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The Kind Brand Company Ltd T/A TanOrganic, company number 428211, registered office at Unit B3, Century Business Park, Newbridge, Co.Kildare, Ireland. TanOrganic is the World’s first and only eco-certified, cruelty-free, and vegan certified self-tanning brand. It is our mission to excel in a marketplace that focuses on ethical practices, safe product formulation and protection of the environment.
Roles of Beauty Results Ltd.
Under this Policy, and unless the circumstances otherwise require, we will be what is known under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) as both the “Controller” and the “Processor” as per the following definition:
The information we collect
We will collect and process the following data about you for the following purposes:
Your Data. This is information about you that you give us by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you use our website, register for, subscribe to or use the available services, search for a product, place an order on our website, participate in discussion boards or other social media functions on our Site and/or when you participate in and respond to our sign-up or other surveys or report a problem with our website and/or the services.
The information you give us may include:
- Identity Data: your full name, address, e-mail address, phone number, address, age, title and personal description.
- Financial Data: your financial and credit card information, including bank account and payment card details, billing contact email address and VAT number.
With regard to each of your visits to our website we will automatically collect the following information:
-Technical Data: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, how often you use the application, geo-localisation and other performance data which may be subject to analytics software such as Google Analytics;
- Usage Data: information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.
We do not require or collect any personal data that is your sensitive personal data or any special category of personal data under the GDPR, unless you decide to provide this information to us.
What we do with your information?
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We have set out below, a description of the ways we plan to use your personal data and the legal basis we rely only on to do so. We have also identified our legitimate interests where appropriate:
|No.||Purpose / Activity||Type of Data||Legal Basis for processing|
|1||Respond to queries and provide users with the information requested from us in relation to our products and services.||Identity Data
|Legitimate interest to respond to new or existing customers queries and grow the business.
Performance of a contract.
|2||Set up and administer an account for the Services requested by the user.||Identity Data||Performance of a contract.|
|3||Provide the Services and perform our oblligations arising from any contract entered||Financial Data||Performance of a contract.|
|Performance of a contract.
Necessary to comply with a legal obligation.
Necessary for our legitimate interests to keep our records updated and study how our customers use our products and services.
|5||Provide information to our users about goods and services offered that are similar to those that have already been purchased or enquired by the user.||Identity Data
|Necessary for our legitimate interests to develop our products or services and grow our business.|
|6||Where consent has been given regarding the provision of information about other goods or services we feel may interest the user.||Identity Data
|7||Ensure that content is presented in the most effective manner for our user and for the user computer device.||Identity Data
|Necessary for our legitimate interests to keep our Website and our Services updated and relevant to develop and grow our business|
|8||Administer and protect our business, our website, our Services and for the internal oeprations, including troubleshooting, data analysis testing, research, statistical and survey purposes.||Identity Data
|Necessary for our legitimate interests to run our business and as a part of our efforts to keep our website and our services safe and secure.|
|9||Use data analytics to improve or optimise our website, services, marketing, customer relationships and experiences.||Technical Data
|Necessary for our legitimate interests to define types of customers for our products and services, to keep our website and our services updated and relevant.|
|10||Measure and understand the effectiveness of advertising we serve our users with and, where applicable, to deliver relevant advertising.||Identity Data
|Necessary for our legitimate interests to study how customers use our products or services, to develop them, to grow our business and to inform our marketing strategy.|
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with this Policy, where this is required or permitted by law.
How long we keep your information for?
We will only retain 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. This means that the period of time for which we store your personal data may depend on the type of data we hold. 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.
For example, we may hold personal data as needed for our accounting or tax compliance purposes for a period of 6 years or for 5 years where needed for our compliance with anti-money laundering regulations. For more information about our data retention policy please contact us at firstname.lastname@example.org.
Disclosure of your information
We do not sell your personal information (or Your End Customer Data) to third parties for marketing purposes. We may disclose information to third parties if you consent to us doing so as well as in the following circumstances:
You agree that we have the right to share your personal information with the following recipients or categories of recipients:
Note that we will disclose your personal information to third party recipients in the following situations:
Personal Data may be transferred to our trusted partners and service providers who maintain their servers outside of the European Economic Area (“EEA”), where the privacy and data protection laws may not be as protective as those in our current jurisdiction. This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. There are special requirements set out under Chapter V of the GDPR, with which we comply, to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer. For more information about this and the safeguards in place relating to the transfer, please contact us by email at email@example.com
We take our security responsibilities seriously, using the most appropriate physical and technical measure. Unfortunately, the transmission of information via the internet is not completely secure. Although we will always do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. These are described in more detail below.
