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Data Protection and Privacy Notice

This Notice applies to anyone who visits Culture Digital’s websites or Culture Digital’s mobile applications (the “Sites”), and any other platforms Culture Digital owns or controls and makes available (the “Culture Digital Platforms”). We refer to the Sites and the Culture Digital Platforms as the “Services”.

When you use the Services, you access linked pages or blogs, features and content (including any information, text, graphics, photos, lists of items compiled by you, comments, reviews, links, or other materials uploaded, downloaded or appearing on, or linked to the Services) (collectively the “Content”).

Any personal data about our users (the “User” or “you”) provided to or gathered by the Services is controlled by Culture Digital LTD (a company incorporated in England and Wales, with company number  12019037 and with a registered office at Flat 101, 30 Barking Road E16 1GR) ("Culture Digital ", “we”, “our” or “us”).

1. What Does This Notice Cover?

This Notice covers Culture Digital’s treatment of personal data that Culture Digital gathers when you access the Services and/or access the Content. We explain what information we gather, why we gather it and the choices you have regarding your personal data.

2. What Information Does Culture Digital Collect, and How?

As customers, you do not have any legal obligation to provide any information to Culture Digital. However, we require certain information from you in order to operate properly, including completing a transaction on your behalf. Login credentials (email and username) enable us to personalize and improve our services. You hereby agree and acknowledge that any information you do provide to us is provided at your own free will, for the purposes mentioned in this Privacy Notice and that we may keep such information in a database(s) which will be registered and kept in accordance with applicable laws and regulations.

a) Information You Provide to Us

We receive and store any information you enter on the Services or provide to us in any other way. The types of information provided by you may include your full name, email address, username, password, home and billing address, shipping address, order details of transactions carried out on the Sites, and payment information (payment information is held by our payment processors rather than us).

b) Information Collected Automatically

i. We receive and store certain types of information whenever you interact with the Sites or use another feature of the Services. In other words, when you are using the Services we are aware of it and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below. Culture Digital automatically receives and records information on our server logs from your browser including your IP address, certain cookie information (please see our Cookie Policy for further information) and the page you requested.

ii. We automatically collect usage information, such as the numbers and frequency of visitors to the Services, similar to user music preference data or to TV ratings that indicate how many people watched a particular show. Culture Digital only uses this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often customers use parts of the Services or another feature of the Content so that we can make the Services appealing to as many customers as possible, and improve the Content.

iii. We also collect information about the devices you use to access our Services. This includes, for example, the type of computer or device you use, the hardware model, operating system and software.

c) E-mail Communications

We often receive a confirmation when you open an email from Culture Digital if your computer supports this type of program. Culture Digital uses this confirmation to help us decide how to make emails more interesting and helpful.

3. What About Cookies?

Technologies such as cookies, beacons, tags and scripts are used by Culture Digital and our partners, affiliates, analytics or service providers. These technologies are used in analyzing trends, administering the Sites, tracking users’ movements around the Sites and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

Please see our Cookie Policy for information as to how we use cookies in relation to the Services.

4. Why Do We Collect Information?

We use the information we collect in order to:

  • Operate and improve the Services and to display Content

  • Allow you to take full advantage of the Services, including using “Wish Lists”

  • Allow you to order products on the Sites (where applicable)

  • Process or facilitate payments through third party payment processors (where applicable)

  • Recommend relevant products, and make it easier for you to track products you’re interested in

  • Communicate with you about your orders and provide customer service, technical assistance and collect feedback

  • Communicate with you about products, sale reminders, services and promotional offers

  • Administer your account if you have one, and update our records

  • Enable third-party service providers and contractors to carry out technical, logistical or other functions on our behalf

  • Conduct research, troubleshoot problems, and detect and protect against error, abuse of the Services, fraud or other criminal activity

  • Control risk, comply with laws and regulations, and comply with other legal process and law enforcement requirements

  • Produce aggregated statistical reports (provided that the reports do not identify customers)

5. Where Will We Store Your Information?

To provide the Services, the information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed and used by staff operating outside the EEA who work for us or by one of our third-party service providers. Such staff may be engaged in, among other things, the fulfilment of your request, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that third parties to whom we transfer any data provide sufficient protection of that data.

