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Privacy

Privacy policy

This document will explain how our organisation uses personal data in compliance with the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).

Under the GDPR “personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Hereinafter all personal information is referred to as “personal data”.

This Privacy Policy applies to all personal data you provide to us and also to all personal data which we collect about you, either about how you use our website (using "cookies") or about your purchasing patterns if you make an order with us. 

  1. Who we are?

Nanushka International Zrt. (registered at Rákóczi street 42. III. floor, Budapest, 1072. Hungary; company registration number: 01-10-049880) acts as a data controller. It means Nanusha International Zrt. decides how the personal data provided to us is processed and for what purposes.

In certain cases, the following companies affiliated with Nanushka International Zrt might also act as data processor:

  • Nanushka Limited, registered at Wisteria Grange Barn, Pikes End, Pinner, HA5 2EX; company registration number: 11127556
  • Nanushka US Inc, registered at 2000 Avenue of the Stars, suite 400 North Tower, Los Angeles, CA 90067; company registration number: 6754695
  1. How to contact us?

In respect of data protection related questions, to exercise your rights or file a complaint, contact us at customercare@nanushka.com or you can reach out to our acting data officer Peter Baldaszti at pb@nanushka.com. 

  1. How do we collect personal data?

We collect personal data from you when you register on our website, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features.

  1. Why do we collect personal data? (data processing purposes)

We collect and use your personal data for the following purposes:

  1. To process and fulfil your order. For this purpose we collect the following data: name, address, email address, phone number, billing address (When different from shipping address) 
  2. To communicate with you in case of any issues with the order fulfilment and to facilitate your engagement with our customer service team. For this purpose we collect the following data: name, email address, order details
  3. To send periodic emails to update you about the status of your order or other products and services. For this purpose we collect the following data: name, email address, order details
  4. To create your Nanushka account. For this purpose we collect the following data: name, email address, date of birth, country of residence
  5. To send you reminders on unfinished orders. For this purpose we collect the following data: name, email address, list of products left in your cart
  6. To send you newsletters and offers tailored to your interests and needs. For this purpose we collect the following data: name, email address, date of birth, country of residence, details of your  historical website behavior and purchase history
  7. To provide offers tailored to your preferences and improve our website to better serve your needs. For this purpose, we collect the following data: details of your historical searches and historical order details
  8. To tailor advertising to make our offers more relevant. For this purpose we collect the following data: email address, details of your historical searches and historical order details

  1. Where and for how long do we keep your personal data?

Your personal data is contained behind secured networks and is only accessible by a limited number of people who have special access rights to such systems, and are required to keep the personal data confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. All transactions are processed through a gateway provider and are not stored or processed on our servers.

We process your personal data for the time required consistent with the purposes set out in this Privacy Policy or for the period specified by the relevant regulations.

In the case of consent-based data processing (like email subscription), personal data will be processed until the consent is withdrawn.

  1. Legal basis of data processing

The legal basis of data processing activities indicated in point a)-e) of Section 4 of this document lies in Subsection (a) Paragraph (1) of Article 5 of Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (hereinafter the “Freedom of information Act”), i.e. based on your consent, and commencing from 25 May 2018 also Article 6 (1) (b) of the General Data Protection Regulation (Regulation No. 2016/679 of the European Parliament and of the Council) ("GDPR"), i.e. such processing activities are necessary for the performance of the contract or in order to take steps at the request of data, subject to entering into a contract.

The legal basis of data processing activities indicated in point f)-h) of Section 4 of this document lies in Subsection (a) Paragraph (1) of Article 5 and Subsection (a) Paragraph (2) of Article 5 of the Freedom of information Act, i.e. based on your consent, and commencing from 25 May 2018 also Article 6 (1) (a) and Article 9 (2) (a) of the GDPR, i.e. such processing activities will be based on your consent.

