Terms and
conditions
This Terms & Condition sets out how we, Ebax collect, store
and use information about you when you use or interact with our website,
vbaxstore.com (our website) and
where we otherwise obtain or collect information about you. This Privacy Policy
is effective from May 24, 2018.
Contents
·
Summary
·
Our details
·
Information we collect
when you visit our website
·
Information we collect
when you contact us
·
Information we collect
when you interact with our website
·
Information we collect
when you place an order on our website
·
Our use of automated
decision-making and profiling
·
How we collect or obtain
information about you from third parties
·
Disclosure and additional
uses of your information
·
How long we retain your
information
·
How we secure your information
·
Transfers of your
information outside the European Economic Area
·
Your rights in relation
to your information
·
Your right to object to
the processing of your information for certain purposes
·
Sensitive Personal
Information
·
Changes to our Privacy Policy
·
Children’s Privacy
·
California Do Not Track
Disclosures
·
Copyright, credit and
logo
Summary
This section summarises how we obtain, store and use information
about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in
conjunction with the corresponding full sections of this Privacy Policy.
·
Data controller: Ebax
Inc
·
How we collect or obtain
information about you:
·
when you provide it to us (e.g. by contacting us , placing an
order on our website, sign up for our email newsletter, take a quiz, or create
an account).
·
from your use of our website, using cookies and similar
technologies, and
·
occasionally, from third parties.
·
Information we collect: name,
contact details, payment information e.g. your credit or debit card details, IP
address, information from cookies, information about your computer or device
(e.g. device and browser type), information about how you use our website (e.g.
which pages you have viewed, the time when you view them and what you clicked
on, the geographical location from which you accessed our website (based on
your IP address), your answers to quizzes or surveys, and information about
your internet connection.
·
How we use your
information: for administrative and business purposes (particularly to
contact you and process orders you place on our website), to improve our
business and website, to fulfil our contractual obligations, to advertise our
goods and services, to analyse your use of our website, and in connection with our
legal rights and obligations.
·
Disclosure of your
information to third parties: only to the extent
necessary to run our business, to our service providers, and to fulfil any
contracts we enter into with you, and where required by law or to enforce our legal
rights.
·
Do we sell your
information to third parties (other than in the course of a business sale or
purchase or similar event): No.
·
How long we retain your
information: for no longer than necessary, taking into account any legal
obligations we have (e.g. to maintain records for tax purposes), any other
legal basis we have for using your information (e.g. your consent, performance
of a contract with you or our legitimate interests as a business). For specific
retention periods in relation to certain information which we collect from you,
please see the main section below entitled How long we retain your
information.
·
How we secure your
information: using appropriate technical and organisational measures such
as storing your information on secure servers, encrypting transfers of data to
or from our servers using Secure Sockets Layer (SSL) technology, encrypting
payments you make on or via our website using Secure Sockets Layer (SSL)
technology, only granting access to your information where necessary and by
only trusted individuals that have been trained and briefed on appropriate
handling of personal information.
·
Use of cookies and
similar technologies: we use cookies and similar information-gathering technologies
such as web beacons on our website including essential, functional analytical
and advertising cookies. For more information, please visit our cookies policy
here: https://vbaxstore.com/pages/cookie-policy
·
Transfers of your
information outside the European Economic Area: We
are a company based in the United States. In certain circumstances we transfer
your information outside of the European Economic Area , including to the
following countries: The United States of America, Canada, Ireland, the United
Kingdom. Where we do so, we will ensure appropriate safeguards are in place,
including the third parties we use
who transfer your information outside the European Economic Area have
self-certified themselves as compliant with the EU-U.S. Privacy Shield.
·
Use of automated decision
making and profiling: we use automated decision making and/or profiling. We do this
in order to protect our business from harm from fraud during the checkout
process via our partner Signify (privacy policy here: https://www.signifyd.com/privacy/ ).
·
Your rights in relation
to your information
·
to access your information and to receive information about its
use
·
to have your information corrected and/or completed
·
to have your information deleted
·
to restrict the use of your information
·
to receive your information in a portable format
·
to object to the use of your information
·
to withdraw your consent to the use of your information
·
to complain to a supervisory authority
·
Sensitive personal
information: we collect what is commonly referred to as ‘sensitive personal
information’ in only two instances on the site: birthday data and skin tone
preferences in your account on our website. Both instances are completely
optional and only accepted upon the provision of explicit consent from users
and are securely stored on our web servers for use in personalizing our
correspondence with you via email or on site. This data is not used in any way,
shape, or form to perform automated decision making other than to customize
website or email content which we may think is most compelling to you. Any
information stored can be viewed and removed directly on your account page or
by contacting us via customer service. Please do not submit other sensitive
personal information about you to us. For more information, please see the main
section below entitled Sensitive Personal Information. This information is
only collected if you provide it to us and our legal basis for collecting it is
that you provide consent to us having this information by granting us this
information in your account. This information can be deleted using the same
mechanism that it is provided to us in your account page or by emailing us
at support@vbaxwallets.com
Our details
The data controller in respect of our website is Ebax Inc of
Dhaka Bangladesh. You can contact the data controller by writing to Ebax
Inc C/O Data Controller Dhaka BD or sending an email to support@vbaxwallets.com
If you have any questions about this Privacy Policy, please
contact the data controller.
