Your Data is Important : It is important to note that, as an eCommerce site, we do collect, use and store data in order to deliver the goods and services you request from us. While we are required to share some data with vendors in order to process credit cards, deliver packages and stream video, we DO NOT resell any data to third parties FOR ANY REASON. Specifically, we DO NOT resell or make available your personal data so that others can sell you stuff you don’t want. We are in the business of delivering the best possible customer experience we can and we use information to help us accomplish this goal. The European Union, to grant people greater visibility into and control over how their data is used, passed legislation that requires companies to gain the active consent from users to collect, use and store data. To comply with this legislation (known as GDPR), we are making a variety of updates to our policies and processes, but there is no change in our fundamental approach to how we use your personal data: we only use your data to help you find relevant products and to deliver your products.
This policy describes the types of information we may collect from you or that you may provide when you visit the above specified website hosted on our platform (our “Website”), our practices for collecting, using, process, maintaining, protecting and disclosing that information, and includes a description of the relevant purposes for which we collect, use, maintain, process, protect and disclose that information. This Policy uses defined terms, the definitions of which are included within the Policy.This policy applies to information we collect:
- On this Website.
- In e-mail, text and other electronic messages exchanged between you, us and/or through the Website.
- When you interact with advertising and applications of third-party websites and services appearing on this Website, if those applications or advertising include links to this policy.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
- Any third party as a result of your interactions with such third party. Such third parties include those with whom you may interact before visiting this Website or through whom you access this Website. Such third parties include those with whom you may interact with because you activated a link (including advertising) that appears or is accessible from or on this Website.
Our website incorporates privacy controls which affect how we will process the data we collect and process. You can use privacy controls to, for example, specify whether you would like to receive direct marketing communications or limit the publication of your information.
Children’s Personal Information
By accepting these privacy policies or using our services you certify that you are of the legal age of majority in the jurisdiction where you reside. We rely upon the understanding that products purchased with a credit card are being purchased by individuals who exceed the legal age of majority in their relevant jurisdiction.
Our Website and any website hosted on our platform is intended for persons of legal age of majority and we do not knowingly collect personal information from individuals of legal age of majority. If you are younger than 18 years of age (or reside in a jurisdiction where the minimum legal age to purchase or view sexually explicit content is greater than 18) then we do not consider you to be of legal age of majority and you may not use this Website or provide, directly or indirectly, any personal or other information about you to or on this Website, including through use of any of its features.
If we learn that we have collected or received personal information from an individual less that the legal age of majority, we will delete that information. If you believe we might have any information from or about an individual less than the legal age of majority, please contact us at: email@example.com.
Information We Collect About You and How We Collect and Use It
Not all data that we collect is “Personal Data”. For the purposes of this Policy the term “Personal Data” means any information that, acting alone or together with other data that we have, is sufficient to identify a specific natural person. Examples of Personal Data elements include: a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a particular natural person.
This Section describes:
- The general categories of personal data that we may process;
- The source and specific categories of data, if any, that we did not obtain directly from you;
- The legal bases and legitimate interest for obtaining or processing such data; and,
- The purposes for which we may obtain and/or process personal data.
Although more details are provided below, we generally use information that we collect about you or that you provide to us, including any Personal Data:
- To present our Website and its contents to you.
- To allow you to participate in interactive features on our Website.
- To provide you with information, products or services that you request from us.
- To provide you with notices about your account, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Website or any products or services we offer or provide though it.
- To fulfill any other purpose for which you provide it.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may collect and process the following categories of information, some or all of which may include Personal Data:
Account data. We may obtain and process data regarding any account you create using the Website. This account data may include your user name, name and other identifying information such as your physical or shipping address, email address, user name, IP address and any preferences you may have established using our Website. It may also include age-verification data that we may be required to obtain to establish that you are of the legal age of majority. Account data may be obtained and processed for the purposes of operating our website, providing our services in the manner in which you may have requested, ensuring the security of our website and services, preventing or investigating attacks and/or fraud, maintaining back-ups of our databases and communicating with you. Our legal basis for this processing is your consent and provision of this data to us, our entry into and performance of any agreement we may have with you, the delivery of goods and services you may have ordered, our legal obligations as required to comply with applicable law regarding age verification, maintenance of proper accounts, attend to security issues and prevent or investigate attacks and/or fraud, protection against money laundering, our need regarding the maintenance of banking and payment processing relationships, and the proper operations of our Website and business.
