Privacy & Cookies Policy | Studio Selé B.V.
Last update: May 2, 2022
Your privacy is important to us.
What information do we collect?
We may collect the following types of Personal Information from you:
- Your name and email address
- Your company’s name and physical address
- Information you choose to provide us through our forums or our services
- Information that you provide in connection with your purchase of Services (or a purchase made through the Service), including credit card number, credit card expiration date, credit card verification code, bank account number, bank account title, bank name, branch location, and routing number
- We may retain server logs which include the IP address of every request to our server.
We may collect certain information about you from third parties, including from social networks (for example, Instagram) if used in connection with our Site or our Services.
We may also collect and aggregate information about the use of our Site and our Services. That information could include information such as your Internet Protocol (IP) address (an IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet), browser type, operating system, the web page that you were visiting before accessing our Site, the pages or features of our Site which you browsed and the time spent on those pages or features, search terms, the links on our Site that you clicked on and other statistics. If you access our Site using a mobile device, we collect information such as a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.
What do we use your Personal Information for?
- To compile statistics and analysis about your and other customers’ use of our Site and our Services.
- To personalize your experience — your Personal Information helps us to better respond to your individual needs.
- To improve our Site and our Services — we continually strive to improve our site offerings based on the information and feedback we receive from you.
- To improve customer service — your Personal Information helps us to more effectively respond to your customer service requests and support needs.
- To send periodic emails — the email address you provide may be used to send you information, notifications that you request about changes to topics or in response to your username, respond to inquiries and/or other requests or questions, or to alert you of updates to protect your system from new types of online attacks and to send periodic emails containing information relevant to your account and the products you use.
We may also use your Personal Information where necessary for us to comply with a legal obligation, including to share information with government and regulatory authorities when required by law or in response to legal process, obligation or request.
- We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose your Personal Information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
- Essential cookies: These cookies help run our site and make your experience better. These include cookies that allow you access to a members-only part of the site or help the content of our site load quickly. These cookies are only used to provide you with these services.
- Functionality cookies: These cookies allow the site to remember preferences you have selected such as login details or other selections you may have made. These are designed to make it easier to use our site and not have to set the same preferences every time.
- Social Media cookies: We may use social media tools on our site; these cookies allow the social media network to record when you have liked or engaged with a social media tool on our site. In some situations, the social network may send us data that you have set to share. If you do not want the social media network to share information with us, please check your privacy settings with the social media network.
- Advertising cookies: These cookies allow us to track browsing habits as you visit the site. Based on your browsing history and with your permission, we may use third-party advertising partners who can then display to you a relevant ad when you are on a third-party site such as a social media platform. Within these cookies, we may also know your precise location such as latitude, longitude, GeoIP, and other location-specific information. Please see below for your choices on cookies and the use of advertising.
“Do Not Track” options will not affect how we use your Personal Information.
Do we disclose any information to outside parties?
Except as set out below, we do not sell or trade your Personal Information. Non-personally identifiable visitor information, however, may be provided to other parties for marketing, advertising or other uses. We may disclose your Personal Information to our subsidiaries and affiliates, or to contractors, service providers, and other third parties we use to support our business. These third-party providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. We may also release your Personal Information when we believe release is appropriate to comply with the law, enforce our site policies or protect our or others’ rights, property or safety.
Your Personal Information may also be transferred to another company in the event of a transfer, change of ownership, reorganization or assignment of all or part of our businesses or assets. This will occur if the parties have entered into an agreement under which the collection, use and disclosure of the information is limited to those purposes of the business transaction, including a determination whether or not to proceed with the business transaction. You will be notified via email or prominent notice on our websites for thirty (30) days of any such change in ownership or control of your Personal Information or as otherwise may be required or permitted by law.
We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, 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 may 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.
How do we protect your Personal Information?
The security of your Personal Information is important to us; but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Retention of your Personal Information.
We retain your Personal Information for as long as you have an open account with us or as otherwise necessary to provide you with the Service, and thereafter as set forth in our any other written agreement with you to license our Services agreement with you. After it is no longer necessary for us to retain your Personal Information, we will dispose of it in a secure manner or anonymize the information. We also retain backups of the data in our Service for a period of ninety (90) days after termination of the service (or after deletion of the data from our production services). These backups may contain your Personal Information, and are deleted on a rolling ninety (90)-day basis unless otherwise retained as set forth in this policy. Despite the foregoing, in some cases we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, regulation or legal process. For example, if we are involved in litigation or a governmental or regulatory investigation, then we keep data throughout the period of litigation or investigation and for 5 years after that. If a settlement means that we have to keep data for longer, then we keep data for the period required to administer the settlement. If we provide data to law enforcement agencies, then we keep a record of this for one year beyond the end of the investigation.
Our Services are not intended for use by children under the age of 13 (“Children”). We do not knowingly collect Personal Information from Children. If you become aware that a person under the age of 13 has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Children without verification of parental consent, we take steps to remove that information from our servers.
Transfers and Processing of your Personal Information?
Special Provisions Applicable to Residents of the European Union.
This section of our Privacy Notice applies to all personal information that is governed by the General Data Protection Regulations (the “GDPR”), within the territorial scope of the GDPR, that may be used to identify you as a visitor to our Site and that is obtained by us in connection with the Site or providing a product or service to you as part of our operations.
For general data protection regulation purposes, the “Data Controller” means the organization who decides the purposes for which, and the way in which, any Personal Information is processed. Where you are using our Services and making decisions about the Personal Information that is being processed in the Services, you are acting as a data controller and Studio Selé is acting as a data processor. In other cases, Studio Selé may be the controller of some of your Personal Information (such as when we collect your billing information, or contact information for marketing purposes, or when monitoring usage information on our Site).