  1. Further processing of personal data

If we wish to use your personal data for a new purpose, not covered by this document, we will provide you with a new Privacy Policy, explaining all detail to the new processing. If required, we will seek your consent before commencing the new data processing activity

  1. What rights do you have for managing your personal data in line with the GDPR?
  1. Right to information - how to handle your personal information and what are your rights in this regard.
  2. Right of access - regarding that your personal data is being processed is there, and if so, it is entitled to us by us you have access to your personal data. This will allow you to verify your personal data privacy legislation.
  3. Right to rectify - you are entitled to request the correction or addition of inaccurate or incomplete personal information.
  4. Right to cancel - also known as "right to be forgotten" ensures that you can request the deletion of your personal data if they are not necessarily handled or otherwise.
  5. Right to restrict data management - you are entitled to restrict the continued handling of your personal information, in this case we will not treat your data except for storage.
  6. Right to data storage - you are eligible for certain personal information we manage to request a copy and submit them to another data handler forward.
  7. Right to protest - you are entitled to object to certain data manipulations (eg. direct marketing).
  8. Automated decision-making and profiling rights - you are entitled to request that we do not have legal or other significant consequences for you to decide on your own decision-making based solely on automated processing (including profiling).

  1. How do we protect your personal data?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal data.

All transactions are processed through a gateway provider and are not stored or processed on our servers.

  1. Sharing your personal data

Nanushka, in the course of its operation may utilise the services of various data processors and external service providers to handle and process your personal data for specific purposes, on behalf of and in accordance with the instructions of Nanushka.

The data processors shall process the personal data at most as long as the term of the data processing contract concluded with them is valid and in force, or until they are required to keep your data under the applicable data retention laws.

We may disclose your personal data to the following categories of third parties for the purposes described below:

  1. Shipping service providers to deliver the product you purchased on our website
  2. Credit card companies, payment service providers to process the payments you initiated on our website
  3. Email service provider platform, in order to facilitate communication with you after purchase and to send you newsletter based on your consent
  4. IT supporting services
  5. Other third party service providers involved by us for data processing

    Cookies In Use on This Site

    Cookies and how they benefit you

    Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites. We store the datas collected by the cookies in our e-commerce site, in our MailChimp database and in our external data warehouse for no longer than 5 years.

     

    Our cookies help us:

    • Make our website work as you'd expect and provide brilliant experiences
    • Remember your settings during and between visits
    • Improve the speed/security of the site
    • Continuously improve our website for you
    • Make our marketing more efficient

    We do not use cookies to:

    • Collect any personally identifiable information (without your express permission)
    • Collect any sensitive information
    • Pass personally identifiable data to third parties

    You can learn more about all the cookies we use below

    Granting us permission to use cookies

    If your device and software (the browser) is set to allow accepting cookies we take this, and your continued use of our website, to mean that you are fine with this. Should you wish to remove or not use cookies from our site you can learn how to do this below, however doing so will likely mean that our site will not work as you would expect.

    More about our Cookies

    Website Function Cookies

    Our own cookies

    We use cookies to make our website work including:

    • Making our shopping basket and checkout work
    • Remembering your settings
    • Remembering if you have accepted our terms and conditions
    • Showing you which pages you have recently visited

    There is no way to prevent these cookies being set other than to not use our site.

    Third party functions

    Our site, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube or Vimeo video. Our site includes the cookies listed below following.

    Disabling these cookies will likely break the functions offered by these third parties therefore we recommend you allowing these.

    Visitor Statistics Cookies

    We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using (e.g. Mac or Windows which helps to identify when our site isn't working as it should for particular technologies), how long they spend on the site, what page they look at etc. This helps us to continuously improve our website. These so called “analytics” programs also tell us if how people reached this site (e.g. from a search engine).

    Advertising Cookies

    Cookies are widely used in online advertising. Neither us, advertisers or our advertising partners can gain personally identifiable information from these cookies.

     

    You can learn more about online advertising at http://www.youronlinechoices.com.You can opt-out of almost all advertising cookies at http://www.youronlinechoices.com/uk/your-ad-choices. It is also worth noting that opting out of advertising cookies will not mean you won't see adverts, just simply that they won't be tailored to you any longer.

