1.We care about your privacy
Sometimes, we may send you a new notice to explain how we may use your personal data in specific situations, and will always give you the choice to opt out of such uses.
2.Who are we?
3.How do we collect data?
Your personal data will either be provided by you, collected by us, or any affiliates of 19&Twentyfour Ltd., or captured automatically when you access or use our Site. For example, we collect your personal data when you complete your User Account Registration, when you purchase a product, when you send us emails or when you browse our Site.
4.Are you over 18?
Our Site is only intended for people over the age of 18. If you are under the age of 18, please do not use our Site, or apply for a User Account.
5.What information do we collect about you?
It may be necessary for you to provide us with certain personal data in order for you to use our Site. We will let you know when such data is essential. All other personal data is up to you to provide or not, as you prefer.
*5.1 Your User Account
If you register for a User Account on our Site (“Member”), some of the personal data we may collect about you includes:
your full name, month of birth, email address, telephone number, shipping address, username and password;
your User Account status and activities relating to your User Account;
your transaction history or payment details when you purchase anything from our Site (including the product or service purchased, the date of purchase, date of delivery, any refunds or exchanges, shipping address, payment preferences, the cardholder’s name, credit card number, expiry date and billing information);
your shopping preferences, including brand preferences and the types of products and services you may be interested in.
*5.2 When you visit our Site either as a Member or visitor/guest
We may use online tracking technology such as cookies, pixel tags, web beacons, and other similar technologies to automatically collect information about: your visits to our Site, such as your browsing history, how long you stay on our Site, and how often you visit; your location information as provided by your mobile or other devices when you interact with our Site, including your IP address and general geographic location; and the device that you use to browse our Site (e.g. your device ID, operating system, type of device, browser type and version, other system activity, and third party sites you were using before interacting with our Site).
You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the section below on Online tracking technology.
*5.3 Other information
We also collect some of your personal data whenever we communicate with you (e.g. email content, contact information, etc.), or when you complete any voluntary surveys and questionnaires we may send you from time to time (e.g. your demographic information and feedback).
6. How do we use your information?
We will only use your personal data for the purposes set out below.
*6.1 Account administration
To help administer and maintain your User Account, including:
creating and updating your User Account;
verifying your identity;
creating a single profile about you, including combining your information with any other personal data already held by us or 19&Twentyfour Ltd.;
providing you with a log-in ID for your User Account to access our Site;
maintaining, updating, administering and processing a record of your activities on our Site, including any purchases or orders made by you through our Site for any products or services (“Orders”) and any points or rewards in relation to any Rewards Programme;
completing transactions, including processing or facilitating payments;
sending you updates about new features and benefits relating to our Site; and
enabling features that allow you to personalise your User Account on our Site, such as bookmarking your favourite products or brands.
*6.2 Customer support
To assist you when you contact us, such as responding to and investigating any of your questions or concerns, and monitoring and improving our customer support services, and to assist you with any delivery, refunds or exchanges for any Orders.
To provide you with marketing and promotional materials (“Marketing Communications”), if you choose to receive them. Please see the section on Direct Marketingbelow for more information.
To create personalised Marketing Communications tailored to your interests and preferences, and to provide you with the best possible customer experience in relation to our Site and your User Account. We may also use data analytics tools to determine whether our or any 19&Twentyfour Ltd. members’ offers, advertisements and promotions are effective, as well as to determine whether you may be interested in new products or services, or to customise the content and types of offers, products, services and rewards that we present to you.
*6.5 Optimisation and improvements
We may use your personal data to understand and improve our Site or our operations, or through various means, such as the use of analytics tools, research, surveys and feedback forms. This will enable us and our members to enhance services or products, develop new features and benefits, and assess and amend business, marketing and strategic operations and plans.
*6.6 Legal and administration purposes
We may use your personal data to investigate or handle any incidents, claims or disputes, or as otherwise required by law or requested by any law enforcement or regulatory authorities, courts or other governmental agencies.
We may also use your personal data in relation to any legal proceedings concerning you.
