Política de privacidad
1. PERSONAL DATA COLLECTION
SOLCH uses information from our interactions with you and other customers as well as certain third parties to help achieve its goal of providing the highest quality products and services. SOLCH respects the privacy rights of our online visitors and recognizes the importance of protecting the information collected about them. To this end, we have established procedures that ensure your personal data is processed in a responsible manner. This privacy policy informs you about the kind of material we collect and how; the purposes for which we collect and use it; your rights about and options concerning our use of your data; how your data is processed and with whom it may be shared; and for how long we store your information etc. Please read it carefully. Certain parts of this policy apply specifically to the collection and processing of your personal data when registering for our email subscription.
DEFINITIONS:
The definition of personal data means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. When we use the term ‘processing,’ we mean any operation or set of operations performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
2. HOW WE HANDLE YOUR DATA
SOLCH determines the means of processing your personal data. Carrying its legal responsibilities, a data controller is legally responsible for the storing and use of personal information on a computer or in manual files. SOLCH does not employ a Data Protection Officer. If you have any questions or concerns regarding privacy or if you have any enquires regarding the personal data you have given us, kindly contact SOLCH at any time. For details on how to contact us, please find the contact information on our website or send an email directly to info@solch.com
3. PERSONAL DATA WE COLLECT
All our activities are based on stringent ethical principles and legal requirements, and we are committed to protecting the privacy of all visitors to our websites and users of our (mobile) applications if any. For this reason, the way in which we collect and store information, including personal data, is dependent on how our website and related services are used. We do not collect any sensitive data about you. 3.1 Data collected through your interaction with us Various technologies may be used on our websites and our (mobile) applications, if any, to improve them, and make them more user-friendly, efficient, and secure. Such technologies may lead to personal data being collected automatically by us or by third parties on our behalf. Examples of such technologies include, but are not limited to cookies, flash cookies, and web analytics. Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies for which we do not accept any liability. Please check these policies before you submit any personal data to their websites. 3.1.1 Click-stream data When you visit our website, data is sent from your browser to our server. This data makes it possible for us to optimize our services and improve your experience on our websites and applications. The data is automatically collected and stored by us or by third parties on our behalf. We may collect information about your computer for system administration purposes as well as to report aggregate information for internal marketing analysis reasons. This is data about our user's browsing actions and patterns and may include the following: • Visitor’s IP address • Date and time of the visit • Referral URL (the site from which the visitor has been referred) • Pages visited and user journey on our website • Information about the browser used (type, version, operating system, etc.) 3.1.2 Cookies We use cookies on our website to aid our web analysis tools. 3.1.3 Re-targeting Technologies Our website and (mobile) applications, if any, use re-targeting technologies. This enables us to advertise directly and personally to visitors who have already shown an interest in our products and/or shop via our partner websites. We also work with companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect information about your visits to our websites or (mobile) applications, as well as your interaction(s) with our communications, including advertising. Re-targeting technologies analyze your cookies and display advertisements based on your past surfing behavior. 3.2 Data about you In addition to the data collected by automated means (see 3.1), we also process data about you that you have provided to us directly or that we have been provided with from someone using our services (for example, by someone sending you a gift through our gifting service). This includes but is not limited to • Personal data that identifies you as an individual—namely, your contact information, title, including your first and last name(s), wedding date, the day we met, photographic image, billing address(es), postcode, date of birth, gender, telephone number, email address, credit, and debit card information. • Information provided by you at the time of registration for a SOLCH account. • Information provided when you create a Wish List, save your preferences, save designs, save your jewelry list, and save your website activities. • Information you provide when you enter a competition or promotion sponsored by SOLCH. • Information you provide to us via third parties such as Facebook, Instagram, WhatsApp, and other social media platforms. • Information that you upload to or share through our site by using our services. • If you have created an online account with us: the preferences and interests are stored in this profile (please see below for further information regarding these profiles). • If you contact us, we may keep a record of your correspondence., • If you contact us to report a problem with our site or for technical and/or customer support, we may keep a record of your correspondence or conversation. • If we choose to participate in any legal dispute resolution procedure, we may disclose personal data to the governing authorities/entities in their capacity as the authorized governing body to deal with the dispute. If you provide us with the personal data of another person, please make sure that you have the right to share this information with us before you do so. We may also ask you to complete surveys that we use for research purposes, although you are not obliged to respond to them. All of this data is characterized by the fact that you have voluntarily provided it. We use this information for the purposes outlined in this privacy policy. You may at any time amend your personal data or object to its further processing (Please refer to section 7).
