Since personal data (“Personal Data”) of users and customers (collectively “Users”) of this Site may be processed in the European Union, any processing of Personal Data will be conducted in compliance with applicable European laws.
Your personal data are collected and processed by OBAAT well as by our service providers located within and outside of the European Union (collectively “us”, “we”, “our”). OBAAT has its registered offices at 4 Conduit Street, W1S 2XE, London, UK.
Your Personal Data will be processed to provide the services you subscribed to or reserved for registered users, to facilitate your navigation of and shopping from the website and to keep you informed of OBAAT news and offers.
OBAAT is a controller of Personal Data collected and processed for purpose of rendering the e-commerce services and the sale of products (herein the “Commercial Purposes”) through the Site.
OBAAT is the sole data controller of the Personal Data processed for marketing purposes, notably to send to Users, also through newsletter, information and updates on its products, offers, exclusive sales, promotional campaigns and on events and similar initiatives organised by OBAAT Ltd (herein the “Marketing Purposes”).
1. Our Policy
Everyone has the right to protection of his/her Personal Data. We respect Users’ right to be informed regarding the collection of and other operations involving their Personal Data. In using data that may directly or indirectly identify you personally, we will apply a principle of strict necessity. For this reason, we have designed the Site in such a way that the use of your Personal Data will be kept to a minimum and will not exceed the purposes for which your Personal Data was collected and/or processed; we do not process your Personal Data when we can provide you with services through the use of anonymous or traffic data (such as marketing research made for improving our services, browsing data processed to provide you with customized contents or offers adapted to your preferred language, your location, etc) or by other means which allow us to identify you, apart from when it is strictly necessary or upon request by competent public authorities or the police (for example, in case of traffic data or your IP address).
2. Who collects and processes Your Personal Data, how and for which purposes?
OBAAT is the controller of your Personal Data as we determine the Commercial Purposes and means of processing Personal Data. For the Commercial Purposes only, OBAAT has appointed certain entities that will also process Personal Data relating to the Site’s Users (herein the “Processors”).
The above-mentioned service providers and Processors have been chosen because of their experience in processing Personal Data and they provide sufficient guarantees regarding compliance with data protection laws (including the technical security measures governing the processing to be carried out). In processing the Personal Data for Commercial Purposes, the Processors shall act only under the instructions from OBAAT. We regularly check that our Processors comply with our instructions and that they continue to provide sufficient guarantees regarding their full compliance with the provisions on Personal Data processing.
Some of the Processors of your Personal Data appointed OBAAT Commercial Purposes directly are:
· Royal Mail & DHL, for purposes related to shipping, delivering and returning products purchased on www.obaat.com
· Campaign monitor for purposes related to sending out Marketing Newsletters and Surveys;
· Sagepay, Izettle & Pay Pal for purposes related to payment transactions;
· Facebook, Twitter, Instagram and other social media channels for purposes related to sending out Marketing Campaigns and images.
For the Commercial Purposes, we collect your Personal Data (such as personal details, e-mail address, address, Credit Card numbers, bank code, IP address and telephone number, etc.) on your order form only for the purpose of selling the products ordered by you. Your Personal Data is mostly processed by electronic means and, in some circumstances, by paper-based means, such as when the processing of your Personal Data is required for preventing fraud on the Site. Your Personal Data shall be stored in a way which allows us to identify you for the period necessary for the purposes which the data was collected for and subsequently processed and, in any case, in accordance with applicable laws. Please report any modification of your Personal Data to our Customer Sevice and select ‘Privacy’ as the argument in the appropriate form or through your personal account on the Site in order to ensure that your Personal Data is always accurate and up-to-date, relevant and complete. Your Personal Data shall not be disclosed to third parties other than us for purposes which are not permitted by law or without your consent.
Aside from the Processors appointed for Personal Data processing, your Personal Data will be made available also to third parties, autonomous controllers, for purposes related to supplying services requested by Users (for example, for purchase transactions) or for purposes of third parties. For more information on the matter, see section 4 (To Whom Your Personal Data Will Be Disclosed). Please contact our Customer Service if you would like to receive a full list of our data Processors involved in processing your Personal Data.
