EU Privacy Policy

 

Last Updated: September 22, 2021

A. Background

vVARDIS AG, Sihlbruggstrasse 109, 6340 Baar, Switzerland (referred to herein as “vVARDIS” “we” “us” and “our”) respects your privacy. This Privacy Policy describes what we do with personal information we collect from you through our European-facing websites and any other microsites (the “Website”) or mobile applications (the “App”) or information you provide to us when you visit our Facebook, Instagram, YouTube, Twitter, and other social media platforms (our “Social Media Pages”). This Privacy Policy does not apply to job applicants, employees or independent contractors who work for us, nor does it cover the privacy and security practices of social media platforms on which vVARDIS has Social Media Pages. Please review the terms, policies, and settings of those social media platforms if you have questions about how they collect and use your data.

Please take the time to read this Privacy Policy.

vVardis is the controller of your personal information collected pursuant to this Privacy Policy and will process your personal information in reliance on the legal bases outlined in Section C below.

We may revise this Privacy Policy periodically and in the event of a material changes, we will notify you by means of a notice on our Website.

A. Information We Collect

The personal information we collect depends on how you interact with us. We may collect the following categories of personal information about you:

  • Device Information: When you visit our Website, use our Apps, interact with our Social Media Pages or online ads, or open our emails, we may learn about your browser, device type, plugins, IP address, MAC address, internet service provider, the name and version of your operating system, the name and version of your browser, the date and time of your visit, the pages you visit, the platform you use, your screen resolution, your time zone, and any search terms you enter while on the Website.
  • Website/Apps Interactions: We collect information about your interactions with our Website and Apps, including pages visited, links clicked, buttons clicked, mouse movement, scroll behavior, and non-sensitive keystroke activity. This data may then be used to create a “session replay” of your interaction, which may be used to troubleshoot customer service issues, either individually or in the aggregate, to improve site functionality and to analyze user interaction. This information could include personal information, depending on what information you provide.
  • Contact Information: We may collect your contact information, including first and last name, address, telephone number, e-mail address, billing address, shipping address.
  • Payment Card information and Payment Details: We may collect your payment card information or payment details if you make an order or add it to your account with us, if any.
  • Shopping History & Transactional Data: We keep track of your shopping history with us, return or exchange, or add to your shopping cart.
  • Call records and email records: If you call, email, text, or chat with our customer service agents, we may keep records of those conversations including all such information you have provided to us in connection with such conversation.
  • Demographic Information: We may collect demographic details about our customers such as birthdate, gender, postal code, social media information and profile data and other similar details.
  • vVARDIS Account Data: :If you want to register or have a registered account with vVARDIS, we will collect your Contact Information, passwords for the account, Demographic Information, Preferences, and Shopping History & Transactional Data.
  • Social Media Usage: We receive aggregated information about people who visit and interact with our Social Media Pages.
  • Preferences: We may collect information about your preferences, such as products you may be interested in.
  • Inferences: We may draw inferences about any of the information above that may relate to your preferences, or other matters.

B. How Your Information Is Collected

We may collect the information described above directly from you, from third parties we work with, or through cookies or other automated means. These sources may include:

  • You: We collect information directly from you, whenever you: make a purchase; contact us with questions or comments; upload content to our Website, Apps, or Social Media Pages; create an account; add items to your shopping cart; opt in to text messages; apply for a job; fill out any forms on our Website, Apps, or Social Media Pages.
  • Your Device or Browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Website, use our Apps, interact with our Social Media Pages or online advertising, or open our emails.
  • Third Parties: We work with third parties who provide services to us, like market research surveys. These third parties share aggregated information (i.e., information that does not identify you) they have collected with us.
  • Social Media Platforms: Social media platforms share information. You can learn more about how social media platforms collect and use your information by reviewing their privacy policies and settings. If you contact us via our Social Media Pages to make a complaint or service request, then we will collect information related to such complaint of service request from the social media platform.
  • Cookies: vVARDIS uses cookies (small files stored on your device or browser), pixel tags (tiny graphic images embedded in a website or email), web beacons, and other similar technologies to automatically collect information when you visit our Website, use our Apps, or interact with our emails.

    We also contract with third party advertising or analytics companies to serve you online ads on other websites. These companies use cookies or similar technologies to collect information about your interactions with our Website and Apps and interactions with other websites. These advertising companies may use and share the information gathered to deliver ads more tailored to your interests. We receive aggregate information from these third parties to understand our advertising effectiveness.

    For more information on our use of cookies and similar technologies please see our Cookies Policy.

