- Who we are
- What information do we collect
- Applying to work with us
- How do we use your information
- Who may use your information
- Third party links and services
- How do we protect your information
- Where is your information processed
- Marketing communications
- How long do we keep your information
- Your rights
- Region/Country-Specific Disclosures
1.3 Your privacy matters to us, so please do take the time to get to know our practices.
1.5 We do not knowingly collect or process data from anyone under the age of thirteen (13) years old.
2 Who We Are
If you are located in California, the United Kingdom, the European Economic Area, or anywhere else in the world, please see additional information provided in the “Region/Country-Specific Disclosures” section below.
3 What Information do we Collect?
3.1 Most of the information we collect is information provided directly by you - for example in customer service, at events, in store or by our associates by phone. This may include:
- Contact information – information such as name, email address, physical mailing address, device identifier and telephone number;
- Personal information – such as your birthday, gender and clothes and shoe size;
- Professional information – such as your employment background, job description and related information;
- Social media – such as your Facebook, Instagram, twitter, WeChat or Google account details. In some cases we may use your Facebook, WeChat or Google credentials to allow access to your account with VERDE;
- Transaction information – your contact information, the products you are interested in, your purchasing requirements, financial or other payment information including your card details and billing address, your PayPal account (if any) and any identification numbers needed.
- Responses to surveys – information you provide in responding to a survey on the Site, via an app or email, on the telephone or otherwise.
3.2 We may also collect and process other information obtained through the Site or the device you are using, including:
- information through ‘My Account’ – information for registration of ‘My Account’ such as your contact information, password and email preferences. If you are a registered user, we collect information about your access to the reserved area of the Site such as information on the date and time of access and with your consent, information on your interests and preferences in relation to our products and services. We also collect information relating to your orders; including order number, list of products you have ordered and information on their delivery status as well as information on your wish list, which includes your personal collection of favorite items;
- location information (including GPS signals sent by a mobile device, location information gathered from social media networks or sensor or IP address data from your device);
- information from cookies, web beacons or from the internet, including your IP address, browser type, operating system, domain name, access times, which pages you visit within our Site and referring website addresses. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive.
- if you ask us to connect with other sites (for example if you ask us to connect with your Facebook account), or if you agree to accept a message from us via AirDrop on your iPhone or through other guerrilla marketing campaigns, we may get information that way too; and we may record telephone calls.
4 Applying to Work with Us
4.1 If you use the Site to apply to work with us, we will use the information you supply to process your application and to monitor recruitment statistics. Please do not send us any sensitive personal data with your application unless we specifically ask you for it. As a global business we may transfer your details outside of your home country and to other companies in our group. We will ask you to sign up to additional confidentiality and privacy terms if you apply for a job with us. Once a person has taken up employment with us, we will compile a file relating to their employment. At that stage we will give more details about how we hold employee data and we will expect the employee to sign up to additional confidentiality and privacy terms as part of their employment.
4.3 We may retain details of candidates who may be of interest to us, either now or in the future, for up to one year. If you would not like us to do that please let us know. Additionally, if your circumstances change – for example you no longer wish to be considered by us for employment – please let us know that too.
5 How do we use Your Information?
5.2 Our primary purpose in collecting your personal data is to conclude an order which you have made for the purchase of our goods and to provide you with services which we believe will optimize your use of the Site. We may use your personal data for the following purposes:
- to complete and execute your order for the purchase of our goods on the Site, in stores or via telephone;
- to register on ‘My Account’ and use the services offered to registered users;
- to provide the information, services or support and to manage your Customer Service requests and related after-sales services;
- to identify you, and to contact you from time to time with product or service updates;
- to send other messages that are useful to the service we provide;
- to manage our relationship with you and to carry out any related administration;
- to provide personalized, targeted, or location-based content, services, and advertising from us and third parties;
- to promote our services, or the services of our suppliers or partners, including by email and via social media platforms (subject to the relevant marketing permissions)*;
- to compare information for accuracy, and verify it with third parties*;
- to carry out surveys, research, including market research, statistical research on site traffic, sales and other commercial information to assist us in improving the services we provide to you and tailor the Site*; and
- to enable the call recording feature to work and to troubleshoot the service.
