November 15, 2019
At MARIA LUCIA HOHAN we are committed to protecting and respecting your privacy.
The term "our online services" refers to www.mlh-shop.com, our pages on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Youtube. The term "our services" refers to our online services.
Should you have any queries about our use of your personal data or questions that are not answered here, or if you would like more information about how we collect, use and store your personal data, you can contact us at any time by emailing firstname.lastname@example.org, calling +40728 922 288 or writing to our Privacy Team at MARIA LUCIA HOHAN, 21 Carol Davila Street, Bucharest, Romania.
1. Who is the data controller?
Under the data protection law, the data controller is responsible for ensuring that your data is held securely, that you are given accurate information about how your data is used, and that your rights regarding your data are respected.
The MARIA LUCIA HOHAN website is owned and run by MLH CREATION FACTORY srl.
2. What personal data do we collect?
We collect and process only the data that is required to allow us to provide our services to you.
We collect, process and retain personal information from you and any devices you may use when you navigate to www.mlh-shop.com web or mobile view, by transacting, by registering an account or by participating in promotional activity and otherwise interacting with us.
We may also collect personal information from you if you physically enter one of our stores or attend an event.
We collect the following data when you browse or shop at www.mlh-shop.com:
• We process the personal data required to complete and dispatch your purchase, including your name, billing address, delivery address, payment details, mobile number, telephone number and email address. We collect your email address in order to send you confirmation of your order; we collect your telephone number so that we can contact you if there are any issues with the order.
• We collect your email address when you sign up to receive MARIA LUCIA HOHAN Newsletter.
• If you register for a MARIA LUCIA HOHAN account, we collect your name, email address, password, country, day and month of birth and additional information regarding your favorite styles and your marketing preferences.
• When you contact our Customer Care team, we may collect additional data to help us resolve any queries relating to your order, delivery, payments, marketing, the website or any other queries.
• We collect and process data about your browsing on www.mlh-shop.com, including the pages you visit and how you interact with these pages. If you have registered for an account, we collect browsing data about your access to the dedicated areas of the website. This is so we can optimize and personalize your experience with us. Content we generate via machine learning algorithms as they apply to personalizing your experience by curating more specifically the items you have an interest in, as well as supporting general service optimization including bid / markdown automation
• If you are a customer of www.mlh-shop.com , or if you have given us your consent, we collect and process your personal data for direct marketing activities.
• If you provide us with someone else’s data – for example, if you purchase a product to be delivered to a friend or as a gift we will collect and process the personal data required to complete the transaction such as the name, delivery address and other contact details for your friend. If you are receiving an item as a gift, we will process your data only to fulfil the gift request and our contractual obligations.
• When you call our Customer Care team, your call will be recorded for training and fraud prevention purposes.
• Device identifiers such as IP addresses, cookie IDs, IDFAs and other device identifiers, as well as geo location information, IoT technologies and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your browsing history, hashed email addresses, and your web log information.
3. How do we use the personal data we collect?
We collect and process your personal data for the following purposes:
a) To fulfil our contract with you, including taking payment, shipping and delivery;
b) To provide you with relevant information about our products and services via our marketing communications and advertising;
c) To help you take full advantage of our website, including placing and holding items in your shopping bag and using services such as Wish Lists;
d) To improve the performance of our website and our promotion of the website;
e) To allow our Customer Care team to help you with queries and requests;
f) To send you updates to important information such as our Terms & Conditions.
4) What is our legal basis for processing your personal data?
Under the Law we must have a valid reason for using your personal data and we may not collect, store or use data about you that is not compatible with that reason. There are four valid reasons for our use of your personal data:
a) Most of the data we collect from you is necessary to allow us to fulfil our contract with you or to enter into a contract with you e.g. you provide a billing address and email address when you purchase an item from www.mlh-shop.com so that we can process your payment and send you order confirmation.
b) In certain circumstances we will ask for your permission or consent to use your personal data e.g. if we would like to send you marketing information about items we believe may be of interest to you via email. If you have given your consent to our use of your personal data, you are entitled to withdraw this consent at any time.
c) We may also have a legitimate interest in using your personal data e.g. to ensure that the content of our website is presented to you and your device as effectively as possible, or to ensure that our marketing communications are relevant to your interests. If this is our reason for using your data, we must make sure that our interests do not override yours and you are entitled to object to this use of your data.
d) Lastly, we may be required to use your data to meet a legal obligation or to protect your interests e.g. we may exchange information with other specialist organizations for the purposes of fraud detection and credit risk reduction and we will retain financial data long term to meet our statutory obligations.
5) Who will process your data?
Your personal data will be processed by the internal staff of MARIA LUCIA HOHAN who have been specifically trained and authorized for this processing.
Your personal data will also be transmitted to other third parties than those we use to provide our services; these parties have been rigorously assessed and offer a guarantee of compliance with the legislation on the processing of personal data. These parties have been designated as data processors and carry out their activities accordingly.
The third parties in question belong to the following categories: banking operators, internet providers, couriers; companies that carry out marketing activities, including social media organizations; companies specializing in market research and data processing; companies offering contact center services; companies providing publishing and distribution services.