4. DATA PROCESSING
When you have registered for our email subscription, we may process your personal data in the following ways: • Ensure that content from our site is presented on your computer in the most efficient manner. • For purposes relating to your order, e.g. to notify you on the status of your order or delivery; to fulfill your requests, such as responding to a question regarding our products; to fulfill your order; to process your payment card and/or to provide you with customer service. We may use your data for any legal purpose. • Verification of your identity and responding to any query you may raise with us; to process your request and provide you with the best service possible. • To carry out our obligations arising from any contracts entered between you and us. • To allow you to participate in the interactive features of our service(s) when you choose to do so. • To notify you about changes to our services, terms, conditions, policies, and/or other administrative information. • To provide you with the benefits and services of being a SOLCH account holder or user of our services • To administer and maintain our records. • To manage your account membership • To store any Wish List, you may create and allow you to share your Wish List with others. • To save your product preferences and to allow you to share them with others. • To allow you to participate in contests and similar promotions and administer such activities. Some of these activities have additional rules which could contain additional information about how we use and disclose your personal information. • Customize your content on our websites to provide you with personalized offers. • Prevent and/or detect any misuse or fraud. • With your permission, we may contact you directly through the details provided by you (e.g., postal services, email, text message, telephone, or any other electronic means) for marketing, advertising, and market research purposes. For example, this includes information related to SOLCH products, e-commerce activities, special offers, and promotions, as well as information on our activities. In order to be able to contact you with information that is of special interest to you, your overall interaction with SOLCH (such as but not limited to, your shopping behavior on our online store; your use of the loyalty program; your ratings and reviews of products; your contact history with our customer service; your newsletter clicks/opening results; your surfing behavior (web tracking); the types of the newsletter you are subscribed to; your participation in promotions or events; your interactions with and use of mobile applications) will be jointly analyzed and used. We may use your personal data for marketing, advertising, and market research purposes. In section 7 you will find information on your rights, e.g., how to withdraw your consent or amend your personal details. Even if you did not subscribe to our newsletter, we may process your personal data to provide the gifting service if you choose to send a SOLCH gift or if you are chosen by someone to be the recipient of a SOLCH gift. 4.1 When you visit SOLCH’s website, your personal data may also be processed in the following ways: • Content, A/B testing, and product browsing analytics • Traffic source analytics • Internal search analytics • Purchase analytics • Device analytics • Marketing re-targeting
5. Legal basis
When you purchase an item in our online store, create an account with us, or enter into any other form of agreement with us, we will process your conventional personal data for that particular purpose. We may also process your conventional personal data if you e.g., have a query or similar that precedes your decision to enter into an agreement with us. The legal basis for which we may process your personal data is in accordance with the laws of the State of Florida, as the processing of your information is necessary for us to fulfill our agreement with you or for us to handle your inquiries and such like, ahead of concluding an agreement. We may also process your ordinary personal data unless our interests are outweighed by your privacy rights and statutory freedom. We have a legitimate interest in processing your personal data (name and email address) for both marketing and analytical purposes. Our legitimate interest is based on your preferences so that we can better customize our offerings to you—and ultimately offer products and services that better meet your needs and wishes. Additionally, we have a legitimate interest in processing your personal data for analytical purposes.
