Privacy policy
Table of Contents
1 KEY TERMS................................................................. 2
2 DATA PROTECTION LEGISLATION................................. 3
3 PERSONAL DATA WE COLLECT...................................... 3
4 ANONYMISED DATA..................................................... 4
5 HOW WE COLLECT PERSONAL DATA............................. 5
6 HOW AND WHY WE USE PERSONAL DATA..................... 5
7 MARKETING................................................................ 7
8 WHO WE SHARE PERSONAL DATA WITH?...................... 9
9 HOW LONG WE KEEP PERSONAL DATA........................ 10
10 RIGHTS OF THE DATA SUBJECT.................................. 11
11 INFORMATION SECURITY........................................... 12
12 ROUTINE ERASURE AND BLOCKING............................ 13
13 COMPLAINTS............................................................. 13
14 AGE LIMITATIONS..................................................... 13
15 CHANGES TO THIS PRIVACY NOTICE........................... 13
16 PROVISION OF PERSONAL DATA................................. 14
17 CONTACT US............................................................. 14
Privacy policy
LAST UPDATED: Monday, December 9, 2024
We are delighted that you have shown interest in the services of SG Luxury Enterprises LLC (the “Company”, “we”, “us”, or “our”) which are provided via our Website www.perrita.com. This Privacy Policy (the “Privacy Policy”) applies only to users who engage with the Company’s Website for the provision of Products and services and does not apply to Products and services that are provided offline or unrelated to the Website.
Your privacy is important to us, and we respect your privacy regarding any Personal Data that we collect when you register on our Website or while availing the services and engaging in transactions thereafter. We treat your Personal Data as confidential and in accordance with the statutory Data Protection Legislation and this Privacy Policy.
You hereby acknowledge and admit that you have read, understood, and accepted to be bound by this Privacy Policy, as may be modified by the Company from time to time. Any amendments or variations thereto shall take effect from their date of publication on the Website. Terms not defined under this Privacy Policy will have the same meaning as that defined under the Terms and Conditions available on the Website.
Our Privacy Policy and data protection declaration should be legible and understandable for the general public, as well as our users. To ensure this, we would like to first explain the terminology used.
In this Privacy Policy, we use, among other things, the following terms:
1.1 “Anonymization” means the Processing of Personal Data in such a manner that the Personal Data can no longer be attributed to a specific Data Subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the Personal Data are not attributed to an identified or identifiable natural person;
1.2 “Consent” means any freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the Processing of Personal Data relating to them;
1.3 “Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data;
1.4 “Data Subject”, “you” and “your” collectively mean any identified or identifiable natural person, whose Personal Data is processed by the Controller responsible for the processing. 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;
1.5 “Personal Data” means any information relating to a Data Subject;
1.6 “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
1.7 “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements; and
1.8 “Recipient” means a natural or legal person, public authority, agency, or another body, to which the Personal Data are disclosed. The processing of those data by those public authorities shall be in compliance with the applicable Data Protection Legislation according to the purposes of the Processing.
We are committed to protecting your privacy and safeguarding your Personal Data. Our use of your Personal Data is subject to the California Consumer Privacy Act (“CCPA”) and in accordance with the country-specific data protection regulations applicable to the Company (together, the “Data Protection Legislation”).
The Website collects a series of Personal Data and information when a Data Subject or automated system calls up the Website. This Personal Data and information are stored in the server log files. The Personal Data collected may be:
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TYPES OF PERSONAL DATA |
EXAMPLES |
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Identity data |
name; title; username; |
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Contact data |
address; email; telephone number; |
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Usage data |
how you use and navigate our Website our social media pages; services you signed up to; products you bought or expressed interest in; |
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Advertising profile data |
interests; preferences; feedback and survey responses; assumptions about your predicted buying behavior and interests based on the usage data collected by us from you and held about you by our advertisers such as Facebook, Twitter, Google, LinkedIn, Instagram; |
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Communication data |
details of enquiries submitted by you through our Website or emailed to us; information obtained through networking; |
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IT data |
logins and usernames to our Website; encrypted passwords; |
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Technical data |
your IP address; your general geographic location based on your IP address; your time zone setting; the type of device you use and its operating system and version; your browser type; the platform you use and other technology on the devices you use to access our website; the pages you view on our Website and how you interact with that content; advertising identifiers (such as those on mobile devices, tablets and streaming media devices that include such identifiers). |
We may also collect, use, analyze and share Anonymized, aggregated data such as statistical or demographic data for any purpose including with the aim of increasing our data protection and data security and to achieve an optimal level of protection for the Personal Data we Process. The Anonymized data of the server log files are stored separately from all Personal Data provided by a Data Subject. Anonymized data may be derived from your Personal Data but is not considered personal information in law as this information does not directly or indirectly reveal your identity.
