Privacy Policy

PRIVACY POLICY

PLEASE READ THIS POLICY CAREFULLY BEORE USING THE WEBSITE

This policy was last updated: 7th August 2019

This policy explains how Feetwonder will handle the privacy of your information. We are committed to maintaining robust privacy protections for all our users. We will take the necessary steps to ensure that users information is safeguarded and kept in accordance with all applicable laws and regulations.

ABOUT US

The Website, https://www.feetwonder.com (“Feetwonder”), is the property of SIA Vitalik, registered in Latvia under registration number 40203219165.

By using the Website, or signing up for an account, you are agreeing to our full Terms and Conditions (see www.feetwonder.com). This Privacy Policy is incorporated into our Terms and Conditions.

Where we manage personal data, we identify as a Data Controller and recognise and act on our obligations under applicable data protection law.

We can be contacted by:

Email to                               support@feetwonder.com

Post to                  Matisa iela 26, Riga, Latvia LV-1001

YOUR AGREEMENT

The Terms and Conditions form a legal agreement between us and you. If there is any conflict between the Terms and Conditions and Privacy Policy, then the Terms and Conditions shall take precedence.

You may only use this Website for lawful purposes under our Terms and Conditions. The information and services available on the Website are for the sole purpose of showing the services we offer, and for the use of such services. Any reference to “you” or “your” means you, the user.

If you use our services, you confirm that you have the relevant authority to enter into a legal agreement with us whether as an individual or other legal entity.

If you do not wish to be bound by our Terms and Conditions, you are advised not to use the Website.

INFORMATION YOU PROVIDE TO US

In order to provide our services to you, you agree to us using any personal information including special categories of personal data that you provide, to create your profile and that we may use this information to show your interests, preferences and availability. By providing your personal data to us, you consent to the use and disclosure of this information

You agree that all information, photographs, videos and other material that you post on the website, or provide to us, belongs to you exclusively and that you assign to us full copyright of the content and use of your profile.

Children

We do not market this website at those under 18 years old. Consistent with the GDPR we will never knowingly request personally identifiable information from anyone under the age of 18 years old.

INFORMATION WE GET FROM OTHER SOURCES

From time to time, we may need to obtain information from third parties about you. This will only apply where it is necessary to provide our services to users and as permitted by law.

We may receive personal data relating to your identity and contact data from data partners; and data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.

HOW WE USE YOUR PERSONAL DATA

Your personal data will be used by us to enable us to provide our services to you. We act as a Data Controller of your information and undertake to protect your personal data in a manner that is consistent with the requirements of all applicable data protection laws including the General Data Protection Regulation (GDPR).

Data protection law requires us to have a “legal basis” for processing personal data. The legal bases we rely on are:

  • Performance of a contract we are about to enter into or have entered into with you;
  • Compliance with a legal or regulatory obligation;
  • Carrying out activities that are legitimate to our business interests;
  • However, generally, we shall not rely on consent as a legal basis for processing your personal data other than where the law requires it. Where our legal basis is consent, you have the right to withdraw consent any time.

We may use the personal data we collect from you as outlined in this table:

Use of personal data Type of data Legal basis
To process orders (a)     Identity

(b)     Contact

Performance of a contract or to take steps to enter into a contract
To provide, manage and personalise our services to you, respond to communications (a)     Identity

(b)    Contact

 

Where necessary for the perform of our agreement or to take steps to enter into an agreement

It is in our legitimate interests to make sure that our customer accounts are well-managed, and to provide a high standard of service

To process payments (a)     Identity

(b)     Contact

(c)     Financial

(d)     Transaction

Performance of a contract

Necessary to comply with a legal obligation

To administer and improve the website (e) Technical

(h) Usage

It is in our legitimate interests to develop and improve our products and services, so that we can continue to provide products and services that our customers want to use, and to make sure we continue to be competitive
To send email notifications which have been specifically requested (a)     Identity

(b)     Contact

It is in our legitimate interests to give you information about our products and services that you may be interested in
To send marketing communications, where expressly agreed (a)     Identity

(b)     Contact

(i)       Marketing and Communications

In the case of electronic marketing we have your consent to do so
To provide third parties with statistical information about our users (e) Technical

(h) Usage

It is in our legitimate interests to better understand how our customers use our products and what changes we could make to improve them
To ask for a review (a)     Identity

