SIRILOVA FASHION

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SIRILOVA

Privacy Policy

Declaration on the obligation to provide information

                                    Effective Date: Dec 24, 2019  
 
 
 
 
This Privacy Policy covers SIRILOVA (“we,” “us,” “our”) policies on the collection, use, and disclosure of personally identifiable and other personal information (as defined by applicable law, including, but not limited to, the California Consumer Privacy Act of 2018, Civil Code sections 1798.100 et seq (“CCPA”) and the European Union institutions is based on the Regulation (EU) 2018/1725 on the protection of personal data by the EU institutions, bodies, offices and agencies) (collectively referred to as “Personal Information”) in connection with your use or access of the www.sirilova.com website (the “Site”).
 
 
 
 
 
 
By checking the “I consent to the Privacy Policy” box and/or accessing the Site, and subject to your opt-in/opt-out preferences, you consent to the collection, use and disclosure practices identified in this Privacy Policy.
 
The protection of your personal data is very important to us. We therefore process your data exclusively on the basis of the statutory provisions (DSGVO, TKG 2003). In this data protection information we inform you about the most important aspects of data processing on our website. 
 
When you visit our website, your IP address and the beginning and end of the session are recorded for the duration of this session. This is due to technical reasons and therefore represents a legitimate interest within the meaning of Art 6 Paragraph 1 lit f GDPR. Unless otherwise regulated in the following, this data will not be processed by us.

 

YOUR CALIFORNIA PRIVACY RIGHTS

California Consumer’s Request to Know, Right to Delete, Right to Opt-Out of Sale Notices. For Information on your California Consumer Rights, please see: California Consumer Privacy Rights Notice (“Notice”)

A Verifiable Consumer Request under this Section may be submitted to The Fashion Store effective January 1, 2020 by emailing The Fashion Store at support@sirilova.com or through the account or as otherwise designated in the Notice.
 
For each request, The Fashion Store will initially verify the email address on file with the email address submitted in the applicable request. Further verification will be based upon confirmation of data correlating to information maintained by The Fashion Store, as applicable. Consumers may designate an authorised agent to make a request on the Consumer’s behalf a support@sirilova.com. Requests by authorised agents are subject to additional verification requirements pursuant to the rules and regulations set forth in the CCPA. 

 

DATA PROTECTION

SECTION 1 – ONLINE STORE TERMS

Categories of Personal Information. 
 
1. What Information Is Collected by THE FASHION STORE And How Is It Used?
 
User Account
Users may create an account by providing their name, email address and password. Registration is optional and users may access the Site as a guest at any time.
 
Purchases
When you purchase products on the Site, The Fashion Store will collect shipment and payment information as follows:
 
Shipment
Users will be required to provide information, including names, emails (for electronic delivery) and addresses (for physical delivery) of products purchased on the Site. Phone numbers and email addresses may also be requested in the event The Fashion Store or the common carrier needs to contact the purchaser or recipient to facilitate delivery of the products to the appropriate location. At your request, shipping information may be saved for faster checkout on future orders.
 
Payment 
Sirilova requires users to input the following payment information: credit or debit card information, first and last name, billing address, card expiration date, and three-digit security code.
 
Email Addresses & Contact Information 
Users may also provide their email address and/or other contact information to The Fashion Store to subscribe to its newsletters, to contact us through the Site with questions about our Site and Services, or to reset their password. When users make a purchase, users may also subscribe to Sirilova’s newsletters. Users can opt-out through the unsubscribe link in that newsletter or corresponding email.
 
2.  Is Information Collected By Or Disclosed To Third Parties?
 
SIRILOVA DOES NOT AND WILL NOT SELL, RENT, OR LEASE PERSONAL INFORMATION. HOWEVER, PERSONAL INFORMATION IS PROCESSED BY SERVICE PROVIDERS WHO HAVE CONTRACTED WITH THE FASHION STORE TO FACILITATE THE PROVISION OF SERVICES THROUGH THE SITE AS FOLLOWS:
 
Shopify
Sirilova’s Site is powered by Shopify, a commerce company that provides software and retail point of sale systems for online stores and merchants. Shopify collects our customers’ name, email, shipping and billing address, payment details, company name, phone number, IP address and device data to enable the shopping capabilities of the Site, including supporting and processing orders, authentication and processing payments. This information is also used to improve Shopify’s Services. Information is collected by Shopify when The Fashion Store’s customers use or access the Shopify services through the Site, such as when a customer visits the Site, places an order, or signs up for an account on the Site. Please refer to Shopify’s Terms of Service and Shopify’s Privacy Policy for more information about their data collection practices.
Google Analytics
The Fashion Store utilizes Google Analytics to access anonymised data to help us understand how our Services are used. Google Analytics is a web analytics tool that helps The Fashion Store understand how users engage with the Site, so that we can review and improve our Services. Google Analytics collects information anonymously. It provides a report to The Fashion Store  with website trends without identifying individual visitors. Please see the Google Privacy Policy for more information on their disclosures. If you do not want your data to be used by Google Analytics, you may opt-out by Google Analytics Opt-out Browser Add-on.
 
