EFFECTIVE DATE: 25 06 2019
INTRODUCTION AND SCOPE OF THIS PRIVACY STATEMENT
WONDER BUCKLE EUROPE NV (WONDER BUCKLE), together “we” or “us”, want to give you the best experience possible. We use the personal information you share with us to make our products and services and your experience even better. This privacy statement aims to give you a clear view of how we use personal information that you provide, our dedication to protecting it, your rights and the options you have to control your personal information and protect your privacy. It also outlines what personal information we collect about you when you visit our websites or stores, how we use your personal information and the third parties we will share it with.
We use personal information for various purposes, as described in detail below.
WHO COLLECTS YOUR PERSONAL INFORMATION
WONDER BUCKLE EUROPE NV, and affiliate entities of WONDER BUCKLE, controls the processing of any personal information collected through marketing cookies used on the WONDER BUCKLE website WONDER BUCKLE EUROPE NV has its offices at Schijnpoortweg 137, 2170 Merksem, Belgium. The local WONDER BUCKLE affiliate handling your purchase on our website controls the processing of your personal information when you order from our web shop, in the course of its handling of your purchase.
PERSONAL INFORMATION WE COLLECT FROM YOU
“Personal information” is any information that relates to you and identifies you personally, either alone or in combination with other information available to us. WONDER BUCKLE will collect various types of personal information about you, including the following (as applicable):
WONDER BUCKLE GLOBAL SINGLE SIGN ON
If you sign up for an WONDER BUCKLE account, we will ask for your name, e-mail address, date of birth and password.
YOUR WONDER BUCKLE ACCOUNT
WONDER BUCKLE will also collect the following information when you sign up for an account if you choose to provide it: telephone number, gender, personal preferences, social identifier if you choose to log in to your account via social media and age or date of birth.
USE OF OUR PRODUCTS AND SERVICES
When you use our products and services we will ask for personal information (at the moment of collection we will explain what information is required in order for us to provide the particular product or service, and what information you may choose to provide), such as:
- your postal address and payment details when ordering from our web shop;
- your date of birth and/or confirmation that you are above a certain age;
- your email-address when signing up for one of our contests, free prize giveaways (“Prize Giveaways”) or newsletters;
- a record of our correspondence with you (including any feedback you have provided on any of our products or services), if you have been in contact with our Customer Service.
If you choose to create an WONDER BUCKLE account through your social network account (such as Facebook), your sign-on credentials will be imported via your social network account. Please note that when you use this “social sign-on” option, we will use the following personal information:
your Facebook identifier
We will often also receive certain personal information (which you have agreed to be accessible on your public profile) via the social network, such as:
your name, age, location, preferences, occupation, and other public profile information such as your pictures or your friends list on the social network, as well as your likes. This information will not be shared with WONDER BUCKLE by Facebook if you have a private profile.
INFORMATION WE COLLECT AUTOMATICALLY
We will also collect personal information about you when you interact with our brand and websites and how you use them, as follows:
Websites: we will collect information about the WONDER BUCKLE websites that you visit and how you use them. A visit to one of our websites results in data being sent from your browser to our servers. We will collect personal information in this way, such as:
- your IP address;
- the date and time of the visit and how long you remained on our website;
- the referral URL (the site from which the visitor has come);
- the pages visited on our website; and
- information about the device and browser (such as, browser type and version, operating system, etc).
Cookies and similar devices: We and our partners use various technologies to collect and store information when you visit our websites, and this will include sending one or more cookies or other similar devices to your device.
SOURCES OF INFORMATION
Most of the information we collect about you will be personal information that you have voluntarily provided to us, for example, through our websites, e-shops, in-store etc. Other sources from whom we may obtain your personal information include:
our Point of Sale systems ([i.e. certain information may be collected about you when you make a purchase in one of our stores]);
other WONDER BUCKLE group companies; and
third parties (such as credit reference agencies, law enforcement/regulatory bodies, and companies providing commercially available databases etc.). Some of these third-party sources may include publicly-available sources of information.
HOW WE USE YOUR PERSONAL INFORMATION
The personal information we collect when you create first sign in will be used for identification and authentication purposes across WONDER BUCKLE services, so you can use the same account details to log in from any location and on any device. The global single sign on will allow WONDER BUCKLE systems to identify you wherever you are in the world, meaning you will not need to register with us again if you are signing in from a different country. It is necessary to process your personal data in this way for the performance of a contract with a WONDER BUCKLE entity.