5.3 We process your personal data where we have your consent to do so, which you may withdraw at any time, or otherwise where this is necessary for:
- the performance of our contract with you for the provision of VERDE or to take preliminary steps at your request;
- us to fulfill our legal obligations; or, the purposes of the legitimate interests pursued by us or by a third party.
5.4 A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests are those indicated with a “*” above, and we consider that we have implemented sufficient checks and protections to ensure that your rights and interests are not unreasonably intruded on.
*However, you can object to processing on any of these bases at any time and, if you do so, we will stop processing the personal data unless we can show compelling legitimate grounds which override your rights and interests, or we need the data to establish, exercise or defend legal claims – see the paragraph “Your rights” below.
6 Who may use your Information?
6.1 We may disclose your personal data to enforce our policies, to comply with our legal obligations or in the interests of security, public interest or law enforcement in any country where we have entities or affiliates. For example, we may respond to a request by a law enforcement agency or regulatory or governmental authority. We may also disclose data in connection with actual or proposed litigation, or to protect our property, security, people and other rights or interests.
6.2 We share your information with third parties who help deliver our products and services to you. Examples include hosting our web servers, analyzing data, providing marketing assistance, and providing Customer Service. These companies will have access to your personal information as necessary to perform their functions, but they may not use that data for any other purpose.
6.3 We may also share your personal data:
- with companies in our group; or,
- with any third party you have asked us to share your personal data with – such as Facebook or any other social media site if you have asked us to connect with your account.
6.4 You may have accessed our Site through a hyperlink from a third party website. If so, you consent to your personal details and purchase information, including behavioral patterns, being shared with that third party in accordance with our contractual relationship with them.
6.6 Please remember that when you share information publicly on the Site, for example a comment on a blog post, it may be indexable by search engines, including Google, which may mean that the information is made public.
7 Third Party Links and Services
7.1 The Site may contain links to third parties’ websites. We are not responsible for the privacy practices or the content of those websites. Therefore, please read carefully any privacy policies on those links or websites before either agreeing to their terms or using those websites.
7.3 If you have asked us to share data with third party sites (such as social media sites), their servers may not be secure.
7.4 Note that, despite the measures taken by us and the third parties we engage, the internet is not secure. As a result, others may nevertheless unlawfully intercept or access private transmissions of data.
8 How do we Protect your Information?
8.1 We take what we consider to be appropriate technical and organizational measures designed to reduce the risk of unauthorized or unlawful processing of your personal data and accidental loss or destruction of, or damage to, your personal data. While no system is completely secure, we believe the measures implemented by the Site reduce our vulnerability to security problems to a level appropriate to the type of data involved. However, it remains your responsibility:
- where you are a registered user with ‘My Account’ for the Site:
- to log off or exit from the Site when not using it;
- to ensure no-one else uses the Site while your device is logged on to the Site (including by logging on to your device through a mobile, Wi-Fi or shared access connection you are using);
- to keep your password or other access information secret. Your password and log in details are personal to you and should not be given to anyone else or used to provide shared access for example over a network. You should use a password which is unique to your use of the Site – do not use the same password as you use for another site or email account; and,
- to maintain good internet security. For example, if your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. You should keep all your account details secure. If you think that any of your accounts has been compromised you should change your account credentials with us, and make sure any compromised account does not allow access to your account with us. You should also tell us as soon as you can so that we can try to help you keep your account secure and if necessary warn anyone else who could be affected.
9 Where is your Information Processed?
10 Marketing Communications
10.1 If you have given permission, we may contact you by mail, telephone, SMS, text / picture / video message, social media and email about products, services, promotions and special offers that may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time. See further 'Your rights', below.
11 How Long do we Keep your Information?
12 Your Rights
12.1 In some countries you may have the right to gain access, correct, update, restrict, delete, be forgotten, or object to the processing of, or request data portability of the personal data collected about you subject to some exceptions and conditions. You can find out more about these rights in the EU by reading the General Data Protection Regulation.
13 Region / Country Specific Disclosures
California Privacy Rights: California residents are entitled to ask us for a notice describing what categories of personal data we share with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses.
