PRIVACY POLICY

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site or sites owned by Thrizen Agency (or service providers we use), including any information you may provide through our site when purchasing a product or service.

When providing us with your data, you must be the over the age of 13.

If you are not with any way your data is taken or handled, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate it if you lay your complaints with us first so we can find a way to resolve it.

It is also very important that information given to us by you is up to date. Please let us know at any point in time when your information has changed at bubutshally@gmail.com

2. WHAT DATA DO WE COLLECT ABOUT YOU

Firstly, Personal data is data used to identify any individual. It does include any anonymized data.

We may process certain types of personal data which are as follows:

  • Identity Data such as First name, Maiden name, Last name, username, marital status, age, title, date of birth and gender.
  • Contact Data such as billing address, delivery address, zip code, email address and telephone number.
  • Financial details which include your bank account, card number and security code.
  • Transaction data which may include the history of payments which you have had with us, payments made between us and other details of purchases made by you.
  • Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone and versions, operating system and platform and other technology on the devices you use to access this site.
  • Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
  • Usage Data may include information about how you use our website, products and services.
  • Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

Note: We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and generic and biometric data.  We do not collect any information about criminal convictions and offences.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

  • Order any of our products or services;
  • Create an account on our site;
  • Subscribe to our service or publications;
  • Request resources or service to be sent to you;
  • Enter a survey, promotion or anything that relates to these;
  • Give us feedback.

Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources: We may receive personal data about you from numerous third parties and publicly available sources stated below:

Technical Data from the named parties below:

  • Analytics providers such as Google situated outside EU
  • Analytics providers such as Facebook situated outside EU
  • Analytics providers such as Click Funnels situated outside EU
  • Advertising networks such as (YouTube/Facebook/Instagram/Twitter/Google/Hotjar/Also Re-targeting services offered by the companies mentioned above) situated [(inside OR outside) the EU];
  • Search information providers Google situated [(inside OR outside) the EU].
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services (such as revolut/PayPal/cashapp/Venmo/any others) situated [(inside OR outside) the EU].
  • Identity and Contact Data from data brokers or aggregators situated [(inside OR outside) the EU].
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when legally permitted. The most common uses of your personal data are:

  • Where we need to perform the contract between us.
  • Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please submit a support form if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

In General, we do not rely on consent as legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have all rights to withdraw your consent to marketing at any time you feel like by clicking on our unsubscribe link at the bottom of our email communications or by submitting a support form.

Purposes For Processing Your Personal Data

Below is a description and explanation of the different ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where needed. The purpose and activities are as follows:

  • Types of Data include;
    • Identity and
    • Contact
  • To register you as a new customer
  • Lawful basis of processing
  • To process and deliver your order including:
  • Manage payments, fees and charges
  • Collect and recover money owed to us
  • Financial
  • Transaction
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests to recover debts owed to us
  • Performance of a contract with you.

  • To manage our relationship with you which will include:
  • Notifying you about changes to our terms or privacy policy.
  • Asking you to leave a review or take a survey.
  • Identity
  • Contact
  • Profile
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary to comply with legal obligation
  • Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
  • To enable you to partake in a prize draw, competition or complete a survey;
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business.
  •  To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  •  Identity
  • Contact
  • Technical
  • Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise.
  • Necessary to comply with a legal obligation.
  • To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising;
  • Identity
  • Profile
  • Usage
  • Marketing and Communications
  • Technical

Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.

  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences;
  • Technical
  • Usage

Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.

  • To make suggestions and recommendations to you about goods or services that may be interests to you;
  • Identity
  • Contact
  • Technical
  • Usage
  • Profile
  • Marketing and Communications

Necessary for our legitimate interests to develop our products/services and grow our business.

You will receive marketing communications from us if you have:

Requested information from us or purchased goods or services from us; OR

If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; AND

In each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by submitting a support form or contact us at bubutshally@gmail.com at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of Purpose

We will only use your personal data for purposes which we collected them for, unless we legitimately consider that we need to us it for another reason and that reason is compatible and relatable with its original purpose. If confused and want more info about how the processing for the new purpose is compatible and relatable with its original purpose. Please submit a support form or contact us at support@thrizen.com.