(b)     Contact

It is in our legitimate interests to better understand how our customers use our products and what changes we could make to improve them
To deal with enquiries and complaints made by or about you relating to the website (a)     Identity

(b)     Contact

(e) Technical

(h) Usage

It is in our legitimate interests to make sure that our customer accounts are well-managed, so that our customers are provided with a high standard of service
To recover debt and exercise other rights we have under any agreement with you, as well as to protect ourselves against harm to our rights and interests in property

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

Where necessary to perform a contract or to take steps to enter into an agreement with you

Where the law requires this

It is in our legitimate interests to ensure that we can recover debts owed to us, as well as making sure our assets are protected

 

Cookies

We use cookies to improve your browsing experience by personalising the website. Data collected from cookies is used to administer the website and will not be used to identify any individual user. See our Cookie Policy below.

Registration

We use the details that you give to us, to follow up on enquiries, to send you general information about us and our services, to deal with complaints and other general communications in relation to our website and services. The basis for holding this information is as being for legitimate business purposes or to fulfil a contractual obligation where the contact is from an existing client or other contact.

In order to provide our services to you, you will be required to provide us with your personal information including some special categories of personal data. You warrant that this information is accurate and correct. If you do not provide full details, we may not be able to provide some or any of our services to you. We will use your personal information to facilitate communications with other third parties as we determine in the provision of our services. This does not affect your rights as a data subject (see below).

Registration is subject to acceptance or refusal by Feetwonder at our sole discretion.

Passwords

You are solely responsible in all respects for protecting the confidentiality of any password for access to or use of the website. Your password may only be used by you personally and you must not share it with or transfer it to any third parties. You are solely responsible for any and all activities that occur under your password and account.

You must notify Feetwonder immediately of any unauthorised use of your password or any other breach of security regarding the website which comes to your attention. Feetwonder will not be liable for any loss that you may incur as a result of a third party using your password or account. However, you may be liable for losses incurred by work as a result of someone else using your password or account.

Payment data

Payments are taken online only. We use the following third party,www.securionpay.com – to manage our subscriptions and payment transactions. You are advised to read their Privacy Policy at https://securionpay.com/docs/privacy

All supplied credit card information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers’ database only to be accessible by those authorised with special access rights to such systems and are required to keep the information confidential. Individual payment details are not given to us and we do not store such data on our servers or in our systems.

Other direct interactions

You may give us your data by filling in forms or by corresponding with us face-to-face, by post, or through social media. This includes personal data you provide when you: sign up to receive our services; make enquiries or request information be sent to you; use our services; ask for information to be sent to you; engage with us on social media; enter a promotion or survey; contact us direct; or leave comments or reviews on our services.

Social media

We use social media to engage with users and link to our Facebook, Instagram, Twitter, Tumblr and YouTube pages. We do not keep any specific data that identifies you as an individual user but hold details of our followers on these platforms. You should refer to the Privacy Policies of these channels to understand how they treat your data in relation to linking to our site:

Facebook:            https://www.facebook.com/privacy/explanation

Instagram:           https://wellbeing.instagram.com/safety

Twitter:                                https://twitter.com/en/privacy

Tumblr:                 https://www.tumblr.com/privacy

YouTube:              https://policies.google.com/privacy?hl=en

Users contacting this website and/or its owners do so at their own discretion and provide any such personal data requested at their own risk. Your personal data is kept private and stored securely until a time it is no longer required or has no use.

Our legitimate interests

When we use our legitimate interests as the legal basis for processing your personal data, we will consider and balance any potential impact on you and your rights before we process your personal data. We will only then proceed where we believe our interests are not overridden by the impact on you. Our legitimate interests include the management of our business operations.

Users of this website do so at their own discretion and provide any such personal details at their own risk.

SHARING INFORMATION

Disclosure

We don’t share, sell, or distribute your data to third parties for marketing purposes, except as provided in this Privacy Policy.

We will share or transfer your data to our authorised partners or third parties at our discretion in order to register your profile on their website. By registering on this website you expressly consent to the use of your data for this purpose. Details of websites that you are registered on will be provided to you and you have the right to withdraw your registration of any website at any time by notice to us.

We may disclose your personal information if we are required to do so by law, in connection with any legal proceedings, and in order to establish, exercise or defend our legal rights, or if otherwise legally permitted.

Your data may be shared with subcontractors working on our behalf, who act on our instruction in relation to the management of your data and must adhere to all data protection laws and regulations.

