Privacy Policy of the Online Store
Everybody London
We created this privacy policy for people visiting the website https://www.everybodylondon.com (hereinafter the „Website”), which is the Everybody London online store (hereinafter the „Store”).
The administrator of your personal data in connection with the use of the Store is: Revolution Beauty Polska sp. z o.o. with its registered office at: ul. Czyżówka, nr 14, lok. 2.06, 30-526 Kraków, entered into the Register of Entrepreneurs of the National Court Register under KRS number: 927-651, NIP: 6-751-757-474, REGON: 520323500
In all matters related to the processing of personal data, you can contact us at the e-mail address: sklep@everybodylondon.com. Written contact is also possible at the address of the registered office provided above.
For convenience, we have divided this document into two parts:If you are short on time, click on the link for the part that interests you most. If you have a moment more, we encourage you to read the entire text.
1. COOKIES AND OTHER TECHNOLOGIES
We use cookies and other similar mechanisms to learn how users use our Website and for marketing purposes, including displaying advertisements to them elsewhere on the Internet.
What are cookies?
A cookie is a small text file saved by a website on your computer, phone, or other device on which you browse the website. A cookie file contains data about your use of that site.
Some cookies are necessary for the operation of our Store and cannot be disabled.
In other cases, when you first enter our Website, we ask you to consent to the installation of cookies. We do not use advertising or analytical cookies (or any cookies other than necessary ones) without your consent.
What cookies do we use?
- Necessary cookies
- These cookies are used for the proper functioning of the site. You cannot disable them, because after disabling them, our site simply will not work properly.
- In this regard, we use a tool that stores your privacy settings. It shows your consent or lack thereof for running individual types of cookies on our site.
- Other necessary cookies on our Website are used for its proper functioning and management, including making changes to the site and running tracking tools to which you consent.
- Statistical analysis of our Website
- We use tools that collect analytical data, thanks to which we can understand how users use our Website. The data we receive from these tools do not provide us with information about a specific person known by name and surname, but allow us to record various aspects of the use of the Website by a given user. We can aggregate and analyze this data statistically and then use it to make decisions about changes in our Store and/or in the ways we conduct advertising and marketing communication.
- A list of analytical tools used by us on the Website, along with an explanation of: (1) who is the tool provider, (2) what exactly it is used for, (3) what data is collected within a given tool – can be found in Appendix No. 1 to this policy, and in brief also in the cookie consent management panel.
- Advertising cookies
- We use advertising tools through which we can display our advertisements on other sites you visit, including social media (so-called targeted ads), measure the effectiveness of our advertising campaigns, and tailor the content of our messages directed to you to the information we have about you.
- In the Store, we enable subscription to our newsletter. In connection with this, cookies are used to embed a subscription form on our Website and to measure the effectiveness of sign-ups in this form. Modern e-mail marketing systems give us the opportunity to combine analytical data from mailing campaigns with analytical data from the Store. We can use this data to optimize the content of messages sent to newsletter subscribers.
- A list of advertising tools used by us on the Website, along with an explanation of: (1) who is the tool provider, (2) what exactly it is used for – can be found in Appendix No. 1 to this policy, and in brief also in the cookie consent management panel.
- Functional cookies
- Some cookies on our site are used to launch additional tools on the Store's site, such as a chat, a product review and/or star rating module, the ability to recommend a product to a friend, the ability to display products recently viewed in our Store, etc.
- A list of functional tools used by us on the Website, along with an explanation of what exactly they are used for, can be found in the cookie consent management panel.
- Social media plugins and links
- On our Website, we have included links to our social media profiles: Instagram / TikTok. If you visit our profile on a given service, the owner of that service will receive – as in the case of users moving from any other website to another website – information that you reached those services from our Store.
- Details regarding data processing by these social networking sites can be found on the pages of the providers of these services:
- Facebook and Instagram - https://www.facebook.com/privacy/center/
- TikTok - https://www.tiktok.com/legal/page/eea/privacy-policy/pl-PL
- In the Store, we use social plugins that allow, for example, sharing a product from our Store on your profile / liking our product on Facebook, or saving graphics from our Website to your Pinterest account. The use of such plugins involves transferring information from cookies to the owners of these social networking sites:
- the service provider will receive information that your browser has displayed our Website, even if you are not logged in to that social network, or do not even have a profile there;
- if you logged in to one of the aforementioned social networking sites before visiting our Store, its owner will be able to directly associate the visit to our Website with your profile on that service.