The Services are a Linux system and, as such, your personal data is not stored locally but on a secure server. No installs are required on your PC or laptop. Our web application is only accessible via HTTPS, which helps ensure your interactions with our app are secure and private.
Your personal data is stored on secure servers hosted by Blacknight. These servers are located in Carlow, Ireland. Blacknight participates in and has certified its compliance with the EU-US Privacy Shield Framework.
Your personal data is backed up on a monthly basis. The Blacknight server data centres are protected by physical barriers and guarded 24/7.
Data is encrypted using SSL Certification when transmitted from our servers to your browser.
Access to the production environment where your personal data is stored is limited and is held by us. Only our authorized staff has access to our servers and this is on a 'need to access' basis. Access to personal data is limited to specific IP address.
New features and updates are developed and released on development servers prior to being pushed live to the main production environment. Extensive testing is undertaken by our Quality Team to ensure all new features are working correctly and the performance of the Site and Services is maintained.
The overall performance of the Site and Services is very important. Google Analytics is a performance management solution used for tracking and monitoring the Site and Services. To help avoid or minimize service interruptions, our servers are constantly monitored and a dedicated team is alerted immediately in case of any service disruptions.
Connection to the Services environment is via TLS cryptographic protocols, using global step-up certificates, ensuring that our users have a secure connection from their browsers to our service. Individual user sessions are identified verified using a unique token created at login. Email address is the unique identifier in the Services. If a user inputs their password incorrectly then a Captcha test is shown to verify that a human and not spammers or bots are inputting it.
Your Personal Data and Your Rights
You may request access at any time to a copy of the personal data we hold about you. Any such request should be submitted to us in writing and sent to firstname.lastname@example.org. We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested. There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a fee at our discretion. Alternatively, we may refuse to comply with your request in these circumstances.
You may restrict us from processing your personal data in any of the following circumstances:
If we hold personal data concerning you, which are no longer necessary for the purposes, for which they were collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at email@example.com.
You have the right to object to the processing of your personal data at any time:
To exercise your right to object at any time, please email firstname.lastname@example.org. Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. For more information about our marketing practices, please see the Marketing Communications section below.
Where we process your personal data by automated means (i.e., not on paper) and this processing is based on your consent or required for the performance of a contract between us, you have the right to request from us a copy of your personal data in a structured, commonly used machine-readable format and, where technically feasible, to request that we transmit your personal data in this format to another controller.
Profiling is an automated form of processing of personal data often used to analyse or predict personal aspects about an individual person. This could relate to a person’s performance at work, economic situation, health, personal preferences, reliability, behaviour, location or movements. An example of this would be where a bank uses an automated credit scoring system to assess and reject a loan application. You have the right to be informed if your personal data will be subject to automated decision-making, including profiling. You also have the right not to be subject to a decision based solely on automated process, including profiling, where that decision impacts on your legal rights. There are some exceptions to this rule, where, for example, the decision is necessary in connection with the performance of a contract between us, is authorized by law or where you have given your explicit consent to this automated processing. In this case, however, we do not engage in profiling or automated processing for profiling purposes.
The rights described in this section are personal rights and are exercisable only by the individual person (or data subject) concerned. If we receive any such request or communication directly from your customers and/or in relation to Your End Customer Data, we will refer the matter to you and cooperate in providing such reasonable assistance as may be required to enable you, as a controller, to respond to the matter. This will be described in more detailed in the Terms of Service or the other relevant contract between us.
We will not use your data to send marketing communications to you about promotions, competitions, updates and new products or services that may be of interest to you, unless we have your permission to do so.
You have the right to object to the processing of your personal data for our marketing purposes. To object or if you change your mind at any later time, you can withdraw your consent to the processing of your personal data for such marketing purposes by contacting us at email@example.com. You may also opt out of receiving marketing communications at any time by selecting the unsubscribe option when you receive an electronic marketing communication from us. The withdrawal of your consent will not impact upon the lawfulness of processing based on your consent prior to the withdrawal.
Third Party Material
Changes to this policy
Any changes made to this Policy from time to time will be published on our website and it is our stakeholders’ responsibility to maintain themselves updated on the changes.
|Revision #||Date of Revision||Responsible||Comments|
|1||22nd May 2018||Benjamin & Jeanne||First Draft|
Questions or Complaints
The Kind Brand Company Ltd . T/A TanOrganic
Unit B3, Century Business Park,
Newbridge, Co. Kildare
Tel: +353 85 480 820
We are committed to complying with the terms of the GDPR and to the processing of personal data in a fair, lawful and transparent manner. If, however, you believe that we have not complied with our obligations under the GDPR, you have the right to lodge a complaint with the Office of the Data Protection Commissioner.