In addition, WONDER BUCKLE will create a profile for you with the information needed to provide you with our products or services. The personal information we collect from the above other sources listed above will be used in the format that it is received, or, where appropriate, will be combined with personal information we obtain from other internal or external sources. We use and analyze this personal information where necessary for the following purposes detailed below:
Improving our products and services: we will use your personal information to build a profile on you in order to understand how you use our products and services, to develop more interesting and relevant products and services, to improve our website, as well as to personalize the products and services we offer you. We process your personal information in this way as it is necessary for the purposes of our legitimate interests in providing better products and services for you and our other customers.
Processing your order: we use relevant personal information described above (including your name, address and payment details) to process and deliver your order, and to notify you of the status of your order. In addition, we may use your age, year of birth or confirmation that you are above a certain age to ascertain whether you meet the minimum age in your country for online purchases and whether you are considered to be a minor for data protection and/or marketing law purposes. It is necessary to process your personal in this way for the performance of a contract with an WONDER BUCKLE entity.
Preventing fraud: we will also use your personal information to assess your creditworthiness and to prevent fraud. For this purpose, we may need to share your personal information with our credit rating providers (see “how we share your personal information” below). This is necessary for the purposes of our legitimate interests in ensuring we are not the victim of fraud and to protect our legal rights set out in the Terms and Conditions.
To provide customer support: if you contact our Customer Service (or vice versa), we will use personal information such as your order information and contact history to process your request and provide you with the best service possible. We will process your personal information in this way if it is necessary for the performance of a contract with an WONDER BUCKLE entity or if it is required for us to comply with any legal obligations. If it is not necessary to process your personal data for either of these reasons we will process it as it is necessary for the purposes of our legitimate interests in ensuring we can provide the best service possible.
To engage with you in relation to the programs or communities you decide to join.: we will use your personal information to provide you with the products and services you have requested from us, such as promotions and events. This will, if applicable, include the use of your personal information for submission and publication (on our website or a third party’s) in relation to contests, Prize Giveaways and promotions, using your contact details for events. We will process your personal information in this way if it is necessary for the performance of a contract with an WONDER BUCKLE. If it is not necessary for the performance of such a contract, we will process it as it is necessary for the purposes of our legitimate interests in providing these products and services appropriately and ensuring they function correctly. To the extent that we process location data, we do this on the basis of your consent to receiving these services, and we will not process location data before you have provided your consent to us doing so.
Social sign-on (this means the use of your social network credentials such as your Facebook user login information to create and sign into your WONDER BUCKLE account): when you use the social sign-on option WONDER BUCKLE will limit the use of public profile information to that which is necessary for the creation of your WONDER BUCKLE account, as it is necessary for the performance of your contract with an WONDER BUCKLE in relation to account creation. WONDER BUCKLE will, upon receipt of any irrelevant information from the social network, discard such information. After having created your account, you will have the opportunity to supplement it with any information you would like to share with us, such as personal information you provide through a completed survey. We will process this personal information as it is necessary for the purposes of our legitimate interests in completing your profile and ensuring we have accurate records about you. To the extent we cannot process it to meet these legitimate interests, we will only process this personal information if you consent to providing it. Any supplemental information you provide to us will be used for the purposes and on the lawful grounds explained in this statement, including to enrich your WONDER BUCKLE profile and to personalize your WONDER BUCKLE experience.
Marketing: when you sign up to receive WONDER BUCKLE newsletters, create an WONDER BUCKLE single sign on, order or provide feedback on a product or service online or use our website, we will use your personal information to create a profile based on the information we hold about you. This is necessary for the purposes of our legitimate interests in ensuring we have accurate information about you in one place. We create your profile in accordance with your preferences in order to provide you with the best personalized experience, to send you personalized marketing messages and newsletters and for opinion research purposes. Below you can find a more detailed description of the ways in which we will use your personal information for these purposes.