Information we collect when you visit our
website
We collect and use information from website visitors in
accordance with this section and the section entitled Disclosure and
additional uses of your information.
Web server log information
We use a third party server to host our website called WordPress
Inc., the privacy policy of which is available here https://www.Wordpress.com/legal/privacy .
Our website server automatically logs the IP address you use to access our
website as well as other information about your visit such as the pages
accessed, information requested, the date and time of the request, the source
of your access to our website (e.g. the website or URL (link) which referred
you to our website), and your browser version and operating system.
Our website servers are located in the United States of America
and Canada and, accordingly, your information is transferred outside the
European Economic Area (EEA). For further information and information on the
safeguards used, please see the section of this privacy policy
entitled Transfers of your information outside the European Economic
Area]].
Use of website server log information for IT security purposes
Our third party hosting provider collect(s) and
store(s) server logs to ensure network and IT security and so that the server
and website remain uncompromised. This includes analysing log files to help
identify and prevent unauthorised access to our network, the distribution of
malicious code, denial of services attacks and other cyber attacks, by
detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal
activity, We/we do not make, nor do we allow our hosting provider to make, any
attempt to identify you from the information collected via server logs.
Legal basis for processing:
compliance with a legal obligation to which we are subject (Article 6(1)(c) of
the General Data Protection Regulation).
Legal obligation: we
have a legal obligation to implement appropriate technical and organisational
measures to ensure a level of security appropriate to the risk of our
processing of information about individuals. Recording access to our website
using server log files is such a measure.
Legal basis for processing: our
and a third party’s legitimate interests (Article 6(1)(f) of the General Data
Protection Regulation).
Legitimate interests: we
and our third party hosting provider have a legitimate interest in using your
information for the purposes of ensuring network and information security.
Cookies and similar technologies
Cookies are data files which are sent from a website to a
browser to record information about users for various purposes.
We use cookies and similar technologies on our website,
including essential, functional, analytical and advertising cookies and web
beacons. For further information on how we use cookies, please see our cookies
policy which is available here: https://vbaxstore.com/pages/cookie-policy
You can reject some or all of the cookies we use on or via our
website by changing your browser settings or non-essential cookies by using our
cookie control tool, but doing so can impair your ability to use our website or
some or all of its features. For further information about cookies, including
how to change your browser settings, please visit www.allaboutcookies.org or
see our cookies policy.
Information we collect when you contact us
We collect and use information from individuals who contact us
in accordance with this section and the section entitled Disclosure and
additional uses of your information.
Email and Contact Form
When you send an email to the email address displayed on our
website we collect your email address and any other information you provide in
that email (such as your name, telephone number and the information contained
in any signature block in your email).
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest(s):
responding to enquiries and messages we receive and keeping records of
correspondence.
Legal basis for processing:
necessary to perform a contract or to take steps at your request to enter into
a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where
your message relates to us providing you with goods or services or taking steps
at your request prior to providing you with our goods and services (for
example, providing you with information about such goods and services), we will
process your information in order to do so).
Transfer and storage of your information
We use a third party email provider/customer service management
tool to store emails and messages you send us. Our third party email provider
is Zendesk, Inc. located in the United States. Their privacy policy is
available here https://www.zendesk.com/company/customers-partners/privacy-policy/
Emails you send us will be stored outside the European Economic
Area on our third party email provider’s servers in the United States and other
locations based on their sub-processors. For further information please see the
section of this privacy policy entitled Transfers of your information outside
the European Economic Area.
Mail
If you contact us by mail, we will collect any information you
provide to us in any postal communications you send us.
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation)
Legitimate interest(s):
responding to enquiries and messages we receive and keeping records of
correspondence.
Legal basis for processing:
necessary to perform a contract or to take steps at your request to enter into
a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where
your message relates to us providing you with goods or services or taking steps
at your request prior to providing you with our goods and services (for example,
providing you with information about such goods and services), we will process
your information in order to do so).
Information we collect when you interact with
our website
We collect and use information from individuals who interact
with particular features of our website in accordance with this section and the
section entitled Disclosure and additional uses of your information.
