PRIVACY & SECURITY POLICY
1. Introduction
Welcome to WearefromUa privacy notice. WearefromUa respects your privacy and is
committed to protecting your personal data. This privacy notice will inform you as to how
we look after your personal data when you visit our website (regardless of where you
visit it from) and when you provide us with your personal data in other ways, including in
store or by post, phone or email and tell you about your privacy rights and how the law
protects you.
Any questions relating to this policy and our privacy practices should be sent
to
[email protected] 2. Purpose of this Privacy Notice and Changes to this Privacy Notice
This privacy notice aims to give you information on how WearefromUa collects and
processes your personal data through your use of this website, including any data you
may provide through this website when you fill in forms on our website, register for an
account on our website, place an order on our website, and when you provide your
personal data to us in store, by post, phone or email.
It is important that you read this privacy notice together with any other privacy notice or
fair processing notice we may provide on specific occasions when we are collecting or
processing personal data about you so that you are fully aware of how and why we are
using your data. This privacy notice supplements the other notices and is not intended
to override them.
This website is not intended for children and we do not knowingly collect data relating to
children.
3. Who We Are and the Personal Information that We Collect From You
We are Public Organization “The Spirit of Freedom” (Company Number 44779727)
(“we”, “our” and “us”). We are data controller of any personal data that you provide us.
Personal data, or personal information, means any information about an individual from
which that person can be identified. It does not include data where the identity has been
removed (anonymous data).
We may collect, use, store and transfer the following kinds of personal data about you:
- Identity Data: includes first name, last name, username or similar identifier, date of
birth.
- Contact Data: delivery address, email address and telephone numbers.
- Financial Data: includes bank account and payment card details.
- Transaction Data: includes details about payments to and from you and other details
of products and services you have purchased from us.
- Technical Data: includes internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in types and versions,
operating system and platform and other technology on the devices you use to access
this website.
- Profile Data: includes your username and password, purchases or orders made by
you, your interests, preferences, feedback and survey responses.
- Usage Data: includes information about how you use our website, products and
services.
- Marketing and Communications Data: includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your health
and genetic and biometric data). Nor do we collect any information about criminal
convictions and offences.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions: You may give us your Identity, Contact and Financial Data by filling
in forms or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us some feedback;
- engage with us on social media
- Automated technologies or interactions: As you interact with our website, we may
automatically collect Technical Data about your equipment, browsing actions and
patterns. We collect this personal data by using cookies, server logs and other similar
technologies. We may also receive Technical Data about you if you visit other websites
employing our cookies. Please see our cookie policy for further details.
- Third parties or publicly available sources: We may receive personal data about you
from various third parties as set out below:
- Data from analytics providers;
- Data from advertising networks;
- Data from search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and
delivery services; and
- Identity and Contact Data from data brokers or aggregators.
To ensure that your credit, debit or charge card is not being used without your consent,
we will validate name, address and other personal information supplied by you during
the order process against appropriate third party databases, public or otherwise. You
acknowledge that such checks will be made. In performing these checks, personal
information provided by you may be disclosed to a registered Credit Reference Agency
that may keep a record of that information. A record of the decision made is available
for us to retrieve for auditory purposes. These checks are performed only to confirm
your identity and will leave a specific non-credit footprint. A credit check is not
performed and your credit rating will be unaffected by these checks. All information
provided by you will be treated securely and strictly in accordance with applicable data
protection legislation.
5. Providing Us with Information about Someone Else
If you provide us with information about another person, you confirm that they have
appointed you to act for them, to consent to the processing of their personal data and
that you have informed them of our identity and the purposes (as set out above) for
which their personal data will be processed. We may ask you to provide proof of your
identity and evidence that you have gained consent from the person that allows you to
act on their behalf.
6. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will
use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered
into with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation.
We usually do not rely on consent as a legal basis for processing your personal data
other than in relation to sending direct marketing communications to you via email or
text message. You have the right to withdraw consent to marketing at any time by
contacting us.
Generally, we need your information and use the information we collect about you:
- to enable us to supply you with products and services that you have requested;
- to help us with understanding more about how our website is used;
- to be able to send you communications that may be of interest to you, either
electronically or otherwise; and
- to prevent fraudulent activity.