User content data. We may also collect and process information that you post for publication on our website or through the use of our services as user contributions. User content data can include content you upload and any metadata associated with the upload, ratings and/or reviews and/or comments you may post to any forum, or information you include or exchange with any other user on our Website. User Content may also be shared with third party websites that may publish all or parts of User content data available on our website. Examples of such instances include affiliates (with whom we may share your review and ratings as a part of our marketplace functionality) and Google (which may reproduce all or a portion of your User content data in its publicly available search results). The legal basis for our collection and processing of such data is your consent (by submitting same). Our legitimate interest in processing this data that you provide is namely to attend to security issues and prevent or investigate attacks and/or fraud, address actual or asserted violations of legal rights, enable us to publish the content you submit and to properly administer our Website and services.
You should generally consider your User content data you share with this Website to be public in nature and you should not share any information that you would not want to become known to the general public. Your user contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your user contributions. Therefore, we cannot and do not guarantee that your user contributions, and any User Content Data contained therein will not be viewed by unauthorized persons. Discretion on your part is a key part of your responsibilities. Moreover, if you delete your User Contributions from the Website, copies of your user contributions, and any User Content Data contained therein, may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.
Customer contact data. We may collect and process information contained in any inquiry you submit to us regarding goods and/or services. Such data may include your name and other identifying information such as your physical or shipping address, email address and/or IP address, the communication content, and metadata associated with the communication. Our legal basis and legitimate interest for obtaining and processing such data is to communicate you, respond to your inquiries, and offer, market and sell relevant goods and/or services to you, attend to security issues and prevent or investigate attacks and/or fraud, maintain our record keeping, and properly administer our Website and business.
Sales data. If you engage in transactions with our Website, we may obtain and process information you supply relating to such transactions, including the purchase and shipping of goods and services, that you request from us or through our Website. Such data may include your user name, name and other identifying information such as your physical or shipping address, email address and/or IP address, your payment details, sales tax exemptions, and other information directly related to the specific transaction. The legal basis for obtaining and processing such data is to enter into and perform any contract we may have with you for the purpose of supplying the purchased goods and services and keeping proper records of those transactions, our legal obligations as required to comply with applicable law regarding age verification, maintenance of proper accounts, attend to security issues and prevent or investigate attacks and/or fraud, protection against money laundering, our need regarding the maintenance of banking relationships, and the proper operations of our Website and business.
Solicitation data. We may also obtain and process such data that you may voluntarily provide to us for the purpose of subscribing to our email notifications and/or newsletters. Subscription to our mailing list requires a double opt-in process, pre-checked with a “General” category opt-out. An opt-out option is also provided in the footer of each email and is also available upon request during any customer service call. You may subscribe using the form available on the Website. Subscribers receive periodic email notices that include special offers, information about sales, promotions, new releases, and other relevant information. To unsubscribe from any list, click on the link at the top or bottom of the email and type your email address in the field marked “unsubscribe.” Our legal basis for obtaining this data is your consent when you opt into such programs. We may legitimately process this data to send you the relevant notifications and/or newsletters as you have requested, attend to security issues and prevent or investigate attacks and/or fraud, and the proper operations of our Website and business.
Affiliation data. We maintain relationships with various wholesalers, distributors and affiliates (“resellers”) regarding the sale of goods and services from our Website. In connection with the formation and duration of our relationships with resellers, we may obtain and process information in each of the above specified categories. We may obtain some such data directly from the resellers. Our legal basis and legitimate interest in obtaining and processing such data is our entry into and performance of any agreement we may have with the reseller, the delivery of goods and services they may have ordered (or that you may have ordered through such reseller), our legal obligations as required to comply with applicable law regarding age verification, maintenance of proper accounts, protection against money laundering, our need regarding the maintenance of banking relationships, attend to security issues and prevent or investigate attacks and/or fraud, and the proper operations of our Website and business.
Other Reasons for data Collection & Processing. We may process any of your personal data, whether or not identified in this policy:
- Where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests to protect and assert our legal rights, your legal rights, and the legal rights of third parties.