For the Marketing Purposes, we may process your Personal Data as well as browsing data (“Traffic data”) resulting from the use of the Site and of our services by any User, in order to provide Users with customized contents and offers on our services or to deliver any newsletter they subscribed to, subject to their discretionary right to withdraw their subscription to such newsletter or to oppose or object to the receiving of any advertising or marketing content which we think is of interest to a specific User. For Marketing Purposes, Personal Data and Traffic data is mostly processed by electronic means and shall be stored for us in any case, in accordance with applicable laws and available to our Processors.
Moreover, your Personal Data may be disclosed to the police or to judicial authorities, according to applicable laws and upon a formal request by such entities, for example in the event we need to prevent fraud on the Site (anti-fraud services).
Data processors will also have access to your Personal Data as stated in section 2 for the specific purposes stated therein. In all the above circumstances, your consent for data processing is not required as Personal
Data Processing would be necessary for the performance of Commercial Purposes.
All the information we collect via our Website or through correspondence with you is used to operate and improve the service we offer you and to personalise our service.
To Whom Your Personal Data Will Be Disclosed?
Personal Data will be disclosed to third party companies that provide, on behalf of OBAAT, specific services as data Processors or to other recipients of Personal Data collected by us that process your Personal Data only for the Commercial Purposes and, in any case, according to applicable laws and regulations.
Notwithstanding the foregoing, Personal Data will not be disclosed to any other third parties or disseminated or transferred without informing our Users of such disclosure/dissemination/transfer, and, in any case, in accordance with the applicable laws.
3. Security Measures:
1. Site functionality cookies – these cookies allow you to navigate the site and use our features, such as “Add to Basket”.
2. Site analytics cookies – these cookies allow us to measure and analyse how our customers use the site, to improve both its functionality and your shopping experience.
3. Customer preference cookies – when you are browsing or shopping, these cookies will remember your preferences (like your location), so we can make your shopping experience as seamless as possible, and more personal to you.
4. Targeting or advertising cookies – these cookies are used to deliver ads relevant to you. They also limit the number of times that you see an ad and help us measure the effectiveness of our marketing campaigns.
Further information about cookies can be found at https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies/ and www.AboutCookies.org.
5. Compulsory processing
We wish to inform you that we may process your Personal Data also without your consent in certain circumstances provided by laws.
6. Your Right to Access Personal Data and Further Rights
You are entitled to obtain at any time from us:
a. the updating, adjustment or, when you have an interest in such, the integration of your personal data;
b. the deletion, the transformation into an anonymous form or blocking of your personal data (unlawfully processed), including data which does not need to be stored for the purposes for which it was collected and subsequently processed;
c. the confirmation that the operations under letters a) and b) have been reported (together with the contents of the same) to whom the data was disclosed or disseminated, except when it becomes impossible or if the means used are clearly disproportionate to the right’s protection.
You are entitled to object, in whole or in part:
a. for legitimate reasons, to the processing of your personal data, even if it is related to the purposes for which it was collected;
b. to the processing of your personal data for advertising or direct marketing purposes or in order to carry out marketing research or commercial communications.
7. Opt-in/Opt out
Each time your consent is required, OBAAT will inform you in advance and will give you the option to either provide or refuse your consent for the use of your Personal Data, including your e-mail address, for the above purposes, by ticking the appropriate boxes.
We wish to inform you that we may process your Personal Data also without your consent in certain circumstances, such as when such processing is necessary for performing a legal obligation to which we are subject or when such processing is necessary for performing obligations undertaken in contracts with the users.
To the extent of applicable laws and subject to your rights, Your personal data may be processed by us for sending you advertising or offers for Marketing Purposes about products and services unless you object to it at any time, either when Your personal data has been collected or at any time, notably when receiving any offer from Us.
In any case, we wish to inform you that we guarantee that our users may exercise, at any time and without having to state their reasoning, their right not to receive future communications connected to particular services upon request.
8. Links to Other Web Sites
9. Governing Law
To the extent that we are established in the UK, your use of this website and any dispute arising out of such use of the website is subject to the laws of England, Northern Ireland, Scotland and Wales.