To ensure your privacy as far as possible, we adhere to the following core values:
Limited collection: We take great care to limit the information we collect and use to only that which is necessary for selling our Products and/or providing our Services (as defined below).
Security: We take the appropriate measures to secure your personal data and require the same from the parties that use your data on our behalf. Branda proactively tests on a continuous basis its websites by means of an automated security scan.
Individuals’ rights: We respect your rights under applicable privacy laws (including the right to access, correct, or delete your personal data in accordance with such laws).
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. PERSONAL DATA WE COLLECT AND USE
The personal data we collect about you when you buy our Products or use our Services, include the following (hereinafter jointly referred to as: “Personal Data”):
Your contact details. Your name, postal address and other contact details, such as your telephone number and e-mail address, and any other contact details you provide to us (including delivery address when you purchase our Products online).
Your account data. To complete your account at Gamila Secret, we use your name, contact details and other information you voluntarily provide to us, such as your favourite Gamila Secret products or personal product advice.
Your purchases online. To complete your online purchases via the official Gamila Secret web-shop or via other official social media-channels of Gamila Secret, we use your name, telephone number, contact details and all relevant information regarding your purchases, such as the amount and date of your purchases, the Product(s) you purchase, the device through which you make your purchases, payment method, payment status, discount code used (if any) and delivery address.
Your data when subscribing to our newsletter. To be able to provide you with the newsletter of Gamila Secret containing inspirational and commercial content, we use your email address and additional information if you add such to your profile, such as name. Gamila Secret also sends out personalised newsletters, based on your personal preferences if you’ve provided us with those.
Your communication data. Any data shared by you when communicating with us via email, telephone, social media or any other form, such as questions, requests or complaints.
Your ratings and reviews and feedback. The opinions, experiences, preferences and interests and Product - or event reviews that you publish on our websites or share with us online or through social media.
3. PURPOSES OF USE PERSONAL DATA
The Personal Data we collect is exclusively used for the following purposes:
For the performance of our agreement with you: In order to carry out our obligations arising from any contracts entered into between you and us, and to provide you with the Products, Services and information that you request, including managing and handling your requests, inquiries or complaints. This also includes enabling you to make a purchase of our Products, to participate in our Gamila Secret program, to responding to your requests to provide customer service, respond to your inquiries, provide you with essential information regarding our Products and Services you request, etc.
For our legitimate commercial interests: We use your Personal Data as described above (both on aggregated and on individual basis) for the purpose of advertising our Products and Services, to contact you via e-mail, social media or otherwise for direct marketing or other commercial purposes. We also use your Personal Data for analysing and improving the quality of our Products and Services, such as providing you with customer services and after-sales, and to understand you as a customer. This enables us to assess what may interest you, to measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising. In addition, based on your use of our Services and Products you purchased, we may target you with advertisement or other marketing materials that are customised to your personal preferences and experiences.
We may also use your Personal Data, for our other legitimate commercial interests such as to operate and expand our business activities; to develop and improve or modify our Products and Services; to generate aggregated statistics about the users of our Products and Services; to facilitate our business operations; to operate company policies and procedures; to enable us to make corporate transactions, such as any merger, sale, reorganisation, transfer of Branda’ assets or businesses, acquisition, bankruptcy, or similar event; or for other legitimate business purposes permitted by applicable law.
Use of information based on your consent:
If you haven’t purchased any Product from us, we will only send you direct marketing communications (such as newsletters, promotions, news on products or service updates) via email or other electronic means, after we have received your consent to do so.
You can withdraw your consent at any time (see the section Your rights below).
To comply with our legal obligations: Any Personal Data we collect may be used to comply with a legal obligation to which we are subject, such as supervisory bodies, fiscal authorities or investigation bodies.
4. SOCIAL MEDIA
When you participate in various social media forums like Facebook, Instagram, LinkedIn, etc., you should be familiar with and understand the tools provided by those sites that allow you to make choices about how you share the personal data in your social media profile(s).
Also, depending on the choices you have made regarding your settings on various social media sites (and/or in combination with your settings on the Gamila Secret pages), certain personal data may be shared with Branda about your online activities and social media profiles (e.g. interests, marital status, gender, user name, photo, comments and content you have posted/shared etc.).
5. SHARING YOUR PERSONAL DATA
We share your Personal Data with the following parties:
Third Party suppliers. We engage third parties, from time to time, to help us providing us our Products and Services, including:
- Business partners, suppliers (such as IT service providers) and sub-contractors (such as Logistics partners);
- Advertising and media companies that carry out marketing and media activities on our behalf;
- Analytics and search engine providers that assist us in the improvement and optimisation of our website and apps, such as Google Analytics.
