This policy applies to: (i) use of the websites owned and operated by us (at world.spyninjasstore.com) ("the Site") and use of our marketing activities, including newsletters, emails, competitions, and any other product or activity that links to, or otherwise references, this policy (collectively, with the Site and the "Spy Ninjas Products"). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting or using the Spy Ninjas Products you are accepting and consenting to the practices described in this policy.
For the purpose of the General Data Protection Regulation, the data controller is Event Merchandising Limited, a company registered in England and Wales under company number 1618411, registered address is at Unit 11, The Edge Business Centre, Humber Rd, London NW2 6EW.
If you have any questions or concerns about this policy, the information we collect about you or our personal data processing activities in connection with your dealings with the Spy Ninjas Products, please contact our Data Protection Officer: General Counsel at Event Merchandising Limited, at firstname.lastname@example.org
You can also contact us through physical mail to Event Merchandising Limited, Unit 11, The Edge Business Centre, Humber Rd, London NW2 6EW, United Kingdom, to the attention of our General Counsel.
Information on data protection generally is also on the Information Commissioner’s website at www.ico.gov.uk or at the official website of the European Union: https://ec.europa.eu/info/law/law-topic/data-protection_en.
Information we collect about you
We will collect and process the following data about you:
Information you give us. This is information about you that you voluntarily give and share with us by filling in the form or field on the Site, by any other communication (e.g. email, phone, mail etc.) or when you request to receive certain content that we may make available through the Spy Ninjas Products. It includes information you provide when you register to sign up to our email newsletter and when you report a problem with our Site or download content from the Site. The information you give us may include your name and email address as well as any other content that you provide through the above communication channels.
Information we collect about you. With regard to your use of the Spy Ninjas Products we will automatically collect the following information:
Certain technical information or usage information may, either alone or when combined with other data, be deemed personal data under data protection laws and we are committed to treating such data in compliance with them.
Sometimes we can also obtain the above information from third party sources, such as the various business support tools and services offered by third party providers that We use (e.g. Crashlytics and Firebase analytics services offered by Google companies).
How we make use of the information
It is important that you understand how and why we use the personal data that we collect about you. This section sets out the different purposes for which we process personal data and which types of personal data we need for each purpose.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We may also use your personal information in the following situations, which are likely to be rare:
In some cases we may use your personal information to pursue legitimate interests of Our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information based on legitimate interests are listed below:
Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
When we may use your details to contact you?
Sharing your information with third parties
We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.
We will also disclose your personal data to third parties:
Where we store your personal data
Transferring information outside the EEA
We may transfer your personal information to Our services providers outside the EU. If we do, you can expect a similar degree of protection in respect of your personal data as is required in the territory of the European Union.
Mail Chimp are based in the US, however we transfer data to them as they are signatories to the EU Privacy Shield framework which requires them to provide similar protection to personal data shared between Europe and the US.
You can find more information about the EU Privacy Shield framework at https://www.privacyshield.gov/welcome, at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_en and https://ico.org.uk/make-a-complaint/eu-us-privacy-shield/.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes secure socket layer (SSL) technology to ensure your details are safe and information you provide is fully encrypted so that it cannot be read by third parties.
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long we retain your personal data
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for and specified in section 3 of this policy.
When We use your personal data for direct marketing purposes, We will retain your data until you opt-out from receiving the marketing materials in accordance with data protection laws, provided that we will need to retain certain information to maintain a record of your request. We may also retain your personal data for such time that is required to pursue Our legal claims and compliance with our legal obligations (such as tax and accounting obligations).
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Your right of access, correction, erasure and restriction
Your duty to inform us of changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data that you voluntarily share with us changes at any point in the future.
Your rights in connection with personal information. Under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Our Data Protection Officer via email to: Jeremy@eventmerch.com
No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Jeremy@eventmerch.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Third party websites
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Automated decision-making or profiling takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
We use information we have about you to tailor the content of communications that are sent to you to try to ensure that the offers are as relevant to you as possible and so you have exclusive access to the best deals.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
Children under 16
We are concerned to protect the privacy of children aged 16 or under. We do not knowingly collect or process personal data from or with respect to children aged 16 or under, and you must be 16 years of age or older in order to use the Spy Ninjas Products.
If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
If you are a parent or legal guardian and believe that your child aged 16 or under has submitted his or her personal data or other data without your consent, permission, or authorization – please let Us know immediately, and We will promptly act to remove your child’s data from our database.
Changes to our policy