PRIVACY POLICY
1. INTRODUCTION
1.1. At Sleex (“Sleex Limited” or “us” or “we” or “our”), we respect the privacy rights of our online visitors and recognise the importance of protecting the information we collect about you. This Privacy Policy is designed to help you understand how we collect, hold, use and disclose personally identifiable information about you.
1.2. This Policy (together with the website’s (“Site”) Terms and Conditions https://www.en.sleex.com/pages/terms-conditions, and any other documents referred to in it) sets out the basis on which we Sleex Limited, company number 05667175 with a registered address of 78 York Street, London, England, W1H 1DP and email address contact@sleex.com will process any personal data we collect from you, or which you provide to us, in the course of using the Site (en.sleex.com).
1.3. For the purpose of the General Data Protection Regulations (“GDPR”), the German Data Protection Act, Bundesdatenschutzgesetz (“BDSG”) and the UK Data Protection Act 2018 (“DPA’18”) we are the data controller.
1.4. We encourage you to read the privacy statements of each and every website that collects personally identifiable information about you. The privacy information in this Privacy Policy applies solely to the Site and the information we collect about you.
2. YOUR INFORMATION
2.1. When you use our Site, there are a number of ways in which you provide information and other data to us. By using the Site, you acknowledge that we will be collecting and processing this personal data, on the terms and for the reasons which are explained below.
2.2. The personal data of users is processed under BDSG and DPA’18 on the lawful basis of legitimate business interest in order to provide products and services to our customers.
2.3. The provision of personal data is necessary to facilitate the provision of the service.
3. INFORMATION WE MAY COLLECT ABOUT YOU
3.1. The following personal data may be collected from you as a user when you use the Site:
- Your full name, address, email address, telephone number or any other information you provide when signing up for an account on the Site, purchasing a product or using our contact form.
- Your IP addresses.
- Your Internet Service Provider (“ISP”).
- Any referring or exit pages taking you to or from our Site.
- Your login information i.e. username and password.
- Your web browser type and version.
- Your time zone and location.
- Date/time stamp.
- Click stream data.
- Any browser plug-ins and version used on your browser.
- Your operating system.
- Information we collect when you interact with our content on the Site or on third-party sites or platforms, such as social networking sites. This may include information such as “Likes”, profile information gathered from social networking sites or interacted with our content.
- To enhance your user experience or help improve and measure our effectiveness, Sleex may receive data from third party sites. Examples of such parties may include Facebook, Twitter, Google, and others. These third parties may collect information about including IP addresses through cookies or other similar technologies in ways Sleex does not control.
4. HOW YOUR INFORMATION IS BEING USED
4.1. We may use your data in the following ways:
- To process any order made through the Site, including sending a digital receipt.
- To update you on the delivery of any order made through the Site.
- To send you our newsletter from time to time.
- To provide you with information, products or services that you request from us or that feel may interest you, where you have consented to be contacted for such purposes.
- To diagnose or fix technology issues.
- To control unauthorised use or abuse of the Site and our products and services, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
- To deliver support and respond to your enquires.
- To administer the Site including data analysis, testing, traffic monitoring, research, statistical and survey purposes.
4.2. If you do not wish to be contacted for marketing purposes please tick any relevant box on which you submit your data or unsubscribe from any marketing communication using the unsubscribe function in the footer of the email. You can also contact us directly by emailing contact@sleex.com.
4.3. Please note that if you click on, or follow, any links from the Site to external websites, our Privacy Policy will no longer apply. Please check the privacy policies of any such external website before submitting any personal data, as we cannot accept any responsibility or liability in relation to them.
5. HOW YOUR DATA MAY BE DISCLOSED
5.1. In order to provide our services, we may transfer your personally identifiable information to third parties, parents, affiliates, subsidiaries and service providers, some of which may process or store your personally identifiable information outside of the UK and the European Economic Area (“EEA”). However, in such instance we will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
5.2. By using the Site or otherwise providing personally identifiable information to us, you are consenting to have your personally identifiable information transferred to and processed in the UK or any other country in which the data controller and its parents, subsidiaries, affiliates and service providers main facilities.
5.3. Third parties in which your personally identifiable information may be disclosed to include, but are not limited to:
- Sendcloud is an e-commerce shipping platform and their privacy policy can be viewed at: https://www.sendcloud.com/privacy-policy/
- DPD provides a shipping and delivery service and their privacy policy can be viewed at: https://www.dpd.co.uk/privacy_policy.jsp
- UPS provides a shipping and delivery service and their privacy policy can be viewed at: https://www.ups.com/de/en/support/shipping-support/legal-terms-conditions/privacy-notice.page
- Back in stock helps us confirm when products are available for sale and their privacy policy can be viewed at: https://backinstock.org/privacy/
- PayPal helps to process our payments and their privacy policy can be viewed at: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full
- Mollie provides payment processing services and their privacy policy can be viewed at: https://www.mollie.com/en/privacy
6. DATA STORAGE
6.1. All information you provide to us via www.sleex.com will be stored on our secure servers based in Germany, encrypted using SSL 256 – bit encryption. Germany, as part of the EEA, benefits from an adequacy decision by the UK Information Commissioners Office (“ICO”) and the European Commission for the storage and processing of personal data under GDPR and DPA’18.