5 HOW WE COLLECT PERSONAL DATA
We collect most of your Personal Data directly from you. However, we may also collect information from other sources.
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TYPE OF SOURCE |
EXAMPLES |
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Your use of our Website and services |
when you register on our Website; when you use or buy our Products; when you submit an enquiry or Feedback to us or complete our survey; when you sign up to our mailing list; when you post any content on our Website. |
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Your use of our social media pages |
when you follow, post on, or interact with our post on our social media pages. |
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Direct interactions with you |
when you contact us (e.g., by phone or email); when you participate in our user research activities (e.g., provide us with feedback or respond to our questionnaires); when you network with us (e.g., provide us with your business card or contact us via our social media); when you register interest in our services. |
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From publicly accessible sources |
your website; your profiles on social media platforms (e.g., LinkedIn, Facebook, Twitter); professional networking groups and databases. |
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Third-parties |
from another organization or professional who told us that you would like to hear from us; or if you visit our Website by clicking on our advertisement on social media or another website or app. |
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Automated technologies or interactions |
as you interact with our Website and advertisements, we may automatically collect technical data (as described in Clause 3 above). We collect this Personal Data by using cookies, server logs and other similar technologies. |
6 HOW AND WHY WE USE PERSONAL DATA
According to the Data Protection Legislation, we can only use your Personal Data if we have a proper reason for doing so, for example: Consent, contact, legitimate interests, or legal obligation.
6.1 Consent. Generally, we do not rely on Consent as a legal basis for Processing your Personal Data other than:
a. to place cookies and similar tracking technologies on your device including third-party cookies; and
b. when using your Personal Data for certain marketing purposes (see the Marketing Clause (Clause 7) of this Privacy Policy for further details).
Where your permission is required, we will ask you for such Consent clearly and separately from the body of this Privacy Policy or our Terms and Conditions. You have the right to withdraw Consent to marketing at any time. For further information, please see the Marketing Clause (Clause 7) of this Privacy Policy.
6.2 Contract. We will use your Personal Data if we need to do it to perform our obligations under a contract with you, or if it is necessary for a contract which we are about to enter with you. For example, if we need to:
a. register you as a new user and process your order (e.g., set up your payment profile);
b. provide our services to you (e.g., facilitate payments by users); or
c. manage our relationship with you (e.g., to respond to your enquiries or to notify you about changes to our services).
6.3 Legitimate interests. We may process your Personal Data when we (or a third-party) have a legitimate reason to use it, so long as this is not overridden by your own rights and interests. For example:
a. to administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
b. to manage your orders and our relationship with you;
c. to manage payments, fees, charges, and to collect debts which you may owe to us;
d. to interact with you professionally (e.g., if you represent our current or prospective customer) to manage our relationship with the organization you represent;
e. to provide you with a free service (e.g., a free trial or the use of the functionalities of our Website);
f. to ask you to leave a review, give feedback or complete a survey;
g. for marketing purposes (see the Marketing Clause (Clause 7) of this Privacy Policy for further details);
h. to increase our business or promote our brand through delivering relevant content, advertisements, and marketing communications to you;
i. to measure or understand the effectiveness of the advertising we provide to you; or
j. to improve our Website, Products, services, marketing, and customer relationships; for the prevention and detection of fraud and spam; and for the establishment, exercise, or defense of our rights under our contract with you and/or legal claims.
6.4 Legal obligation. We may Process your Personal Data to comply with our legal obligation, including but not limited to:
a. notify you about changes to our terms or Privacy Policy;
b. address your complaint; or
c. comply with a request from a competent authority.
7.1 Our marketing communication. We may contact you about our services by email, in-platform messages, phone, or post. We rely on our legitimate interests to use your Personal Data in this way, except when your express Consent is required by law. If you are not representing a business and are not our existing customer, we will only send marketing emails to you when you expressly agree to that.
7.2 Profiling. If you are our existing user, we may use the information we have about you (such as what Products you previously bought from us, where you are based, how you use our Website) to make predictions on what other Products may be of interest to you. We will use that information to make our marketing emails and offers relevant to you. This type of Personal Data use is called ‘Profiling’. We will do that on the basis of our legitimate interests.