- Where necessary and as legitimately required for us to secure and maintain adequate insurance policies, manage risks, ensure the security of our website and services, attend to security and prevent or investigate attacks and/or fraud in order to legitimately protect our Website and business against risks.
- To to the extent reasonably is necessary to comply a legal obligation to which we are subject, or to protect the vital interests of you, us or any third party.
Important. Please bear in mind that the data we collect may fall within one or more of the categories set forth above. In such an instance, the legal basis and legitimate interest in our collection and/or processing of such data is inclusive and we will apply the legal basis and legitimate interest most favorable to our activities with regard to such data.
Cookies and other Automatic Data Collection Technologies.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
- Information about your computer and Internet connection, including your IP address, operating system and browser type.
The information we collect automatically helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Session Cookies. A session cookie only lasts as long as you are online. We use these cookies to identify your shopping cart and its contents and to help us personalize your service experience. These session cookies help us facilitate any promotions or surveys that we provide. These cookies do not contain any personally identifying information and we do not store data collected by them.
- Persistent Cookies. As part of the sign-in process, we may also use what are commonly called persistent cookies, which stay with you and are on your computer, after your session is over and you are offline. We use these cookies in connection with a sign-in feature that allows you to remain partially logged in so that the next time you sign in, you will only need to provide your password.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Disclosure of Your Information to Others
We may disclose, without restriction, any aggregated and other information about our users that does not identify any individual and does not constitute Personal Data as defined above.
- To any member of our group of companies (including our subsidiaries, our ultimate holding company and all its subsidiaries);
- To our resellers or third party suppliers insofar as reasonably necessary for the purposes described regarding ” Account data“, ” Sales data” and ” Affiliation data“;
- To contractors, service providers and other third parties to the extent reasonably necessary for the maintenance, security, and proper operation of the Website;
- To our insurers and/or professional advisers to the extent reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, prevention or investigation of security breaches and fraud, obtaining professional advice, or the establishment, exercise or defense of legal or equitable claims, whether in court proceedings or in an administrative or out-of-court procedure;
- To a potential buyer or other successor (and/or their advisors) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is among the assets transferred;
- To our payment services providers to the extent necessary for the purposes of processing or refunding payments or addressing complaints and queries relating to such payments or refunds;
- To one or more of our third party advertisers or suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that you can receive the goods or services you have purchased while using our Website;
- To the extent reasonably necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of a third person;
- To third party service providers to the extent reasonably necessary to fulfill, provide and ship goods and/or services you have purchased through the Website;
- Consistent with the purpose for which you agreed to provide it. For example, shipping goods or services to your location, or providing specified recipients the contents and source of your email if you use the “e-mail a friend” feature of our Website;
- For any other purpose disclosed by us, and to which you consent, when you provide the information; and/or,
- With your consent.
Advertisers & Third-Party Websites & Providers
Through our provider, Google Analytics, data is collected about use of our Website. We will not provide Google Analytics with your name, phone number, email address or credit card information. We assign a random number to your usage so that Google Analytics can identify a unique user of our Website although Google Analytics does not associate that number with your personally identifiable information. We recognize that you may prefer to limit or eliminate the data that Google Analytics collects about your use of the Website. Google Analytics does provide an “Opt-out” option. You can review instructions and relevant information about Google Analytics at: http://www.google.com/intl/en/analytics/privacyoverview.html.
International Data Transfers
This section provides information about the circumstances in which your personal data may be transferred between different countries, including countries outside the European Union (EU).
Generally, we may transfer your personal data between different jurisdictions. However, in doing so we will comply with the European Data Protection Directive 95/46/EC (“GDPR”) and other applicable laws regulating the protection for the transfer of personal information between jurisdictions. This means that we may transfer your data to the United States, the EU, or other countries. If you are a European resident, we will endeavor to confirm that either the European Commission has determined that the receiving jurisdiction provides adequate protection of personal data or that other appropriate safeguards are in place, namely the use of relevant standard data protection clauses adopted or approved by the European Commission.