6. PERSONAL DATA DISCLOSURE
Treating your data with the utmost care and confidentiality is one of our core values. If required by law, your data may be disclosed to third parties. In addition, we employ service providers and data processors to process data on our behalf. These services include authentication, hosting and maintenance services, analysis services, e-mail messaging services, gift services, delivery services, handling of payment transactions, solvency, address, and e-mail checks. These third parties are our data processors and may only process personal data to the extent necessary to deliver their services. Our data processors are contractually obliged to treat such information in the strictest confidence. They are prohibited from using the data in any other way than required. Necessary steps are taken to ensure that our data processors, including service providers and other processors working on behalf of SOLCH, uphold and protect the confidentiality of your data. Some of our data processors may be situated outside the State of Florida or the United States. Consequently, we will share your personal data with countries outside the United States. However, we will only provide this information based on the recipient fulfilling the applicable requirements, including • The country in question is considered a safe third country. •The supplier in question shall accede to the State of Florida’s rules for the transfer of personal data to third countries. • The supplier in question is a duly registered entity, or • The supplier in question has a set of approved Binding Corporate Rules. There may be occasions on which we disclose our partner's non-personal data in an anonymous form. Such non-personal data may include information about the number of visitors to a website or (mobile) application during a certain period. Please note that any information you post or disclose through your interaction with SOLCH (e.g., personal data contained in the photos, stories, comments, and videos that you submit) will become public information and may be available to visitors to the site as well as to the public. We may disclose your information to the extent that we are duty-bound to disclose or share your personal data to comply with any legal obligation or the directions of the Court or any other body of competent jurisdiction, or to enforce or apply our privacy policy and other agreements; or to protect the rights, property or safety of SOLCH, our employees, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. If we choose to participate in any dispute resolution procedure, we may disclose your personal information to the concerned authority.
7. Your rights
If you provide us with personal data on our websites or other channels, this is done on an entirely voluntary basis. If you choose not to provide the requested information, various customer benefits may not be available to you. In certain cases, only those who have submitted to us the required personal data are able to order products, use certain services, and in other ways avail themselves of the activities and offers available on our website and (mobile) applications. We provide numerous options, depending on the exact circumstances, to help you retain control over your data. These options may include displaying and editing your data online. It may also be possible to unsubscribe from services or delete user accounts or receive information about the data held. You can access and amend your personal data at any time by logging on to your account on SOLCH.com and entering your account profile details to gain access to your personal details. If any of the information that you have provided us with has changed, e.g., if you change your email address or other contact details, or if you wish to cancel your registration with us, please let us know by editing your details on the profile and/or account pages or by sending an email outlining the changes to: info@solch.com. In general, you have the following rights: 7.1 The right to request access to your personal data You are entitled to gain access to some of the personal data you provide to SOLCH. By filling in this online form here you may request details of the information about you that we hold and process, including the purposes for which it is used. You can also access your personal details by logging on to your SOLCH account on SOLCH.com and entering your account profile details to gain access to your personal details. 7.2 The right to amend and/or delete your personal data You have the right to request the correction, appendage, deletion, or blockage of your stored personal data. To do so, send your request to cs@solch.store. Without undue delay of receipt of your request, we will comply to the required extent. If for any reason, we cannot comply with your request, we will contact you. 7.3 The right to restrict the processing of your personal data In special circumstances, you have the right to restrict the processing of your personal data. To request restriction, kindly contact us through our email: info@solch.com. 7.4 The right to object to the processing of your personal data and to unsubscribe You have the right to ask us not to process your personal data when processing is based on a legitimate interest pursued by SOLCH, e.g., for marketing purposes. You can exercise your right to object at any time by contacting us here or in writing at the postal address included at the end of this document. Emails sent to you by SOLCH containing newsletter or marketing content include the option to unsubscribe by following the instructions set out in the email. If you do not wish to receive emails from us, you can simply click on the unsubscribe hyperlink and we will stop sending you emails. For all other types of messages, you may receive from us, such as maintenance announcements or administration notifications, the receipt of such can only be terminated by deleting your account. These messages are a mandatory part of user accounts and the related use of our websites and (mobile) applications. Contact us by sending an email to info@solch.com. 7.6 The right to withdraw your consent at any time You are at any time entitled to withdraw your consent to our processing of your personal data. The withdrawal of consent shall, however, not affect the lawfulness of processing based on consent before its withdrawal. Contact us by sending an email to info@solch.com to withdraw your consent. If you wish to withdraw your consent to receiving promotional information and offers in general, including by postal services, email, text message, telephone, or any other electronic means, please contact us by sending an email to info@solch.com. Should we have misgivings regarding your identity, we may ask you to provide identification. 7.7 Conditions and/or limitations on your rights There may be conditions to or limitations on your rights. We are therefore unable to guarantee your right to data portability, as it is dependent on the specific circumstances of the processing activity.