A “Data Processor” is an organization which processes Personal Information for a Data Controller. As a Data Processor, we may be bound by the requirements of the GDPR.
“Data processing” is any operation or set of operations (whether automated or not) performed upon Personal Information. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organizing, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:
- You can request access to, and rectification or erasure of, personal data;
- If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of your personal data in a usable and portable format;
- If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
- You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances; and
- For residents of France, you can send us specific instructions regarding the use of your data after your death.
To make such requests, contact us at email@example.com. When we are processing data on behalf of another party that is the Data Controller, you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns. Please be aware that those rights set out above may not apply in some instances, for example where our right to processing your personal data may be necessary for exercising the right of freedom of expression (e.g., news gathering), or for the establishment, exercise or defense of legal claims.
We will only use your Personal Information if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.
- Contractual Necessity: We process the following categories of Personal Information because we need the Personal Information to perform the Service: (a) contact information; (b) user account information; (c) billing and financial account information; (d) transaction information; and (e) user content you may submit to us.
- Legitimate Interest: We process the following categories of Personal Information when we believe doing so furthers the legitimate interest of us or third parties. This may include when we operate and improve our business, products, and services; or when marketing our products and services to you; or protecting our Services from fraud or security threats; or completion of corporate transactions, and includes (a) contact information; (b) user account information; (c) billing and financial account information; (d) transaction information; and (e) user content you may submit to us; and (f) log data.
- Consent: In some cases, we process Personal Information based on the consent you expressly grant to us at the time we collect such data. When we process Personal Information based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Information to comply with a legal obligation, if it is necessary to protect the vital interests of you or other persons, or if it is necessary for a task carried out in the public interest.
We will not transfer your Personal Information outside the European Economic Area (“EEA”) unless it takes such measures as are necessary to provide adequate protection for such Personal Information consistent with the requirements of applicable laws. To the extent that we process (or causes to be processed) any Personal Information originating from the EEA in a country that has not been designated by the European Commission as providing an adequate level of protection for Personal Information, the Personal Information shall be deemed to have adequate protection (within the meaning of EU Data Protection Legislation) by virtue of the European Commission’s Standard Contractual Clauses for data transfers between EU and non-EU countries, whereby you will be regarded as the Data Exporter and we will be regarded as the Data Importer. In the event that the Contractual Clauses are deemed to no longer be a valid mechanism to legitimize transfers of personal data outside the European Economic Area, we will amend this Policy in order to establish a legitimate transfer of personal data outside the European Economic Area.
Principle of Onward Transfer. In the context of an onward transfer of data to a third party, we have responsibility for the processing of Personal Data we receive and subsequently transfer to a third party acting as an agent on our behalf. We shall remain liable under applicable law if our agent processes such Personal Data in a manner inconsistent with applicable law, unless we prove that we are not responsible for the event giving rise to the damage.
Governed by the requirements contained in GDPR, we will provide you with a reasonable opportunity to access your Personal Information that we have collected, correct it if it is inaccurate, erase it, or to request we restrict processing of the data. You also have the right to data portability, to have us provide the data to other entities. Please see GDPR Articles 15 through 18 then 20 for the requirements and procedures necessary to exercise these rights. We do not engage in automated data processing or profiling as those terms are understood under GDPR.
With respect to these rights, (a) we reserve the right to not provide information until we receive adequate information to identify that you are the relevant data subject and to request additional information to confirm your identity; (b) with an access request or data portability request, we reserve the right to deny access to information where the rights or freedoms of other individuals may be adversely affected; (c) for requests for copies of data pursuant to an access request, we reserve the right to charge an administrative fee for any request after the first; (d) when requests are manifestly unfounded or excessive, we reserve the right to charge an administrative fee or to refuse to act on the request. When the purpose for data processing is based on consent, you have the right to withdrawal consent at any time, although that does not affect the lawfulness of processing based on consent before it is withdrawn. When the purpose for data processing is based on contract, we will likely not be able to provide you services without the Personal Information we request and so will likely have to terminate the relationship.
Special Provisions Applicable to Residents of California
If you are a California resident, you may have additional rights under the California Consumer Privacy Act (“CCPA”) relating to the collection and processing of your personal information. Please read the following if you are a California resident. For additional information, you may contact us at the address listed below or at firstname.lastname@example.org.For purposes of this section, the terms personal information, consumer, and sell or sold shall be defined only as broadly as set forth in the CCPA and to the extent applicable to the Site visitor.
- We do not sell the personal information of California consumers.
- We have no actual knowledge that we have sold personal information of minors under the age of 16 years old.
Under the CCPA, California consumers may be provided the following rights:
- the right to know about the categories or specific pieces of Personal Information we collect (including how we use and disclose the information)
- the right to have your Personal Information deleted
- the right not to be discriminated against for exercising consumer rights under the CCPA
- the right to opt-out of any “sales” that may be occurring
- the right to opt-out of marketing communications we send you at any time
- the right not to receive discriminatory treatment for the exercise of your privacy rights under California law.
California consumers may exercise their rights by emailing us at email@example.com. Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. If we need additional information, we will let you know. If you would prefer, you may designate an authorized agent to make a request on your behalf.
You can opt-out of marketing communications we send you at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under “Contacting Us”.
In addition, you are entitled to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident and would like to request this information, then please submit a request to us as described below at “Contacting Us”.
California’s “Shine the Light” law, California Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place.
We welcome any queries, comments or requests you may have regarding this policy please do not hesitate to contact us at firstname.lastname@example.org.
If you have questions on information we may hold about you, you may contact us as follows:
1. Email our Data protection officer at email@example.com with the following information: Your name; Your company; Your title; Your country; Your state of residence; Your contact information.
2. Write to us at: Herengracht 340-O, 1016 CG, Amsterdam, The Netherlands.