Privacy Policy

BACKGROUND:

DEVIDE understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.devide.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested whenever you visit Our Site and.

1. Definitions and Interpretation 

In this Policy the following terms shall have the following meanings:  

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

2. Information About Us

Our Site is owned and operated by Vindorale Limited, a limited company registered in Malta under company number C75796.

Registered address: 30A, Triq il-Gejza, Swieqi, SWQ 3223, Malta.

Main trading address: Calle Jean 4, office 3B, 28604 San Pedro de Alcantara, Malaga, Spain

VAT number: MT25292432.

3.What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR” or “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5.What Are Your Rights?

Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:

a)The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact Us to find out more or to ask any questions using the details in Part 15.

b)The right to access the personal data We hold about you. Part 13 will tell you how to do this.

c)The right to have your personal data rectified if any of your personal data held by Us is inaccurate or incomplete. Please contact Us using the details in Part 15 to find out more.

d)The right to be forgotten, i.e. the right to ask Us to delete or otherwise dispose of any of your personal data that We hold. Please contact Us using the details in Part 15 to find out more.

e)The right to restrict (i.e. prevent) the processing of your personal data.

f)The right to object to Us using your personal data for a particular purpose or purposes.

g)The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h)The right to data portability. This means that, if you have provided personal data to Us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask Us for a copy of that personal data to re-use with another service or business in many cases.

i)Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact Us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep Us informed as long as We have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office.

If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact Us first, using the details in Part 15.

6.What Data Do We Collect and How?

Depending upon your use of Our Site, We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data AND/OR personal data relating to children AND/OR data relating to criminal convictions and/or offences.

Data Collected	How We Collect the Data
Identity Information including name, date of birth, gender	Web form
Contact information including address, email address, telephone number	Web form
Business information including business name, business address, VAT-number, company number	Web form
Payment information including bank account details for withdrawals of commisions	Web form
Profile information including preferences, login details, purchase history, login history	Web form
Technical information including IP address	Automatically upon visits
Data from third parties including name, contact and shipping details. Purchase history.	API call from brand partner sites

7How Do We Use Your Personal Data?

Under the Data Protection Legislation, We must always have a lawful basis for using personal data. The following table describes how We may use your personal data, and Our lawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Registering you on Our Site.  To be able to log in to our site and to ship purchased products to the customer.	Name, address, gender, date of birth, phone, email, username, password	Processing is essential for You to have functional access to Our site.  Processing is essential for the performance of Our contract with You.
Providing and managing your access to Our Site.	username, password	Processing is essential for You to have functional access to Our site.
Administering Our Site. To be able to contact the customer regarding support issues	Email	Processing is essential for the performance of Our contract with You.
Creating voucher code valid at brand partners website. To provide the user with a voucher code valid for purchases at brand partners website.	Username, amount	Processing is essential for the performance of Our contract with You.
Supplying Our products AND/OR services to you.	Name, address	Processing is essential for the performance of Our contract with You.
Managing payments for Our products AND/OR services.	bank account details	Processing is essential for the performance of Our contract with You.
Customer account security, e.g. Sending forgotten password emails	email	Processing is essential for You to have functional access to Our site. Processing is essential for the performance of Our contract with You.
Communicating with you.	Email	Processing is essential for You to have functional access to Our site. Processing is essential for the performance of Our contract with You.

With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on Our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties (including Google Analytics) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that We do not control the activities of such third parties, nor the data that they collect and use themselves, and We advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless We reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish Us to explain how the new purpose is compatible with the original, please contact Us using the details in Part 15.

If We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows Us to do so.

In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8.How Long Will We Keep your Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long We Keep It
Identity Information including name, date of birth, gender	6 years after the last transaction with, or communication from, the customer
Contact information including address, email address, telephone number	6 years after the last transaction with, or communication from, the customer
Business information including business name, business address, VAT-number company number	6 years after the last transaction with, or communication from, the customer
Payment information including bank account number	6 years after the last transaction with, or communication from, the customer
Profile information including preferences, username and password, purchase history	6 years after the last transaction with, or communication from, the customer
Technical information including IP address	6 years after the last transaction with, or communication from, the customer

9.How and Where Do You Store or Transfer My Personal Data?

We do not store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the EEA. This means that We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the Data Protection Legislation as follows:

We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, Our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.

AND

Where We transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

Please contact Us using the details below in Part 15 for further information about the particular data protection mechanisms used by Us when transferring your personal data to a third country.

The security of your personal data is essential to Us, and to protect your data, We take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

10.Do We Share Your Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If We sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy Policy.

In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may share your personal data with other companies in Our group for billing, shipping, and marketing reasons. This includes subsidiaries AND/OR Our holding company and its subsidiaries.

We may sometimes contract with the following third parties to supply certain products AND/OR services.

Recipient	Activity Carried Out	Sector	Location
Hauger	Billing, shipping	Lifestyle products	Sweden
Saint Roches	Billing, shipping	Lifestyle products	Sweden

If any of your personal data is shared with a third party, as described above, We will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, We will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the Data Protection Legislation, as explained above in Part 9.

If We sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy Policy.

In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11.How Can You Control Your Personal Data?

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and/or at the point of providing your details and by managing your Account).

12.Can You Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict Our use of Cookies. For more information, see Part 14.

13.How Can You Access Your Personal Data?

If you want to know what personal data We have about you, you can ask Us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell Us everything We need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will aim to respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of Our progress.

14.How Do We Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products AND/OR services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Site for <<insert description of use(s) of third-party cookies>>. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a <<insert description of prompt, e.g. pop-up>> requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

The following first-party Cookies may be placed on your computer or device:

Name of Cookie	Purpose	Strictly Necessary
Devide	PHP session cookie	Yes

and the following third-party Cookies may be placed on your computer or device:

Name of Cookie	Provider	Purpose
_cfduid	Cloudflare	Statistics and tracking

Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products AND/OR services offered through it.

The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

The analytics service(s) used by Our Site use(s) the following Cookies:

Name of Cookie	First / Third Party	Provider	Purpose
_ga	Third	Google analytics	Statistics and tracking
_gid	Third	Google analytics	Statistics and trackin
_gat_gtag_UA_*	Third	Google analytics	Statistics and tracking

In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15.How Do You Contact Us?

To contact Us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: [email protected]

Telephone number: + 356 355 054 86.

Postal Address: 30A, Triq il-Gejza, Swieqi, SWQ 3223, Malta.

16.Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 6 March 2019.