California Consumer Privacy Act Notice
The California Consumer Privacy Act (“CCPA”), which provides California Consumers certain rights regarding their Personal Information (“PI”) as those terms are defined in the CCPA, became effective on January 1, 2020.
We are providing you with notice of the PI we collect and our purposes for that collection for data that may be subject to the CCPA (“CCPA Notice”). This CCPA Notice does not cover information that is outside of the scope of the CCPA. This notice also does not apply to data collected from employees, applicants or contractors or to data collected from individuals acting as representatives of another business in connection with business communications or transactions.
We collect PI directly from you, your device or browser, our service providers and suppliers, and our corporate affiliates. We use and share PI for the following business purposes:
- to provide requested products and services;
- to advertise and offer new products and services;
- to improve our products and services;
- for quality assurance;
- for research development;
- for prevention of fraud and illegal activity; and
- for marketing purposes.
We collect the following categories of PI from Consumers which we share with our service providers, agents and licensees who perform services on our behalf, and with our affiliates:
- identifiers (e.g., name, phone number, email address, I.P. address);
- personal records (e.g., name, phone number, email address);
- consumer characteristics (e.g., age, gender);
- customer account details / commercial information (e.g., your order history); and
- inferences from PI collected (e.g., your preferences, your likelihood of interest in certain of our services).
We collect the following categories of PI from Consumers which we only share with our affiliates:
- Internet usage information (e.g., information regarding your interaction with our online services);
- geolocation data (e.g., if you enable this feature on your device while using our app); and
- sensory data (e.g., recordings of customer service calls).
If you are a California Consumer and would like to register a request under your “right to know about Personal Information collected, disclosed or sold” (including right to obtain copies of specific pieces and/or information about categories of PI practices), “right to request deletion of Personal Information,” or “right to opt-out of the sale of Personal Information,” or if you have questions about our privacy policies or practices, you can contact us at firstname.lastname@example.org. You have the right to not receive discriminatory treatment in a manner prohibited by the CCPA as a result of your exercising your rights under the CCPA.
To fulfill your CCPA request, we may require you to provide sufficient information to reasonably verify you are the Consumer about whom we collected PI. This verification process includes providing us at least two (2) unique data points, depending on the type of request.
Consumers have the right to exercise CCPA privacy rights via an authorized agent who meets the agency requirements of the CCPA. Authorized agent requests must include a copy of the agency agreement between the authorized agent and the consumer. We will ask the consumer to independently confirm the agency relationship.
The Right to Know
Categories: You have the right, subject to statutory exceptions, to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
- The categories of PI we have collected about you.
- The categories of sources from which we collected your PI.
- The business or commercial purposes for our collecting or selling your PI.
- The categories of third parties to whom we have shared your PI.
- A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
Specific Pieces: You have the right, subject to statutory exceptions, to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.
The Right to Deletion
You have the right, subject to statutory exceptions, to request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.
You may alternatively exercise more limited control of your PI by instead by canceling or modifying our email marketing communications you receive from us. You can do so by following the instructions contained within our promotional emails.
The Right to Opt Out of Sale of Personal Information
We do not “sell” Personal Information that we collect from you, including Personal Information of minors under the age of 16, in accordance with the definition of “sell” in the CCPA.
You may opt out of interest-based advertising using ad industry opt out tools by visiting youradchoices.com/control or optout.networkadvertising.org. To effectively manage cookies via browser settings or through ad industry opt out tools, you must opt out and set cookie preferences on all browsers and all devices that you use. If you clear the cookies on your device, you may need to set your cookie preferences again. We are not responsible for the completeness, accuracy or effectiveness of any third-party programs, tools or frameworks, or the information they provide.
VERDE NEW YORK, a company registered in the United States.
If you are a European citizen, you may also have the right to lodge a complaint with a data protection regulator, which you may lodge with the Information Commissioner’s Office (ICO), as the EU lead supervisory authority. The ICO’s contact details are as follows:
Wycliffe House, Water Lane, Wilmslow
Cheshire, SK9 5AF
Telephone: + 44(0)303 123 1113