E-Newsletter
When you sign up for our e-newsletter on our website or opt to
receive news, offers, updates on out-of-stock items from us by entering your name and email address and clicking
subscribe or ticking a box at checkout indicating that they would like to
receive your e-newsletter, we collect your email address , information
about your browser, information about the page you signed up on, and any
other additional information you may provide to us.
Text Marketing and notifications (if applicable): By entering
your phone number in the checkout and initializing a purchase, you agree that
we may send you text notifications and text marketing offers. You can
unsubscribe from further text messages by replying STOP. Message and data rates
may apply.
Legal basis for processing: your
consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent
to us sending you our e-newsletter by signing up to receive it using the steps
described above.
Transfer and storage of your information
We use a third party service to send out our e-newsletter and
administer our mailing list, Klaviyo. Their privacy policy is available
here: https://www.klaviyo.com/privacy .
Information you submit to subscribe for our e-newsletter will be
stored outside the European Economic Area on our third party mailing list
provider’s servers in the United States. For further information about the
safeguards used when your information is transferred outside the European
Economic Area, see the section of this privacy policy below
entitled Transfers of your information outside the European Economic Area.
Use of web beacons and similar technologies in emails]
We use technologies such as web beacons (small graphic files) in
the emails we send to allow us to assess the level of engagement our emails
receive by measuring information such as the delivery rates, open rates and
click through rates which our emails achieve. We will only use web beacons in
our emails if you have consented to us doing so.
or more information on how we use web beacons in our
e-newsletter emails, see our cookies policy which is available here: https://vbaxstore.com/pages/cookie-policy
[For more information about our third party mailing list
provider and they use web beacons, please see their privacy policy which is available
here: https://www.klaviyo.com/privacy
Registering on our website
When you register and create an account on our website, we
collect the following information: Email address, IP address, and any other information
you provide to us when you complete the registration form.
If you do not provide the mandatory information required by the
registration form, you will not be able to register or create an account on our
website.
Legal basis for processing: our legitimate
interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest:
registering and administering accounts on our website to provide access to content,
secure access to order history and status for customers and to facilitate the
running and operation of our business.
Transfer and storage of your information
Information you submit to us via the registration form on our
website will be stored outside the European Economic Area on our third party
hosting provider’s servers in The United States and Canada. Our third party
hosting provider is WordPress with servers located throughout North America and
where its sub-processors may be located. Their privacy policy is available
here: https://www.Wordpress.com/legal/privacy
For further information about the safeguards used when your
information is transferred outside the European Economic Area, see the section
of this privacy policy below entitled Transfers of your information outside
the European Economic Area.
Information we collect when you place an order
on our website
We collect and use information from individuals who place an
order on our website in accordance with this section and the section
entitled Disclosure and additional uses of your information.
Information collected when you place an order
Mandatory information
When you place an order for goods or services on our website, we
collect your name, email address, billing address, shipping address, company
name (if applicable), billing name, and information about your browser.
If you do not provide this information, you will not be able to
purchase goods or services from us on our website or enter into a contract with
us.
Legal basis for processing:
necessary to perform a contract (Article 6(1)(b) of the General Data Protection
Regulation).
Reason why necessary to perform a contract: we
need the mandatory information collected by our checkout form to establish who
the contract is with and to contact you to fulfil our obligations under the
contract, including sending you receipts and order confirmations.
Legal basis for processing:
compliance with a legal obligation (Article 6(1)(c) of the General Data
Protection Regulation).
Legal obligation: we
have a legal obligation to issue you with an invoice for the goods and services
you purchase from us and we require the mandatory information collected by our
checkout form for this purpose. We also have a legal obligation to keep
accounting records, including records of transactions.
Optional information
We also collect optional information from you, such as your
phone number or information about how your experience was in the form of a
survey. We also ask you if you would like to receive marketing communications
from us. For further information, see ‘Marketing communications’ in this
section below.
If you do not supply the optional information requested at
checkout, such as phone number. we
will not be able to contact you by phone or SMS.
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation.
Legitimate interests: finding out how a customer’s experience was to improve your business’ website or to be able to contact the
customer by phone in relation to their order.
AND
Legal basis for processing: your
consent (Article 6(1)(a) of the General Data Protection Regulation).
Legitimate interests: you
consent to us processing any optional information you provide by submitting
that information to us.
Processing your payment
After you place an order on our website you will need to make
payment for the goods or services you have ordered. In order to process your
payment we use a third party payment processor (WordPress Payments) and a fraud
gateway to ensure that your order is not fraudulent (Signify inc. Your payment
will be processed by WordPress Payments.
WordPress Payments collects, uses and processes your
information, including payment information, in accordance with their privacy
policies. You can access their privacy policy via the following link(s):
WordPress Payments: https://pay.Wordpress.com/tos-privacy-policy
Signify: https://www.signifyd.com/privacy/
Transfer and storage of your information
WordPress Payments is located in Canada. Information relating to
the processing of your payment is stored outside the European Economic Area on
our [third party payment processor’s servers in Canada and the United States.