Google-Tag-Manager
We also use Google Tag Manager. Google Tag Manager itself does not collect any personal data. Tag Manager makes it easier for us to integrate and manage our tags. Tags are small code elements that, among other things, are used to measure traffic and visitor behavior, to understand the effect of online advertising and social channels, to set up remarketing and orientation towards target groups, and to test and optimize websites. If you have performed deactivation, Google Tag Manager takes this deactivation into account. http://www.google.de/tagmanager/use-policy.html
Google Web Fonts
For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly. For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.
If your browser does not support web fonts, a standard font is used by your computer. Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”).
reCAPTCHA is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google. The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that such an analysis is taking place.Data processing is based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in protecting its site from abusive automated crawling and spam. For more information about Google reCAPTCHA and Google’s privacy policy, please visit the following links: https://www.google.com/intl/de/policies/privacy/ and https://www.google.com/recaptcha/intro/android.html.
Google Maps
We use the “Google Maps” component of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter “Google.”
Google sets a cookie in order to process the user configuration and data when the page with the integrated “Google Maps” component is displayed. As a general rule, this cookie is not deleted by closing the browser, but rather expires after a certain time, as long as it is not previously manually deleted by you. If you do not agree with this processing of your data, you may choose to deactivate the “Google Maps” service and thereby prevent the transfer of data to Google. To do this, you must deactivate the Java Script function in your browser. However, we would like to point out that in this case you will not be able to use “Google Maps” or at least only to a limited extent. The use of “Google Maps” and the information obtained through “Google Maps” is according to Google’s Terms of Use http://www.google.de/intl/de/policies/terms/regional.html
as well as the additional Terms and Conditions for “Google Maps” https://www.google.com/intl/de_de/help/terms_maps.html.
Instagram
We promote the service Instagram on our website. Instagram is a service of Instagram Inc. By means of the integrated “Insta” button on our page, Instagram receives the information that you have accessed the corresponding page of our website. If you are logged into Instagram, Instagram may assign the visit to our site to your Instagram account and link the data by this means. The data transmitted by clicking the “Insta” button is stored by Instagram. You can find more information regarding the purpose and scope of data collection, its processing and use, as well as your related rights and settings options for protecting your privacy in the Instagram data protection notice under https://help.instagram.com/155833707900388. To prevent your visit to our site from being accessed by your Instagram account, you must log out of your Instagram account before visiting our site.
YouTube Plugins
Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited. If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR. Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.
PayPal
We use PayPal as one of its payment processors. You must agree to PayPal’s Acceptable Use Policy, Terms and Conditions and any other legal requirements of operating a PayPal account. Any information you provide to PayPal is subject to its policies and procedures as outlined in its privacy policy, and we are in no way responsible for PayPal’s use of your information or its privacy practices.
 
Facebook Plugins
Our website integrates Facebook plugins, Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”) The plugins are identifiable by a Facebook logo or the “Like” button on our website. For a full list of all social Plugins, please see: http://developers.facebook.com/docs/plugins/. When you visit a page of our website that contains a social plugin, your browser establishes a direct connection to Facebook servers. Facebook receives information that you have visited our site with your IP address. If you click on the Facebook “Like” button while you are logged into your Facebook account, you can link the content of our pages on your Facebook profile. This allows Facebook to correlate your visit of our site with your user account. We wish to point out that we as providers of the website, we do not receive information about the content of the transferred data nor its use from Facebook. For more information, please see Facebook’s privacy policy at http://de-de.facebook.com/policy.php If you do not wish Facebook to be able to trace your visit of our website to your Facebook user account, please log out of your Facebook account before visiting our website.
 
