It also explains the process to exercise individual privacy rights regarding one’s personal data held by BOTH.
I BOTH COLLECTION OF PERSONAL DATA
1. Collection of data
BOTH collects personal data through website visits and purchases.
You can disable cookies through your browser. To know more about cookies please refer to Section III below.
When making your first purchase, you proceed to open an account and provide us with the information required in order to place your order and have it delivered. In doing so, you provide the personal data necessary to contact you and deliver your purchase, such as your full name, email address, shipping address, as well as certain financial information (such as your credit card number). In doing so, you allow BOTH to store some of this information in the BOTH customer database. Your credit card information is not stored by BOTH and is sent to a secure third party payment processor.
BOTH may also collect non-personal information about you even if you do not purchase any products on the both.com website.
What use is made of the information you provide on both.com?
BOTH may share certain financial and other information that you submit with third parties who provide services to the website. Said third parties proceed to credit reporting, payment or order fulfillment services, such as verifying your information, authenticating payments and processing orders. In order to combat fraudulent online payments, BOTH, may also share your financial information with a third-party service provider using an online fraud detection tool in order to verify your payment.
BOTH may also disclose the information you provide on the Both.com website to other corporate affiliates in the BOTH group, so that they may contact you namely regarding products and services of such corporate affiliates that may be of interest to you.
BOTH may disclose your information if we believe in good faith that such disclosure is necessary to comply with applicable laws, a subpoena or other legal process. For example, BOTH may disclose such information as is necessary to identify, contact or bring legal action against a person or entity who may be violating the both.com Terms and Conditions, or who may be causing injury to, or interfering with, other users of the both.com website. In the event that BOTH, the BOTH group, or all or part of its or their assets, are acquired by a third party, the both.com customer list may be included in the transferred assets.
Please be aware that BOTH does not control the policies or practices of third parties to which BOTH discloses information about users of the both.com website and that any use or disclosure of such information by third parties is not governed by this Policy. However, transfers of personal information are governed by contractual clauses which ensure compliance with data protection legislation.
Location of data
BOTH transfers personal data to the US through the protection of the EU-US Privacy Shield.
BOTH has implemented security measures to protect the personal information you provide against unauthorized access and use. In particular:
- All data is protected according to the varying levels of risks through physical measures, such as secure areas, technical measures, such as encryption, and organisational measures such as employee security through vetting and supervision.
- All data is retained only for as long as it is legally required to be kept and for as long as necessary for the purposes for which it was collected or transferred, in accordance with BOTH’s Retention Schedule.
- Should BOTH suffer a breach, it would implement its Incident and Breach Response Plan, including notification to Data Protection Authorities, individuals and/or Both’s clients, as applicable, without undue delay.
II PROCESSES TO EXERCISE PRIVACY RIGHTS AT BOTH
1. Changes and access to your personal information
BOTH responds to individual requests for access to one’s personal data, and for changes as necessary, within one month. You can make these requests by following the instructions in Section II, Clause 6 - Contact Us. BOTH may ask for an extension and may charge a reasonable fee to cover administrative costs if necessary. Should BOTH deny the request, it will provide an adequate justification.
Rectification requests can be made by following the instructions in Section II, Clause 6 - Contact Us.
BOTH provides rectification as soon as possible within one month. Should BOTH deny the request, it will provide an adequate justification.
Right to object
Individuals may withdraw consent and object to the use of their personal information. In that case, BOTH will keep the data until the individual chooses to unsubscribe but will not use the data except to provide services requested by said individual.
Restriction on processing
BOTH will inform suppliers and subcontractors as the case may be, of the restrictions on processing of data relating to that individual.
An individual whose data is held by BOTH may challenge our compliance with data protection obligations by filing a complaint with BOTH's Data Protection Officer (the "DPO") by following the instructions in Section II, Clause 6 - Contact Us.
The DPO investigates the complaint in consultation with the BOTH department which is responsible for the use of the data. Should the complaint be well-founded, BOTH will take all appropriate measures to resolve the complaint and, if necessary amend its practices as needed.
To exercise your rights pursuant to the present section, to reach BOTH's DPO or if you have any questions about BOTH's Policy and practices, please feel free to us by phone at +852 2668 9122 or via email at email@example.com.
By using the Both.com website, you consent to the collection, use and disclosure of your information as described in this Policy. This Policy reflects the BOTH current business practices and is subject to change. In the event of any such change or update, a revised policy will be posted on the Both.com website. Please check the Both.com website periodically to remain informed of any changes or updates to the BOTH privacy policies and practices. If you allow BOTH to retain the personal information you provide on the Both.com website in its customer database and BOTH intends to disclose that information to third parties or affiliated companies in a manner that is not already outlined in this Policy, BOTH will notify you by email and provide you with an opportunity to opt out of any further use or disclosure of your personal information.
8.Managing your email preferences
When you subscribe to newsletters or notifications, we collect your email to send you exclusive email updates and promotions. You may unsubscribe from newsletters or 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.
III INFORMATION ABOUT COOKIES
1. What is a Cookie
By continuing to use the both.com website, you consent to our cookie settings and agree that you understand the terms of our cookies policy.
You can edit your preferences at any time. To do so, please refer to our “Managing your cookie preferences” Section below.
What cookies do we use?
There are two categories of cookies on the both.com website:
Website functionality cookies
These cookies are required for basic site functionality. They are essential for the website to function properly and to complete any signup or proceed to any purchase on the website. They also allow us to personalize, facilitate and improve your browsing experience.
Third party cookies
These cookies allow us to track navigation during your visits to the website. This allows us to personalize our activities and advertisements to your preferences and to identify transactions facilitated by our affiliated partners for commission purposes.
Disabling these cookies may result in poorly-tailored recommendations, slow site performance, advertising that is not as relevant to you or not being able to link or share effectively with you over social networks.
We only partner with trusted third-parties with data compliance and protection policies and all of the information sent to third-party partners is anonymized or pseudonymized.
Managing your cookie preferences
You can easily disable and/or delete cookies from your computer, tablet or mobile phone by managing your browser settings.
By following the instructions below, you will be disabling all cookies, including the website functionality cookies described above which enable you to order online and enjoy the services of the both.com website.
In order to manage cookies to best suit your needs, please bear in mind the purpose of cookies when setting your browser.
Please find below instructions about managing and disabling cookies, depending on your browser:
Go to Tools menu, then Internet Options.
Click on Confidentiality, then click on Advanced.
In the Cookies window, select your preferences.
Click the Chrome menu, the upper right button.
Select Settings then click on Show advanced settings.
In the Privacy section, click the Content settings button.
Select your preferred option(s) in the Cookies section.
Click the Menu button and choose Preferences.
Select the Privacy & Security panel and go to the History section.
In the drop-down menu next to Firefox will, choose Use custom settings for history.
Check-mark Accept cookies from websites to enable cookies, and uncheck it to disable them.
Select your preferred option(s) in the Cookies section.
Click on Safari, then Preferences.
Click on the Privacy tab.
Go to Block cookies and select your preferred option(s).