For further information about the safeguards used when your
information is transferred outside the European Economic Area, see the section
of this privacy policy below entitled Transfers of your information
outside the European Economic Area.
Legal basis for processing: necessary
to perform a contract (Article 6(1)(b) of the General Data Protection
Regulation).
Reason why necessary to perform a contract: to
fulfil your contractual obligation to pay for the goods or services you have
ordered from us.
Marketing communications
At checkout and upon first arriving to the site you will have
the option of receiving marketing communications from us.
Our similar goods and services
You can opt-out from receiving marketing communications in
relation to our goods and which are similar to those which you purchase from
us, by ticking a box to opt out or clicking ‘unsubscribe’ in any email from us.
We will send you marketing communications in relation to similar
goods and services if you do not opt out from receiving them.
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interests:
direct marketing and advertising our products and services.
Transfer and storage of your information
We use a third party service to administer our mailing list,
Klaviyo, Inc. Information you submit to subscribe for our e-newsletter will be
stored outside the European Economic Area on our third party mailing list
provider’s servers in the United States. For further information about the
safeguards used when your information is transferred outside the European
Economic Area, see the section of this privacy policy below
entitled Transfers of your information outside the European Economic Area.
Use of web beacons [and similar technologies] in emails
We use technologies such as web beacons (small graphic files in
the emails we send to allow us to assess the level of engagement our emails
receive by measuring information such as the delivery rates, open rates and
click through rates which our emails achieve. We will only use web beacons in
our emails if you have consented to us doing so.
For more information on how we use web beacons in our emails,
see our cookies policy which is available here: https://vbaxstore.com/pages/cookie-policy
For more information about our third party mailing list provider
and they use web beacons, please see their privacy policy which is available
here: https://www.klaviyo.com/privacy
Our goods and services
You can opt in to receiving marketing communications from us in
relation to our goods and services by email ticking a box indicating that you would like to receive such
communications during checkout or at any time while browsing the site by
entering your email address into our newsletter sign-up form.
We will send you marketing communications in relation to our
goods and services only if you opt-in to receive them.
Legal basis for processing:
consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent
to us sending you information about our goods and services by signing up to
receive such information in accordance with the steps described above.
Transfer and storage of your information
We use a third party service to administer our mailing list,
Klaviyo, Inc. Information you submit to subscribe for our e-newsletter will be
stored outside the European Economic Area on our third party mailing list
provider’s servers in the United States. For further information about the
safeguards used when your information is transferred outside the European
Economic Area, see the section of this privacy policy below
entitled Transfers of your information outside the European Economic Area.
Use of web beacons [and similar technologies] in emails
We use technologies such as web beacons (small graphic files in
the emails we send to allow us to assess the level of engagement our emails
receive by measuring information such as the delivery rates, open rates and
click through rates which our emails achieve. We will only use web beacons in
our emails if you have consented to us doing so.
For more information on how we use web beacons in our emails,
see our cookies policy which is available here: https://vbaxstore.com/pages/cookie-policy
For more information about our third party mailing list provider
and they use web beacons, please see their privacy policy which is available
here: https://www.klaviyo.com/privacy
Information collected or obtained from third
parties
This section sets out how we obtain or collect information about
you from third parties.
Information received from third parties
Generally, we do not receive information about you from third
parties. The third parties from which we receive information about you will
generally include partner companies who we are doing a joint promotion with..
It is also possible that third parties with whom we have had no
prior contact may provide us with information about you.
Information we obtain from third parties will generally be your
name and contact details, but will include any additional information about you
which they provide to us.
Legal basis for processing:
necessary to perform a contract or to take steps at your request to enter into
a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where
a third party has passed on information about you to us (such as your name and
email address) in order for us to provide services to you, we will process your
information in order to take steps at your request to enter into a contract
with you and perform a contract with you (as the case may be).
Legal basis for processing:
consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked
that a third party to share information about you with us and the purpose of
sharing that information is not related to the performance of a contract or
services by us to you, we will process your information on the basis of your
consent, which you give by asking the third party in question to pass on your
information to us.
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interests: where
a third party has shared information about you with us and you have not
consented to the sharing of that information, we will have a legitimate
interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing
your information to perform our obligations under a sub-contract with the third
party, where the third party has the main contract with you. Our legitimate
interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us
if you have infringed or potentially infringed any of our legal rights. In this
case, we will have a legitimate interest in processing that information to
investigate and pursue any such potential infringement.
Where we receive information about you in
error
If we receive information about you from a third party in error
and/or we do not have a legal basis for processing that information, we will
delete your information.
