1 – Data collected and use
1.1 Data collected
When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:
• information you give us:
You may give us information about yourself if you sign up for an account on our Website, place an order for products, complete any online forms (such as registration forms, competitions).
Depending on what you provide, this information can include your name, address or location, phone number and email address, date of birth, gender, purchase information, shopping preferences
• information we receive from other accounts or sources:
We can receive information about you from other sources, such as our affiliated boutiques, social media providers like Facebook and Twitter, advertising networks and analytics partners.
• information our IT systems collect about you:
Each time you visit the Website, certain information will be created and automatically recorded by our IT systems. That information includes:
– device information: the information provided by your device will differ depending on which type of device you are using (whether it’s a PC, Mac, iPhone, Android, or otherwise) and the settings on that device, but includes the type of device you have (such as an iPhone 6S or Samsung Galaxy S7), the device’s IP address, the browser you are using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location
• information we collect in store:
The Webster is always looking for new opportunities to improve your shopping experience and this extends to your experiences in-store. When you visit one of our 6 locations in the US, sales associate may collect your information.
1.2 Use of data
To provide you services and the Website, including to allow you to order and receive products using our Website, administer your account and to optimize your experience we need to use the information that we collect in a number of different ways.
We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications or when you have made a purchase using our services, we will use your personal information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information to tailor these messages to you. You may unsubscribe from email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt out link at the end of each email we send you.
We also carry out research, analysis, and surveys on your use of our Website, and views. We keep tracking of your spend on our Website to see if you can benefit from our exclusive VIP program. Finally we use your information to confirm your identity and perform credit checks or anti-fraud checks, in order to ensure your, and our, financial security.
Please note that we do not sell your information to any third party.
To register and manage your account in our Website, we collect your name, email, password and other additional details you may wish to add in your account, like phone number, addresses and gender. The legal basis is the performance of a Contract with you.
To fulfil the orders you make through our website, we collect your Name, addresses, phone number, Order details, like the products you are buying, the size and price. The legal basis is the performance of a Contract with you.
To collect payment from you we collect your payment information, which comprises the credit/debit card’s number, holder’s name and CCV – we do not store them and only transfer them to our authorized payment providers. The legal basis is the performance of a Contract with you.
To provide you with our customer services (including helping you to solve any issue you have with our services, updating you about any change to our terms of service, or contacting you to know how was your experience with us) we collect your name, email, password and addresses and your contact history with us (including phone records of our conversations. The legal basis is the performance of a Contract with you and our legitimate interests in retaining you as a customer.
To administer, maintain and optimize our Website and our services, we collect your device information (such as your device IP address and device type), Cookie identifiers and browsing information. The legal basis is the legitimate interests in running our business.
To perform fraud and credit checks and if we can do business with you, we collect your name; email; addresses; credit/debit card details; browsing history; purchase history; date of birth; gender; device information (such as IP address and device type), any national identifiers (like driver’s license or ID cards) and any publicly available information (like social media profiles or news). The legal basis is the legitimate interests to protect The Webster and its customers from fraudulent activities and compliance with a legal obligation.
To send you marketing communications and personalized offers, we may collect your Name; Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behaviour; Device information; Shopping preferences; Cookie identifiers; Internal identifiers; Country. The legal basis is the legitimate interests to electronic direct marketing of similar products and services to that which you have acquired using our Website or, when such is not applicable, your Consent.
Advertising and retarget advertising, we collect your email, cookie identifiers and device information. The legal basis is our legitimate interests in running our business.
To provide the Website and our services, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:
• Third party service providers for business purposes:
To function properly, we rely on a number of carefully selected third parties to provide us with services and products. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products. Below you can find the types of third parties we use:
Courier companies, such as DHL and UPS, Fedex that we use in order to deliver the products to you and, as such, they need to have access to your order information, including your name and address. These providers have a global outreach, with many local companies that can be engaged depending on your shipping address;
Payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. These are based in the European Union, United States and China and are engaged depending on your location;
Anti-fraud providers to keep us and you secure. They have access to and process your information and associated orders in order to check for any fraudulent behavior. Our current provider is based in Israel.
Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimization of the website. These providers are based in the United States and in Europe.
Marketing Tools providers that help us to enable our marketing, such like Bronto Software, Inc. (Powered by Oracle) and Mention Me. These providers are based in the United States.
Performance Marketing Providers that help us deliver advertising of Europann tailored to your interests and needs. These providers are based in Europe (mostly in the UK) and in the United States.
• advertisers for marketing purposes:
We can provide your information to our advertising and social media partners (including Facebook and Twitter, where you choose) where they require the data to select and serve relevant adverts about our products and services to you and others;
• to comply with legal requests:
On occasion we may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands; and
• aggregated information with third parties:
we may aggregate your information with the information of other customers, creating a dataset of information about the usage of our Website, purchase of products, and other general, grouped information about our customers on the basis of our legitimate interest to understand the usage of our service and demand for our product. Although this dataset is aggregated and anonymized, meaning it cannot identify you as an individual, it provides a valuable insight into the use of our Website and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies to help measure traffic, our partner boutiques and other providers to allow them to better stock products, and our investors. Please note that we do not share your information with any third party advertisers or networks for the provision of third party advertising on our Website.