6.2. Our subdomains (www.en.sleex.com, www.de.sleex.com and www.fr.sleex.com) are hosted on secure US based servers with the necessary Standard Contractual Clauses (“SCCs”) in place.
6.3. We take your privacy seriously, and will take all reasonable steps to protect your personal data, but please be aware that any data which you send to the Site is sent at your own risk.
6.4. The data that we will collect from you may be transferred to, processed and/or stored at a destination outside of the UK and EEA. By submitting your personal data, you agree to this. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
6.5. We hold personally identifiable information in a combination of hard copy and electronic files for the period necessary to support the Site, comply with our legal obligations, resolve disputes, or otherwise fulfil the purposes outline in this Privacy Policy. We use third party information system providers who may store or have access to your personal information. We may also retain backup information on our servers for some time to comply with applicable law or our internal security policies. We do not always remove or delete all of your information for a number of reasons including due to technical and systems constraints, contractual or legal requirements.
6.6. We operate a data retention period of 10 years from the date of our last interaction with a user in order to comply with German Law. 10 years after the date of our last interaction with a user all of the data provided by the user during all of their interactions with us will be reviewed and securely deleted/destroyed.
6.7. We ask you not to send us, and you not to disclose, any sensitive personally identifiable information (such as information related to racial or ethnic origin, religion or other beliefs, health, criminal background or trade union membership) on or through the Site or otherwise. If, contrary to this request, you do provide any sensitive information, in doing so you consent to us collecting and handling that information in accordance with this Privacy Policy.
6.8. No method of transmission over the internet, method of electronic storage or other security methods are one hundred percent secure. Therefore, while we strive to use commercially acceptable means such as firewalls, password protected databases with limited physical and electronic access, and encryption to protect your personally identifiable information against unauthorised use, disclosure or modification, we cannot guarantee its absolute security.
7. CHILDREN UNDER 16
7.1. This Site is not intended for the use by anyone under the age of 16 nor does Sleex knowingly collect or solicit personally identifiable information from anyone under the age of 16. If you are under the age of 16, you may not attempt to send any information about yourself to us, including your name, address, telephone number, or email address.
7.2. In the event that we confirm that we have collected personally identifiable information from someone under the age of 16 without verification of parental consent, we will delete/destroy that information promptly. If you are a parent or legal guardian of a child under the age of 16 and believe that we might have any information from or about such child, please contact us at the email or mailing address provided at the end of this Privacy Policy.
8. THIRD PARTY SITES
8.1. The Site may also contain links to other third-party websites including social media networks. This Privacy Policy applies solely to information collected by us at Sleex. Even if the third party is affiliated with us through a business partnership or otherwise, we are not responsible for the privacy practices of other websites. We encourage you to familiarise yourself with the privacy policies of such websites to determine how they handle any information they separately collect from you. Please be aware that we do not warn you when you have chosen to click through to another website or property when using the Site.
9. ACCESS TO INFORMATION
9.1. Subject access request - You have the right under the BDSG and DPA’18 to access the information we hold about you. If you wish to exercise this right, please send your request to contact@sleex.com.
9.2. Right to erasure - You have the right under the BDSG and DPA’18 to have all of the information that we hold about you deleted in line with our statutory and legal responsibilities. If you wish to exercise this right, please send your request to contact@sleex.com.
9.3. Right to data portability - You have the right under the BDSG and DPA’18 to request a copy of all of the information we hold about you if the processing is based on consent, contract or the processing is being carried out by automated means. If you wish to exercise this right, please send your request to contact@sleex.com.
9.4. Right to data rectification - You have the right under the BDSG and DPA’18 to request the amendment or updating of all of the information that we hold about you. If you wish to exercise this right, please send your request to contact@sleex.com.
9.5. Right to restriction of processing – In line with Article 18 (1) (a) to (d) of GDPR, you have the right under DPA’18 to obtain from the controller restriction of processing. If you wish to exercise this right, please send your request to contact@sleex.com.
10. ENFORCEMENT
10.1. Sleex regularly reviews its compliance with relevant data protection law and this Privacy Policy. We cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding that transfer of personally identifiable information that cannot be resolved between Sleex and the individual.
11. NOTICES AND PROVISIONS
11.1. We reserve the right to change our Privacy Policy at any time. These changes will take immediate effect unless you are notified otherwise. We recommend that you refer to this Privacy Policy on an ongoing basis so that you understand our current practice at the time of using our service. Unless stated otherwise in a separate agreement, this Privacy Policy applies to all information we hold about you.
12. CONTACT US
12.1. If you have any questions or want to get in contact with us regarding this Privacy Policy, please feel free to email us at contact@sleex.com.
12.2. Should you not be satisfied with the process, conduct or response to a request you may have made you have the right to complaint to the ICO (https://ico.org.uk/make-a-complaint/) or The Federal Commissioner for Data Protection and Freedom of Information (“BfDI”) (https://www.bfdi.bund.de/EN/Service/Kontakt/contact_node.html).