Our use of automated decision-making and
profiling
We use automated decision making and profiling on our website.
We do not consider that this has any legal effect on you or similarly
significantly affects you.
You have the right to object to our use of automated decision
making and profiling described in this section. You can do that by opting-out
of cookies and similar technologies in accordance with the method described in
the relevant section below. If you do not want us to process your actual IP
address (usually the IP address assigned to you by your Internet Service
Provider) when you visit our website, you can use a Virtual Private Network
(VPN) or a free service such as Tor.
You can find out more about our use of cookies and similar
technologies (including the legal basis on which we use them) and how to opt
out from them in our cookies policy, which is available here: https://vbaxstore.com/pages/cookie-policy
Automated decision making
Automated decision making is decision making by technological
means (i.e. by a machine) without human involvement.
Use of automated decision making for display advertising]
We automate the display advertisements containing our products
and services on other websites you visit, you based on the fact that you have
visited our website using cookies. For further information on the cookies we
use, please see our cookies policy which is available here: https://vbaxstore.com/pages/cookie-policy
Logic involved:
automatically displaying advertisements to individuals who have visited our
website results in increased efficiencies and costs savings for us than
manually displaying advertisements or displaying advertisements by different
means.
Significance and envisaged consequences:
cookies will be used to recognise the fact that you have visited our website in
order to display advertisements to you (unless you have blocked such cookies)
and will collect information about your online behaviour.
How to object: you
can block these cookies by using
the cookies control management tool on our site or by opting out of seeing
personalised ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB]. For
further information, please see our cookies policy: https://vbaxstore.com/pages/cookie-policy
Profiling
Profiling is any form of automated processing of your information
to evaluate personal aspects about you, in particular to analyse or predict
things like your performance at work, economic situation, health, personal
preferences, interests, reliability, behaviour, location or movements.
Use of profiling for web analytics
Our web analytics services, Google Analytics and Qubit, Inc. use
collects information such as your location (based on your IP address) and your
behaviour (based on cookies) when you access our website (such as the pages you
visit and what you click on) and how much you are spending on our site. We will
only process information from cookies if you have consented to us setting
cookies on your computer in accordance with our cookies policy. Information
collected about you, once collected is anonymised and stored on an aggregate
basis. IP addresses are anonymized at the point of collection on our site.
Logic involved: by
automatically analysing and categorising information such as the location
(based on IP address) as well as the behaviour and devices of visitors to our
website (using cookies), we are able to gain a better understanding of what our
website visitors want (in terms of the content of our website and our
products), how to improve our website and how to advertise and market our
services to them.
Significance and envisaged consequences:
cookies will be used to track and store information about your behaviour and
device on our website (unless you have opted out from receiving such cookies by
using our cookie control tool and your location will be analysed based on your
IP address. We may target advertisements or content on our site based on the
level of interest we receive from certain visitors and their behaviour on our
website.
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation) and the basis upon you give us consent to use this by opting into
cookie tracking.
Legitimate interest: :
improving our website for our website users and getting to know our website
users’ preferences so our website can better meet their needs and desires. Also
to serve advertisements to you which seem most relevant to the visitor.
Use of profiling in marketing emails
We use web beacons in our marketing emails to analyse who opens
our emails and what actions they take (for example, what they click on). We
will only process information from web beacons if you have consented to their
use in accordance with our cookies policy (https://vbaxstore.com/pages/cookie-policy ).
Logic involved: by
analysing how our email recipients respond to our emails, we are able to
improve the content and effectiveness of our emails and gauge who is most
interested.
Significance and envisaged consequences: your
behaviour when you open our emails will be tracked using small gif files (web
beacons), including open rates, click through rates, and what items you clicked
on in an email.
How to object: You
may object to this by contacting us at support@vbaxwallets.com or you
may opt out by using our cookie control tool.
Legal basis for processing:
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest:
analysing the level of engagement and effectiveness of our marketing emails and
content
Disclosure and additional uses of your
information
This section sets out the circumstances in which will disclose
information about you to third parties and any additional purposes for which we
use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services
which are necessary to run our business or to assist us with running our
business and who process your information for us on our behalf. These include
the following:
·
Email provider(s), including Klaviyo Inc. Their privacy policy
is available here: klaviyo.com/privacy
·
Customer Service System Provider: Zendesk Inc. Their privacy
policy is available here:
·
IT service provider(s), including Shipping Easy and Microsoft
Azure. Their privacy policies are available here: https://support.shippingeasy.com/hc/en-us/articles/115003637406-Privacy-Policy https://privacy.microsoft.com/en-us/privacystatement
·
Hosting provider(s), including WordPress Inc. Their privacy
policy is available here: WordPress.com/privacy
Our third party service providers are located in the
United State and Canada.
