Notes: I have prepared this one document to the best of my knowledge and to be as comprehensive as possible and cover all website features and 3rd party technologies we have deployed on our 3 Live websites.
Obviously, all RED marks should also be completely removed from each version of the final document for each website.
The final version for each GEO location or website, should be reviewed by our legal professional for final publication on each website.
SimplyNUC may also need a full Terms & Conditions page too, however this should also be decided by our legal professional.
SimplyNUC is committed to safeguarding your privacy.
Contact us at firstname.lastname@example.org if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
Table of Contents
- Definitions used in this Policy
- Data protection principles we follow
- What rights do you have regarding your Personal Data
- What Personal Data we gather about you
- How we use your Personal Data
- Who else has access to your Personal Data
- How we secure your data
- Information about cookies
- Contact information
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – SimplyNUC
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us, from our Privacy Tools page. You can also request that we erase any personal data we hold about you, again from our Privacy Tools page. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
Data we gather
What personal data we collect and why we collect it
We collect several different types of information to provide and improve our Products or Service to you.
Information you have provided us with
This might be your e-mail address, name, billing address, home address etc – mainly information that is necessary for delivering you a product/service or to enhance your customer experience with us. We save the information you provide us with in order for you to comment or perform other activities on the website. This information includes, for example, your name and e-mail address.
For users that register on our website, or register during checkout whilst purchasing from us, we store the personal information provided, in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Our website administrators can also see and edit user information. This information is retained indefinately or for the length of time your customer/user account is active with us.
Contact / Support / Solutions / Services / Feedback – WebForms
If you use any of the contact forms on our website, your data is stored only for the maximum duration required for our systems to successfully process your request and direct your data to the relevant department. After this time your personal information is no longer stored anywhere on this website or its accompanying database. Your data is simply processed for the sole purpose of sending an email to the relevant department in order to respond to your requests. These contact details are retained, but not used or transferred except to contact you about your request.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Support / Chat Instant Messaging
If you use our websites support instant messaging system to request support or product information from our sales or support staff. Some personal data like a visitors name, and also a visitor’s IP address and browser user agent string is retained with our trusted third-party partner Klaviyo, in order to provide this service to you. Retaining this information allows us to keep track of our conversations with you and provide you with a more customized and personal service.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your shopping cart information, your IP address, your shopping history (if there is any) etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.
We may also collect information on how our website is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
We may use third-party Service Providers to monitor and analyze the use of our website and web pages.
Information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds.
Embedded content from other websites
How we use your Personal Data
We use your Personal Data in order to:
- provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
- enhance your customer experience with us;
- fulfil an obligation under law or contract to you;
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- to identify you;
- to provide you a service or to send/offer you a product;
- to communicate either for sales or invoicing;
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
- to send you personalized offers* (from us and/or our carefully selected partners);
- to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
- to conduct questionnaires concerning client satisfaction;
As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
- to send you newsletters and campaign offers from us;
- for other purposes we have asked your consent for;
We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than 6 years.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- the link between purposes, context and nature of Personal Data is suitable for further Processing;
- the further Processing would not harm your interests and
- there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
Who else can access your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We share your data with:
Our Payment processing partners:
Connected third parties services:
- Google Analytics (Universal Analytics + Google Analytics 4) – ( All Sites )
- Klaviyo – ( All Sites )
- Facebook Pixel – ( USA )
- AdRoll Pixel – ( USA )
- LinkedIn Insights – ( All Sites )
- Twitter Universal Pixel – ( USA )
- ClickShield – ( USA & UK )
- SEOWerks – ( USA & UK )
- TrustPilot – ( All Sites )
- Youtube – ( All Sites )
We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
We collect information about you during the checkout process on our store.
What we collect and store
While you visit our site, we’ll track:
- Products you’ve viewed: we’ll use this to, for example, show you products you’ve recently viewed
- Location, IP address and browser type: we’ll use this for purposes like estimating taxes and shipping
- Shipping address: we’ll ask you to enter this so we can, for instance, estimate shipping before you place an order, and send you the order!
When you purchase from us, we’ll ask you to provide information including your name, billing address, shipping address, email address, phone number, credit card/payment details and optional account information like username and password. We’ll use this information for purposes, such as, to:
- Send you information about your account and order
- Respond to your requests, including refunds and complaints
- Process payments and prevent fraud
- Set up your account for our store
- Comply with any legal obligations we have, such as calculating taxes
- Improve our store offerings
- Send you marketing messages, if you choose to receive them
If you create an account, we will store your name, address, email and phone number, which will be used to populate the checkout for future orders.
We generally store information about you for as long as we need the information for the purposes for which we collect and use it, and we are not legally required to continue to keep it. For example, we will store order information for 6 years for tax and accounting purposes. This includes your name, email address and billing and shipping addresses.
We will also store comments or reviews, if you choose to leave them.
Who on our team has access
Members of our team have access to the information you provide us. For example, both Administrators and Shop Managers can access:
- Order information like what was purchased, when it was purchased and where it should be sent, and
- Customer information like your name, email address, and billing and shipping information.
Our team members have access to this information to help fulfill orders, process refunds and support you.
What we share with others
We share information with third parties who help us provide our orders and store services to you; for example to allow us to track your package whilst we ship your order to you. For more information please see the Shipping: Order Tracking section of this document below.
We accept payments through a number of our trusted third-party payment processors. When processing payments, some of your data will be passed to your selected payment processor, including information required to process or support the payment, such as the purchase total and billing information. For more information on our payment processors please see the Who else can access your Personal Data section of this document.
Shipping: Order Tracking
Email: Mail Logging
When you use this site several actions (e.g. commenting) trigger the dispatch of emails. They contain information about you associated with your email address. Which data are part of these emails depends on the action performed. These emails are stored and accessible to the site management as log.
Social Media Sharing
Links to other websites and third parties
Our website may include links to and from the websites of our partner networks, advertisers and affiliates, or to social media platforms. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to their websites.
Security: How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks. Using both on-site & server level, monitored security systems.
Even though we try our best we can not 100% guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
Who we share your data with
This site is scanned for potential malware and vulnerabilities by our security systems Site Scanner. We do not send personal information to the scanner; however, the scanner could find personal information posted publicly (such as in comments) during the scan. Security logs are retained for 180 days.
Where we send your data
We do not intend to collect or knowingly collect information from children. We do not target children with our products or services.
Cookies and other technologies we use
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our website and services
- Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
- Performance cookies – these are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
Data Protection Officer
Name: (DPO) NAME HERE
Representative Contact in the EU
Name: REP NAME HERE
Phone: REP PHONE HERE
Supervisory Authority – ( USA Only )
At present, there is no single national data protection authority in the USA.
The Colorado Attorney General has the authority to enforce the CPA.
The Virginia Attorney General has the authority to enforce the VCDPA.
Last modification was made May 6, 2022.