C. How We Use Your Information

  • Fulfillment: Fulfilling your orders and other requests, including, but not limited to, processing payments, confirming or updating you on the status of your order, delivering packages, facilitating returns, and responding to your customer service inquiries. . Legal Basis for customers in the EEA/UK: This processing is necessary for us to establish and perform our contract with you.
  • Understanding Our Customers: Analyzing your activity with us (including your interactions with our Website, Apps, Social Media Pages, and emails or other forms of communications, analyzing trends and statistics). We keep track of the pages you visit and the manner in which you use the Website to determine what products are most popular and whether to make changes to the Website. We may, from time to time, review your information and information of other customers to help us analyze trends, purchasing patterns and preferences, and demographics. . Legal Basis for customers in the EEA/UK: We consider that we have a legitimate interest in carrying out such analyses to improve the user experience and provide a higher quality service.
  • Personalization and Marketing: Using your preferences and other collected information to personalize your shopping experience by using your product interests, shopping patterns and purchase information to recommend other products, services or promotions that we believe you may be interested in as well as personalizing advertising and experiences on our Website, Apps, emails, and ads. Legal Basis for customers in the EEA/UK: With your consent which you can withdraw at any time.
  • Communications: Communicating with you, including responding to your requests. . Legal Basis for customers in the EEA/UK: . We consider that we have legitimate interest in responding to your requests / queries efficiently and effectively. To the extent the request relates to the exercise of your privacy rights, we have a legal obligation to process such requests.
  • Anti-Fraud: Performing credit and anti-fraud checks on your and the payment method that you have provided; these checks may be required, amongst other things, to verify your identity, to validate your credit or debit card, to obtain an initial credit or debit card authorization and/or to authorize individual purchases. . Legal Basis for customers in the EEA/UK: . We consider that we have a legitimate interest to carry out the necessary verifications to detect and prevent potential fraud. This allows us to (i) implement measures to protect you against attempted fraud perpetrated by third parties; (ii) avoid unauthorized use of our Website and App. We may also be required to carry out such processing by law in certain instances.

Where we need to collect your personal information in order to comply with our legal or contractual obligations, and you fail to provide such personal information when requested, we may not be able to provide the service to you.

You have a right to object to the processing of your personal information where that processing is carried out for our legitimate interests or for direct marketing purposes.

D. How We Share Information and for What Purposes

vVARDIS may share personal information with third parties for certain purposes. For example, we share personal information with:

  • Service Providers: We partner with third parties to assist with many aspects of our business, including Website and other IT hosting, fulfillment, customer support, marketing, translation, ratings and reviews, reporting, advertising, and analyses of your interests and activity on our Website and Social Media Pages. These third parties may provide services related to any of the purposes described in How We Use Your Information, and we may share with them any types of information described in Information We Collect. This includes sharing information with banks and the providers of credit reports as well as fraud prevention, tax processing, and credit reference agencies. We may also receive information collected by these third parties and combine it with the information we have collected. Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy notices.
  • Marketing Agencies and Data Analytics Providers: We may partner with third parties to assist with the advertising and marketing of our business and performing business analytics. We may share with them the types of information described in Section A.
  • vVARDIS Affiliates: We are part of a group of companies that vVARDIS controls or is controlled by or that are otherwise affiliated with vVARDIS. We may share your personal information with these affiliates.
  • Other Third Parties: We may also share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your personal information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may transfer your personal information to a third party in the event of a merger, reorganization of our entity or other restructuring.

E. International Transfers of Personal Information

Personal information collected from you will be processed in Switzerland, where we are located. Certain of the recipients identified in Section D above may, however, be located in the EEA/UK, in the United States or elsewhere. Your personal information may therefore be transferred to us and our service providers located in countries outside the EEA / Switzerland / UK and which are not considered to provide an adequate level of data protection. Such transfers will only take place in accordance with applicable data protection laws by putting in place appropriate safeguards where required or appropriate (including, for example, entering into a data transfer agreement with the recipient and as necessary implementing supplementary measures to ensure an essentially equivalent level of protection as provided in the EEA / Switzerland / UK).

F. Privacy Rights for Customers

You have certain rights in relation to the personal information which we process about you which may be subject to limitations and/or restrictions. These include the right to:

  • request access to and rectification or erasure of your personal information;
  • withdraw consent to the processing of your personal information;
  • obtain restriction of processing or to object to the processing of your personal information; and
  • ask for a copy of your personal information to be provided to you, or a third party, in a digital format.

If you wish to exercise any of these rights please click here.

You also have the right to lodge a complaint about the processing of your personal information with the competent data protection authority.

G. Children

vVARDIS does not knowingly or purposefully request or collect personal information from any person under the age of 16 years old. If you believe that your child under the age of 16 has submitted personal information to vVARDIS in connection with our Sites, please contact us at contact@vvardis.com.

H. Retention of your Personal Information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

I. Security

We implement and maintain reasonable security safeguards that are appropriate to the size and complexity of our business and the sensitivity of the personal information we collect. Although we use measures to protect your personal information, even the most robust safeguards may not always be able to prevent all breaches of security.

J. Links to Other Websites

This Website may, from time to time, contain links to websites owned and operated by third parties (“Third Party Sites”). vVARDIS has no influence on whether operators of such Third-Party Sites comply with the applicable data protection regulation. We encourage you to review the privacy policies of such Third Party Sites so that you understand how those websites collect, use and share your information. We are not responsible for the privacy policies or other content on Third Party Sites.

K. Contact Us

We welcome your comments and questions. Please contact us at:

vVARDIS AG
Attn: Privacy Policy Inquiries
Sihlbruggstrasse 109, 6340 Baar, Switzerland
Email: contacteu@vvardis.com
Data Protection Representative EEA:
vVARDIS Baltic SIA
Kr.Valdemāra iela 21-11
Riga, LV-1010, Latvia