7.3 Cookies and similar technologies
a. Our Website uses cookies. Cookies are text files that are stored in a computer system via an Internet browser.
b. Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Website and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the Data Subject from other Internet browsers that contain other cookies.
c. A specific Internet browser can be recognized and identified using the unique cookie ID.
d. Through the use of cookies, we can provide users of our Website with more user-friendly services that would not be possible without the cookie setting.
e. By means of a cookie, the information and offers on our Website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our users. The purpose of this recognition is to make it easier for users to utilize our Website. The user that uses cookies, e.g., does not have to enter access data each time the Website is accessed, because this is taken over by the Website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.
f. The Data Subject may, at any time, prevent the setting of cookies through our Website employing a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the Data Subject deactivates the setting of cookies in the Internet browser used, not all functions of our Website may be entirely usable.
g. We may also use such cookies and similar tracking technologies (for example tracking pixels in our marketing emails and website/app advertisements) and analytics services (such as Google Analytics) to collect information about your use of our Website, services and your interactions with our marketing emails and advertisements.
h. In addition, third-party advertising platforms (for example, Facebook, Google, and LinkedIn) may also use their advertising pixels and other cookies on our Website and in our emails with our permission. Their cookies are used to track visitors across websites in order to deliver adverts more relevant to them and their interests. The advertisers may use information about your visit to our Website to target advertising to you on other websites.
i. We will ask for your Consent to the use of non-essential cookies, including third-party cookies.
7.4 Third-party advertising
a. We may share your name, email address, telephone number, and other information, such as whether you made any purchases with us and how much you spent, for our advertising purposes with social media platforms and other third-party advertising providers (for example, Facebook, Google, or LinkedIn). The third-party advertising provider will use that information to match it against the list of their own users. If the email address or telephone number we give them matches with their list, they will use it to show you our advertisements on their website.
b. The third-party advertising providers will also use that information to combine it with the information they hold on you (for example, your interests, likes, advertisements you previously clicked on) and match it with other users of their services who share similar characterizes. They will then show our advertisements to those other people. The third-party advertising providers will use your Personal Data and the other ‘look like’ users’ data in this way as data controllers on the basis of their terms and policies that govern their users’ use of their services. They will not share any of that information with us. However, if you are one of such ‘look like’ users of the third-party advertising provider and come to our Website by clicking on our advertisement on that provider’s platform, we will know that you came to us that way. The third-party advertiser may also share certain statistical information with us (for example, the demographic composition of persons that interacted with our advertisement).
c. We will share information with third-party advertising providers for the above purposes only if you Consent to our sharing of your Personal Data with third-parties for advertising purposes on third-party platforms.
8 WHO DO WE SHARE PERSONAL DATA WITH?
We may share your information with third-party for the purposes set out in this Privacy Policy.
8.1 Service provision
a. We may also share your Personal Data with payment processor, to process payments in connection with providing our services and Products. If you pay us using our payment processor or if you receive payments from us through our payment processor, you will be providing your Personal Data (for example, details of your payment card and billing address) to our payment processor.
b. The payment processor will, if necessary, pass on Personal Data to affiliates and service providers or subcontractors to the extent that this is necessary to fulfil contractual obligations or for Personal Data to be Processed in the order.
c. The Data Subject has the possibility to revoke Consent for the handling of Personal Data at any time from the payment processor. A revocation shall not have any effect on Personal Data which must be Processed, used, or transmitted in accordance with (contractual) payment processing.
d. For information on how the payment processor uses Personal Data, please see their privacy policy.
8.2 Social media. We may share your Personal Data with Facebook, Google, and LinkedIn when you use the social media buttons embedded in our Website. Please also see the Marketing Clause (Clause 7) for further details of sharing information with social media platforms.
8.3 IT and technology. We may also share your Personal Data with providers of other IT, digital, and technology products and services, which we use to operate our business. For example, providers of website hosting services, website and app analytics services, customer email services, digital marketing services, and social media advertising services. We impose contractual obligations on the above providers to ensure that your Personal Data is protected.
8.4 Other sharing. We may also:
a. share your Personal Data with members of our staff, our subsidiaries, affiliates and licensors;
b. disclose your Personal Data to professional advisers (e.g., lawyers, accountants, auditors, or insurers) who provide professional services to us;
c. disclose your Personal Data to certain third-party if specifically requested or agreed with you (e.g., if you ask us to introduce you to a third-party);
d. disclose and exchange certain Personal Data (where applicable) with law enforcement agencies and regulatory bodies to comply with our legal obligations; and
e. share some Personal Data with other parties, such as potential buyers of some or all our business, potential investors, or group companies if our business undergoes a corporate re-structure.
Such data Recipients will be bound by confidentiality obligations.
9 HOW LONG WE KEEP PERSONAL DATA
9.1 We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
9.2 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 use or disclosure of your Personal Data, the purposes for which we Process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
9.3 If the Data Subject requests for termination, the Personal Data shall be retained for a period of one (1) year from the date of such termination.
9.4 We may also Anonymize your Personal Data (so that it can no longer be associated with you) for analytics, research, or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have several rights in relation to your Personal Data, which allow you to access and control your information in certain circumstances. You can exercise these rights free of charge unless your request is manifestly unfounded or excessive (in which case we may charge a reasonable administrative fee or refuse to respond to such request).