8. PERSONAL DATA RETENTION
SOLCH will not retain your personal data for longer than necessary for the purposes for which it is processed within the following processing activities: Club Members - Has Club membership - Can have Account - Can have signed up for Newsletter prior to joining the Club How do we define an inactive Club Member? An inactive Club member is someone who has not engaged with us by logging in to the Club, making a purchase on a SOLCH-owned website, or opening, and clicking an email for up to 5 years from the last engagement. What Personal data will be Erased if a Club Member is inactive? All Personal data, such as Name, email address, address, zip code, anniversaries, Gender, Phone number, day of birth, wish list, product preferences, purchase data (if not in breach with local mandatory law), etc. Full Erasure. When will Personal data be Erased? Personal data will be Erased if the Club Member has been inactive for up to five years. What Personal data will be kept after the 5-year inactive period? No Personal data will be kept unless required by local mandatory law. How do we Erase Personal data? Our IT will on a quarterly basis manually Erase Personal data. Personal data will be Erased in all IT systems. Newsletter- No Club membership - No Account - Signed-up for Newsletter (e.g., through online channels Guest check out, Retail Uploads, etc.) How do we define an inactive Newsletter sign-up? An inactive Newsletter Sign up is a person that has not opened and clicked an email for a period of up to 24 months. If a newsletter signup, makes a purchase online, or signs up to the Club, he/she is automatically transferred to the new status of a Purchaser, see below, and therefore follows the inactive definition of this new status. What Personal data will be Erased if a Newsletter sign-up is inactive? All Personal data, such as Name, gender, email address, and product preference will be Erased. Full Erasure. When will Personal data be Erased? Personal data will be Erased if the Newsletter Sign up has been inactive for up to 24 months. What Personal data will be kept after the 3-year inactive period? No Personal data will be kept unless required by local mandatory law. How do we Erase Personal data? Global IT will on a quarterly basis manually Erase Personal data. Personal Data will be Erased in all IT systems. An account with Club membership Someone who actively has created an account online with a Club membership. Having an account does not mean that they have made a purchase. How do we define an inactive Newsletter sign-up? Someone who actively has created an account online with a Club membership. Having an account does not mean that they have made a purchase. How do we define an inactive account holder? An inactive account is someone who has not engaged with us by either making a purchase online on a SOLCH-owned website while creating an account, logging into the account, opened and clicked an email for a time period of up to 5 years from the last engagement. What Personal data will be Erased if an account holder is inactive? All Personal data, such as Name, email address, address, zip code, gender, phone number, anniversaries, day of birth, wish list, and purchase. This means full Erasure. When will Personal data be Erased? Personal data will be Erased if the account holder has been inactive for up to five years. What Personal data will be kept after the 5-year inactive period? No Personal data will be kept unless required by local mandatory law. How do we Erase Personal data? Our IT will on a quarterly basis manually Erase Personal data. Personal Data will be Erased in all IT systems. Purchase – no account/guest check out Someone who has made a purchase either online or offline without creating an account How do we define an inactive customer? An inactive customer is someone who has not engaged with us by making a purchase online on a SOLCH-owned website while creating an account, logging into the account, opening, and clicking an email for a time period of up to 5 years from the last engagement. What Personal data will be Erased if a customer is inactive? All Personal data, such as name, email address, address, zip code, gender, phone number, day of birth, and purchase. This means full Erasure. When will Personal data be Erased? Personal data will be Erased if the customer has been inactive for up to five years. What Personal data will be kept after the 5-year inactive period? No Personal data will be kept unless required by local mandatory law. How do we Erase Personal data? Our IT will on a quarterly basis manually Erase Personal data. Personal Data will be Erased in all IT systems. Web visitors – IP address Someone who has visited our website. How do we define an inactive visitor? An inactive visitor is someone who has not visited our website for 24 months. What Personal data will be Erased if a customer is inactive? All data that we have collected regarding the visit is on our website. Such as -Content, A/B testing & product browsing analytics - Traffic source analytics - Internal search analytics - Purchase analytics - Device analytics - Marketing retargeting When will Personal data be Erased? Personal data will be Erased 25 months after collection. What Personal data will be kept after the 25-month inactive period? No Personal data will be kept unless required by local mandatory law. How do we Erase Personal data? The data will automatically be erased after 25 months.
