Collecting Personal Information

When you visit our website, we collect information to make sure we are creating the right orders for you and update you about latest offer through newsletters. We take full responsibility for all the personal data (such as your name, address, email address, phone number, and date of birth, measurements etc) that you provide us with, obtained when you subscribe to our newsletter or when you create a personal profile.

Personal Data

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Device information

• Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
• Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
• Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
• Disclosure for a business purpose: shared with our processor Hostinger, Stripe, Courier companies etc.

Device information

• Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers, debit card, google pay etc), email address, and phone number.
• Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
• Source of collection: collected from you.
• Disclosure for a business purpose: shared with our processor Hostinger, Stripe, Courier companies etc.

Customer support information

• Customer support will have information about name, address, order history, body measurements, chat history of the client profile.
• Purpose of collection: to provide customer support.
• Source of collection: collected from you.

Minors

The Site is not intended for individuals under the age of 18. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

Sharing Personal Information

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 Hostinger to power our online store. You can read more about how Hostinger uses your Personal Information here: https://www.hostinger.com/legal/privacy-policy.
• 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 Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

• We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Using Personal Information

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

Lawful Basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

• Your consent;
• The performance of the contract between you and the Site;
• Compliance with our legal obligations;
• To protect your vital interests;
• To perform a task carried out in the public interest;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic Decision-Making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our processors Hostinger and Stripe use limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

• Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
• Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.

Your Rights

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us here

Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Hostinger’s GDPR Whitepaper: https://www.hostinger.com/blog/what-the-european-gdpr-means-for-hostinger- customers

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information here.

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address here.

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use the following cookies to optimize your experience on our Site and to provide our services. We do not use cookies to store personal information or to disclose information to third parties.

Cookies Necessary for the Functioning of the Store

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

TYou can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

Third-Party cookies

We use third-party cookies to collect statistics in aggregate form in analysis tools such as Google Analytics. The cookies used are both permanent and temporary cookies (session cookies). The permanent cookies are stored on your computer or mobile device for no longer than 24 months.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

The Shoperts Privacy Commitment

At Shoperts, we respect our customers' privacy and take great care to safeguard personal information. As part of our ongoing commitment to putting customers first, we have a long-standing policy of protecting privacy in all of our business operations.

We believe that an important part of protecting privacy is to be clear about how we handle customers' personal information, and to make information about our approach easily accessible.

We have developed this Privacy Commitment to provide you with specific details about our privacy practices. We have also developed the Shoperts Privacy Code which sets out the general principles that govern the collection, use and disclosure of our customers' personal information.We have learned from our customers that sometimes you just want the big picture, while other times you may want more details or examples of how a policy or process works.

For this reason, we have structured this Privacy Commitment in layers. Importantly, both our Privacy Commitment and Privacy Code reflect the requirements of Canada's applicable privacy legislation, including the *Personal Information Protection and Electronic Documents Act*, and our own continuing commitment to customer privacy. The bottom line is that we want you to understand the purposes for which we collect, use and disclose personal information about our customers. The following is a summary of our privacy practices.

Why we collect personal information

• To establish and maintain a responsible commercial relationship with you and to provide ongoing service.
• To understand your needs and preferences.
• To develop, enhance, market or provide products and services.
• To manage and develop our business and operations.
• To meet legal and regulatory requirements, including tax reporting obligation.

When we share personal information

• To facilitate and improve the provision of products and services to you.
• To enable our service providers and partners to help us serve you better.
• When data crosses borders: Personal information collected by Shoperts may be stored and processed outside the jurisdiction where it was collected. In either case, the information is protected with appropriate security safeguards, but may be available to foreign government agencies under applicable law. In particular, your personal information may be stored in the cloud, which may include transfers of data outside of Canada. Where appropriate, we use de-identification and other means to protect and minimize the amount of personal information we transfer.
• For emergency purposes When it appears that there is imminent danger to the life, health or security of an individual which could be avoided or minimized by disclosure of the information.
• Where required by law or applicable regulation

Some of the ways we respect your privacy

• We maintain a robust information security governance program to protect your personal information.
• We may de-identify personal information.
• We strive to keep your personal information as accurate and up-to-date as is reasonably necessary for the identified purposes.
• We respond in a timely manner to your requests for access to your personal information.
• We keep personal information only as long as reasonably necessary for the purposes we have identified to you, or as required by law.
• We take privacy and security training and awareness seriously,
• Unless you provide your express consent, Shoperts does not disclose your personal information to marketers of third-party products or services to enable targeted advertising, or for any other purpose.
• We are committed to being transparent with you about how we handle your personal information,
• We use cookies in a limited manner, and only for purposes consistent with this Commitment.
• Privacy legislation generally sets out certain circumstances under which organizations may collect, use or disclose personal information without consent. Examples include emergency circumstances or the investigation of a contravention of laws. Other than under such specified circumstances, Shoperts will not collect, use or disclose your personal information for any purpose other than those identified in this Commitment, our Privacy Code, your Customer Service Agreement, or our Service Terms, except with your consent.
• Shoperts will continue to review this Commitment to ensure it is relevant, remains current with changing technologies and laws, and continues to meet your evolving needs.

Choices we offer you

• We rely on your consent to continue to collect, use and disclose your personal information for the purposes we have identified to you. However, we want you to know that you do have choices and can refuse or withdraw your consent as follows:
• You may have your name removed from one or more of our marketing lists, such as our telephone, mail or email marketing lists. We use these lists to inform you of relevant products, services and special offers that may be of benefit to you.
• You may refuse to provide personal information to us. You may also withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, in either case, this may limit our ability to serve you and may force us to cancel some or all of the services you receive from us.Unless you tell us otherwise, we will assume that we have your consent to continue to collect, use and disclose your personal information for the purposes we have identified to you.