*6.7 Online Purchase
To administer, process and manage your Orders, including any delivery, arrangement for collection, refunds or exchanges.
7. Who do we share your information with?
7.1 La Bella Roma
Your personal data may be transferred to any La Bella Roma members for any of the purposes we have set out above. However, we will not provide your personal data to any member in order for them to send you marketing materials regarding their own products and services, unless we obtain your prior consent.
7.2 Service providers
Your personal data may be shared with us or any La Bella Roma members’ service providers (including agents and contractors) who process personal data on our behalf to help us administer and operate our Site, to fulfil, administer and process your Orders, to conduct data analytics, to help aggregate and anonymise the personal data, or to carry out any of the purposes set out above. These may include IT vendors, back-office and front-end or ancillary service providers, marketing agencies, data management and analytics service providers, and customer contact services. Our service providers may contact you on our behalf or on behalf of our 19&Twentyfour Ltd. members, for any of the purposes set out above.
7.3 Professional advisors and assignees
When necessary, we may share your personal data with our professional advisors, including lawyers, accountants, financial advisors and insurers. Your personal data may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets.
7.4 Government and regulatory authorities
8. Aggregated and anonymised data
Aggregated or anonymised data that does not include any personally identifiable information, may be used by us, any members of the 19&Twentyfour Ltd. or other third parties for various purposes, including enabling them to better understand customer needs or to improve and adapt their operations, products and services, or for the purposes of industry benchmarking, machine learning, research or analytics.
9. Direct Marketing
If you have opted to receive offers and promotions from us, we may use your personal data to:
send you direct Marketing Communications in connection with the latest news, events, updates, contests, promotions, offers, products, services and rewards offered by us or any members of the Dairy Farm Group, which relate to our Site, Reward Programmes, retail, clothing, accessories, cosmetics, beauty, healthcare and wellness, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, lucky draws and contests, food, beverages, dining, travel, transportation, banking, electronics, home, household, textiles, telecommunications, groceries, office and business supplies, technology, outdoor furniture and accessories, furniture, lighting, décor, home accessories, media, e-commerce platforms and facilitators, and publications; analyse your preferences, online behaviour and transactional history in order to gain insights, so that we can customise the content and types of news, events, updates, contests, promotions, offers, products, services and rewards that we present to you via our Site, our direct marketing communications, social media or other communication means; and in conjunction with any seasonal events, lucky draws and contests or other promotional activities. We may send you direct Marketing Communications and market research invitations by email, through your User Account, when you access the Site, or through online banner advertisements, post, telephone or SMS. Before providing you with direct marketing communications, we will always ask for your consent. You can choose at any time not to receive any direct Marketing Communications from us. Please see the section on Your rights below.
10. How do we keep your information secure?
11. How long do we keep your data for?
12. Your rights
Access and correction
You have the right to access and correct your personal data held by us, at any time, by sending an email to firstname.lastname@example.org
In order to ensure that your personal data is kept as accurate as possible, please notify us at the email address above of any changes to your personal data.
Opt-out of direct marketing
At any time, you can ask us to stop using your personal data to send you direct Marketing Communications, or you can customise how you would like to receive direct Marketing Communications from us. You can exercise your rights to do this by:
changing your settings on your User Account; or following the unsubscribe instructions in the Marketing Communications we send to you. We will stop using your personal data to send you Marketing Communications in accordance with your request. However, we may still send you non-promotional communications such as information concerning the administration of your User Account, and may use non-personally identifiable information collected via cookies and other tracking technology to display marketing information via online advertising banners on websites and apps visited by you. If you would like to stop receiving any marketing materials from us, then please contact us directly.
13. Online tracking technology
14. Links to other sites
Our Site may contain links to other third party websites and applications, including those of our 19&Twentyfour Ltd. (“Third Party Sites”). We do not own or control, and are not responsible for the privacy practices of those Third Party Sites. We encourage you to remain alert if you follow any links to leave our Site, and to review the privacy policies of those Third Party Sites so that you are aware of how your personal data may be collected and used by such third parties.
15. How do we manage updates to this policy?
16. How to contact us