Privacy Policy

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BACKGROUND:

IRYNVIGRE LTD is committed to respecting the privacy rights of the visitors to Our Website. We will only collect and use information in ways that are useful to You and in a manner consistent with Your rights and Our obligations under the law.

This Policy explains how We collect, store and use Personal Data about You when You browse this website www.irynvigre.com, shop with Us or otherwise provide Your Personal Data to Us. Please read this Policy carefully and ensure that You understand it. By accessing, browsing or otherwise using Our Website, You confirm that You have read and understood this Policy.

This Policy also sets out Our obligations with regard to data protection, the rights of Our Website’s users, customers and business partners in respect of their Personal Data under the Data Protection Act 1998 and the procedures that are to be followed when dealing with Personal Data by Us, Our employees, agents, contractors, or other parties working on behalf of IRYNVIGRE LTD.

IRYNVIGRE LTD is registered with the Information Commissioner as a data controller under the register held by the Information Commissioner pursuant to Section 19 of the Data Protection Act 1998 (ZA183141)


1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account” - means an account required to access and/or use certain areas and features of Our Website;

“Cookie” - means a small text file placed on your computer or device by Our Website when you visit certain parts of Our Website and/or when you use certain features of Our Website;

“Data Controller” - means IRYNVIGRE LTD, registered as a Data Controller with the Information Commissioner’s Office in accordance with the Data Protection Act (ZA183141);

“the Act” - means Data Protection Act 1998;

“Personal Data/Data” - means data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the Data Controller possession, and includes any expression of opinion about the individual and any indication of the intentions of the Data Controller or any other person in respect of the individual;

“Our Website” - means this website, www.irynvigre.com;

“UK and EU Cookie Law” - means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;

“We/Us/Our” - means IRYNVIGRE LTD, a limited company registered in England under Companies House No. 9727747, whose registered address is at Flat 19 Felton Hall House, 100 George Row, London, England, SE16 4UP;

“You/Yours” - means visitors to Our Website and Our customers.


2. Information about Us

2.1 Our Website, www.irynvigre.com, is owned and operated by Us.

2.2 Our business operates exclusively online. We do not operate a physical store.


3. What does this Privacy Policy cover?

This Privacy Policy applies only to Your use of Our Website. It does not extend to any websites that may be linked to Our Website. We have no control over how Your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.


4. What Data do We collect?

Some Data will be collected automatically by Our Website (for further details, please see section 13 on Our use of Cookies), other Data will only be collected if You voluntarily submit it, for example, when signing up for an Account. Depending upon Your use of Our Website, We may collect some or all of the following Data:

• name;

• date of birth;

• gender;

• contact information such as email addresses and telephone numbers;

• demographic information such as post code, preferences and interests;

• financial information such as credit / debit card numbers;

• IP address (automatically collected);

• web browser type and version (automatically collected); • operating system (automatically collected);

• a list of URLs starting with a referring site, your activity on Our Website, and the site you exit to (automatically collected);


5. How do we use Your Data?

5.1 All Personal Data is stored securely in accordance with the principles of the Act. For more details on security see sections 6 and 7, below.

5.2 We use Your Data to provide the best possible products to You. This includes: • providing and managing Your Account; • providing and managing Your access to Our Website; • personalising and tailoring Your experience on Our Website; • supplying Our products to You; • personalising and tailoring Our products for You; • responding to communications from You; • analysing Your use of Our Website and gathering feedback to enable Us to continually improve Our Website and your user experience;

5.3 The Company may also use Personal Data in meeting certain obligations imposed by law.

5.4 With your permission and/or where permitted by law, We may also use Your Data for marketing purposes which may include contacting you by email or post with information, news and offers on Our products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.


6. How do We store Your Data?

6.1 We only keep Your Data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have Your permission to keep it.

6.2 We only keep Your Personal Data that is directly relevant to Our dealings with You. That Data will be collected, held, and processed in accordance with the Act and with this Policy.

6.3 Your Data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).

6.4 Data security is of great importance to Us, and to protect Your Data We have put in place suitable technical and organisational measures to safeguard and secure data collected through Our Website.


7. What steps do We take to secure and protect Your Data?

Steps We take to secure and protect Your Data include:

• all emails containing Personal Data are encrypted;

• Personal Data is transmitted over secure networks only;

• Personal Data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;

• Personal Data contained in an email, whether sent or received, is copied from the email and stored securely. The email itself will be deleted. All temporary files associated therewith should also be deleted;

• where Personal Data is to be sent by facsimile transmission the recipient will be informed in advance of the transmission and should be waiting by the fax machine to receive the data;

• where Personal Data is to be transferred in hardcopy form it will be sent using recorded delivery;

• all hardcopies of Personal Data, along with any electronic copies stored on physical, removable media will be stored securely in a locked box, drawer, cabinet or similar;

• Personal Data will be handled with care at all times and will not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;

• if Personal Data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user will lock the computer and screen before leaving it;

• any unwanted copies of Personal Data (i.e. printouts or electronic duplicates) that are no longer needed will be disposed of securely. Hardcopies will be shredded and electronic copies should be deleted securely;

• no Personal Data will be transferred to any device personally belonging to an employee and Personal Data will only be transferred to devices belonging to agents, contractors, or other parties working on Our behalf where the party in question has agreed to comply fully with this Policy and the Act;

• all electronic copies of Personal Data will be stored securely using passwords and data encryption;

• all passwords used to protect Personal Data will be changed regularly and will not use words or phrases that can be easily guessed or otherwise compromised. All passwords will contain a combination of uppercase and lowercase letters, numbers, and symbols;

• under no circumstances will any passwords be written down or shared between any employees, agents, contractors, or other parties working on Our behalf, irrespective of seniority or department. If a password is forgotten, it will be reset using the applicable method. IT staff do not have access to passwords;

• where Personal Data held by Us is used for marketing purposes, it shall be the responsibility of Eugeniu Grecul of Flat 19 Felton Hall House, 100 George Row, London, England, SE16 4UP to ensure that You have added Your details to any marketing preference databases including, but not limited to, the Mail Preference Service, and the Email Preference Service.


