Privacy Policy

TYPE OF DATA

PURPOSES OF PROCESSING

LAWFUL BASIS UNDER THE GDPR

Website Visitors

Contact Communications:

Where you contact us with any inquiries, either through any means of communications we make available (e.g., an online form available on the Website, email correspondence or by phone), you will be requested to provide us with your contact information such as your name, email address telephone number, and any other information you choose to share with us through your correspondence or other communications with us (collectively “Contact Information”).

We will use your Contact Communications data for the purpose of responding to your inquiries and provide you with the support or information you have requested.

Our correspondence with you, and its content, may be further processed and stored by us in order to improve our customer services as well as in the event we reasonably determine it is needed in order to comply with any regulatory requirement, or for handling and defending against any dispute you might have with us.

Your Contact Communications will be processed subject to our legitimate interest.              

Online Identifiers & Website Interaction:

When you access our Website or otherwise interact with its content and features (including if you are our Customer and you access and interact with your account) we collect certain online identifiers, such as internet protocol address (IP), Cookie ID and other unique identifiers (“Online Identifiers”).

Further, we will collect information related to your use and interaction with our Website. This information may include, for example, the referring URL (that is, the webpage directing you to our Website, and other websites you visited in the session), how you interact with our Webpages and content, access time and date, duration of use, pages you have viewed on our Website, clickstream, etc. (“Usage Information”).

We process Online Identifiers and Usage Information through our or third-party cookies and tracking technologies for analytic, marketing and advertising purposes.

For example, we process this data to understand how Visitors use our Website and to measure effectiveness of our content and advertising campaigns in order to improve our marketing efforts as well as to serve cross-websites ads to Visitors. 

In addition, Usage Data related to our Site and Platform helps us to better understand our business, analyze our operations, maintain, improve, design, and develop the Service, conduct statistical analysis, etc.

In addition, we process such data for our Websites operation and functionality, security and fraud prevention purposes, debugging purposes and to resolve technical problems.

Note that, we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any information such as your name or email address.

Where we collect Online Identifiers or Usage Data for operation and security purposes, we process your data based on our legitimate interest.

Where we collect Online Identifies or Usage Data for analytic and advertising purposes, we process such data based on your consent which we will obtain through our cookie notice and consent management tool.

You may withdraw consent at any time by using the cookie settings tool made available on our Website or by managing opt-out through your browser or device.

Newsletter Registration:

If you register to receive our newsletter, updates, and other marketing materials, you will be requested to provide us your email address and your country.

We use this data in order to send you the content you have signed-up to receive.

We will further store this data in order to include you, and maintain, our marketing and mailing lists, as well as the "opt-out" list (solely the necessary information for such purpose), to ensure we respect your choice and comply with applicable laws in this regard.

We process this data based on your consent. You may withdraw your consent at any time by using the “unsubscribe” link within the emails you will receive from us.

In addition, we will further maintain a suppression file – meaning lists of applicable emails that have requested to opt-out, under our legitimate interest and to ensure we comply with such preference and choice.

Customers

Registration Information:

When placing an order, you may decide to create an account (“Account”). During the registration process you will be requested to provide us with certain information such as your full name, and email address. If you choose to sign in through your social accounts (e.g., Google, Apple or Facebook account), we will be provided with your email address related to such account as well as information you have made public (such as profile picture, etc.). 

Additionally, during the registration process you will be required to create a password. This information will be processed when you login as well.

(collectively “Account Registration Data”). 

We use Account Registration Data to create and designate your Account, authentication and validate access, enable log-in, access and use of your Account as well as to send you needed information related to our engagement (e.g., send you a welcome message, notify you regarding any updates to your orders, send applicable invoices, etc.).In addition, we use this information for direct marketing purposes, meaning, as our Customer we may send you marketing related communications, materials and content regarding our Product or any other products we may offer in the future, to keep you up to date.

We process your Account Registration Data for the purpose of performing our contract with you.

Processing of this Account Registration Data for direct marketing purposes is made subject to our legitimate interest. You can opt-out at any time using the “unsubscribe” link within the emails you will receive from us.

Please note that if you choose to unsubscribe from our direct marketing, we will still send you service-related emails, such as invoices.

Order Placement:

If you place an order, as part of the checkout process, you will be requested to provide us with certain information such as your full name, email address, telephone number, as well as billing and shipping address, (“Order Placement Data”).

Note that, you will further be required to provide your payment method details, however, as your payment is being processed by our third-party payment processor, we will not store not have access to your full payment information, rather, where applicable, solely the 4 last digits of your payment method and expiry date which we must obtain for record keeping purposes. Consequently, payment information shall be governed by the third party payment processors  privacy practices.