6. Sharing Information With Third Parties

We share your information only as described in this Notice and require commercial entities with which we share your information to agree to keep it confidential.

b) Payment processors

For purchases made on the Sites via the Integrated Checkout, your payment information (e.g. credit or debit card details) will be processed by third-party payment process providers such as Paypal

c) Advertisers

Advertisers and advertising networks may use automated technologies such as cookies to collect information about your website activity on the Sites and other sites. This is used to target advertising to you online that may be of interest to you. For more information on cookies and how to reject targeted advertising or interest-based advertising cookies, please read our Cookie Policy.

d) Analytics

We have implemented the Google Analytics Demographics and Interest Reporting feature and may share your information to analytics and search engine providers that help us to improve and optimise the Services.

e) To comply with legal requests

We may provide your information to relevant third parties when we believe in good faith that it is necessary in order to (i) comply with the law, regulation or a legal request; (ii) enforce or apply our conditions of use in other agreements; or (iii) protect the rights, property, or safety of Culture Digital, our employees, our users, or others. This may include exchanging information with other companies and organisations for fraud protection and credit risk reduction.

h) Third parties where a corporate transaction is contemplated

In some cases, we may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that are transferred. In addition, in the event of a merger, acquisition, reorganisation, asset sale or in the unlikely event that Culture Digital goes out of business or enters bankruptcy, customer information may be one of the assets that is transferred to or acquired by a third party. If such transfers occur, the third-party transferee may continue to use your information as set out in this Notice.

7. How is Your Information Kept Secure?

We take care to maintain appropriate safeguards and security features to protect the integrity and privacy of the information you provide us with and to try to prevent unauthorised access to it. We encrypt your information to protect it from unauthorised use, and we use pseudonymisation, information access controls, and firewalls.

All information you provide to us is hosted and stored on Shopify

 

9. Data Retention

Subject to any legal obligations to keep your information longer, we store the data you provide to us for as long as is necessary to provide the Services to you.

10. What’s Our Legal Basis for Processing Your Information?

We process your information where we have a legal basis for doing so.

a) Necessary for our legitimate interest. Out legitimate interests include:

  • Improving our Site and Services

  • Ensuring that our marketing communications, advertising and recommendations are relevant to you

  • Understanding customer usage of our Services

  • Ensuring our Services are managed correctly

b) Based on your consent.

For example, where you provide us with marketing consents in order to send you information about products that may be of interest to you. Your consent may be withdrawn at any time by contacting us.

c) Necessary to comply with relevant legal obligations.

For example, to make mandatory disclosures to law enforcement.

11. What rights do You have in relation to information We hold about You?

You have certain rights in relation to the information that we hold about you, which are detailed below. Some of these rights only apply in certain circumstances.

a) Access

If you are based in the EU, you have a legal right under the General Data Protection Regulation (the "GDPR") to request access to a copy of your personal data held by us. To do this, please contact us at hello@cultureisdigital.com, use the subject line “DSAR” and include the details about what personal data you are looking for.

12. Children

We do not knowingly market or sell products for purchase by children. The Services are not designed for use by children under 13 years old. Children under 13 are not allowed to register with Culture Digital or use the Services, or submit personal data through the Services. We do not knowingly collect personal data from anyone under the age of 13. If you have any reason to believe that anyone under the age of 13 has provided their personal data to us, please contact us as specified below, and we will work to delete that information from our databases.

13. Changes To This Notice

Culture Digital reserves the right to change this Notice from time to time. Use of information we collect now is subject to the Notice in effect at the time such information is used. If we make substantial changes in the way we use personal data, we will notify you by posting an announcement on the Services or sending you an email. Otherwise, all other changes to this Notice are effective as of the stated “Last Revised” date.

14. Questions Or Concerns

If you have any questions or concerns regarding privacy on our Services or the Content, please send us a detailed message at hello@closefriendsonly.co.uk We will make every effort to resolve your concerns. If your questions or concerns are not answered online, you may write to us at Flat 101, 30 Barking Road E16 1GR

This Agreement has been drawn up in the English language. In case of discrepancies between the English text version of this Agreement and any translation, the English version shall prevail.

Last Revised: March 16th 2021.

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