What kind of information: the way you interact with our brand across all the different channels described above (e.g. the WONDER BUCKLE website, social media and marketing messages we send you) and the information we collect in that regard from each of these channels provides us valuable information about your interests and preferences. This insight gives us the opportunity to offer you the best WONDER BUCKLE experience possible. To learn about you and your interests, we analyze your interactions with our brand using various kinds of information, as set out above. In particular, we may combine the information we collect with information we lawfully obtain from third parties. This is necessary for the purposes of our legitimate interests in ensuring that we provide you the most appropriate offers for products and to personalize your experience. You can opt-out of us combining your personal information with the information lawfully collected from third parties through your account settings page or by contacting us using the contact details set out below. If you have given us your consent to send you marketing communications or if we are permitted by law to send such communications without obtaining your consent, we use the information that you have provided to us when interacting with us for sending you personalized marketing messages about WONDER BUCKLE products or services, events, Prize Giveaways and promotions. In some instances we will also aggregate your personal information with that of other individuals, to create comprehensive reports about how customers use our products and services, and experience our brand. This is necessary for the purposes of our legitimate interests in analyzing our brand and determining how to improve our services.
What kind of channels: we will send direct marketing communications to you via the channel you choose, such as email, phone, or social media. We ask for your consent, where required by applicable law, in order to use the contact details you have provided to us to send our personalized marketing communications.
What kind of messages: the messages we will send you will be personalized and tailored to your individual preferences and interests. We use analytics in order to generate such personalized messages. These analytics will process your personal information and place you in marketing segments, which determine the content of the messages and the offers you will receive from us. These direct marketing messages may contain information about our products and services, events, Prize Giveaways or promotions and WONDER BUCKLE news. We personalize these messages on the basis of that it is necessary for the purposes of our legitimate interests in ensuring that we provide the most appropriate information. We will, in certain circumstances, also use the channels for opinion research (such as to ask if you would like to participate in a survey) and to learn about your experience and improve your experience with WONDER BUCKLE, including by sending you personalized messages.
Re-targeting: our websites use re-targeting technologies, which we will only use after you have provided your consent. This enables us to show our visitors, who were already interested in our shop and our products and/or services, advertisements from us on partner websites. We believe that the display of personalized, interest-based advertising is more interesting and relevant to our customers than advertising that does not have a personal connection. Re-targeting technologies analyze the information we collect about your interactions with each WONDER BUCKLE platform as described in relation to marketing above and information obtained from other parties, including your cookies, and display advertisements based on your past web-surfing behavior. We will process your data for re-targeting purposes with your explicit consent.
Ads: we also work with non- WONDER BUCKLE companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect personal information about your visits to our websites and your interaction with our communications, including advertising. They will only collect this information to the extent you have consented to the placement of cookies for marketing purposes.
Conducting analytics: we will use the personal information we hold about you (as well as pseudonymized or anonymized information generated from your personal information) to carry out analysis and research. We carry out all such analysis and research on the basis that it is necessary for the purposes of our legitimate interests in understanding our customers and ensuring that our products meet the needs of our customers. The specific ways in which we carry out this analysis include:
data science/analytics, whereby we combine information we hold on a large scale in order to:
- learn more about our customers and their preferences;
- to identify patterns and trends amongst our customers;
- enhance user experience on our websites;
- provide information, content and offerings tailored to our customers’ needs;
- for general research and statistical purposes; and
- for aggregated reporting purposes within WONDER BUCKLE;
- develop new products and services;
- monitor performance of our products and services and/or improve our technology;
- to be able to send you personalized marketing messages;
- to display online ads to you.
- Analyzing our business: we will use your personal information (including by anonymizing and aggregating it with other customers’ personal information) for sales, supply chain and financial analysis purposes, to determine how WONDER BUCKLE is performing and where improvements can be made and where necessary to report back to our parent or affiliate group companies. This is necessary for the purposes of our legitimate interests in understanding how our business is performing, and considering how to improve our performance.
We will ask for your consent if we wish to use your personal information for purposes other than those listed in this privacy statement and as required to do so under applicable law. We will not use your personal information for other purposes before we have received such consent.
HOW WE SHARE YOUR PERSONAL INFORMATION
We treat your personal information with care and confidentiality and do not share it with third parties other than as set out below:
With other WONDER BUCKLE entities
Each WONDER BUCKLE entity that you interact with will share limited personal information which you provide when you sign up (your name, email address, password and date of birth) with other WONDER BUCKLE entities to enable the global single sign-on and for authentication purposes, so that you can use the same sign in information anywhere in the world and our systems will recognize your details. This is necessary for the performance of your contract with WONDER BUCKLE.
