Last updated 6 April 2022
THE INFORMATION WE COLLECT AND HOW WE USE IT
TYPES OF INFORMATION
We may collect the following types of Information through our Services:
(1) “Personal Data” such as your name, e-mail address and phone number, account or mailing address, and other information that can be used to directly identify and contact you (which, in some cases, may include certain Device Information or information from the signature block of your e-mail);
(2) “Device Information” which is information relating to the computer or device you are using when you access our Services, such as your computer’s IP address, your mobile device identifiers (including Apple IDFA or an Android Advertising ID), the type of browser and operating system you are using, the identity of your internet service provider, and your device and browser settings.
(3) “Usage Data” which is data related to your use of the Services such as the pages you visit, the sites you use before or after visiting ours, your actions within the Services, the type of content or advertisements you have accessed, seen, forwarded and/or clicked on, Wi-Fi connections, date and time stamps, log files, and diagnostic, crash, website, and performance logs and reports.
As described in more detail below, we collect Personal Data only when you provide it to us but may collect other types of Information whenever you use our Services through automated means such as software developer kits, cookies and web beacons (which are discussed in more detail below).
You may enter the Website and browse its content without submitting any Personal Data. However, we will need to collect relevant Personal Data to provide you with certain services offered by the Services, including if you choose to create an account on our website, contact us or otherwise communicate with us in any way, subscribe or opt in to our newsletter, alerts, or other communications, subscribe or opt in to SMS messages,
DEVICE INFORMATION AND USAGE DATA
Whether or not you submit Personal Data, any time you visit our Services, we or our service providers may collect, store or accumulate certain Device Information and Usage Data. This Information may be used in furtherance of the purposes described above with respect to Personal Data and in aggregate form for internal business purposes, such as optimising the Services, evaluating the popularity of content, generating statistics and developing marketing plans, and otherwise for general administrative, analytical, research, optimization, and security purposes.
INFORMATION TO AND FROM SOCIAL NETWORKS
SHARING OF INFORMATION
In no event will we disclose, rent, sell or share any of your Personal Data to third parties for direct marketing purposes. We only share your Information with third parties for the purposes described below.
We contract with companies or individuals to provide certain services related to the functionality and features of the Services, including content streaming, email and hosting services, software development, data management, orders, payment processing, management of forms, quizzes and polls, customer service, returns, live chat, marketing, fraud prevention, product review and questions, and administration of contests and other promotions. We call them our “Service Providers.” We may share your Information with Service Providers as appropriate for them to perform their services for us and our Service Providers are permitted to use your Information only for such purposes.
The 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.
We may also share or transfer Device Information and Usage Data in aggregated, anonymized form with or to our affiliates, licensees, partners and Service Providers for administrative, analytical, research, optimization, and security purposes, but no such Information will be linked with your Personal Data or be used to identify or contact you.
AUTOMATED COLLECTION / COOKIES
We may use certain automatic analytics and tracking technologies to assist us in performing a variety of functions, including storing your Information, collecting Device Information and Usage Data, understanding your use of the Services and customising the content offered to you on the Services. We may use platforms like Google Analytics to provide aggregated or anonymized information relating to demographics, geography, interests or affinities. Other technologies we may use include:
(2) Web Beacons. We may also use "web beacons" or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor the behaviour and collect data about the visitors viewing a web page or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).
(3) Mobile Device Identifiers and SDKs. We also sometimes use, or partner with publishers or app developer platforms that use, mobile Software Development Kits ("SDKs") that are incorporated into the Services to collect Information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), geolocation information, and other information about your device or use of the Services. A mobile SDK may act as the mobile version of a web beacon (see "Web Beacons" above).
By visiting the Services, whether as a registered user or otherwise, you acknowledge, and agree that you are giving us your consent to track your activities and your use of the Services through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to you. Please note that no such tracking technologies will collect any Personal Data from you unless you choose to submit it to us and that data relating to you individually is not shared with any third parties.
PERSONAL DATA RETENTION
PRIVACY AND SECURITY
We take reasonable precautions to protect our customers' Personal Data against loss, misuse, unauthorised disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security of any Information that you transmit to us or from us, and you do so at your own risk. You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.
If you believe your Personal Data is being improperly used by us or any third party, please immediately notify us via email at firstname.lastname@example.org
LINKS TO THIRD PARTY PLATFORMS
Our Services or communications may contain links to third party websites, over which we exercise no control, including the form of embedded content, sponsored content or co-branded content. Except as set forth in this Policy, we do not share your Personal Data with those third parties and are not responsible for the privacy policies of any third party or their management of your Personal Data. Because they may treat your Information differently than we do, we suggest you read the privacy policies on those third-party websites prior to submitting any Personal Data to such sites.
In addition, you may be redirected to a third-party platform for certain functions, including returns, forms, and customer service. See above section regarding “Sharing of Information.”
Opting Out of Communications
As described above, we may use the Personal Data we collect from you to send you newsletters or other communications from us, including those promotional or marketing in nature. If you do not want to receive such communications, you can opt out by clicking here.
