Privacy Policy and Information about the Processing of your Personal Data
1. What is a Privacy Policy?
1.1. In our privacy policy, we explain who is responsible for the processing of
personal data that occurs when you order goods or services from us. We also describe
which elements of personal data about you is being processed when you provide
information to us in various situations, how we process personal data, why we do so, and
what legal support we rely on to justify the processing, as well as explaining which
third parties may be processing your personal data about you so that we will be able to
provide the goods and services you have ordered. You also receive information about your
rights concerning our processing of your personal data, and how to proceed in order to
exercise your rights.
2. Important terms and concepts
Here are some important terms and concepts that may be helpful to gain a fuller
understanding our privacy policy:
a) “Personal Data” means any information relating to an identified or
identifiable natural person. An identifiable natural person is an individual who can be
identified directly or indirectly with reference to an element of data, for instance
name, an identification number such as a Swedish personal ID number, information about
location, online identifiers such as an IP address, or one or more factors specific to
the physical, physiological, genetic, psychological, financial, cultural or social
identity of the individual.
b) “Processing” means a measure or combination of measure concerning personal
data, such as the collection, registration, organising, structuring, storage, adaptation
or modification, production, reading, usage, disclosure by transfer, dissemination or
provision by other means, adjustment or compilation, limitation, erasure or destruction.
c) “Zinzino Partner” means a person or company who is registered at Zinzino as a
reseller of Zinzino’s products.
3. Who is responsible for the processing?
3.1. Zinzino Sverige AB is the data controller in relation to the
processing. In this text, Zinzino Sverige AB is referred to as “We” and you who
order goods and services from us, or who have shown an interest in ordering goods and
services from us, are referred to as “You”.
4. Generally about our processing of personal data
4.1. We will only process the personal data about you that is necessary for the
purposes as specified in Section 5 below. In addition, we have procedures for how we
store and remove identifying information from personal data in order to continuously
ensure that your personal data is sufficient and relevant at all times.
Where the data is obtained from
4.2. The information is collected directly from you at the time of purchase, and
you will need to provide the information we ask for in the order form in order that we
will be able to process your order. Therefore, providing the information we request is
necessary so that we will be able to enter into an agreement with you.
5. Which personal data we process about you and the reasons for the processing, and
related matters
We process personal data to be able to deliver goods and services to you
5.1. When you order goods or services from us, you enter into an agreement with
us. Therefore we will process all of the personal data you provide to us in connection
with placing the order, such as your name, civil registration, number, address, e-mail
address and telephone numbers, and the details of how you contacted us, such as IP
address, in order to fulfil the obligations of the agreement with you – also in order to
process your order and/or your subscription, deliver goods and services to you that have
been ordered, manage the payment for them, and deal with and fulfil any customer service
obligations in respect to the goods you purchase. These types of personal data that are
provided in connection with placing orders is referred to as “Ordering Data.”
5.2. The Ordering Data we collect so that we can process and otherwise deal with
your orders will be processed in order to fulfil the agreement with you during the time
your Customer Relationship with us remains in effect, and during the time period for any
warranty commitments on our part.
We process personal data when others use our website
5.3. When using our website, we will automatically collect and process technical
information including IP address, login information, type and version of operating
system and device, time settings, selected language, cookies, etc., and time expended
for planning orders, keystrokes, etc. These types of personal data that is provided in
connection with using our website we refer to as “User Data.”
5.4. Your User Data is processed in order to provide you with sign in rights and
use your user account on our website, ensure your identity and age, have accurate and
up-to-date information about you, so that you will be able to track and manage your
orders in process, to manage your choices in regards to settings and payment details, to
assist with further developing and improving our website and the IT systems used to
provide it, as well as to be able to deliver the goods and services to you that you have
ordered, in accordance with our General Terms and Conditions. The User Data about you we
have collected will be saved for the same period of time as the Ordering Data about you
we process.
We process personal data to facilitate your membership in the Zinzino4 Free
programme and to report the commissions, etc. to our partners
5.5. We also process your personal data and information about what you have
ordered and paid to manage your membership in the “Zinzino4Free” program, and may also
process your personal data in order to be able to provide a report to our Zinzino
Partners concerning commissions and points regarding the sales to you if you have been
referred to us by or otherwise chosen to be associated with a Zinzino Partner.
5.6. The personal data processed within the framework of the “Zinzino4Free”
programme is processed for as long as you choose to remain as a member of the customer
club, for the purpose of fulfilling our membership agreement.
5.7. The information that is processed in order to be able to report commissions and
points to our Zinzino Partners regarding the sales to you is processed based on a
balancing of interests, where we assess that our interest in fulfilling our reporting
obligation to the Zinzino Partners who are involved is such a legitimate interest that
means that the processing is permissible. This data will be processed for a maximum of
12 months after the customer relationship has ended.
We process personal data in order to be able to market our goods and services to
you
5.8. Finally, we process your personal data for marketing purposes, in other words in
order to be able to promote and market our products to you.
5.9. Even when the data is processed for marketing purposes, it is based on a
balancing of interests where we assess that our interest in marketing our products to
you is such a legitimate interest that means that the processing is permissible. Such
processing for marketing purposes will take places for a maximum of one year after our
customer relationship with you has ended.
Data we need to process as required by law
5.10. In addition to the above, we may process your personal data to fulfil legal
obligations, for instance the obligation to keep accounting records, to the extent and
during the time period as specified by law.
