PRIVACY POLICY
1. INTRODUCTION
We are Stavri Zavrou and TheLifeofXoXo (referred as “we”, “us”, “our”) and are committed to protecting your privacy.
This Privacy Policy provides information on how we collect and use personal data. We operate www.lifeofXoXo.com (the “SITE”). This Privacy Policy sets out the information that we collect, the reasons for which we collect the information, and how we can use and share the information.
The Site and services provided by us are not intended to be used by children. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, you can contact us by sending an email to thelifeofxoxo@outlook.com .
2. WHAT INFORMATION DO WE COLLECT, AND HOW?
When you interact with us, whether by using our Site or communicating with us, we may collect the following information about you:
• Information you give us: you may give us information about yourself if you sign up for an account on our Site, place an order for products, complete any online forms (such as registration forms, competitions, and surveys), opt in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions with our Site, or correspond with us (by email, telephone, instant messaging apps, social media or otherwise).
Depending on what you provide, this information can include your name, address or location, phone number, email address, date of birth, gender, purchase information, shopping preferences, images and financial information.
If you register an account on the Site, then you may choose to give us your photograph and nickname. From your account, you can also invite your friends to shop at our Site (including by email, Facebook, or Twitter). Even though we let them know that we’ve received their details from you, please ensure that you have your friend’s permission before sharing their contact details with us and only forward emails to people you know would be happy to receive them.
• Information we receive from other accounts or sources: we can receive information about you from other sources, such as from your other accounts (like when you use your Apple ID or Google Sign In to sign in on our Site) or other websites, including data brokers, social media providers like Facebook and Twitter, advertising networks and analytics partners, and payment and delivery service providers.
We supplement the data you provide us with data from data appending services such as public or social graph data in order to better serve you with content or promotions. We will append this data to our existing customer account information to better understand customers’ interests and to provide more relevant product recommendations and advertising, to increase our customer’s security when using our Site and to comply with our legal obligations, such as sanctions laws. This information may include household size, household income, or profession. This information can be associated with your personal information such as name, email, address, physical address or phone number.
• Information our IT systems collect about you: each time you visit the Site, certain information will be created and automatically recorded by our IT systems. That information includes:
Cookies: you can see more details about cookies in our Cookies Policy, but these small text files can help improve your experience with the Site and make it easier to interact with us. This may include storing your location or language preferences to save you having to re-enter information when returning to, or ensuring that items you wish to order don’t disappear as you navigate between pages on our Site. We also use cookies to provide you with tailored advertising.
Device information: the information provided by your device will differ depending on your operating system and device settings (eg. PC, Mac, iPhone, Android, or otherwise), but includes the type of device you have (eg. iPhone 6S or Samsung Galaxy S7), the device’s IP address and location, the browser you’re using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.
3. WHAT DO YOU USE MY INFORMATION FOR?
To provide you services and the Site, including to allow you to order and receive products using our Site, administer your account and to optimise your experience we need to use the information that we collect in a number of different ways.
We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications or when you have made a purchase using our services, we will use your personal information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information, to tailor these messages to you. You may unsubscribe from our email marketing communications by following the opt out instructions in the promotional emails that are sent to you.
We may use your information to provide you with shopping recommendations and personal styling-related services, therefore, you’ll have access to an improved and more interactive shopping experience.
We also carry out research, analysis, and surveys on your use of our Site, and views. Finally we use your information to confirm your identity and perform credit checks or anti-fraud checks, in order to ensure your, and our, financial security. Please scroll down to find out the detailed purposes for which we collect your information, what specific information is collected and the legal basis for which we purpose that data.
- To register and manage your account in our Site, we collect your name, email, password and other additional details you may wish to add in your account, like phone number, addresses and gender. The legal basis is the performance of a Contract with you.
- To fulfil the orders you make through our Site, we collect your Name, addresses, phone number, Order details, like the products you are buying, the size and price. The legal basis is the performance of a Contract with you.
- To provide you with our customer services (including helping you to solve any issue you have with our services, updating you about any change to our terms of service, or contacting you to know how was your experience with us): we collect your name, email, password, phone number and addresses and your contact history with us. The legal basis is the performance of a Contract with you and our legitimate interests in retaining you as a customer.
- To monitor the quality of our customer services, we collect your name, email, password, phone number and addresses, your response to our SMS inquiries about the quality of the service and your contact history with us (including phone records of our conversations and conversations through email or other instant messaging apps). The legal basis is the legitimate interests in running our business.
- To administer, maintain and optimise our Site and our services, we collect your device information (such as your device IP address and device type), cookie identifiers and browsing information. The legal basis is the legitimate interests in running our business.
- To send you marketing communications and personalised offers, we collect your name, email, phone number, addresses, date of birth, purchase history, browsing history and behaviour, device information, shopping preferences, cookie identifiers, internal identifiers and country. The legal basis is the legitimate interests in electronic direct marketing of similar products and services which you have acquired using our Site.
- To provide you with personalised recommendations and enhance your experience, we collect your name, email, phone number, addresses, date of birth, purchase history, browsing history and behaviour, in-stores interactions with products, device Information, shopping preferences, nickname, cookie identifiers, internal identifiers, country, spent tier level and wealth. The legal basis is our legitimate interests in running our business and improving your shopping experience.