We maintain hosting facilities in Canada and the US . The exact locations of CDN servers processing data from our Website is dependent upon user location and traffic loads – none of which is within our control. CDNs are used to increase the performance of our Website and speed up delivery content to users located in different locations around the globe. Any category of Personal Data may reside in our hosting facilities and/or CDNs for the purposes of providing the services you have requested through our Website and for other purposes set forth as to each such category. To our knowledge the European Commission has made an “adequacy decision” with respect to the adequacy of any data protection laws of Canada and the United States (under the Privacy Shield framework). To our knowledge the European Commission has not made an “adequacy decision” with respect to the adequacy of any data protection laws of Curacao and we have no knowledge as to the exact locations of our provider’s CDN servers. Transfers of your personal data to Curacao will be protected by the fact that all members of our group with access to your personal data have agreed to comply with the GDPR, and by other appropriate safeguards, namely the use of relevant standard data protection clauses adopted or approved by the European Commission.
We maintain a relationship with one or more entities in the United States that perform website development, customer service and marketing services for our group. Website development typically does not involve the transfer of Personal Data but website developers may from time to time have access to information stored on our servers located in Canada for the purposes of performing their work. Customer service may involve access to or the transfer of your Personal Data from our servers in Canada to our service provider but may also include information you provide directly when interacting with our customer service department located in the United States. Marketing services may require access to or transfer of your Personal Data stored on our servers in Canada for the purposes of providing you with marketing services you have requested, including email address, user ID, postal codes, category preferences and the aggregate amount you may have spent utilizing this Website.
We maintain a relationship with one or more service providers in the United States to handle the fulfillment of any orders of tangible goods you have ordered from our Website and we provide them with Account data, Customer Contact Data and Sales Data to the extent necessary to deliver such goods to you. The European Commission has made an “adequacy decision” with respect to the adequacy of any data protection laws of the United States (under the Privacy Shield framework).
In connection with our processing of payments made by you in connection with goods or services you purchase, we use third-parties in Europe to provide banking and credit card processing. When you purchase goods or services from our Website, payment is typically processed via your direct interaction with a webpage provided and controlled by the payment processor. We may share Account Data, Customer Contact Data, and Sales Data with these processors to the extent relevant and necessary to process your payments, refunds, or adjustments necessary in connection with your request to purchase goods and services from our Website, to comply with legal, regulatory, and banking requirements concerning money laundering, attend to security issues and prevent or investigate attacks and/or fraud, maintain our record keeping, and properly administer our Website and business. We have no knowledge or control over such third parties and/or their data practices and any information you enter with such banks and credit card processors is subject to such privacy policies as are maintained by such providers. We are neither liable nor responsible for identifying or otherwise notifying any person regarding changes in any third party’s privacy policies or their actions or omissions pertaining to such information.
In any event, transfers of your personal data to any jurisdiction as to which the European Commission has not made an “adequacy determination” we will endeavor to impose appropriate safeguards, namely the use of relevant standard data protection clauses adopted or approved by the European Commission.
You acknowledge that User Content Data that you voluntarily submit for publication through our Website or services may be available, via the Internet, around the world. Examples of such information could, depending upon the nature of your User Content Data, include personal data. We cannot prevent the use (or misuse) of such data by others.
Data Retention Policy
There are two main categories of data we are primarily concerned with: Personal Data (all of the information that identifies a particular customer (e.g. name, address, email address, etc.) and Sales Data (the purchases any customer may make). We undertake that we will not retain your personal data for periods that are longer than necessary for the purpose for which it was obtained and/or held for processing. We must, however, retain sales data for a minimum of seven years in order to comply with the requirements of various legal and financial regulatory agencies. As a result, in addition to a user’s ability to export/modify/purge personal data from our system, we have a two-tiered approach to purging personal and sales data.
Generally speaking, we will retain your personal data for a minimum period of three (3) years following the last day in which you interacted with us regarding the purpose for which the personal data was obtained and processed. For example, we will retain Sales Data related to any sale for a minimum of three (3) years from the date the relevant goods or services were delivered to or, in the case of streaming video, used by you.
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we undertake to determine a period of retention based upon the relevant applicable statute of limitations as concerns any claim you may have as against each other based upon your interaction with the Website and/or the order or delivery of any goods or services and to attend to security issues and prevent or investigate attacks and/or fraud, maintain our record keeping, and properly administer our Website and business.