Your information will be shared with these service providers
where necessary to provide you with the service you have requested, whether
that is accessing our website or ordering goods and services from us.
We do not display all the identities of all of our service
providers publicly by name for security and competitive reasons. If you would
like further information about the identities of our service providers, however,
please contact us directly via our contact form or by email at
help@vbaxstore.com and we will provide you with such information where you have
a legitimate reason for requesting it (where we have shared your information
with such service providers, for example).
Legal basis for processing:
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest relied on: where
we share your information with these third parties in a context other than
where is necessary to perform a contract (or take steps at your request to do
so), we will share your information with such third parties in order to allow
us to run and manage our business efficiently.
Legal basis for processing:
necessary to perform a contract and/or to take steps at your request prior to
entering into a contract (Article 6(1)(b) of the General Data Protection
Regulation).
Reason why necessary to perform a contract: we
may need to share information with our service providers to enable us to
perform our obligations under that contract or to take the steps you have
requested before we enter into a contract with you.
Disclosure of your information to other third
parties
We disclose your information to other third parties in specific
circumstances, as set out below.
Providing information to third parties such as Google Inc. Google collects information
through our use of Google Analytics on our website. Google uses this
information, including IP addresses and information from cookies, for a number
of purposes, such as improving its Google Analytics service. Information is
shared with Google on an aggregated and anonymised basis. To find out more
about what information Google collects, how it uses this information and how to
control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s):
meeting our contractual obligations to Google under our Google Analytics Terms
of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by installing the browser
plugin here: https://tools.google.com/dlpage/gaoptout
Transfer and storage of your information
Information collected by Google Analytics is stored outside the
European Economic Area on Google’s servers in the United States of America.
For further information about the safeguards used when your
information is transferred outside the European Economic Area, see the section
of this privacy policy below entitled Transfers of your information
outside the European Economic Area.
Sharing your information within our business’ group of
companies, including Seed Beauty for internal administrative purposes,
including client, customer and employee information.
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest:
running and managing our business effectively.
AND
Legal basis for processing:
necessary to perform a contract [or to take steps at your request prior to
entering into a contract] (Article 6(1)(b) of the General Data Protection
Regulation).
Reason why necessary to
perform a contract: we need to share your information with other companies in
order to be able to meet our contractual obligations to you or to take steps at
your request prior to entering a contract., for example because of the services
or information you have requested.
Sharing your information with a prospective or actual purchaser
or seller in the context of a business or asset sale or acquisition by us, a
merger or similar business combination event, whether actual or potential.
Legal basis for processing:
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest(s):
sharing your information with a prospective purchaser, seller or similar person
in order to allow such a transaction to take place.
Disclosure and use of your information for
legal reasons
Indicating possible criminal acts or threats to public security
to a competent authority
If we suspect that criminal or potential criminal conduct has
been occurred, we will in certain circumstances need to contact an appropriate
authority, such as the police. This could be the case, for instance, if we
suspect that we fraud or a cyber crime has been committed or if we receive
threats or malicious communications towards us or third parties.
We will generally only need to process your information for this
purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interests:
preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our
legal rights
We will use your information in connection with the enforcement
or potential enforcement of our legal rights, including, for example, sharing
information with debt collection agencies if you do not pay amounts owed to us
when you are contractually obliged to do so. Our legal rights may be
contractual (where we have entered into a contract with you) or non-contractual
(such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest: enforcing
our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or
proceedings
We may need to use your information if we are involved in a
dispute with you or a third party for example, either to resolve the dispute or
as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest(s): resolving
disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal
requirements
We will use and process your information in order to comply with
legal obligations to which we are subject. For example, we may need to disclose
your information pursuant to a court order or subpoena if we receive one.
Legal basis for processing:
compliance with a legal obligation (Article 6(1)(c) of the General Data
Protection Regulation).
Legal obligation(s): legal
obligations to disclose information which are part of the laws of the United
States of America.
Legal basis for processing: our
legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest: where
the legal obligations are part of the laws of another country and have not been
integrated into the United States’ legal framework, we have a legitimate
interest in complying with these obligations.
How long we retain your information
This section sets out how long we retain your information. We
have set out specific retention periods where possible. Where that has not been
possible, we have set out the criteria we use to determine the retention
period.
Retention periods
Order information: when
you place an order for goods and services, we retain that information
indefinitely or until you request that we delete unless this conflicts with our
compliance of a legal responsibility.
Correspondence and enquiries: when you make an enquiry or
correspond with us for any reason, whether by email or via our contact form ,we
will retain your information for as long as it takes to respond to and resolve
your enquiry and indefinitely afterward unless it is requested to be deleted
AND it does not interfere with our compliance with laws and our legitimate
business interest.