Under some circumstances we may be required to disclose or share your data without your consent, for example if we are required by the police, the courts or for other legal reasons. Your data may be transmitted to the police, judicial and administrative authorities, in accordance with the law, for the investigation and prosecution of crimes, the prevention of and protection from threats to public security, to allow MARIA LUCIA HOHAN to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.
6) Data transfer outside the European Union
Some of the third parties listed in the previous paragraph 'Who will process your data?' may be located in countries outside the European Union that nevertheless offer an adequate level of data protection, as established by specific decisions of the European Commission (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en)
The transfer of your personal data to countries that do not belong to the European Union and that have not been assessed as offering adequate levels of protection will be performed only:
I. after the completion between MARIA LUCIA HOHAN and said parties of specific agreements containing safeguard clauses and appropriate guarantees for the protection of your personal data (known as “standard contractual clauses” and approved by the European Commission), or
II. if the transfer is necessary for the completion and execution of a contract between you and MARIA LUCIA HOHAN (for the purchase of goods offered on our website, for registration on the website or use of services on the website), or
III. for the management of your requests.
7) How long do we keep your data?
We keep your personal data for a limited period of time in line with our data retention policy. The specific retention period will vary according to the reason for processing your personal data. After this period, your data will be permanently erased or otherwise irreversibly rendered anonymous.
Your personal data are retained in accordance with the following criteria:
When you have purchased goods from www.mlh-shop.com , we will retain the billing data until the end of the relevant accounting period, normally seven years from the billing date;
When you make a payment, we will retain your payment details up to the certification of the payment and the completion of the relevant administrative-accounting formalities regarding your right of withdrawal and the terms applied for the disputing of the payment;
When you provide us with personal data in order to use the services of www.mlh-shop.com , such as marketing communications subscription, we will keep your data for this purpose until the termination of the service or until you cancel your subscription to the service;
When you give us your consent to send you marketing communications, you can withdraw your consent at any time. We will consider your consent to be current for five years from your last interaction with any email that we send you, or with www.mlh-shop.com.
When we use your personal data and browsing history to analyze your behavior in order to customize the website and to show you personalized sales offers, we will keep the data for analytical purposes until you ask us to delete it;
When we use personal data for market research and satisfaction surveys, we will keep the data until you ask us to stop.
When you contact our Customer Care team, we will keep any additional personal data you provide that is specific to your enquiry for as long as you remain an active customer of www.mlh-shop.com
When you contact our Customer Care team, we will keep the call recording for 6 months. Credit card details are not recorded as part of the call.
8) Your rights
You have the right to request a copy of the data that we hold about you (and we will provide this to you free of charge once we have confirmed your identity).
If you would like a copy of some or all of your personal data, please email or write to us using the contact details in this policy.
If we do hold data about you we will:
o give you a description of it
o tell you why we are holding it
o tell you who it could be shared with
o tell you how long we will keep the data
o if the data was not provided by you, we will give you any available information such as the source of the data
o tell you if the data has been used for automated decision making
o tell you if the data is stored outside of the European Economic Area, and if so what safeguards are in place to protect your personal data
o let you have a concise and clear copy of the data
You have the right to ask us to correct any inaccuracies in the personal data we hold about you and to stop us using your data until it has been corrected. We want to make sure that your personal data is accurate and up to date and we will be happy to correct or remove data you think is inaccurate. You can also update your own information at any time by logging into My Account at www.mlh-shop.com
You have the right to withdraw your consent to marketing at any time by calling our Customer Care team, clicking “unsubscribe” on a marketing email or replying STOP to a text message. Alternatively, you can sign in to your account on www.mlh-shop.com and update your requirements. You may receive a small number of further communications immediately after unsubscribing but we will implement your request as quickly as possible.
You have the right at any time to oppose our processing of your personal data on the basis of our legitimate interest. You will need to explain the reasons behind your request and allow us to consider your request and respond.
You have the right to request the deletion of your personal data. After receiving and reviewing your request, if legitimate it will be our responsibility to cease processing promptly and to delete your personal data.
You have the right to receive a copy of your data that we process based on your consent or on the basis of a contract with you in a standard format. If you wish, where technically possible, we can transfer your data directly to a third party indicated by you.
To exercise any of these rights, you can sign in to your account, contact our Customer Care team at email@example.com or +40728 922 288 or write to our Privacy Team at MARIA LUCIA HOHAN, 21 Carol Davila Street, Bucharest, Romania.
To ensure that the data of our users are not subject to breaches or illegitimate use by third parties, we will ask you to confirm your identity before carrying out your request.
We protect your personal data with specific technical and organizational security measures aimed at preventing your personal data from being used illegitimately or fraudulently.
In particular, we use security measures that guarantee: pseudonymisation or encryption of your data; the confidentiality, integrity, and availability of your data as well as the resilience of the systems and services that process them; the ability to restore data in the event of a data breach. Furthermore, MARIA LUCIA HOHAN undertakes to test, verify and regularly evaluate the effectiveness of technical and organizational measures in order to guarantee continuous improvement in the safety of processing.
10) Changes to this notice
You can contact the MARIA LUCIA HOHAN Data Protection Officer at firstname.lastname@example.org
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.