [Terms of Use] or for us to fulfil an order placed by you);

4.2.2 to comply with any applicable law or regulation; or

4.2.3 for the purposes of the legitimate interests pursued by us or third parties. These legitimate interests include the purposes identified above in paragraph 3.1 but also include other general commercial interests and our internal administrative purposes.

  1. What if you refuse to provide us with any personal data?

5.1 Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

5.2 Whilst we may be able to provide you with certain products and services notwithstanding your refusal to submit personal data, this may limit your ability to participate in some activities or features or your use of certain online services.

5.3 We may lawfully obtain information from third parties or public sources and we may process that information where it is an essential component of the products and services we offer you.

 


 

Sharing information with affiliates and third parties

 

6.1 We will not share any of your personal data with third parties except as set out in paragraph 6 or otherwise notified to you or agreed between you and us from time to time.

6.2 We may share personal data with our group companies and partnered companies (together, “Affiliates”) in order to provide our goods and services to you and for the other purposes outlined in this policy. 

6.3 From time to time, we will also need to share personal data with the following types of third party service providers who we engage to provide services which facilitate our business and who may need to process your personal data to the extent necessary to provide those services:

6.3.2 web analytics services such as Google analytics;

6.3.3 retail management, payment processing and point of sale services such as CEGID, Magento, Adyen, Avalara and Woocommerce;

6.3.4 credit reference and fraud prevention services such as Signifyd (as well as law enforcement and fraud prevention agencies more generally);

6.3.5 professional service providers, such as marketing agencies, advertising partners and website hosts such as Rackspace;

6.3.10 any similar or replacement third parties from time to time.

6.4 We seek to ensure that any third party engaged by us who processes your personal data has policies and procedures in place to ensure compliance with the Data Protection Legislation. For any third parties that are based, or process data, overseas, we only engage such third parties in accordance with paragraph 7. Unless otherwise disclosed to you from time to time, we will remain the data controller in respect of your personal data notwithstanding that third parties may be engaged as data processors.

6.5 We may share your personal information with third parties where we are required to do so by law or regulation (such as in connection with an investigation of fraud or other legal enquiry) or in connection with other legal proceedings (including where we believe that your actions violate applicable laws, our [Terms of Use] , or any usage guidelines for specific products or services, or threaten the rights, property, or safety of our Company, our users, or others.

 


 

Your rights as a data subject

 

Under the Data Protection Act 1998, you have rights as an individual which you can exercise in relation to the information we hold about you.

Subject to any conditions or requirements set out in the relevant Data Protection Legislation, you may have some or all of the following rights in relation to the personal data we hold about you:

7.1 the right to request a copy of your personal data held by us;

7.2 the right to request that we erase the personal data we hold about you;

7.3 the right to request that we restrict the processing of your data;

7.4 the right to have your personal data transferred to another organisation;

7.5 the right to object to certain types of processing of your personal data by us; and

7.6 the right to complain.

You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/