9. SECURITY OF INFORMATION AND DATA INTEGRITY
We take the appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized use, disclosure, or access, where the processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse. SOLCH uses third-party data processors to collect and process your personal data. Any data processors commissioned by SOLCH will only process your personal data in accordance with SOLCH’s instructions and are legally obliged to adhere to strict security procedures when handling personal data. 9.1 Keeping information secure SOLCH may employ third parties to collect personal information on its behalf. In such cases, these third parties are subject to confidentiality and data processing agreements and will be instructed by SOLCH to comply fully with the SOLCH Privacy Policy. Where we have provided you with, or where you have chosen, a password that enables you to access certain parts of our site, you are responsible for ensuring this password remains confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the Internet is not wholly secure. Although we do our utmost to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is done so at your own risk. Once we have received your information, we employ strict procedures and rigid security measures to try to prevent unauthorized access. 9.2 Social Networks Our website and (mobile) applications provide you with social plug-ins from various social networks. Suppose you choose to interact with a social network. In that case, your activity on our website or (mobile) applications will also be made available to social networks such as, but not limited to Facebook and Twitter. If you have logged in to one of these social network sites during your visit to one of our websites or (mobile) applications, the social network site may add this information to your profile. If you are interacting with one of the social plug-ins, this information will be transferred to the social network site. If you do not want this data transfer, please log out of your social network site before entering one of our websites or (mobile) applications. We cannot prevent this data collection and social plug-in information transfer. Please carefully read the privacy policies of your social networks for detailed information about their collection and transfer of personal data, your rights, and how you can achieve satisfactory privacy settings. Additionally, to improve your user and brand experience, your data may be passed to a third party (e.g., Facebook) for processing in accordance with data protection and privacy regulations. Facebook: http://www.facebook.com/about/privacy/ Twitter: http://twitter.com/privacy Google +: http://www.google.com/intl/en/policies/privacy/ 9.3 Geolocation Services Location-enabled services may be employed within some of our (mobile) applications. Should you use these (mobile) applications, they may receive information about your actual location, such as GPS signals sent by a mobile device or information that can be used to approximate a location. You can enable or disable your location services in your device or browser settings.
10. CONSEQUENCES OF NON-DISCLOSURE OF PERSONAL DATA
It is not possible to create a SOLCH account for a newsletter subscription or to make a purchase on the SOLCH website if you are unable to provide us with the required information.
11. CONTACT INFORMATION
Should you have any questions about our privacy policy or the processing of your personal data, please feel free to contact us. info@solch.com
12. COMPLAINTS
Complaints should be submitted directly to the State of Florida data protection supervisory authority.
13. CHANGES TO THIS POLICY
SOLCH has pledged to adhere to the fundamental principles of privacy and data protection. We therefore regularly review our privacy policy in order to keep it up to date and compliant with privacy and data protection principles. This privacy policy may be changed from time to time in order to keep pace with new developments and opportunities relating to the Internet and to stay in line with prevailing legislation. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, may be notified to you by email.
Last updated 3 November 2022