Each WONDER BUCKLE entity may share information we keep in your profile with other WONDER BUCKLE entities if both entities are responsible for your personal information, or if the other entities are acting as our service providers and processing your personal information on our instructions or on our behalf. This sharing is to ensure that each WONDER BUCKLE entity has access to all data for which it is responsible, in order that it can comply with its legal obligations.
Each WONDER BUCKLE entity will also share your other personal information, as well as anonymized and aggregated information, with other WONDER BUCKLE entities (such as WONDER BUCKLE EUROPE NV, the parent company of the group, and/or other WONDER BUCKLE entities as necessary). They will use this personal information for trend analysis, which is necessary for the purposes of their legitimate interests in analyzing their performance.
The local affiliate handling your purchase will share information about your purchases when ordering from our web shop with WONDER BUCKLE EUROPE NV WONDER BUCKLE EUROPE NV will share information collected through cookies used on the WONDER BUCKLE website with the local WONDER BUCKLE affiliate handling your purchase on our website. We will collect and share information from marketing cookies on the basis of your consent. If you do not give your consent, we will only use functionality cookies. We will collect and share information from functionality cookies to meet our legitimate interests in ensuring that our website functions correctly and that we keep our records accurate and up to date.
With service providers
We will share limited the personal information you provide when you sign up for an WONDER BUCKLE single sign-on (your name, email address, password and date of birth) with our cloud service providers for the purposes of identification and authentication, so that you can log on to your WONDER BUCKLE account quickly and with the ease and speed you expect from us from anywhere in the world.
We will also share your personal information as necessary and only for the purposes and on the lawful grounds described above with various third parties who process your personal information on our behalf, such as third parties that run Prize Giveaways/competitions, hosting, delivery, payment and fraud management providers, credit scoring agencies and analytics platform providers. We require that these service providers and other third parties adhere to strict rules when processing your personal information, including to only use your personal information in accordance with WONDER BUCKLE’s instructions and the applicable laws.
WITH SOCIAL NETWORKS
Our website will, in certain circumstances, provide you with social plug-ins from various social networks. If you choose to interact with a social network such as Facebook or Twitter (for example by registering an account), your activity on our website will also be made available to that social network. This is necessary for the performance of your contract with an WONDER BUCKLE entity which allows you to interact with a social network. If you are logged in on one of these social networks during your visit to one of our websites or are interacting with one of the social plug-ins, the social network might add this information to your respective profile on this network based on your privacy settings. If you would like to prevent this type of data transfer, please log out of your social network account before you enter one of our websites where possible. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal information, what rights you have and how you can maintain suitable privacy settings for your needs.
WITH LEGAL AND LAW ENFORCEMENT
WONDER BUCKLE will disclose personal information where required by law or legal process, for the administration of justice, to protect your vital interest, for investigations by law enforcement or regulatory bodies, to protect and defend WONDER BUCKLE’s property and legal rights, to protect the personal safety of WONDER BUCKLE website or by order of a valid injunction from a court or law enforcement agency.
WITH YOUR CONSENT
We will share your personal information with other third parties (different from those described above, for example, sports or fitness centers or when you decide to connect our devices with third party devices) in other limited circumstances. In these instances we will, where required by applicable law, obtain your consent to share your personal information in this way.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We are committed to protecting your personal information and implement appropriate technical and organizational security measures to protect it against any unauthorized or unlawful processing and against any accidental loss, destruction, or damage.
RETAINING YOUR PERSONAL INFORMATION
We will keep your personal information for two years from your last interaction with us, such as the date your account was deleted, your last purchase or in some other way contacted or interacted, unless a longer or shorter retention period is required by law, is necessary in the course of legal proceedings or is otherwise needed for a particular purpose under applicable law.
The following are examples to illustrate how WONDER BUCKLE keeps your personal information for as long as necessary for a particular purpose:
we may keep your personal information collected during a purchase for as long as required by tax laws (longer than 2 years in some European countries);
we may keep your personal information for a shorter period if you ask us to delete your personal information. In such a case, WONDER BUCKLE will aim to delete your personal information within a maximum period of one month from the date of the request;
information collected in connection with promotions will be kept for no longer than one month following the end of the promotion.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION
Unless stated otherwise, we store and process your personal information in the European Union. There will, however, be occasions when we need to transfer your personal information outside of the European Economic Area (“EEA”) to a country is not regarded under European Law as providing the same level of data protection as the country in which you normally use our products and/or services. For example, the personal information you provide when you sign up for an WONDER BUCKLE account will be stored in the European Union, and also by other WONDER BUCKLE entities and our cloud services providers located outside the EEA for the purposes of authenticating your account and signing you in. In these circumstances we will take appropriate steps to ensure that your personal information is adequately protected. Typically, such steps include carrying out data security reviews of any recipients and putting in place contracts with such recipients to ensure they employ the same or similar appropriate technical and organizational measures as WONDER BUCKLE, so your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the contact details below.
