- 1.2. Ellaycom General Trading LLC (“Ellaycom”, “we” “us” or “our”) is committed to safeguarding the privacy of the personal information that is provided to us or collected by us during the course of our business as well as the personal information we receive from you (“User”, “you” or “your”) to this website (“Website”):This Policy, describes how and why we collect, store and use personal information, and provides information about your rights. Please read the following information carefully to understand our views and practices regarding how we handle personal information.
- 1.3. For the purposes of applicable data protection law, Ellaycom is the "data controller" of your personal information.
2. COLLECTION OF PERSONAL INFORMATION
- 2.1. By using the Website you expressly consent to our collection, use and disclosure of your personal information in accordance with the terms of this Policy. You may withdraw such consent at any time, however this will not affect the lawfulness of the processing based on your consent prior to the withdrawal.
- 2.2. We may collect and process the following personal information:
- a. Information you give us:
- i. If you are enquiring about our services, then we may request and process your personal information including your name, e-mail address, telephone number and date of birth;
- ii. personal information from you, such as your name, email address, postal address, phone number, credit card number, gender, birthday, personal interests, etc., when you engage in activities such as placing an order online or by phone, saving your information with us online, or participating in a contest, promotion, or survey
- iii. You may give us information about you when you complete a form on our Website or by corresponding with us by phone, e-mail or other electronic means, or in writing, as well as other information you provide directly to us, including in conversation with our employees and staff.
We may also combine your personal information with information we receive from other sources, such as joint marketing partners, public databases, publicly available pages on social media platforms and other third parties.
- b. Information we collect about you:
With regard to each of your visits to our Website, we may automatically collect the following information:
- i. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- ii. a record of your product interests and the purchases you make online, through a mobile app or by phone; and
- iii. information about your visit; property you viewed or searched for; page response times, download errors, length of visits, page interaction information (such as scrolling, clicks, and mouse-overs)
- c. We may collect information in a variety of ways, including:
- i. Your browser or device (e.g. your operating system, browser type and version installed browser plugins, referrer information, requested site, date and time of access, IP address, webserver status code).
- ii. Mobile applications: When you download and use one of our mobile applications, we may track and collect usage data, such as the date and time the app on your device accesses our servers and what information and files have been accessed, viewed and/or downloaded to the app based on your device number or other identifier.
- iv. Using pixel tags and other similar technologies: We may use pixel tags to, among other things, track the actions of users of the Website and our services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Website and our services and response rates.
- vi. IP Address: Your Internet Protocol (“IP”) address is a number that is automatically assigned to the computer that you are using by your Internet service provider. An IP address may be identified and logged automatically in our server log files whenever you access our websites, along with the time of the visit and the pages that were visited. Your IP address may also indicate your approximate physical location. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other technologies. We use IP addresses for purposes such as calculating usage levels and diagnosing server problem
- d. How is my information used for behavioral or targeted advertising and what choices do I have?
- We use our own cookies to help determine which of our ads are shown to you on other websites.
- We also work with third-party companies that use their tracking technologies (including cookies and pixel tags) on our websites in order to provide tailored advertisements on our behalf and on behalf of other advertisers across the Internet. These companies may collect information over time about your activity on the Website and other sites and your interaction with our advertising and other communications and use this information to determine which ads you see on third-party websites and applications. These technologies and the information collected about you may also be used to track your activity across multiple devices. For more information about this practice and to understand your options including how to opt out of receiving these tailored advertisements, please visit www.ellay.com.
- Please note that even if you opt-out, these tracking technologies may still collect data and you will still see ads, but they will not be targeted based upon the information collected through these tracking technologies.
- a. Information you give us:
- 3.1. We may use your personal information to provide products and services and to support our business functions. For example, we may use this information for the following purposes:
- a. To process and fulfill your order, including by shipping products to you, or others you designate, and sending emails to you, or others you designate, to confirm your order status and shipment and to process merchandise returns;
- b. To communicate with you and to send you information by email, postal mail, telephone, text message, or other means about our products, services, contests, and promotions, including marketing communications that we believe may be of interest to you;
- c. To communicate with other persons using contact information you provide, such as when you designate another person as the recipient of a refer-a-friend message or a gift;
- d. To make your shopping experience easier, more enjoyable and more efficient;
- e. To address problems with and improve our products, brands, services and technologies, as well as to develop new products and services;
- f. To allow you to use our in-store and online technologies;
- g. To provide consistent, personalized services across all channels and all of our brands, including to personalize our advertising, marketing communications, shopping experiences and promotional offers;
- h. To organize local community events, promotions and in-store experiences;
- i. To facilitate social sharing
- j. To allow you to apply for an offer of credit from a payment card provider;
- k. To allow you to enroll and participate in a loyalty or customer relationship programme;
- l. To administer and fulfill our contests and other promotions;
- m. To help us learn more about your shopping preferences;
- n. To prevent, detect, mitigate and investigate fraud, security breaches and activities that are or potentially may be prohibited or illegal;
- p. As we believe to be required or appropriate to protect the rights, property, safety and security of the Website, TSC Trading, and our employees, customers and others; and
- q. As we believe to be required or appropriate under applicable law, to respond to requests from government authorities and to comply with legal process
- You always have the choice not to receive marketing information or calls. For instructions on opting out, please see the section entitled, "How do I make choices about receiving promotional communications?" below.