- If you do not want social networking sites to associate the data collected during your visit to the Store with your social media service, log out of those services before visiting our Site. You can also completely prevent social plugins from loading on our Website by selecting the appropriate settings in the cookie consent management panel.
Legal issues regarding cookies
The legal basis for the Store's use of necessary cookies (indicated above in the section „What cookies do we use?”) is our legitimate interest, i.e., the right to run a Website supporting our business, and the need to maintain its security.
The legal basis for our use of other cookies is your consent.
In connection with our processing of your personal data using cookies, you have the rights at any time that we describe in the section Your rights in connection with data processing.
Our use of cookies, particularly for advertising purposes, may involve so-called profiling. This means that we or the marketing companies whose services we use may create a user profile based on collected information (e.g., e-mail address, order history, type of device, technology used, frequency of visits) and, on this basis, formulate purchasing forecasts for the future. This allows us to make decisions about what content (including advertisements) to display on our and other websites.
How long do cookies stay on the user's device?
It depends on whether they are „persistent” or „session” files. Session cookies, i.e., information necessary for browser functionalities to work correctly, expire after the user's session ends, i.e., each time you close our Site. Persistent cookies, which make using the site easier (e.g., they remember the selected resolution, content layout, user preferences, recently viewed products), will be stored by the browser for a longer period and will remain there until they expire, unless you delete them yourself using the settings in the browser menu.
Third-party cookies (i.e., analytical, advertising, and social media-related) are subject to their own privacy policies, to which we provide links in this policy.
2. Other purposes of processing personal data of Store users
What data do we process and for what purposes?
In addition to the cookies described above, we process the following of your data for the following purposes related to the functioning of the Store:
| Purpose of processing | Type of processed data | Legal basis for processing |
|---|---|---|
| Order fulfillment in the Store, management of customer accounts in the Store | Customer identification and contact data (e-mail address and other data necessary to fulfill the order). Details and order fulfillment history. |
Agreement concluded with you as a customer of the Store - Art. 6(1)(b) of the GDPR |
| Contact with you, handling inquiries | Identification data and other information you provide in the contact form or other correspondence. Correspondence history. |
Our legitimate interest in ensuring communication with persons who send us an inquiry / correspondence - Art. 6(1)(f) of the GDPR |
| Handling complaints and other after-sales service (e.g., in the event of withdrawal from the contract) | Customer identification and contact data. Details and history of order fulfillment. Correspondence history. | Our legitimate interest in handling complaints and implementing the contract withdrawal procedure - Art. 6(1)(f) of the GDPR |
| Collecting reviews and comments about products | Content of the review / comment. Identification data of the person submitting / publishing the review / comment. |
Your consent, expressed through the act of submitting and/or publishing a review and/or comment - Art. 6(1)(a) of the GDPR |
| Archive | All data listed in this table, received from customers and Store users for various purposes | Our legitimate interest in securing data for the purpose of establishing, defending, or pursuing claims and for the purpose of demonstrating compliance with obligations resulting from the GDPR - Art. 6(1)(f) of the GDPR |
| Accounting, tax purposes | Customer identification and contact data. Invoice details. |
Implementation of tax obligations resulting from legal provisions - Art. 6(1)(c) of the GDPR |
| Newsletter | E-mail address. Statistical data related to sent messages, including open rate history. |
Our legitimate interest resulting from the marketing consent granted by you - Art. 6(1)(f) of the GDPR |
| Analysis and statistics of sales in the Store | Statistics of sales in the store and user behavior (traffic) on the Website | Our legitimate interest in conducting business analyses to optimize our operations. In terms of traffic statistics on the Site – a legitimate interest resulting from your consent to cookies - Art. 6(1)(f) of the GDPR |
| Marketing purposes | Data on the history of browsing the Store's content, purchase history, demographic characteristics (age, gender, etc.) and other characteristics characterizing target groups (customer segments) | Our legitimate interest in marketing our own products and services, provided that marketing activities related to the use of cookies and/or marketing communication directed directly to you require your prior consent - Art. 6(1)(f) of the GDPR |
Providing the above data by you is not mandatory, but it is necessary to fulfill your order, issue an invoice, notify you of the order status, respond to your inquiry or complaint, etc.