7. Sharing Your Information
The information you provide to us will be treated by us as confidential and will be
processed only by our employees within the Ukraine(UA). We may disclose your
information to other third parties who act for us for the purposes set out in this notice or
for purposes approved by you, including payment providers and marketing suppliers,
who may be based outside of the UA.
We require all third parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your
personal data for their own purposes and only permit them to process your personal
data for specified purposes and in accordance with our instructions..
8. Data Security
We have put in place appropriate security measures to prevent your personal data from
being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents,
contractors and other third parties who have a business need to know. They will only
process your personal data on our instructions and they are subject to a duty of
confidentiality.
To ensure that your online data is secure, we do the following:
- Secure Server: we use a secure server when you provide us with personal
information as part of the website user registration process. SSL (the secure server
software) encrypts your information before it is sent to us. We also take appropriate
measures to ensure that the information disclosed to us is kept secure, accurate and up
to date and kept only for so long as is necessary for the purposes for which it is used.
- Encryption: we encrypt your credit/debit details to minimise the possibility of someone
being able to read your details as they are sent to us over the Internet.
- Secure Socket Layer (SSL): we accept orders only from Web browsers that permit
communication through Secure Socket Layer (SSL) technology - this means you cannot
inadvertently place an order through an unsecured connection. In technical terms this
means, we use a state of the art payment platform.
- Encryption Technologies: We use a variety of encryption technologies including RSA,
3-DES and AES. Credit card details are encrypted with AES before being stored. The
production network is partitioned into a proxy server tier, an application server tier, and
a database server tier. Servers running at each tier are protected using
ipchains/iptables firewalling, which is set to only permit the necessary network traffic
and deny and log everything else. The front end of the entire infrastructure is protected
with a virtual firewall rack from a company called Inkra (http://www.inkra.com/) which
provides additional firewalling and DoS protection.
9. Your Rights
You have the right at any time to:
- Request correction of the personal information that we hold about you. This enables
you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or
remove personal information where there is no good reason for us continuing to process
it. You also have the right to ask us to delete or remove your personal information
where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate
interest (or those of a third party) and there is something about your particular situation
which makes you want to object to processing on this ground. You also have the right to
object where we are processing your personal information for direct marketing
purposes.
- Request the restriction of processing of your personal information. This enables you
to ask us to suspend the processing of personal information about you, for example if
you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
- Withdraw your consent to the processing of your personal information at any time.
If you wish to exercise any of the rights set out above, please
contact
[email protected] 10. How Long We Will Keep Your Information
We review our data retention periods regularly and will only hold your personal data for
as long as is necessary for the relevant activity, or as required by law (we may be
legally required to hold some types of information), or as set out in any relevant contract
we have with you.
To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through other
means, and the applicable legal requirements.
11. Marketing
We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising. You can update your communication preferences at
any time by contacting our customer services team
[email protected].
Registered users can also log in to their online account and update their communication
preferences by selecting and unselecting the options found under Edit Profile in the My
Account section of this website.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on
what we think you may want or need, or what may be of interest to you. This is how we
decide which products, services and offers may be relevant for you (we call this
marketing).
You will receive marketing communications from us if you have requested information
from us or purchased products from us. We will also get your express opt-in consent
before we share your personal data with other company.
12. Opting-Out
You can ask us or our associated third parties to stop sending you marketing messages
by contacting us at any time or by unsubscribing from our campaigns via the methods
listed above.
Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of an attempted product purchase on our
website, product experience/review or enquiry received by our customer services team.
13. Contact Information
We have appointed a Data Protection Officer, who is responsible for overseeing
questions in relation to this privacy notice. If you have any questions or suggestions
about this privacy notice, including any requests to exercise your legal rights or if would
like to make a complaint, please contact the Data Protection Officer using the details set
out below.
Online:
[email protected]Postal address:
PO “The Spirit of Freedom”
ГО «Дух свободи»
провулок Комарова 5, б.10
м. Вінниця
Україна, 21008
This privacy policy was last updated on 05th May 2022