8. Who will be responsible for Your Data protection?

8.1 We have appointed Eugeniu Grecul of Flat 19 Felton Hall House, 100 George Row, London, England, SE16 4UP as Our Data Protection Officer with the specific responsibility of overseeing data protection and ensuring compliance with this Privacy Policy and with the Act. In order to ensure that the following measures are taken with respect to the collection, holding and processing of Personal Data, the Data Protection Officer shall in particular be responsible for: • overseeing the implementation of, and compliance with this Policy, working in conjunction with the relevant employees, managers, agents, contractors and other parties working on Our behalf; • organising suitable and regular data protection training and awareness programmes; • reviewing this Policy and all related procedures not less than every six months;

8.2 All employees, agents, contractors, or other parties working on Our behalf are made fully aware of both their individual responsibilities and Our responsibilities under the Act and under this Policy, and shall be provided with a copy of this Policy;

8.3 All employees, agents, contractors, or other parties working on Our behalf handling Personal Data will be bound to do so in accordance with the principles of the Act and this Policy by contract;

8.4 All agents, contractors, or other parties working on Our behalf handling Personal Data must ensure that any and all of their employees who are involved in the processing of Personal Data are held to the same conditions as Our employees arising out of this Policy and the Act;

8.5 Where any agent, contractor or other party working on Our behalf handling Personal Data fails in their obligations under this Policy, that party shall indemnify and hold Us harmless against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

8.6 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us Data via the internet.


9. Do We share Your Data?

9.1 We may sometimes contract with third parties to supply products to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of Your Data. Where any of Your Data is required for such a purpose, We will take all reasonable steps to ensure that Your Data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

9.2 We may compile statistics about the use of Our Website including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates and partners. Data will only be shared and used within the bounds of the law.

9.3 In certain circumstances We may be legally required to share certain data held by Us, which may include your Personal Data, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from You in order to share Your Data in such circumstances and will comply as required with any legally binding request that is made of Us.


10. What happens if Our business changes hands?

10.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by You will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was originally collected by Us.

10.2 In the event that any of Your Data is to be transferred in such a manner, You will be contacted in advance and informed of the changes. When contacted, You will not, however, be given the choice to have Your Data deleted or withheld from the new owner or controller.


11. How can You control Your Data?

When you submit information via Our Website, you may be given options to restrict Our use of Your Data. In particular, We aim to give you strong controls on Our use of Your Data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.


12. Your right to withhold information

12.1 You may access Our Website without providing any data at all. However, to use all features and functions available on Our Website You may be required to submit or allow for the collection of certain data.

12.2 You may restrict your internet browser’s use of Cookies. For more information, see section 13.


13. Cookies

13.1 Our Website may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Website and to provide and improve Our products. For more details, please refer to section 5 above. We have carefully chosen Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

13.2 All Cookies used by and on Our Website are used in accordance with current UK and EU Cookie Law.

13.3 You can choose to enable or disable Cookies in Your internet browser. Most internet browsers also enable You to choose whether You wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with Your device.

13.4 You can choose to delete Cookies at any time however You may lose any information that enables You to access Our Website more quickly and efficiently including, but not limited to, login and personalisation settings.

13.5 It is recommended that You keep Your internet browser and operating system up-to-date and that You consult the help and guidance provided by the developer of Your internet browser and manufacturer of Your computer or device if You are unsure about adjusting your privacy settings.


14. What rights do You have under the Act?

You have the following legal rights under the Act:

• to ask for a copy of any of Your Personal Data held by Us (where such data is held) on payment of a small fee which will not exceed £10. Please contact Us for more details at Flat 19 Felton Hall House, 100 George Row, London, England, SE16 4UP or using the contact details below in section 16;

• to object to any processing of Your Personal Data that is likely to cause (or that is causing) damage or distress. You should make any such objection in writing to Eugeniu Grecul of Flat 19 Felton Hall House, 100 George Row, London, England, SE16 4UP and We shall respond within 21 days either notifying You of Our compliance, or explaining why We feel that any aspect of Your request is unjustified;

• to object to decisions being taken by automated means (where such decisions will have a significant effect on You) and to be informed when any such decision is taken (in which case You have the right to require Us by written notice to reconsider the decision);

• to have inaccurate Personal Data rectified, blocked, erased or destroyed in certain circumstances;

• to claim compensation for damage caused by Our breach of the Act.


15. Request to access

Your Data If You ask for a copy or any of Your Personal Data held by Us, We shall have a maximum period of 40 calendar days within which to respond fully, but shall always aim to acknowledge the receipt of request within 5 business days. The following information will be provided to You:

• whether or not We hold any of Your Personal Data;

• a description of any of Your Personal Data held;

• details of what that Personal Data is used for;

• details of how to access that Personal Data and how to keep it up to date;

• details of any third-party organisations that Personal Data is passed to; and

• details of any technical terminology or codes.


16. Contacting Us

If You have any questions about Our Website or this Policy, please contact Us by email at london@irynvigre.com, by telephone on +(44) 759 247 8511 or by post at Flat 19 Felton Hall House, 100 George Row, London, England, SE16 4UP. Please ensure that Your query is clear, particularly if it is a request for information about the Data We hold about You (as under section 14, above).


17. Changes to Our Policy

We may change this Policy as We may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Website and You will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Website following the alterations. We recommend that you check this page regularly to keep up-to-date.