How long do we process data?
We process your data related to placing an order in the Store for as long as it is necessary to complete the order, and also according to accounting and tax regulations.
In addition, we will process data for the time necessary to achieve the goals listed in the table above (and therefore until our legal interest allowing for processing ceases, or until you object to the processing, or until you withdraw your marketing consent – if you have granted us one). Further processing will be possible only if such a legal obligation is imposed on us as the administrator (in particular for tax purposes) and possibly for archival purposes to protect against potential claims (until such claims expire).
To whom do we transfer your data?
In our business, we use the services of other cooperating companies, therefore your data may be entrusted by us to: the company providing us with the software to run the Store, the accounting company, our Website hosting provider,
our email service providers, e-mail marketing system providers, and other companies whose marketing services and tools we use. Your data is also transferred to courier companies and, if applicable, payment intermediaries in order to fulfill your order, whereby these companies are separate personal data administrators.
We participate in a customer satisfaction / customer review survey program. If you consent to being included in such a survey, your data will be shared with the organizer of the customer satisfaction survey system. This entity is a separate administrator of your personal data.
For the purposes of the marketing activities described above in the "Cookies" section, we use services provided by entities based in the USA (Google, Facebook). Consequently, personal data may be transferred to third countries that are not members of the European Union. An appropriate level of protection for your data is ensured by the Data Privacy Framework program, about which you can read more at https://www.dataprivacyframework.gov.
Your rights in connection with data processing
We are committed to respecting the confidentiality of your personal data and guaranteeing that you can exercise your rights. You can exercise your rights without incurring any costs by sending us an e-mail or contacting us in another way.
Remember that in connection with the processing of your data, you have the right to:
- request access from Us to the data we hold regarding your person;
- rectify your data;
- delete your data if it is no longer needed for the purposes for which it was processed, or if we do not have another legal basis for processing it;
- withdraw consent to the processing of your personal data, if you have granted such consent;
- object to the processing of your data if we process it based on a legitimate interest;
- restrict data processing;
- file a complaint with the President of the Personal Data Protection Office if you believe that your data is being processed by us unlawfully.
Additional information for newsletter subscribers
If you have signed up for our newsletter, we will send you marketing information regarding our products and/or services, e.g., about new items in our offer, promotions, or special offers.
You can unsubscribe at any time by clicking the link found in every newsletter or simply by writing us a message.
A modern e-mail marketing system allows us to analyze the actions of recipients, i.e., it provides us with information whether a given message was opened by you. We analyze such information to better tailor the content of the newsletter and notifications to your interests and send you personalized messages (profiling). You can object to such processing of your data by us at any time. In the event of subscriber inactivity for 100 months, we may stop sending the newsletter. In such a case, we will remove you from our subscriber list (with additional prior notice).
Your data is not used by us to make decisions based on automated data processing that could affect your legal situation or produce other similarly significant effects for you.
Further legal information on the rules for sending the newsletter can be found in the Newsletter Regulations (part of our Store Regulations).
APPENDIX NO. 1 TO THE STORE'S PRIVACY POLICY Everybody London
- LIST OF ADVERTISING AND ANALYTICAL TOOLS USING COOKIES
- ANALYTICAL COOKIES:
- We use Google Analytics
- The information collected by Google Analytics about users includes, for example: how many times a user visits the site; which subpages they visit; the date of the first and last visit; duration of the visit; the page from which the user visited the site (referral source); the browser the user uses; the link that was clicked; the place in the world from which the user accesses it, anonymized (shortened) IP address, etc.
- Google assigns its own identifier (the so-called Google ID) to individual users and collects data obtained from cookies from various websites on its servers. We – as the owner of the Website – may receive reports (statistics) from Google related exclusively to traffic on our Website. These reports obviously only include persons who have consented on our Website to having their visits recorded by Google Analytics.