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YOUR RIGHT |
EXPLANATION |
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Access |
This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully Processing it. |
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Rectification |
The right to require us to correct any inaccuracies in your Personal Data. |
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To confirmation |
The right to confirmation is granted to obtain confirmation from the Controller as to whether Personal Data concerning you is being Processed. |
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Erasure (to be forgotten) |
The right to require us to delete your Personal Data in certain situations. |
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Restriction of Processing |
The right to require us to restrict Processing of your Personal Data in certain circumstances (e.g., if you contest the accuracy of the data we hold). |
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Data portability |
The right to receive, in certain situations, the Personal Data you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that Personal Data to a third-party. |
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To withdraw Consent |
The right to withdraw your Consent, if we rely on your Consent to use your Personal Data. |
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To object |
The right to object at any time to your Personal Data being Processed for direct marketing (including Profiling) or, in certain other situations, to our continued Processing of your personal Data (e.g., Processing carried out for the purpose of our legitimate interests). |
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Not to be subject to automated individual decision-making |
The right not to be subject to a decision based solely on automated processing (including Profiling) that produces legal effects concerning you, or similarly significantly affects you. |
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To know status |
The right to know if Personal Data has been sold or disclosed to third parties |
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To say no to sale |
Data Subject has the right to say ‘no’ to the sale of their Personal Data |
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To not be tracked |
If a Data Subject chooses the ‘Do Not Track’ settings in their browser regarding targeted advertising, then we do not monitor or respond to Do Not Track browser requests. |
If you would like to exercise any of those rights, please contact us at contacto@perrita.com. Please let us know what right you want to exercise and the information to which your request relates.
11.1 We have appropriate security measures to prevent Personal Data from being accidentally lost or used or accessed unlawfully. We limit access to your Personal Data to those who have a genuine business need to access it. Those Processing your Personal Data will do so only in an authorized manner and are subject to a duty of confidentiality.
11.2 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
11.3 This Website ensures that Personal Data is encrypted when leaving the Website. This process involves the converting of information or data into a code to prevent unauthorized access. This Website follows this process and employs secure methods to ensure the protection of all credit and debit card transactions. Encryption methods such as SSL are utilized to protect customer data when in transit to and from this Website over a secure communications channel.
11.4 Whilst we do everything within our power to ensure that Personal Data is protected at all times from our Website, we cannot guarantee the security and integrity of the information that has been transmitted to our Website.
12 ROUTINE ERASURE AND BLOCKING
12.1 The Controller Processes and stores the Personal Data of the Data Subject only for the period necessary to achieve the purpose of storage, or as far as it is granted by the legislators in laws or regulations to which the Controller is subject.
12.2 If the storage purpose is not applicable, or if a storage period prescribed by the legislators expires, the Personal Data are routinely blocked or erased in accordance with legal requirements.
13.1 We hope that we can resolve any query or concern you may raise about our use of your Personal Data. You may contact us by using the contact methods set out in the ‘Contact Us’ section of this Privacy Policy.
13.2 This Privacy Policy also gives you a right to lodge a complaint with a supervisory authority, in the country where you work, normally live or where any alleged infringement of data protection laws has occurred. The supervisory authority in your respective area of residence may be contacted through the official mail address or contact number, or by post addressed to the concerned supervisory authority.
13.3 We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
14.1 Our Website is not intended for unsupervised use by persons under the age of 18. No one under the age of 18 may provide any information to our Website or through any of its features, make purchases, use interactive features, or provide personal information, including name, address, telephone number, or email address.
14.2 Our interactions and transactions strictly adhere to age-appropriate practices. We do not knowingly collect, use, or disclose personal information from minors. If you are a parent or guardian and believe that we have inadvertently collected personal information from a minor, please contact us immediately at contacto@perrita.com, and we will take appropriate steps to delete such information
15 CHANGES TO THIS PRIVACY NOTICE
15.1 This Privacy Policy was last updated on the date first mentioned above.
15.2 We may change this Privacy Policy from time to time; when we do, we will publish the new version of the Privacy Policy on our Website. If you are our user, we may also inform you via email or post. However, by continuing your access to our Website you agree that you have read the updated Privacy Policy and are bound by it.
We clarify that the provision of Personal Data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contractual partner). Sometimes it may be necessary to conclude a contract that the Data Subject provides us with Personal Data, which must subsequently be processed by us. The Data Subject is, for example, obliged to provide us with Personal Data when we sign a contract with him or her. The non-provision of the Personal Data would have the consequence that the contract with the Data Subject could not be concluded. Before Personal Data is provided by the Data Subject, the Data Subject must contact us. We will clarify to the Data Subject whether the provision of the Personal Data is required by law, contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the Personal Data, and the consequences of non-provision of the Personal Data.
If you have any questions regarding any part of this Privacy Policy or our use of your Personal Data, please contact us by email at contacto@perrita.com.
You acknowledge that you have read, understood, and accepted to be bound by this Privacy Policy.