E-Newsletter: we retain the information you used to sign up for
our e-newsletter for as long as you remain subscribed (i.e. you do not
unsubscribe) or if we decide to cancel our e-newsletter service, whichever
comes earlier.
Criteria for determining retention periods
In any other circumstances, we will retain your information for
no longer than necessary, taking into account the following:
·
the purpose(s) and use of your information both now and in the
future (such as whether it is necessary to continue to store that information
in order to continue to perform our obligations under a contract with you or to
contact you in the future);
·
whether we have any legal obligation to continue to process your
information (such as any record-keeping obligations imposed by relevant law or
regulation);
·
whether we have any legal basis to continue to process your
information (such as your consent);
·
how valuable your information is (both now and in the future);
·
any relevant agreed industry practices on how long information
should be retained;
·
the levels of risk, cost and liability involved with us
continuing to hold the information;
·
how hard it is to ensure that the information can be kept up to
date and accurate; and
·
any relevant surrounding circumstances (such as the nature and
status of our relationship with you).
How we secure your information
We take appropriate technical and organisational measures to
secure your information and to protect it against unauthorised or unlawful use
and accidental loss or destruction, including:
·
only sharing and providing access to your information to the
minimum extent necessary, subject to confidentiality restrictions where
appropriate, and on an anonymised basis wherever possible;
·
using secure servers to store your information;
·
verifying the identity of any individual who requests access to
information prior to granting them access to information;
·
using Secure Sockets Layer (SSL) software to encrypt any
information you submit to us via any forms on our website and any payment
transactions you make on or via our website;
·
only transferring your information via closed system or
encrypted data transfers
Transmission of information to us by email
Transmission of information over the internet is not entirely
secure, and if you submit any information to us over the internet (whether by
email, via our website or any other means), you do so entirely at your own
risk.
We cannot be responsible for any costs, expenses, loss of
profits, harm to reputation, damages, liabilities or any other form of loss or
damage suffered by you as a result of your decision to transmit information to
us by such means.
Transfers of your information outside the
European Economic Area
We process data both inside and outside of the
United States and rely on legally-provided mechanisms to lawfully transfer data
across borders. Countries where we and our data processors process data may
have laws which are different, and potentially not as protective, as the laws
of your own country.
Your information will be transferred and stored outside the
European Economic Area (EEA) in the circumstances set out below. We will also
transfer your information outside the EEA or to an international organisation
in order to comply with legal obligations to which we are subject (compliance
with a court order, for example). Where we are required to do so, we will
ensure appropriate safeguards and protections are in place.
Server log information
Information collected when you visit our website is transferred
outside of the EEA and stored on the servers of our third party hosting company
, WordPress. You can access their privacy policy here: www.Wordpress.com/privacy
Country of storage: Canada and the United States
Safeguard(s) used: our third party hosting provider has
self-certified its compliance with the EU-U.S. Privacy Shield.
Contact form and Email
Information you submit to us via our contact form is transferred
outside the EEA and stored on our third party email and customer service
systems. Our email provider is
Klaviyo Inc. You can access their privacy policy here: www.klaviyo.com/privacy. Our customer service
system provider is Zendesk. You can access their privacy policy here: https://www.zendesk.com/company/customers-partners/eu-data-protection/
Country of storage: United States. This country is not subject
to an adequacy decision by the European Commission.
Safeguard(s) used: our third party email provider has
self-certified its compliance with the EU-U.S. Privacy Shield
E-Newsletter
Information you submit to us when you sign up for our
e-newsletter is transferred outside the EEA and stored on our third party
mailing list provider’s servers. Our third party mailing list provider is:
Klaviyo. You can access their privacy policy here: www.klaviyo.com/privacy
Country of storage: The United States. This country is not
subject to an adequacy decision by the European Commission.
Safeguard(s) used: our third party mailing list provider has
self-certified its compliance with the EU-U.S. Privacy Shield.
Google Analytics
Information collected by Google Analytics (your IP address and
actions you take in relation to our website) is transferred outside the EEA and
stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is
not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with
the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The
EU-U.S. Privacy Shield is an approved certification mechanism under Article 42
of the General Data Protection Regulation, which is permitted under Article
46(2)(f) of the General Data Protection Regulation. You can access the European
Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Payment Processor
Information you submit to us by our third party payment
processor, WordPress Payments, is transferred outside the EEA and stored on
their servers. You can access their privacy policy here: https://pay.Wordpress.com/tos-privacy-policy
Country of storage: The United States and Canada. These
countries are not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our payment processor has self-certified its
compliance with the EU-U.S. Privacy Shield.