6. Consent to certain processing and “the right to be forgotten”
6.1. You may, from time to time, also be offered the opportunity to provide us
with additional information about you, other than what is stated above, via our website,
such as uploading a picture of you or participating in promotions, etc. Any and all
information you provide to us and which will not be used for any of the other purposes
as stated above will be processed after obtaining your consent. At the present time,
this applies to a) pictures you upload to our website, until you withdraw your consent
or until your profile with us is deleted (for instance due to that long period of time
has passed since your last order, and b) in regard to promotional campaigns, until the
winner is announced and the prize in the campaign is given out. By participating in
promotions with us, you also agree that your name and picture will be publicly
publicised on our website, if you are one of the winners of the promotional campaign.
Your right to revoke your consent
6.2. With regards to your personal data and during the time your personal data is
being processed only based on your consent, you may withdraw your consent at any time by
contacting us. If you withdraw your consent in such case, the personal data we process
based on only your consent will be deleted (the “right to be forgotten”). If the data is
also being processed for other purposes, the data will instead no longer be processed
for the purposes where the processing is based on your consent.
7. How we will process your information and who it can be provided to
7.1. The personal data we process about you will primarily be processed
internally within Zinzino and by companies in the same Group as us, however in relevant
parts may be provided to those partners who are to receive a commission or points on the
sales to you, as well as to companies that help us with the production and distribution
of products and services, such as postal and parcel delivery companies and other
vendors/suppliers. We also retain subcontractors, for example those providing customer
service systems, that will receive access to your personal data as a personal data
processor on our behalf.
7.2. Zinzino will not disclose your personal data to other companies for
marketing purposes.
8. Where is your personal data stored?
8.1. Your personal data is stored primarily in IT infrastructure provided by one
of our personal data processors. The personal data is processed and stored primarily
within the EU/EEA, with the exceptions set out below.
9. Data processed outside of the EU/EEA
9.1. Zinzino retains personal data processors for the management of customer
service systems, as well as suppliers and distributors outside of the EU/EEA. Therefore
in connection with this processing, your personal data will be transferred to the United
States and Canada.
9.2. With regard to Canada, the EU Commission has decided that there is an
adequate level of protection for your personal data, which is why the processing is
considered securely. Regarding the processing in the United States, there is no decision
yet concerning adequate levels of protection. Instead, we have signed an agreement with
the companies that will process your personal data as a processer on our behalf, or as a
joint data controller (the latter applies to Zinzino’s Group companies in the United
States) in accordance with the standard agreement clauses developed by the EU Commission
which are regarded as ensuring a sufficient level of protection for the data. If you so
desire, you can obtain a copy of the agreement with these companies by contacting us.
For more information concerning the EU’s standard contract clauses, see e.g.
https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_sv.
10. Your rights concerning access to the information we process
10.1. You are entitled to receive notice of and information about the data we
process about you, and a copy of the data (without charge), by contacting us. However
for any additional copies, over and above the one you are entitled to receive free of
charge, we will charge an administrative fee corresponding to the costs incurred in
order to produce and provide you the additional copies.
11. Your right to correction of incorrect data and deletion of data
11.1. If you believe that any data about you is incorrect, you are entitled to
request that the information be corrected or deleted. If such a situation arises, please
contact us and tell us what information you think is incorrect and tell us why it should
be corrected or deleted.
12. Your right to object to certain processing
12.1. You are entitled to object to the part of our processing of your personal data
that is based on the “balancing of interests.” For more information which processing
this applies to, refer to sections 5.7 and 5.9 above.
12.2. In regards to the processing of personal data that is done for marketing
purposes, you may make objections to this at any time. If you do so, your personal
data will no longer be processed for marketing purposes. If you make objection
relating to other uses, we will consider it against the reasons we have to continue
with the processing of your personal data.
12.3. Contact us if you want to make any objections to any part of the processing
that takes place based on a balancing of interests.
13. Your right to a restriction or limitation
13.1. You may also request that the processing of your personal data be limited
(frozen) if in your opinion the personal data we are processing is not correct, if the
processing would be unlawful/illegal, if we no longer need to retain or process the data
but if you, despite this, still need them in order to be able to make a legal claim or
if you have opposed the processing, and until we have dealt with your objections.
14. Your rights to data portability
14.1. You are entitled to obtain the personal data about you that you provided to
us in a structured, widely-used and machine-readable format in order to be able to
transfer this information to another data controller. This applies only to the
information you yourself have provided to us, and only when the processing is based on
your consent or for the purpose of being able to fulfil an agreement with you. If you
want to obtain your personal data in this manner, please contact us.
15. Your right to lodge a complaint
15.1. At Zinzino, we take your privacy very seriously. We are therefore very
happy that your personal data is always processed in a proper and secure manner. If you
have any comments about our handling or processing of personal data, please feel free to
contact us.
15.2. If you believe that our personal data processing is incorrect in some
manner, you are entitled to file a complaint to the Swedish
Integritetsskyddsmyndigheten/Protection of Privacy Authority (formerly the
Datainspektionen), which is the regulatory authority for these matters. More information
is available at www.datainspektionen.se.
16. Feel free to contact us
16.1. Our contact details are: Zinzino Sverige AB (556645-5869), Hulda Lindgrens
gata 8, SE-421 31 Västra Frölunda, Sweden.
16.2. You can reach our customer service at: +46 31 771 71 51 or via e-mail at:
customer.eu@Zinzino.com.
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