     

    Remarketing Cookies

    You may notice that sometimes after visiting a site you see increased numbers of adverts from the site you visited. This is because advertisers, including ourselves pay for these adverts. The technology to do this is made possible by cookies and as such we may place a so called “remarketing cookie” during your visit. We use these adverts to offer special offers etc to encourage you to come back to our site. We are unable to proactively reach out to you as the whole process is entirely anonymised. You can opt out of these cookies at anytime as explained below.

    Affiliate Cookies

    We have a number of partners who promote our service on a success-only basis (i.e. instead of paying for advertising, we pay them commissions on sales). Cookies are required to allow us to reward these partners and these cookies are usually provided by specialist companies (known as affiliate networks). Neither us, the networks, or the partner advertising or recommending our services are able to identify you personally. We ask you to support us by allowing these cookies which ultimately help us to offer you the service we do at the price we do. Our affiliate cookies are provided by: CJ Affiliate Network.

    Turning Cookies Off

    At any time, you have the option to accept or decline the use of cookies by changing your browser settings. On most browsers, the “Help” portion of the toolbar will tell you how to prevent it from accepting cookies, how to have it notify you when you receive cookies or how to disable cookies altogether. Below are pages describing these settings in more detail for each browser:

    Chrome
    Firefox
    Internet Explorer
    Safari
    Opera

    Be aware that disabling cookies will affect the functionality of this website and the experience you’ll have. Disabling cookies will result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.


     

     

    Cookies we use: (Table)

     

     

    Name

    Domain

    Description

    HTTP

    Expiration

    Category

    _shopify_sa_t

    .nanushka.com

    Shopify analytics relating to marketing & referrals.

     

    0 days

    Advertising Cookies

    _shopify_sa_p

    .nanushka.com

    Shopify analytics relating to marketing & referrals.

     

    0 days

    _fbp

    .nanushka.com

    Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.

     

    90 days

    fr

    .facebook.com

    Encrypted Facebook ID and Browser ID

     

    90 days

    MUID

    .bing.com

    Used as a unique user Microsoft identifier.

     

     

    uuid2

    .adnxs.com

    This cookie allows targeted advertising through the AppNexus platform - collects anonymous data on ad views IP address, page views, and more.

     

     

    cto_lwid

    .nanushka.com

    Criteo - Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that the visitor is shown the same advertisement. - Criteo

     

    1 year

    Remarketing Cookies

    criteo_write_test

    .nanushka.com

    Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers.

    TRUE

    1 day

    cto_tld_test

    .nanushka.com

    Used to identify the visitor across visits and devices. This allows the website to present the visitor with relevant advertisement - The service is provided by third party advertisement hubs, which facilitate real-time bidding for advertisers.

    TRUE

    1 day

    IDE

    .doubleclick.net

    This cookie is used for re-targeting, optimisation, reporting and attribution of online adverts.

     

    90 days

    uid

    .criteo.com

    Collects anonymous data related to the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads.

    TRUE

    1 year

    __zlcmid

    .nanushka.com

    Enables live customer service chat via Zendesk

     

    1 year

    Third party functions

    AWSALB

    de20.zopim.com

    The AWSALB cookie allows them to deliver their service seamlessly from multiple services using a load balancer, so the cookie simply records which server cluster is serving you.

     

     

    personalization_id

    .twitter.com

    This domain is owned by Twitter. The main business activity is: Social Networking Services. Where Twitter acts as a third party host, it collects data through a range of plug-ins and integrations, that is primarily used for tracking and targeting.

     

    2 years

    vuid

    .vimeo.com

    We use Vimeo to embed videos onto our website. These cookies are used by Vimeo to collect analytics tracking information.

    TRUE

    Session

    session-set

    .nanushka.com

    Pending

     

    20 years

    Unspecified

    amazon-pay-abtesting-new-widgets

    .nanushka.com

    Pending

     

    Session

    vs.bid

    .nanushka.com

    Pending

     

    2 years

    session-id

    .amazon.com

    Pending

     

     

    session-id-time

    .amazon.com

    Pending

     

     

    session-token

    .amazon.com

    Pending

     

     

    ubid-main

    .amazon.com

    Pending

     

     

    _gat

    .nanushka.com

    Google Analytics cookies to track users as they navigate the website and help improve the website's usability.

