Keeping your data secure and maintaining your privacy is a significant responsibility and one that we take very seriously. We’ve written this policy to help you understand “what” personal information we collect, “how” we process it, “where” it is stored and how you can access or request deletion of your personal data.
Contact us at if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
Table of Contents
- Definitions used in this Policy
- Data protection principles we follow
- What rights do you have regarding your Personal Data
- What Personal Data we gather about you
- How we use your Personal Data
- Who else has access to your Personal Data
- How we secure your data
- Information about cookies
- Contact information
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) –
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
Data we gather
– Information you have provided us with
This includes the Personal Data you provide, or somebody else provides on your behalf when completing any of the following activities:
- Registering a new account on saintloupe.com or any of its sub-domains
- Submitting information or uploading data within a saintloupe.com or any of its sub-domains account
- Subscribing to a mailing list
- Ordering a standalone product or service or a rolling contract/subscription
- Initiating a support request or submitting information on our “contact us” form.
- Completing a product referral form
- Completing an online survey or questionnaire
The information may include the following types of direct or indirect Personal Data:
- Your name
- Your contact information (e.g. phone, email, address etc)
- Employee details
- Personal Data contained within receipts and invoices
- Personal Data contained within uploaded files
- Personal Data contained within bank account transactions or other merchant service transactions
This might be your e-mail address, name, billing address, home address etc – mainly information that is necessary for delivering you a product/service or to enhance your customer experience with us. We save the information you provide us with in order for you to comment or perform other activities on the website. This information includes, for example, your name and e-mail address.
– Information we collect about you
We also collect information about how you use your account, this helps us to deliver a more customised user experience, identify trends and improve security. Some of this data may be “Personal Data”, in cases where it can be used to identify a person. Here is the information we collect and how it is used:
- Login dates and IP addresses – This allows us to understand how you are using SAINT LOUPE and identify unusual access patterns.
- Account usages statistics – This includes things like how much time you spend on the website and which features you use. This helps us to optimise your user experience and make you aware of specific features that may be of interest to you.
- Website traffic – This includes general information on how you found our website, which referring site you arrived from (e.g. Google, Facebook etc), and what device or browser you are using. This helps us to improve our marketing strategies and tailor our website for different devices.
- Order history – This information includes a record of any orders you place. This helps us to fulfill our obligations to you and provide accurate financial records when requested.
- Email opens and bounces – We track when the emails we send are opened or bounced. This allows us to optimise our mailing list by delisting addresses that are inactive or unresponsive.
– Information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds. See the list of our partners here.
Publicly available information
We might gather information about you that is publicly available.
How we use your Personal Data
We use your Personal Data in order to:
- provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
- enhance your customer experience;
- fulfil an obligation under law or contract;
We use your Personal Data and Financial Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- to identify you;
- to provide you a service or to send/offer you a product;
- to communicate either for sales or invoicing;
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
- to send you personalised offers* (from us and/or our carefully selected partners);
- to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
- to conduct questionnaires concerning client satisfaction;
- to monitor trends. We collect anonymised data about how people use the SAINT LOUPE website or service. This includes collecting information on the number of visitors, what pages or features are accessed, which country visitors are connecting to the website from, browser types, display size and average viewing times. We may occasionally share this anonymised data with our community, although we will never include specific Personal Data here or any information that would identify you or your business.
As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
- to send you newsletters and campaign offers (from us and/or our carefully selected partners);
- for other purposes we have asked your consent for;
- You may choose to share your Personal Data and Financial Data with a third-party company or professional you engage on the SAINT LOUPE website or during any of our services and meetings.
- You may also elect to use a third-party Marketplace Application to provide additional functionality for your service and/or contract.
- Your data will only be shared with your explicit consent, although we do ask that you carryout appropriate due diligence before granting any third-party access to your account.
We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- the link between purposes, context and nature of Personal Data is suitable for further Processing;
- the further Processing would not harm your interests and
- there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
Who else can access your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it. We share your data with:
Third-party web services
In some cases it will be necessary to share Financial Data or Personal Data with a third-party web service you have authorised to work with your SAINT LOUPE account, service and/or contract. This may be something like passing invoice information to a third-party payment processor like PayPal or Worldpay. It may also include the export of your data to a document storage service like Dropbox or a project management service like Airtable.
In these cases data will be shared only on the basis that you have provided explicit consent and that you have completed the necessary authorisation for us to pass data to each of these web services. When we work with a third-party web service in this way, we always make sure that your data is only sent over a secure encrypted connection.
Our outsourcing partners:
In order to provide a robust and reliable service, we depend on a number of service providers to carry out key operations within our business. This includes things like document storage, payment processing, email processing, marketing assistance, social media management and website security.
Whenever we entrust your data with an outsourcing partner, we always carry out thorough due diligence and ongoing monitoring to ensure that appropriate privacy controls are in place and maintained at all times.
Sale of business assets:
We reserve the right to share Personal Data with a prospective buyer of business assets. This would be subject to the terms of a Non Disclosure Agreement.
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks. We protect our systems with security and antivirus softwares.
Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret and take all reasonable steps to protect your account from unauthorised access.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
Cookies and other technologies we use
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our website and services
- Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
SAINT LOUPE Data Protection Officer
Mauro Pellegrini DPO – [email protected]
Last modification was made 22/04/2020.