INFORMATION ABOUT CHILDREN
As a general rule, we do not intentionally collect personal information about children under the age of 13. If we become aware that we have inadvertently collected personal information about children under the age of 13, we will take steps to delete the information as soon as possible, except where we are required by applicable law to keep it.
Where we know a child is above the age of 13, but considered a minor under applicable law, we will obtain parental/guardian consent prior to using that child’s personal information.
LINKS TO OTHER WEBSITES AND SERVICES
Our websites may contain links to third party websites, and some of our services provide you with access to third party services (such as social networks).
We have no control over how third party websites and services process your personal information. We do not review third party websites and services, and we are not responsible for such third party websites and services or their privacy practices. Please read the privacy statements of any third party websites or services that you access from our websites or services.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
Fair play and transparency are important to us. We are open about the personal information we collect and have implemented mechanisms to enable you to exercise any rights you might have with respect to your personal information.
Where we have obtained your consent in relation to any matter in relation to your personal information (e.g. your consent to receiving direct marketing messages or your consent to the placement of cookies on your device), you can withdraw this consent at any time by contact us using the contact details set out below or changing your cookie settings.
ACCESS TO, DELETION, AND CORRECTION OF PERSONAL INFORMATION
If you have ordered products or services or registered an account with us, you can access your personal information through one of our websites. Our websites generally present you with the option to add, update or remove information we have about you
If any personal information we have about you is not accessible through our website, you can send us a request for access to this information at no cost using the contact details set out at the end of this privacy statement.
After receiving your request and sufficient information to verify your identity we will provide you with a copy of the personal information we have about you which you are entitled to have under applicable law. We will also confirm the purposes for which such personal information is being used, its recipients and the origin of the information.
You may write to us at any time requesting amendments to certain personal information that you consider to be incorrect or irrelevant or to request that we block, erase or otherwise remove your personal information. You may also write to us at any time to object to our use of your personal information, restrict our use of your personal information, or request that we provide your personal information in a usable electronic format and transmit to a third party (right to data portability). We will comply with these requests in relation to your personal information in line with applicable law.
OPTING OUT AND UNSUBSCRIBING FROM MARKETING MESSAGES
All our marketing communications contain an easy way to opt out from receiving future messages, such as a link through which you can unsubscribe. You may also opt out for particular channels (for example email or SMS) as indicated in the message received in such channel or through your WONDER BUCKLE account settings.
If you would like to opt out of receiving WONDER BUCKLE marketing messages you may use the unsubscribe link contained in the messages you have received, or alternatively you could contact our:
Customer service department at customercare@WONDERBUCKLE.com.
Note that if you choose to opt out of receiving marketing messages in the manner explained above, we will continue to process your personal information, in particular to allow us to understand your interests and preferences, but we will stop using your personal information to send you personalized or non-personalized marketing messages. If you would like us to stop such processing in part or in full, we have explained how to do this in the above paragraph.
CHANGES TO THIS POLICY
WONDER BUCKLE has pledged to adhere to the fundamental principles of privacy and data protection. We therefore regularly review our online privacy statement in order to ensure that it is free of errors and clearly visible on websites, that it contains appropriate information about your rights and our processing activities, and that it is implemented and is compliant with applicable law. We may update this privacy statement from time to time to keep it up to date, to keep pace with new developments and opportunities relating to the Internet and to stay in line with applicable law. If we make significant changes to this privacy statement, we will inform you by posting a notification on our websites and/or mobile apps along with an updated version of the privacy statement
If you have any questions about our use of your personal information, how to exercise your rights or about our privacy statement you are welcome to contact us at:
Online at firstname.lastname@example.org
DATA PROTECTION TEAM
by E-mail at: email@example.com you prefer to contact us by regular mail, please send your request to the following address:
WONDER BUCKLE Europe NV
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority using their website.
LAST UPDATED: 25 06 2019