If we need to use your personal data for a purpose unrelated too the purpose for which we collected the data, we will notify you right away and we will explain and give every detail about the legal ground of processing.

We may process your data without your knowledge or consent where and when this is required and needed or permitted by law.

5. WILL YOUR DATA BE SHARED WITH ANYONE

We may have to share your personal data with the parties named below for legitimate purposes we’ve mentioned in paragraph 4 above:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in United Kingdom and Ireland, court order, government requests, a judicial proceeding and other relevant jurisdictions who require reporting of processing in circumstances above our control

We oblige all third parties to whom we work with and transfer your data to respect the security of your personal data and to treat accordingly to the law. We only allow such third parties to process your personal data for specified purposes and accordingly to our instructions.

6. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, mismanaged, used or accessed in an unauthorized way, altered or disclosed.

In addition, we limit access of your personal data to those employees, agents, contractors and other third parties who have business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have also put in place measures and procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally permitted and required to.

Although we do our very best to protect your personal data, we do advice that you also carry out necessary prevention methods such as access the website within a secure environment and browser.

7. INTERNATIONAL TRANSFERS AND THIRD PARTIES

We share your personal data with our approved and legitimate service suppliers, some of which are outside European Economic Area (EEA). Countries outside the European Economic Area (EEA) do not always offer the same level of protection to your personal data, so European law has prohibited transfer of personal data outside the EEA unless the transfer meets certain criteria. A wide variety of our third-party provider reside outside the European Economic Area (EEA), so their processing of your personal data will vary from ours. But rest assured that when we transfer your personal data outside the EEA, we do our absolute best to ensure a similar (if possible, better) degree of security of data by ensuring that at least one of the following safeguards is implemented.

We will only transfer your personal data to countries that have been approved and deemed to provide the adequate protection for personal data by the European Commission; OR

Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; OR

Where we use service providers from the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and US.

If none of the above safeguards is available, we will then request your explicit consent to the specific transfer. You have all rights to withdraw this consent at any time. Please contact us by submitting a support form or contact us at bubutshally@gmail.com if you want any further information on the specific process used by us when transferring your personal data out of the EEA.

Concerning Third Parties, this website may include links to third-party websites, plug-ins and applications. Clicking on those links or activating those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read their privacy policy and privacy policies of every other website you visit.

8. DATA RETENTION (HOW LONG WILL WE KEEP YOUR DATA)

We will only retain your personal data for as long as necessary to fulfil the purposes that the were collected for, including purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized and unwanted use or disclosure of your personal data, the purposes for which we process your personal data and whether we can whether we can achieve those purposes through other means, and applicable legal requirements.

By law we have to keep basic information about our customers (Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws relating to your personal data. These include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request removal or deletion of personal data.
  • Object to processing of your personal.
  • Request restriction on processing your personal data.
  • Ask for a transfer of your personal data.
  • Right to withdraw consent.

You can visit this website at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ for further information concerning your legal rights.

If you wish to carry out any of the rights outlined above, please contact us by submitting a support form or contact us at support@thrizen.com.

You are not required to pay a fee to access your personal (or to carry out any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, disturbing, repetitive or excessive.

We may require a specific information from you to help us confirm your identity and ensure your right to access your personal (or to carry out any of the other rights). This is a security measure to make sure your personal data is not disclosed or shown to any other person who has no right to see or receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests, then it may take us longer than a month. In this case, we will notify you and keep you updated.

10. COOKIES

A cookie is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present already made options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.

Cookies are used by almost all websites and bring no harm to your system

If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not able to access all or parts of our site.

How we use cookies

We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and/or services in response to what you might want or need.

Cookies are one of the following:

  • Session Cookies: These types of cookies are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; OR
  • Persistent Cookies: A persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. (We use persistent cookies for Google Analytics). (We also us Facebook Pixels).

Cookies can also be ordered as follows:

  • Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and/or service, and therefore cannot be turned off. Without these cookies, the services available to you on the website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been internet.
  • Performance cookies: These cookies enable is to monitor and improve the performance of our website. For example, they allow us to count visits, identity traffic sources and see which parts of the site are most popular.
  • Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able provide you with news or updates relevant to the services you use. Ther may also be used to provide services you requested such as viewing a video or comment on a blog. The information these cookies collect is usually anonymized.