Facebook Pixel
If you agree, we use “conversion pixels” from Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”) for our online offering. The Facebook pixel set allows us to see how successful a Facebook ad is. From Facebook we only receive statistical data without direct personal reference. If you are logged into Facebook, you should review Facebook’s privacy policy at www.facebook.com/about/privacy/. In addition to opting in to our site, you can check your personal settings on Facebook at www.facebook.com/ads/preferences/. The legal basis for the processing of personal data using cookies in connection with the use of Facebook “Conversion Pixel” for analysis purposes is, if you have given your consent to this, in accordance with Art. 6 para. 1 lit. a DSGVO. In addition, we have a legitimate interest in data processing within the meaning of Art. 6 para. 1 lit. f DSGVO, because we have an interest in the optimization of our online offer, our advertising presence and our marketing measures on Facebook. You can contradict a given consent to the data processing described above at any time by changing the settings with regard to the permitted cookies or by changing the settings in your browser.
Credit or Debit Card Information
The Fashion Store  does not itself store debit or credit card information on its servers. The Fashion Store utilizes Shopify Payments (powered by Stripe), GPay (powered by Google), PayPal and Amazon Pay to process payments on the Site. Please see Stripe’s Privacy Policy, Shopify’s Privacy Policy, Google Privacy Policy and the Amazon Privacy Notice for more information on their privacy disclosures.
Shipping Information
Shipping Information: The Fashion Store  utilizes service providers to access major shipping carriers, track packages and obtain shipping labels. Information may be shared with such service providers to process shipping requests. Shipping information will also be shared with our Product Partners to provide fulfilment services for all customer orders.
Web Hosting
Personal Data is stored on cloud servers maintained by Google Web Hosting. For more information on its privacy policy, please see Google’s Privacy Policy. Consumer Communications
The Fashion Store utilizes MailChimp to assist in customising its email marketing campaigns to its customers. Please refer to MailChimp’s Privacy Policy for additional information.
Social Plug-Ins
Users may share their The Fashion Store  experiences on social media. Users may follow and share their experiences on Instagram, Facebook, Twitter, LinkedIn and Pinterest. Users should click on the hyperlinks to review the applicable privacy policies.
Other Potential Third Party Disclosures
Personal Information may be disclosed to third parties to serve our legitimate business interests as follows: (1) as required by law, such as to comply with a subpoena, or similar legal process, (2) if The Fashion Store  is involved in a merger, acquisition, or sale of all or a portion of its assets, (3) to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (4) enforce our agreements with you, and/or (5) investigate and defend ourselves against any third-party claims or allegations. We will use commercially reasonable efforts to notify you about law enforcement or
court ordered requests for data unless otherwise prohibited by law.   Please see Section 5 for a more specific disclosure of the applicable categories of personal information collected and processed under the CCPA. 
 
3.  How Does THE FASHION STORE Comply With The Children’s Online Privacy Protection Act and Other Privacy Regulations Relating to Children? The Fashion Store does not knowingly collect Personal Information from anyone under the age of 18. If a parent or guardian becomes aware that his or her minor child as defined by applicable privacy laws has provided Personal Information without their consent, he or she should contact The Fashion Store at sales@thefashion-store.com. The Fashion Store will delete such Personal Information from our files within a commercially reasonable time, but no later than required under applicable law.
4.  How Long Does THE FASHION STORE Retain Information Collected? Unless erasure is otherwise requested by a customer, The Fashion Store will retain account and purchase data as long as it is necessary to provide services our customers. When a customer’s account is terminated or closed upon request, Personal Data collected through the Site will be deleted in accordance with applicable law. Personal Information obtained from Site visitors will be maintained as long as it is necessary to provide requested communications and information-based services or until a visitor exercises the right to opt-out of requested communications or information-based services. Anonymised and pseudo-anonymized data will be retained as long as The Fashion Store determines such data is commercially necessary for it legitimate business interests.

COOKIES

Our website uses so-called cookies. These are small text files that are stored on your device with the help of the browser. They do no harm. We use cookies to make our offer user-friendly. Some cookies remain stored on your device until you delete them. They enable us to recognise your browser the next time you visit.  As described in Section 2,The Fashion Store  also utilizes third party analytics services which may also use tracking cookies to provide information about the use of our Site. Users can set their browser to remove or reject the following cookies utilized by the Site:
    • _session_id, unique token, sessional, Allows Shopify to store information about your session (referrer, landing page, etc).
    • _shopify_visit, no data held, Persistent for 30 minutes from the last visit, Used by our website provider’s internal stats tracker to record the number of visits
    • _shopify_uniq, no data held, expires midnight (relative to the visitor) of the next day, Counts the number of visits to a store by a single customer. cart, unique token, persistent for 2 weeks, Stores information about the contents of your cart.
    • _secure_session_id, unique token, sessional_storefront_digest, unique token, indefinite. If the shop has a password, this is used to determine if the current visitor has access.
If you do not want this, you can set up your browser so that it informs you about the setting of cookies and that you only allow this in individual cases. Deactivating cookies may restrict the functionality of our website. {When using web analysis tools such as Google Analytics, eTracker, etc.}

 CONTACT US

If you contact us using the form on the website or by e-mail, the data you provide will be stored by us for six months in order to process the request and in the event of follow-up questions. We do not pass on this data without your consent. 