You may also at any time opt out of receiving communications from us by sending an e-mail to email@example.com with the subject line “Opt Out.”
Under certain laws, including the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”), you have the right to: obtain confirmation that we hold Personal Data about you, request access to and receive information about the Personal Data we maintain about you, restrict the use of the data, receive the data in a portable format, receive copies of the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, object to the continued processing or use of your Personal Data, complain to a supervisory authority, and have the Personal Data blocked, anonymized or deleted, as appropriate. The right to access Personal Data may be limited in some circumstances by local law. If you qualify, in order to exercise these rights, please contact us on firstname.lastname@example.org
We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.
Please understand, however, that we reserve the right to retain an archive of such Personal Data for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such Information.
HOW WE USE YOUR INFORMATION
We may use your Personal Information to provide products and services and to support our business functions. For example, we may use this information for the following purposes:
PROVIDE, IMPROVE AND DEVELOP THE ELLENCLO WEBSITE.
Provide the Services to you
Process and fulfil your order, including by shipping products to you, or others you designate, and sending emails to you, or others you designate, to confirm your order status and shipment and to process merchandise returns
Provide customer service
Operate, protect, improve, and optimise the Ellenclo Website and the user experience, such as by performing analytics and conducting research
Communicate with you and to send you information by email, postal mail, telephone, text message, or other means about our products, services, contests, support messages, updates, security alerts, and account notifications
Communicate with other persons using contact information you provide, such as when you designate another person as the recipient of a gift purchase
Make your shopping experience easier, more personalised, more enjoyable and more efficient
Address problems with and improve our products, brands, services and technologies, as well as to develop new products and services
Allow you to use our in-store and online technologies
Provide consistent, personalised services, including to personalise our advertising, marketing communications, shopping experiences and promotional offers
Organise local community events, promotions and in-store experiences
Facilitate your ability to share information to social media
Administer and fulfil our contests and other promotions
Help us learn more about your shopping preferences or product preferences
Fulfil a contract we have with you
Operate, protect, improve, and optimise the Ellenclo Website and experience, and personalise and customise your experience (such as making automatically entering your saved shipping information), we conduct profiling based on your interactions with the Ellenclo Website, your search and booking history, your profile information and preferences, and other content you submit to the Ellenclo Website.
We process this information given our legitimate interest in protecting the Ellenclo Website, to measure the adequate performance of our contract with you, and to comply with applicable laws.
PROVIDE, PERSONALISE, MEASURE AND IMPROVE OUR ADVERTISING AND MARKETING.
Send you promotional messages we believe may be of interest to you, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Ellenclo or partner campaigns and services) and social media advertising through social media platforms such as Instagram, TikTok or Google).
Personalise, measure, and improve our advertising.
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Ellenclo or its third party partners.
Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Ellenclo Website, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.
We will process your Personal Information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Ellenclo Account.
When you consent to it
When it is necessary to protect your vital interests or that of another person
When it is necessary for the performance of a task carried out in the public interest
When it is in our legitimate interests. Legitimate interests are our business or commercial reasons for using your data, such as (i) keeping our records up to date (ii) providing the Services to you; (iii) maintaining or administering the Services (iv) performing business analyses or for other internal purposes to improve the quality of our business and the Services we offer; (v) prevention of fraud and financial crime to protect the public; (vi) communicating with you concerning programs or services consistent with our obligations to provide those services or otherwise; and (vii) participating in litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving our customers who use or have used our Services or other third parties. We will not unfairly place our legitimate interests above what is best for you.
SOURCES OF PERSONAL INFORMATION
We collect Personal Information from the following categories of sources:
From You. For example, if you choose to create an account on our website; contact us or otherwise communicate with us in any way; subscribe or opt in to our newsletter, alerts, or other communications; subscribe or opt in to SMS messages; sign up for product waitlists; participate in a contest or promotion, order our products; submit product reviews, questions, feedback or user comments; complete an optional survey; contact customer service; or otherwise interact with the Services.
Operating Systems and Platforms. For example, we automatically collect information relating to the computer or device you are using when you access our Services, such as your computer’s IP address, your mobile device identifiers, the type of browser and operating system you are using, and your device and browser settings.
Data Analytics Providers. For example, we and our technology providers automatically collect data related to your use of the Services through the use of logging and analytics tools (such as Google Analytics), cookies, pixel tags, and other tracking technologies and as a result of your use of and access to the Services, such as the pages you visit, the sites you use before or after visiting ours, your actions within the Services, the type of content or advertisements you have accessed, seen, forwarded and/or clicked on, Wi-Fi connections, date and time stamps, log files, and diagnostic, crash, website, and performance logs and reports.
Social Networks. For example, if you connect to our Services through a third-party social network such as Facebook, Twitter or Instagram (each, a “Social Network”), we may collect Personal Information from your profile, such as your name, username, and e-mail address..
YOUR CALIFORNIA PRIVACY RIGHTS
If you'd like more information about our privacy practices or want us to delete your Personal Information, feel free to contact us at email@example.com