- Further detailed information on how Google Analytics works can be found at https://policies.google.com and https://support.google.com.
- You can also permanently prevent Google Analytics from recording information from your browser by installing a special plugin located at https://tools.google.com.
- We use the Hotjar tool
- This tool records data regarding user behavior on the Website, such as: how the user navigates the site, scrolling the page, cursor movement, approximate location, device used, operating system, browser type. The data obtained in this way is processed collective and anonymized manner – in order to improve the way our Website functions.
- More information about the operation of the Hotjar tool can be found at https://www.hotjar.com/privacy/.
- You can block the tracking of your activity by Hotjar using the link https://www.hotjar.com/policies/do-not-track/.
- We use Google Analytics
- Cookies of our Store software provider
- The software provider through which our Store operates - i.e. the owner of the shoper.pl platform - places cookies on our Website to collect collective information on how customers use online stores (subpages opened and time spent on them, products displayed, clicks on the Store's website, analytical information regarding purchases, e.g. conversion rates).
- This data is used to create collective reports for e-store owners containing general information (without personal data), including which products interest customers of a given store, in which period of the year there is increased traffic or sales in stores, etc. This allows sellers (including us) to improve their stores and optimize sales processes.
- Full information on this subject can be read in the Cookie policy for people visiting Shoper stores.
- ADVERTISING COOKIES
- We use Google Ads and other Google advertising tools
- Google collects data obtained from cookies placed on your device on its servers. This data is collected on all pages where you have allowed the use of cookies for advertising purposes by Google (including our Website), as well as from advertisements you have clicked on. Google uses this information to display advertisements on other pages you visit. Typically, cookies from Google expire after 3 months.
- As advertisers using Google services, we do not have access to data from cookies stored on your device, but we can commission advertisements to groups of recipients with characteristics selected by us, e.g. to all people who visited our website (or a specific subpage) within the last 7 days. This data constitutes only statistical material for us, and we commission advertisements only based on collective criteria (to specific target groups, not to a specific user).
- We may also use (within the Google Marketing Platform) tools to measure the effectiveness of advertising campaigns (e.g. how many people clicked on a given advertisement in a specific period).
- More about how Google uses cookies to display advertisements and how you can manage your advertising settings can be read at https://policies.google.com and https://support.google.com.
- Meta Conversion Pixel (Facebook and Instagram)
- We use the so-called Meta „conversion pixel” (remarketing pixel) to manage advertisements on Facebook and Instagram.
- If you consent to the use of this cookie on our Website, Meta Platforms services obtain information that you have visited our Website through this tool. This information is assigned to your profile on the given service, if you have one. If you are not a user of these services, the information is assigned to the so-called „Facebook ID” created for you.
- This allows us to commission advertisements on Facebook and Instagram to those people who have already visited our Website or its individual subpages (remarketing). We then receive only statistical data from Meta Platforms regarding the effectiveness of advertisements (e.g. how many people saw our ad, how many people clicked on it), without reference to specific users.
- If you have an account on Facebook or Instagram, we encourage you to read further information on data protection on these services at https://www.facebook.com/privacy/policy/?entry_point%3Ddata_policy_redirect%26entry%3D0&sa=D and https://help.instagram.com/155833707900388.
- More about the Meta remarketing pixel itself can be read at https://www.facebook.com/business/help/742478679120153?id=1205376682832142.
- Marketing automation tools
- We use a tool for so-called marketing automation, which allows us to collect information on how Store customers use it, as well as combine data from our sales records with other data we have about a specific customer.
- This allows us to tailor the content of our advertising messages directed to a specific person (e-mail/SMS marketing) and targeted advertising campaigns (advertising target groups) to the preferences and/or history of a given user. The tool also allows us to adapt the content of our Website (e.g. banners, displayed messages, or products suggested for purchase) to the information we have about the customer.
- E-mail marketing
- For newsletter purposes, we use a tool provided to us by an external company.
- The e-mail marketing system embeds cookies on our Website to display subscription forms and to measure the effectiveness of these forms (conversion rate).
- We use Google Ads and other Google advertising tools