In providing their services, they will access, receive, maintain or otherwise process Personal Data on our behalf. Our contracts with these service providers do not permit use of your Personal Data for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require such Third Party suppliers to adequately safeguard your Personal Data and only process it in accordance with our instructions.
Corporate transaction. In addition, Personal Data may be disclosed as part of any merger, sale or transfer of Branda’ assets.
Third parties in case of legal requirement. We may also disclose your Personal Data if we believe we are required to do so by law.
With consent. We may also disclose information about you, including Personal Data to any other third party, where you have consented or requested that we do so, for example in case of a promotional campaign with another sponsor.
6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
In most cases your Personal Data will be processed within the European Union. However, please be informed that Branda may transfer and process any Personal Data you provide to us to countries other than your country of residence. The laws of these countries may not provide the same level of protection to your Personal Data. Branda or Third Party suppliers we use will therefore seek to ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such transfer, more in particular for Personal Data transferred to countries outside the European Economic Area. This means that we entered into legally necessary contracts with recipients of your data, including standard contractual clauses as approved by the European Commission or other supervisory authority where required.
You are entitled to receive a copy of any documentation showing the suitable safeguards that have been taken by making a request via firstname.lastname@example.org.
We will take reasonable steps to ensure that your Personal Data are properly secured using appropriate technical, physical, and organisational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss.
8. DATA RETENTION
We retain your Personal Data for as long as required to satisfy the purpose for which they were collected and used (for example, for the time necessary for us to provide you with customer service, answer queries or resolve technical problems), unless a longer period is necessary for our legal obligations or to defend a legal claim.
9. YOUR RIGHTS
Subject to the conditions set forth in the applicable law, you have the the following rights with regard to our processing of your Personal Data:
Right of access – You have the right to request confirmation if Branda processes personal data about you, and if such is the case, access to the personal data and additional information. Upon request, we can also provide you with a copy of the personal data undergoing processing;
Right to rectification – You have the right to request that Branda corrects, adjusts or completes your Personal Data if we have inaccurate or incomplete data relating to you. You can also correct, adjust or complete your personal data yourself by updating your profile. We also kindly request you to ensure that changes in personal circumstances (for example, change of address, bank account, etc.) are notified to Branda so that we can ensure that your Personal Data is up-to-date. Branda will take all reasonable steps to ensure that all Personal Data are correct;
Right to withdraw consent – You have the right to revoke your consent for receiving marketing communications at any time, by following the instructions in any marketing communication or by sending a written request as specified below. If we use your Personal Data based on your consent for other reasons than marketing communication, you can revoke your consent by filling the form as set out below;
Right to delete - You have the right to request deletion of any irrelevant Personal Data we hold about you when (i) the data is no longer necessary in relation to the purposes for which they are collected; (ii) you withdraw your consent and there is no other legal ground for processing; (iii) you object to the processing in case of direct marketing purposes, or – in any other case - there is no overriding legitimate ground for processing; (iv) we unlawfully processed your data. If you have such a request and all requirements are met, we shall make sure that Branda erases the data of which we are not under a legal obligation to retain;
Right to restriction of data use - You have the right to restrict our use of your Personal Data where (i) you contest the accuracy of the Personal Data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the Personal Data for the relevant purposes, but you require them for the establishment, exercise or defence of legal claims; or (iv) you have objected to data use justified on our legitimate interests pending verification as to whether Branda has indeed compelling interests to continue the relevant data use;
Right to data portability - to the extent that we use your Personal Data for the performance of an agreement with you, and that personal data is processed by automatic means, you have the right to receive all such Personal Data which you have provided to Branda in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible;
Right to object - to the extent that we are relying on our legitimate interests to use your Personal Data, you have the right to object to such use, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. You also have the right to object to profiling activities conducted by Branda;
For further information regarding your rights, or to exercise any of your rights, please send an e-mail to email@example.com with the following information:
- Social security number (please note that in some identity cards/passports this is stated on 2 different places);
- Document number;
- Date of birth;
- Place of birth;
- Date of issue;
- Expiry date;
Upon receipt of all the information as set out above we shall respond to your request consistent with applicable law.
What are cookies?
Cookies are text files placed on your computer to collect standard Internet log information and visit behavior information. When you visit our website, we may collect information automatically through cookies or similar technology.
Our company sometimes may share some limited aspects of this data with third parties for advertising purposes only. We may also share online data collected through cookies with our advertising partners. This means that when you visit another site, you may be shown advertisements based on your browsing patterns on our website.
How to manage cookies?
You can set your browser not to accept cookies and to remove it from your browser. However some of our wesite features may not function or function with limitations in result.
11. CHANGES TO THE POLICY
12. CONTACT US
November 25th 2021