Data Processors

We may use Data Processors who act on our instruction in relation to the management of your data and they must adhere to all data protection laws and regulations. We have contracts with our Data Processors to ensure compliance with this requirement under the GDPR.

You will be informed of any other Data Controllers who have access to your data and may determine processing activities separately to us, or as a Joint Data Controller.

Marketing

We will only send you emails about our products and services i.e. newsletters and direct marketing, with your express consent. You have the option not to give consent and to withdraw consent at any time. You may withdraw your consent for us to contact you by contacting us at support@feetwonder.com

If you subscribe to our newsletters via the website, we will keep details of your name and email for this purpose on the lawful basis of your consent. You will be able to unsubscribe (or withdraw your consent) from receiving these by clicking on a link for that purpose at the bottom of our e-mail with the newsletter at any time. Newsletters are normally sent to registered subscribers 3-4 times per month.

External links

Users of the Feetwonder website are advised to adopt a policy of caution before clicking on any external web links – clickable text / banner / image links to other websites. Clicking an external link will take the user away from our website. Once you leave our website or are redirected to a third party website or application, you are no longer governed by this Privacy Policy or our website’s Terms and Conditions.

Feetwonder cannot guarantee or verify the contents of any externally linked website and users click on external links at their own risk. Feetwonder and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Adverts may be placed on the Website by private advertisers and third parties. We do not guarantee the accuracy or detail of any advert in any form.

Social media platforms

Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to our terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate and/or engage with them with due care and caution in regard to their own privacy and personal details. This website nor its owners will not ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

Feetwonder uses social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised that before using such social sharing buttons, that they do so at their own discretion, and should consider that the social media platform may track and save requests to share a web page, through the users’ social media platform account.

Analytics

We use Google Analytics and Yandex Metrica, to provide us with details about user’s interactions on the website. You are also advised to read our separate Cookie Policy.

DATA RETENTION

We keep your personal information in accordance with our Data Retention Policy which reflects our needs to provide services to you as contracted and also as required to meet legal, statutory and regulatory obligations. The need to hold information is regularly reviewed and information/data will be disposed of when no longer required.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such system and are required to keep the information confidential.

We take appropriate steps to ensure a safe processing of personal data, however, we cannot guarantee the security of data transmitted through our website or by email.  Any transmission is at your own risk.

DATA STORAGE

Our website is hosted by http://www.tmdhosting.com. Any information that you supply to us may be stored and processed by their servers located in Chicago, or any other country that provides suitable and adequate security measures to protect the data. Your data maybe transferred in accordance with the relevant data protection laws.

Any information that you supply to us may also be stored and processed on servers outside of the European Economic Area (EEA). When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law.

  • In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
  • In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

DATA SUBJECT RIGHTS

Subject Access Requests

The General Data Protection Regulation (GDPR) gives individuals, known as ‘data subjects’, the right to access personal data that is held by organisations by a subject access request (SAR). We will endeavour to respond quickly to any such requests, which legally require us to respond within one month of receiving the request and necessary information. We have a formal request form to deal with SAR requests that can be accessed on our website, www.feetwonder.com or by emailing us at support@feetwonder.com. You will need to tell us how we acquired the information and in what form.

Right to rectification

Data subjects have the right to request that we amend or change personal information that we hold about you, that is inaccurate or incorrect.

Right to erasure

Data subjects have the right to ask us to delete personal information from our systems without giving any reason and at any time. We will act on any request without delay.

Right to restrict processing

Data subjects have the right to rectification or erasure of personal data in the following circumstances:

  • Personal data is not accurate;
  • The processing of data is unlawful. Data subjects may request that processing is restricted;
  • Data is required to exercise legal rights or defend legal claims;
  • Data is unlawful but there may be lawful grounds for processing, which override this right.

Right to data portability

Data subjects have the right to obtain and transfer their data to different service providers.

Right to object

Data subjects have the right to object to the processing of data at any time based on their particular situation. This includes objecting to profiling unless it is in the ‘public interest’ or exercised lawfully by an official authority. We will only process data where we can demonstrate lawful grounds for doing so.

Right not to be subject to decisions based on automated processing

We do not use any automated processing that results in any automated decision based on a data subject’s personal information.