- To carry on research, analysis, enquiries and surveys on your use of our Site, we collect your Name; Addresses; Email; Device information, legal basis is our legitimate interests in running our business and improve our Site and your experience.
- To advertise and retarget advertising of our products and services, we collect your email, cookie identifiers and device information. The legal basis is our legitimate interests in running our business.
- To produce aggregated statistical reports, we use your order history, provided that the result of such reports do not identify you. The legal basis is our legitimate interests in running our business and improving our Site.
4. WHO DO YOU SHARE MY INFORMATION WITH?
To provide our services and the Site, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:
- Third party service providers for business purposes: to function properly, we rely on a number of carefully selected third parties to provide us with services and products. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products. Below you can find the types of third parties we use:
o Courier companies that we use in order to deliver the products to you and, as such, they need to have access to your order information, including your name and address.
o Payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you.
o Anti-fraud and credit check providers to keep us and you secure. They have access to and process your information and associated orders to check for any fraudulent behaviour.
o Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimisation of the Site.
o Customer Service management providers, that allow us to provide our customer services and improve and manage your customer experience.
o Marketing Tools providers that help us enable our marketing.
o Performance Marketing and Recommendations Providers that help us deliver advertising and recommendations of our products tailored to your interests and needs.
o Research companies that we can engage to help us carry out surveys regarding your use of our Site and Services.
o IT/technology providers that we use to support, maintain and provide our technology and IT infrastructure that supports our Site and the storage of your information.
2. Advertisers for marketing purposes: we can provide your information to our advertising and social media partners that you select (including Facebook and Twitter), where they require the data to select and serve relevant adverts about our products and services to you and others.
3. Third parties where we are considering a corporate transaction: We are always looking for new opportunities and directions in which to grow. This means sometimes we may consider corporate transactions such as merger, acquisitions, reorganisations, asset sale, or similar. In these instances, we may transfer your information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, your personal information may be one of the assets that are transferred.
4. To comply with legal requests: on occasion we may be required to liaise with various regulators and law enforcement agencies, whether as a result of law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands.
5. WHERE YOUR INFORMATION WILL BE HELD
When we share your information your information may be transferred outside the European Economic Area.
The transfer of this information is governed by a contract including standard contractual clauses (SCCs) approved by the European Commission.
We will only transfer data to jurisdictions outside the scope of the European General Data Protection Regulation (GDPR) where the appropriate safeguards set out in the GDPR are in place.
6. YOUR RIGHTS AND DATA SUBJECT RIGHTS
You may have certain rights in relation to your information including a right to access or to correct the information we hold on you.
Other rights may be available in certain circumstances. Please see below more details about the rights that may available.
DATA SUBJECT RIGHTS
We’ve listed the rights you have over your information and how you can use them below.
These rights will only apply in certain circumstances. They will generally not be available if there are outstanding contracts between us, if we required by law to keep the information or if the information is relevant to a legal dispute.
- You can remove consent, where you have provided it, at any time.
- You can ask us to confirm if we are processing your information.
- You can ask for access to your information.
- You can ask to correct your information if it’s wrong.
- You can ask us to delete your information. You have a right to be forgotten and you can ask that our systems stop using your information.
- You can ask us to restrict how we use your information.
- You can ask us to help you move your information to other companies.
- You can ask us to stop using your personal information, but only in certain cases.
- You have the right to complain to the relevant supervisory authority.
7. SECURITY
Keeping you and your personal information secure is very important to us. We take a number of reasonable steps to try to protect the personal information that you provide, including:
• Using a Transport Layer Secure (TLS) to encrypt the personal data that you send us during the order process.
• Requiring you to establish a unique username and password to access your account on our site.
• Regularly monitoring our servers and IT systems for possible vulnerabilities and attacks. Unfortunately, despite this, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal data transmitted to or through our Site, and any such transmission is at your own risk. In particular, please keep in mind that if you voluntarily disclose personal information through other means of communication than the Site in a non-protected environment (such as through email, sms, online messages) then that information can be collected and used by others outside of our or your control.
8. HOW LONG WILL YOU USE MY INFORMATION FOR?
We retain the data you provide to us for as long as you have your account with us and thereafter for such period as you may have questions or a claim in relation to our services, notwithstanding any superior retention period that we may be obliged to observe in accordance with legal requirements applicable to us.
In some circumstances you can ask us to delete your data by sending us an email.
After you have terminated your use of our services, we may store your information in an aggregated and anonymised format.
9. UPDATES TO THIS POLICY
Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.
COOKIES POLICY
We use technology such as “cookies” to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.
We use the following categories of cookies on our website:
- Strictly necessary cookies: these cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided. These cookies will also inform us, by your behaviour in our website, if we can do business with you and protect us and our customers from fraudulent activities.
- Performance cookies: These cookies collect anonymous information on how you use our Site (eg. we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site) and highlight areas we can improve such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. They are also used to help measure the effectiveness of an advertising campaign. You may opt-in to these cookies using your browser settings.
- Functionality cookies: These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. You may opt in to these cookies using your browser settings.
- Targeting cookies or advertising cookies: These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies to provide you with more personalised adverts when visiting other websites. You may opt-in to these cookies using your browser settings.
You can withdraw your consent to these cookies at any time through the following options:
• Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;
• Other third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu.
• Any other type of cookies, you can clean the cookies through your browser settings.
Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.