     

    0 days

    Visitor Statistics Cookies

    _gid

    .nanushka.com

    Registers a unique ID that is used to generate statistical data on how the visitor uses the website.

     

    1 day

    _ga

    .nanushka.com

    Registers a unique ID that is used to generate statistical data on how the visitor uses the website.

     

    2 years

    tracked_start_checkout

    .nanushka.com

    Shopify analytics relating to checkout.

    TRUE

    1 year

    _landing_page

    .nanushka.com

    Tracks landing pages.

    TRUE

    14 days

    _shopify_sa_p

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

     

    0 days

    Website Function Cookies

    cookieconsent_dismissed

    .nanushka.com

    Memorizeing the choice of your response at the cookie law popup challange.

     

    1 year

    cart_ts

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

    TRUE

    14 days

    _shopify_fs

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

     

    2 years

    _shopify_ga

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

     

    Session

    _y

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

     

    2 years

    _shopify_y

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

     

    2 years

    _shopify_s

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

     

    0 days

    _s

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

     

    0 days

    cart_sig

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

    TRUE

    14 days

    cart_currency

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

     

    14 days

    checkout

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

    TRUE

    21 days

    checkout_token

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

    TRUE

    1 year

    remember_me

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

    TRUE

    1 year

    _orig_referrer

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

    TRUE

    14 days

    _shopify_country

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

     

    Session

    cart_sig

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

    TRUE

    14 days

    secure_customer_sig

    .nanushka.com

    Used in connection with customer login.

    TRUE

    20 years

    _secure_session_id

    .nanushka.com

    Used in connection with navigation through a storefront.

    TRUE

    1 day

    cart

    .nanushka.com

    Used in connection with shopping cart.

     

    14 days

    fsb_previous_pathname

    .nanushka.com

    Nanushka uses the Shopify Ecommerce Platform. Our system creates these session ids. They are used to aid the functionality of the website, and aid personalisation. Click here for an overview of privacy at Shopify.

     

    Session

    zte2095

    .nanushka.com

    This cookie is generally set to enhance the performance and functionality of the website.

     

    Session

    Opting out:

    Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

    California Online Privacy Protection Act

    CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. - See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

    According to CalOPPA, we agree to the following:

    Users can visit our site anonymously.

    Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

    Our Privacy Policy link includes the word 'Privacy' and can easily be found on the page specified above.

    • On our Privacy Policy Page

    Can change your personal information:

    • By emailing us

    How does our site handle Do Not Track signals?

    We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

    Does our site allow third-party behavioral tracking?

    It's also important to note that we allow third-party behavioral tracking

    COPPA (Children Online Privacy Protection Act

    When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

    We do not specifically market to children under the age of 13 years old.

    Fair Information Practices

    The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

    In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

    We will notify you via email

    • Within 7 business days

    We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

    CAN SPAM Act

    The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

    We collect your email address in order to:

    • Send information, respond to inquiries, and/or other requests or questions

    To be in accordance with CANSPAM, we agree to the following:

    • Not use false or misleading subjects or email addresses.ó

    If at any time you would like to unsubscribe from receiving future emails, you can email us at hello@nanushka.com and we will promptly remove you from ALL correspondence.

    Contacting Us

    If there are any questions regarding this privacy policy, you may contact us using the information below.

    www.nanushka.com

    Nanushka Studio
    1 Vörösmarty tér
    Budapest 1051, Hungary
    +36 70 418 4162

    You may request information, data correction, deletion, blocking, refusal of data protection, refusal of data protection, refusal of access to personal data, violation of your rights, claim for damages and damages or complain to the data protection authority at Hungarian National Privacy Authority (Registration number: NAIH-142470/2018).

    22/c Szilágyi Erzsébet fasor
    Budapest 1122, Hungary
    +36 1 391 1400
    www.naih.hu

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