Using your rights

If you wish to invoke any of these rights, you can contact our us by email to support@feetwonder.com

DATA BREACHES

We will report any unlawful breach of data as required by the GDPR within 72 hours of the breach occurring, if it is considered that there is an actual, or possibility, that data within our control including the control of our data processors, has been compromised. If the breach is classified as ‘high risk’ we will notify all data subjects concerned using an appropriate means of communication. We will report any relevant breaches of date to the Data State Inspectorate in Latvia.

COOKIES POLICY

PLEASE READ THIS POLICY CAREFULLY. IF YOU DO NOT ACCEPT THESE TERMS, YOU ARE ADVISED NOT TO USE THE WEBSITE

This website (https://feetwonder.com) uses cookies to track users’ interactions on the website and improve functionality as outlined below. You are advised to read this policy carefully. If you do not accept these terms, please do not use the website.

WHAT ARE COOKIES?

Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server, to provide the user with a tailored experience when navigating the website. Session cookies may be used to validate your access to different parts of the website.

PIXEL TAGS

We may use pixel tags (also known as web beacons) which are small strings of html or JavaScript code that provide a method for delivering a graphic image on a web page. Pixel tags may be used to obtain information about the computer or device being used to view a particular web page such as the IP address of the computer or device to which the pixel tag is sent, the time it was sent, the computer or device’s operating system and browser type, and similar information.

DISABLING COOKIES

If you are uncomfortable with the use of cookies, you can disable cookies on your device by changing the settings in the preferences or options menu in your browser.  You can set your browser to reject or block cookies or to tell you when a website tries to put a cookie on your device. You can also delete any cookies that are already stored on your device. However, please be aware that if you do delete and block all cookies from our website, parts of the site my not fully function.

HOW WE USE COOKIES

The website uses cookies to help us identify and track visitors, their usage of the website, and their website access preferences. Cookies are a used to identify and distinguish you from other users on the website.

Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer or device. This complies with EU legislation which requires that explicit consent is given by users before reading files are left, or applied, on a user’s computer or device.

CONSENT

If you accept the use of Cookies on this website, you consent to the processing of data about you by us and any third parties as identified above in accordance with this policy and our Privacy Policy. You have the right to withdraw your consent at any time by sending an email to support@feetwonder.com

TYPES OF COOKIES

The types of Cookies are:

  • Strictly necessary cookies. These help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
  • Analytical/performance cookies. These help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
  • Functionality cookies. These are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
  • Targeting cookies. This information to make our site and the advertising displayed more relevant to your interests. We may also share this information with third parties for this purpose.

Cookies can be placed for a user’s session and will disappear as soon as the browser software is closed or the computer is turned off, or cookies may be persistent and will remain on the device.

COOKIES WE USE

COOKIE PROVIDER TYPE USE RETENTION PERIOD
STATISTICS
_ga feetwonder.com HTTP Registers a unique ID that is used to generate statistical data 2 years
_gat feetwonder.com HTTP Used by Google Analytics to throttle request rate 1 day
_gid Feetwonder.com HTTP Registers a unique ID that is used to generate statistical data 1 day
collect google-analytics.com Pixel Used to send data to Google Analytics about the visitor’s device and behaviour Session

ANALYTICS

We use tracking software provided by Google Analytics and Yandex Metrica to monitor our visitors, and to better understand how they use the site. This software uses cookies to track visitors’ usage. The software will save a cookie to the user’s hard drive in order to track and monitor engagement and usage of the website. The cookie will not store, save or collect personal information.

Google’s Privacy Policy is available at                          http://www.google.com/privacy.html

Yandex Metrica’s Privacy Policy is available at         https://yandex.com/legal/privacy/

Users may opt-out from having their data collected by disabling the tracking.

CHANGES TO THIS POLICY

We reserve the right to change this Cookies Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. You will be deemed to have accepted any changes to the terms of this Cookies Policy on your next visit of the website following the amendment.

COMPLAINTS

If you have any concerns about how we handle your data, you can contact the person responsible for data protection by email to support@feetwonder.com

You can raise a formal concern or complaint to the Data State Inspectorate, the supervisory authority in Latvia:

Data State Inspectorate (the “DSI”)

Blaumana 11/13 – 11

Riga, LV-1011

Latvia
www.dvi.gov.lv

FURTHER INFORMATION

Guidelines for the processing and handling of data in the EU is available at:

www.ec.europa.eu/ipg/basics/legal/cookies/index_en.html

 

Copyright © 2019 SIA Vitalik

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