Effective Date: August 1, 2020
1. PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”. If you upload photos to our “My Boards” section, we also automatically collect information about that. We collect Device Information using the following technologies:
• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
2. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to: • Communicate with you; • Screen our orders for potential risk or fraud; and • When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services. We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
3. SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site — you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. Additionally, we may share your Personal Information with Oracle Data Cloud customers and partners, including digital marketers, ad agencies, web publishers, connected TV providers, demand side platforms, data management platforms, supply-side platforms and social media networks and third-party service providers as necessary to perform Oracle Marketing & Data Cloud services on behalf of Oracle. You can read more about how Oracle uses your Personal Information here: www.oracle.com/legal/privacy/marketing-cloud-data-cloud-privacy-policy, and opt-out here: https://datacloudoptout.oracle.com/#optout. Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
4. BEHAVIORAL ADVERTISING
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. You can opt out of targeted advertising by using the links below:
• Facebook: https://www.facebook.com/settings/?tab=ads
• Google: https://www.google.com/settings/ads/anonymous
• Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info.
5. DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
6. YOUR RIGHTS
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. Additionally, if you are a European resident, we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States. Further, if you are a European resident, please see our GDPR Terms below.
7. DATA RETENTION
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.
9. GOVERNING LAW; INTERPRETATION
The Site is not intended for individuals under the age of 18. We do not knowingly collect information online from individuals under the age of 18.
13. CHANGE YOUR INFORMATION; CONTACT US
If our system allows it, you can log into your user’s profile and correct, amend, or delete information about yourself. Otherwise, to find out what information we have collected about you and to request any changes or for more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at email@example.com or by mail using the details provided below: Bensoleimani.com Inc., Attn: Privacy Compliance Officer 433 N Camden Drive, Suite 730 Beverly Hills, CA 90210.
14.1. “Company” means Bensoleimani.com, Inc.
14.2. “GDPR” means the European Union’s General Data Protection Regulation.
14.3. “Responsible Person” means the person responsible for data protection within the Company.
14.4. “Register of Systems” means a register of all systems or contexts in which personal data is processed by the Company.
- Data protection principles The Company is committed to processing data in accordance with its responsibilities under the GDPR. TO THE EXTENT THESE GDPR TERMS CONFLICT WITH ANY OF OUR OTHER PROVISIONS, THESE GDPR TERMS CONTROL. Article 5 of the GDPR requires that personal data shall be:
15.1. Processed lawfully, fairly and in a transparent manner in relation to individuals;
15.2. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
15.3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
15.4. Accurate and, where necessary, kept up to date, with every reasonable step taken to ensure that personal data are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
15.5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
15.6. Processed in a manner that ensures appropriate security of the personal data, including appropriate protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
- General provisions
16.1. This policy applies to all personal data processed by the Company.
16.2. The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
16.3. This policy shall be reviewed at least annually.
- Lawful, fair and transparent processing
17.1. To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
17.2. The Register of Systems shall be reviewed at least annually.
17.3. Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner.
- Lawful purposes
18.1. All data processed by the Company must be done on one of the following lawful bases: Consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
18.2. The Company shall note the appropriate lawful basis in the Register of Systems.
18.3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
18.4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems will be in place to ensure such revocation is reflected accurately in the Company’s systems.
- Data minimization
19.1. The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
20.1. The Company shall take reasonable steps to ensure personal data is accurate.
20.2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
21.1. To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
21.2. The archiving policy shall consider what data should/must be retained, for how long, and why.
22.1. The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
22.2. Access to personal data shall be limited to personnel who need access and appropriate security will be in place to avoid unauthorized sharing of information.
22.3. When personal data is deleted this will be done safely such that the data is irrecoverable.
22.4. Appropriate back-up and disaster recovery solutions shall be in place.
23.1. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and report this breach as may be required.
YOUR CALIFORNIA PRIVACY RIGHTS
California law defines "personal information" broadly as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. This Notice also uses that definition for personal information.
California law provides you the right to request:
- Access. Request access to the specific pieces of personal information collected about you.
- Deletion. Request deletion of your personal information.
- Disclosure. Request disclosure of the categories of personal information we collect, the purposes for which we collect, sell or disclose that information, and the categories of third parties with whom we share the information.
- Opt Out. Opt out of the "sale" of your personal information.
These additional disclosures are required by the California Consumer Privacy Act:
CATEGORIES OF PERSONAL INFORMATION WE COLLECT
PURPOSES FOR WHICH WE USE PERSONAL INFORMATION
In addition, we may offer certain discounts or rewards in connection with our loyalty program, or other promotions we may offer from time to time in exchange for our use of your personal information that you provide. Where we offer discounts or rewards in this manner, we will obtain your consent to our use of your personal information for this purpose.
CATEGORIES OF PERSONAL INFORMATION WE HAVE DISCLOSED FOR A BUSINESS PURPOSE
RIGHT TO REQUEST ACCESS TO OR DELETION OF PERSONAL INFORMATION
NO SALE OF PERSONAL INFORMATION
In the twelve months prior to the effective date of this Notice, we have not sold any personal information of consumers, as those terms are defined under the California Consumer Privacy Act. Notwithstanding the foregoing, California law may characterize our providing the following categories of information we share with companies that provide services to you or to us, such as personalizing your experience with us or helping us to market or advertise our products and services to you, as "sales" of personal information:
Device and browsing information and other Internet activity information
Purchase or other commercial information
Identifiers and contact information
RIGHT TO NON-DISCRIMINATION
We will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.
REQUESTS FROM AUTHORIZED AGENTS
CONTACT FOR MORE INFORMATION
UPDATES TO THIS NOTICE
We may make changes to this Notice, and may apply any changes to information previously collected, as permitted by law. When we make material changes to this Notice, we will notify you by posting the updated Notice on our website, and we will update the effective date at the end of this Notice.
This Notice is effective August 1, 2020.