DATA STORAGE

We point out that for the purpose of easier shopping process and for subsequent contract processing from Web shop operator as part of Cookies the IP data of the access line are stored, as well as name, address and credit card number […] of the buyer. In addition, we also save the following data for the purpose of processing the contract: [please complete data] . The data you provide are required to fulfil the contract or to carry out pre-contractual measures. Without this data, we cannot conclude the contract with you. There is no data transfer to third parties, with the exception of the transfer of credit card data to the processing bank / payment service provider for the purpose of debiting the purchase price, to the transport company / shipping company commissioned by us to deliver the goods and to our tax advisor to fulfil our tax obligations. After canceling the shopping process, the data stored by us will be deleted. If a contract is concluded, all data from the contractual relationship will be stored until the expiry of the tax retention period (7 years).   The data name, address, purchased goods and date of purchase are also stored until the product liability expires (10 years). The data processing takes place on the basis of the legal provisions of § 96 Abs 3 TKG as well as Art 6 Abs 1 lit a (consent) and / or lit b (necessary to fulfil the contract) of the GDPR.   {If personal cookies are used}

 

WEB ANALYSIS

Our website uses functions of the web analysis service … [name of the tool and company of the provider including company headquarters including information on whether data is being transferred to a (non-European) third country]. Cookies are used for this, which enable an analysis of the use of the website by your users. The information generated in this way is transferred to the provider’s server and stored there. You can prevent this by setting up your browser so that no cookies are saved. We have concluded a corresponding contract data processing agreement with the provider. {Use of IP addresses based on the legal basis “legitimate interest”; In this case, pseudonymization is recommended:} Your IP address is recorded, but pseudonymized immediately (e.g. by deleting the last 8 bits). This means that only a rough localisation is possible. {For non-European providers:} The relationship with the web analysis provider is based on … [standard contractual clauses / an adequacy decision by the European Commission (eg in the case of the USA: “Privacy Shield”)]. The data processing takes place on the basis of the legal provisions of § 96 Abs 3 TKG as well as Art 6 Abs 1 lit a (consent) and / or f (legitimate interest) of the GDPR. Our concern within the meaning of the GDPR (legitimate interest) is to improve our offer and our website. Since the privacy of our users is important to us, the user data is pseudonymized [pseudonymization is recommended for the legal reason “legitimate interest”; this must be clarified with the web analysis service]. The user data will be kept for the duration of 12 months.  {If a newsletter is offered for subscription, also implement it under the corresponding menu item or link to this data protection information}

NEWSLETTER

You can subscribe to our newsletter via our website. For this we need your e-mail address and your declaration that you agree to receive the newsletter. {If further data is collected:} In order to provide you with targeted information, we also collect and process voluntarily provided information on areas of interest, birthday and postcode […] . {With double opt-in:} As soon as you have registered for the newsletter, we will send you a confirmation email with a link to confirm your registration. You can cancel your subscription to the newsletter at any time. Please send your cancellation to the following e-mail address: sales@thefashion-store.com . We will then immediately delete your data in connection with the sending of the newsletter. This revocation does not affect the legality of the processing carried out on the basis of the consent until the revocation.

WHAT IS THE FASHION STORE SECURITY POLICY

We have implemented reasonable administrative, technical and physical security measures to protect Personal Information against unauthorised access, destruction or alteration. The Fashion Store utilizes only PCI-DSS compliant third party payment processors to ensure the security of your personal information. Credit/debit card information provided is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption.

HOW DOES THE SITE RESPOND TO “DO NOT TRACK”SIGNALS?

“Do Not Track” is a feature enabled on some browsers that sends a signal to request that a website disable its tracking or cross-Site user tracking. At present, the Site does not respond to or alter its practices when a Do Not Track signal is received.

HOW WILL I BE NOTIFIED OF CHANGES TO YOUR PRIVACY POLICY? 

If we make material changes to our Privacy Policy, we will notify you by (1) changing the Effective Date at the top of the Privacy Policy, or (ii) sending an electronic notification to all active account holders, or (iii) adding a banner/notification to the Site itself.  

YOUR RIGHTS

You stand with regard to your data stored with us basically the right to information, correction, deletion, restriction, data portability, revocation and objection. If you believe that the processing of your data violates data protection law or your data protection claims have been violated in any other way, you can complain to us at sales@thefashion-store.com or the data protection authority.

YOU CAN REACH US UNDER THE FOLLOWING CONTACT DETAILS:

If you have any questions regarding your Personal Information or about our privacy practices, please contact us at: IONLUXE 
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