4. SHARING YOUR PERSONAL INFORMATION
- 4.1. We may also share your personal information with third parties including certain service providers we have retained in connection with our business activity, such as Wirecard Bank AG (“Wirecard”) for credit card processing. Please find additional information of Wirecard according to Article 13 of the General Data Protection Regulation (EU) 2016/679 (known as the “GDPR”) on the following information page:
- 4.2. Moreover, we may disclose your personal information to third parties:
- a. If Ellaycom sells or buys any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
- b. If Ellaycom, its business, or its assets are acquired by a third party, in which case personal information held by it about its users, suppliers, or customers will be one of the transferred assets;
- c. If we are under a duty to disclose or share your personal information in order to comply with any legal obligation or if we are required to do so by a legal process, or in order to enforce or apply our terms and conditions and other agreements; or if we reasonably consider this necessary; or to protect the rights, property, or safety of Ellaycom, our users, our customers, or others; and
- d. For the purposes of crime prevention and fraud protection.
- 4.3. We may also disclose your personal information to law enforcement authorities or other government officials.
- 4.4. We will disclose your personal information to Wirecard for the purposes of processing your credit card payments. In this capacity, Wirecard is acting as a “controller” under Article 4(7) of the GDPR.
- 4.5. We may also disclose your personal information to any competent administrative or judicial authority in prevention of money laundering and terrorist financing in compliance with the Prevention of Money Laundering regulation, for the purposes of preventing any operation related to money laundering or terrorism financing.
5. HOW DO I CONTACT YOU?
- We use up to date information storage and security to hold your personal information securely in electronic and physical form to protect your personal information from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss. Whilst we have put in place physical, electronic and managerial procedures to secure and safeguard your personal information, we will not be held responsible for any unauthorized access by third parties and we cannot guarantee that the personal information provided by you or that is transmitted via the Website or by e-mail is totally secure and safe and you provide it at your own risk.
7. CROSS-BORDER TRANSFERS
- Your personal information may be transferred to and stored in servers and facilities located in your region or another country. Some of these countries do not provide the same level of data protection as the country in which you reside and may not be recognized as providing an adequate level of protection.
- When we transfer your information to other countries, we will use, share and safeguard that information as described in this Policy. To conduct sales or to manage your participation in promotions and events, we may transfer the personal information we collect to countries which do not provide the same level of data protection as the country in which you reside and are not recognized in that country as providing an adequate level of data protection. We only transfer personal information to these countries, with your consent, when it is necessary for the services we provide you, or subject to appropriate safeguards that assure the protection of your personal information, such as European Commission approved standard contractual clauses.
8. MARKETING COMMUNICATIONS
- 8.1. We, or trusted third parties on our behalf, may contact you by email or post with information about our products or promotions that might be of interest to you. Where necessary, at the time that you provide your personal information to us, you will be given the opportunity to indicate whether or not you are happy for us to use your personal information in order to tell you about such product and promotions.
- 8.2. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services. You may, at any time, withdraw your consent to receive commercial marketing communications by clicking on the link provided in the relevant email, or by emailing us on firstname.lastname@example.org
9. YOUR RIGHTS
- 9.1. Under certain circumstances you have the following rights:
- a. Access: You have the right to request a copy of the personal data that we hold about you. Please note that there are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. You are entitled to see the personal data held about you. If you wish to do this, please contact us using the contact details provided below.
- b. Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date. You can also review and correct/ update some of your personal data by logging-in to your account on our Website.
- c. Objecting: In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data. If you would like us to stop using your personal data, please contact us using the contact details provided below.
- d. Porting: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
- e. Erasure: You have the right to the erasure of your personal data when the personal data are no longer necessary for the purposes for which they were collected, or when, among other cases, your personal data have been unlawfully processed.
- f. Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint to the applicable supervisory authority or to seek a remedy through the courts.
- g. Withdrawal of consent: When personal information is processed on the basis of consent, you may withdraw such consent at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
- 9.2. You may, at any time, exercise any of the above rights, by writing to the e-mail address email@example.com
10. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
- 10.1. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
- 10.2. Your personal information that is processed for marketing purposes will be stored until you exercise the right to withdraw consent, and once such right is exercised, your personal information will be kept only during the applicable statute of limitations period for any disputes or liabilities that may arise as a consequence of the processing of that information (which is up to 15 years in the UAE). Once potential actions are time barred we will proceed to delete the personal data. In any other circumstances, we will only retain your personal information for a shorter or longer period as required by any applicable law.
11. LINKS TO THIRD PARTY SITES
- This Website may link to other, unaffiliated third party websites. Please note that Ellaycom is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third party websites. You must always carefully review the privacy and confidentiality policy of any third party website that you may visit in order to understand how the operators of that website may collect, store and use your personal information.
13. CONTACT DETAILS
- If you have any questions about this privacy notice, or our processing of your personal data, please contact us on firstname.lastname@example.org