Your Order Placement Data will be collected and used by us in order to process and deliver your order, including to provide you services related notice (such as send you order confirmation, invoices, shipment status, etc.).

We will further store your Order Placement Data in order to maintain bookkeeping records and to comply with any regulatory requirement (e.g., tax related).

We process your Order Placement Data for the purpose of performing our contract with you.

Following the completion order delivery, we nay further retain and store the data as part of our internal record keeping, including for legal defense from any future claim, as well as, subject to applicable law requirements, subject to our legitimate interests.

Shopping History:

We will retain records of the Products’ orders you have made from us (“Shopping History”)

You Shopping History is retained and used in order to process returns, handle any inquiry you may have, as well as to maintain bookkeeping records.

In addition, we may use this information in order to analyze Customers’ preferences, enhance and personalize your shopping experience (including, for example, to offer additional products) and improve our Services, and marketing efforts.

Where we use your Shopping History in order to comply with your order-related inquiries, we process it in order to perform our contract with you.

Where we process your Shopping History for other purposes, we process it based on our legitimate interest.

Account and Orders Placement - Usage Data:

When you go through the orders’ placement process (as a registered Customer or a guest check-out process), including where you add Products to your cart or wish list, information regarding such use and interactions is automatically gathered and collected, which may include the click stream, specific Product added to your cart, analytics data, crash data etc. (“Orders Process Usage Data”). If you are not a registered Customer or otherwise provided your email through the order placement process, this information will be associated with Online Identifiers collected from your device (as explained above).

We Orders Process Usage Data to help us to understand how Customers interact with the orders submission flow, their preferences, and how to better provide and improve our Services. We may further use it to personalize your experience, for example, where you are a registered Customer or otherwise provided your email address through the order placement process, we may send you an email to remined you have not completed your order of Products you have added to your cart.

In addition, we process Orders Process Usage Data for security, operation and debugging purposes, and for example, to resolve technical errors. 

Where we collect Orders Process Usage Data for operation and security purposes, we process your data based on our legitimate interest.

Where we collect Orders Process Usage Data for analytic and marketing purposes, we process such data based on your consent which we will obtain through our cookie notice and consent management tool.

You may withdraw consent at any time by using the cookie settings tool made available on our Website or by managing opt-out through your browser or device.

Customers Support:

Where you contact our customer support team regarding your order or the placement of an order (i.e., returns and refunds, order tracking, etc.), you will be requested to provide us with your email address and any additional information required in order to allow us to handle your inquiry (“CustomerSupport Communications”).

Customer Support Communications will be used for the purpose of responding and handling your inquiries.

In addition, our correspondence with you, and its content, may be processed and stored by us in order to improve our customer services and in order to comply with any regulatory request or for the defense of any future claim.

We process Customer Support Communications based on our legitimate interest.

User Reviews

If you choose to submit your reviews to us, you may be requested, through the submission process, to provide your name (or nickname), as well as additional information such as your experience regarding use of our Products, etc.  (“Reviews”).

If we will decide to publish your Reviews, it may be posted under the name or nickname you have provided us (including where the submission was made through your Account).

We will use your Reviews in order to publish them on our Websites or additional media channels, for marketing purposes, and in order to improve our Services and the way we offer them.

Note that, we recommend you to not disclose additional Personal Data through your review, as such content might be publicly posted and we cannot control any third party's use of such information.

We process your Reviews subject to our legitimate interest.

CATEGORY OF RECIPIENT

TYPE OF PERSONAL DATA SHARED

PURPOSE OF SHARING

Service providers

All types of Personal Data

We employ other companies and individuals to perform functions on our behalf. This might include: sending communications, processing payments, analyzing data, providing marketing and sales assistance (including advertising and event management), identifying errors and crashes, conducting customer relationship management, delivery, shipments, etc. These third-party service providers have access to Personal Data needed to perform their functions, but they are prohibited from using your Personal Data for any purposes other than providing us with requested services.

Any acquirer of our business

All types of Personal Data

We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Affiliated companies

All types of Personal Data

We may share Personal Data with our affiliated companies in accordance with the terms of this Policy and for the purpose of providing the Services.

Enforcement of our rights and security detections. 

All types of Personal Data

We may disclose Personal Data to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Data to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.

Legal and law enforcement 

Subject to law enforcement authority request.

We may share certain data when we believe it is appropriate to do so in order to comply with the law enforcement, governmental agencies or authorized third parties, or protect the rights, property, or security of Virility, our Customers or others.