2. Updating and Correcting Information
We believe you should have the ability to access and edit the information that lets us know the specifics of who you are ( « Personally Identifiable Information ») that you have provided to us. You may change them in your account online at any time by linking to your account in accordance with instructions posted elsewhere on this site. You may also access and correct your personal information and privacy preferences by writing us at firstname.lastname@example.org
We encourage you to promptly update your Personally Identifiable Information if it changes.
You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on this site. In addition, it may be impossible to completely delete your information without some residual information due to backups.
3. User Choices on Collection and Use of Information
We may, from time to time, send you E-mail regarding our products and services. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally send you direct mail about products and services that we feel may be of interest to you. Only The Webster (or agents working on behalf of The Webster and under confidentiality agreements) will send you these direct mailings and only if you indicated that you do not object to these offers. If you do not want to receive such mailings, simply tell us when you give us your personal information. Or, at any time you can easily edit your account information to no longer receive such offers and mailings.
You also have choices with respect to cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our site may not work properly in your case.
4. Security of Information
At our site you can be assured that your Personally Identifiable Information is secure, consistent with current industry standards. The importance of security for all Personally Identifiable Information associated with our user is of utmost concern to us. Your Personally Identifiable Information is protected in several ways. Access by you to your Personally Identifiable Information is available through a password and unique customer ID selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone. In addition, your Personally Identifiable Information resides on a secure server that only selected The Webster personnel and contractors have access to via password. We encrypt your Personally Identifiable Information and thereby prevent unauthorized parties from viewing such information when it is transmitted to us.
Personal information that you provide that is not Personally Identifiable Information also resides on a secure server and is only accessible via password. Since this information is not accessible from outside The Webster you will not be asked to select a password in order to view or modify such information.
In order to most efficiently serve you, credit card transactions, and order fulfillment are handled by established third party banking, processing agents, and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
For example, cookies that are inserted into web pages allow the following actions, depending on the case:
To record the last page visited by the User before entering or just after entering the website;
To record the date, time and duration of the visit;
To record the pages viewed;
To automatically authenticate the User’s login without him having to enter his login credentials at each visit;
To identify system information (language, country, operating system, browser etc.).
We use the following categories of cookies on our Website:
– STRICTLY NECESSARY COOKIES These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided.
– PERFORMANCE COOKIES These cookies collect anonymous information on how you use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. You may opt in to these cookies using your browser settings but it may affect the performance of our Website.
– FUNCTIONALITY COOKIES These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. You may opt in to these cookies using your browser settings but it may affect the functionality of our Website.
– TARGETING COOKIES OR ADVERTISING COOKIES These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies to provide you with more personalised adverts when visiting other websites. You may opt-in to these cookies using your browser settings.
5.2 How to prevent cookies from being installed ?
If you want to delete any cookies that are already on your computer, you can configure your Web browser:
– Google Chrome: Settings → Show advanced settings → Content settings → Cookies / All cookies and site data → Click on Remove All to remove the cookies.
– Firefox: Tools → Options → Privacy → Cookies → Show Cookies → Remove All Cookies
– Opera: Tools → Preferences → “Advanced” tab → “Cookies” heading → Click on “Manage cookies” → Delete the Cookies one by one
– Internet Explorer: Tools → Settings → Options then under History, click on Select, select the Cookies checkbox → Delete
– Safari: Open Safari → Click on Safari → Click on Reset Safari → Check the Empty the cache checkbox → Check the Remove all cookies checkbox → Click on the Reset button at the bottom right.
Information on deleting or controlling cookies is available at www.AboutCookies.org.
Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website.
For other third party cookies relating to behavioural advertising, please go to www.aboutads.info
6. Privacy Policies of Third Party Sites
7. Google Analytics
The information generated about your use of the site including your IP address is transmitted to Google. The information is then used to evaluate visitor interactions with this site and to compile reports on website traffic activity for www.thewebster.us. Neither The Webster nor Google will ever link or seek to link Personally Identifiable Information provided by you to the site to the data collected by Google Analytics.
If you would like to opt out of Google Analytics, Google has developed a tool that works with major internet browsers to permit you to opt-out. For more information and to install their opt-out tool, please click here: https://tools.google.com/dlpage/gaoptout.
8. California Users: Your Privacy Rights
Pursuant to California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing the types of personal information that we share with third parties or affiliates for those third parties or affiliates’ marketing or any other purposes. That notice will identify the types of personal information shared with third parties and used for marketing and any other purposes and the name and address of the third parties that received such personal information. If you are a California resident and want a copy of this notice, please submit a written request to the following address: 1220 Collins Ave., Miami Beach, FL 33139. In your request, please specify that you want a “Your The Webster’s California Privacy Rights Notice.” Please allow up to thirty (30) days for a response.
As stated below in Section 11, we DO NOT respond to Do Not Track signals.
If you are a minor under 18 and have a profile on www.thewebster.us, you may ask us to remove reviews or other content that you posted on the site by writing to 1220 Collins Ave., Miami Beach, FL 33139. We will begin to process your request within thirty (30) days. Please note that we cannot ensure a complete or comprehensive removal of all of the content that you posted.
9. Miscellaneous Privacy Issues
You must be at least 13 years old to have our permission to use this site. Our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors that are under 13 years of age.
At www.thewebster.us, we DO NOT respond to Do Not Track signals.
You should also be aware that when Personally Identifiable Information is voluntarily disclosed (i.e. your name, E-mail address, etc.) in the discussion forums or other public areas on this site, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to chat rooms or other public areas on this site are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you’re online.