In any event, we may retain your personal data where retention is necessary for legal or regulatory compliance purposes or in order to protect the vital interests of either of us or of a third party.
It is important to note that once personal data is purged either by request or our data retention policy, there will be no way for the customer or our customer service department to access any of the data or digital products stored on our servers and associated with that account.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional Offers from the Company. If you do not wish that we retain or use your e-mail address/contact information to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the order form) or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to: firstname.lastname@example.org = Data Privacy Rights – Unsubscribe. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions.
Accessing and Correcting Your Information
Changes relevant to an order may also be made to Personal Data when placing an order.
If your physical address changes or you change your email address, please advise us in writing or update your user account information so our records remain up to date and there is no delay to your receipt of an order. We are not responsible for lost goods or incomplete services due to your failure to update such information.
To exercise any of your rights in relation to your personal data, or to request access to, correct or delete any personal information that you have provided to us, please contact us by e-mail at email@example.com – Privacy Inquiry General- Request Regarding Access or Change and/or by letter to Helmund The Palm Jumeirah – Dubai – United Arab Emirates and/or a fax to (502) 221-7825. Your first and last name cannot be modified once created. We also cannot delete your personal information except by also deleting your user account with us. There are exceptions to our obligation to delete or modify your personal data. In general, we may not accommodate a request to delete or change information if the change would violate any law or regulation or if retention is necessary to exercise the right of freedom of expression and information, comply with a legal obligation, attend to security issues and prevent or investigate attacks and/or fraud, maintain our record keeping, and properly administer our Website and business, to protect the vital interests of you, us, or any third party, or for the establishment, exercise or defense of legal claims.
We reserve the right to require proof of identity and residence, and (subject to applicable legal restriction) to obtain reasonable compensation as a condition to providing access to, modifying or deleting your data.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us at: firstname.lastname@example.org subject=California Privacy Rights Inquiry.
Special Rights For European Residents.
If you reside in the European Union you may have additional rights as set forth under the GDPR. The GDPR is a complex regulatory scheme and we have not provided an exhaustive summary in this Policy. We advise you to read the relevant regulation and guidance provided by the relevant regulatory authorities for a full explanation of your rights.
Your principal rights under the GDPR are access, rectification, erasure, processing restriction or objection, portability, withdrawal of consent and the right to complaint to a regulatory authority. These rights are not absolute and exceptions apply. For example, we may not accommodate a request to delete or change information if we can demonstrate compelling legitimate grounds that override your interests or the change would violate any law or regulation or if retention is necessary to exercise the right of freedom of expression and information, comply with a legal obligation, attend to security issues and prevent or investigate attacks and/or fraud, maintain our record keeping, and properly administer our Website and business, to protect the vital interests of you, us, or any third party, or for the establishment, exercise or defense of legal claims.
If the legal basis for our processing your personal data is your consent, or the necessity to comply with your requests, or for the performance of a contract we have with you, and we are automatically processing your personal data, you have the right to receive from us a copy of such personal data in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time subject to applicable exceptions. Withdrawal will not affect the lawfulness of processing before the withdrawal.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.
Privacy Shield & Data Protection Authorities
We commit to resolve complaints about our collection or use of your Personal Data as required under the applicable Principles of the Privacy Shield. EU individuals with inquiries or complaints regarding our policies and their inter-relation with Privacy Shield principles should first contact our Data Protection Officer at email@example.com subject=US Privacy Shield – Data Protection Inquiry.
If you have a complaint concerning our use of relevant Personal Data, which remains unresolved by other means, you may have the right to binding arbitration. The pre-conditions for arbitration, and your rights in this regard are more fully described on the Privacy Shield website which as of the date of this Policy was located at: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any ordering/payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for selecting one that is strong and keeping it confidential. We ask you not to share your password with anyone. We also urge you to be careful about disclosing any personal information in public areas of the Website. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
The Website is owned by Helmund The Palm Jumeirah – Dubai – United Arab Emirates, Tel: +1 (502) 221-7825,
If a complaint or dispute regarding use and disclosure of personal information cannot be resolved, we agree to dispute resolution using as a third-party resolution provider