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the
following rights in relation to your information, which you can exercise by
sending an email to help@vbaxstore.com
·
to request access to your
information and information related to our use and processing of your
information;
·
to request the correction
or deletion of your information;
·
to request that we
restrict our use of your information;
·
to receive information
which you have provided to us in a structured, commonly used and
machine-readable format (e.g. a CSV file) and the right to have
that information transferred to another data controller (including a third
party data controller);
·
to object to the
processing of your information for certain purposes (for
further information, see the section below entitled Your right to object
to the processing of your information for certain purposes); and
·
to withdraw your consent
to our use of your information at any time where we rely
on your consent to use or process that information. Please note that if you
withdraw your consent, this will not affect the lawfulness of our use and
processing of your information on the basis of your consent before the point in
time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection
Regulation, EU Residents also have the right to lodge a complaint with a
supervisory authority, in particular in the Member State of your habitual
residence, place of work or of an alleged infringement of the General Data
Protection Regulation.
Further information on your rights in relation to your personal
data as an individual
The above rights are provided in summary form only and certain
limitations apply to many of these rights. For further information about your
rights in relation to your information, including any limitations which apply,
please visit the following pages on the ICO’s website:
·
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as
well as information on any limitations which apply to those rights, by reading
the underlying legislation contained in Articles 12 to 22 and 34 of the General
Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your
information
Where you request access to your information, we are required by
law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to
reduce the risk of identity fraud, identity theft or general unauthorised
access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we
will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or
if we have insufficient information about you, we may require original or
certified copies of certain documentation in order to be able to verify your
identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to
verify your identity in your specific circumstances if and when you make such a
request.
Your right to object to the processing of your
information for certain purposes
You have the following rights in relation to your information,
which you may exercise in the same way as you may exercise by writing to
Ebax Dhaka Bangladesh or sending an email to
: support@vbaxwallets.com
·
to object to us using or processing your information where we
use or process it in order to carry
out a task in the public interest or for our legitimate interests,
including ‘profiling’ (i.e. analysing or predicting your behaviour based on
your information) based on any of these purposes; and
·
to object to us using or processing your information for direct marketing purposes (including any
profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or
processing your information for direct marketing purposes by:
·
clicking the unsubscribe
link contained at the bottom of any marketing email we send to
you and following the instructions which appear in your browser following your
clicking on that link;
For more information on how to object to our use of information
collected from cookies and similar technologies, please see the section
entitled How to accept or reject cookies in our cookies policy, which
is available here: https://vbaxstore.com/pages/cookie-policy
Sensitive Personal Information
‘Sensitive personal information’ is information about an
individual that reveals their racial or ethnic origin, political opinions,
religious or philosophical beliefs, or trade union membership, genetic
information, biometric information for the purpose of uniquely identifying an
individual, information concerning health or information concerning a natural
person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal
information from individuals, and you must not submit sensitive personal
information to us.
If, however, you inadvertently or intentionally transmit
sensitive personal information to us, you will be considered to have explicitly
consented to us processing that sensitive personal information under Article
9(2)(a) of the General Data Protection Regulation. We will use and process your
sensitive personal information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will
update our Privacy Policy with a new effective date stated at the beginning of
it. Our processing of your information will be governed by the practices set
out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we
process your information
Where we make major changes to our Privacy Policy or intend to
use your information for a new purpose or a different purpose than the purposes
for which we originally collected it, we will notify you by email (where
possible) or by posting a notice on our website.
We will provide you with the information about the change in
question and the purpose and any other relevant information before we use your
information for that new purpose.
Wherever required, we will obtain your prior consent before
using your information for a purpose that is different from the purposes for
which we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online,
we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA).
COPPA and its accompanying regulations protect the privacy of children using
the internet. We do not knowingly contact or collect information from persons
under the age of 18. The website is not intended to solicit information of any
kind from persons under the age of 18.
It is possible that we could receive information pertaining to
persons under the age of 18 by the fraud or deception of a third party. If we
are notified of this, as soon as we verify the information, we will, where
required by law to do so, immediately obtain the appropriate parental consent
to use that information or, if we are unable to obtain such parental consent,
we will delete the information from our servers. If you would like to notify us
of our receipt of information about persons under the age of 18, please do so
by sending an email to support@vbaxwallets.com
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in
their web browsers. When a user turns on a Do Not Track signal in their
browser, the browser sends a message to websites requesting that they do not
track the user. For information about Do Not Track, please visit www.allaboutdnt.org
For information on how to opt out from tracking technologies
used on our website, see our cookies policy which is available here: https://vbaxstore.com/pages/cookie-policy
Copyright, credit and logo
This Privacy Policy is based on a General Data Protection
Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by
GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org
The copyright in this Privacy Policy is either owned by, or
licensed to, us and is protected by copyright laws around the world and
copyright protection software. All intellectual property rights in this
document are reserved.
Where
we display the GDPR Privacy Policy logo on our website, this is used to
indicate that we have adopted a privacy policy template provided by GDPR
Privacy Policy as the basis for this Privacy Policy.