GDPR

MoyeClub Privacy Policy Update For GDPR

MoyeClub is committed to keeping your data safe and secure.

So you’re well-informed about your data, here’s why we need it and how we use it.

• We collect your data to provide you the best user experience
• We respect your privacy and protect your data like it’s our own
• You decide what and how you want to hear from us

We have updated our Privacy Policy to reinforce our commitment to protecting your data in light of the General Data Protection Regulation (GDPR), which takes effect in the European Union on May 25th.

With the new update, rest assured, our purpose remains the same – to uphold safeguarding your data and protecting your privacy – in addition to taking steps to improve upon our data privacy controls and practices to better explain options for how you can update, manage, edit or delete your data. We will be continuing to improve our data privacy capabilities and will update our Privacy Policy in line with our transparency obligations.

Highlights of what we have updated to our Privacy Policy:

• Specified our responsibility to you for processing your data
• Appointed a Data Protection Officer, who can be reached by email or post
• Clarified what information we collect from you, how we use it and why it is needed to provide our services
• Explained the rights you have in relation to your data and steps to exercise those rights allowing you to better manage your data
• Provided more details as to how you can contact us for any data queries or requests

As our commitment to you, we are constantly striving to best serve you in continuing to improve your user experience across our websites and apps. To bring you more personalized content, features and recommendations that we hope you will like, we collect information to help deliver the best user experience that we can to you.

As always, you are in control of your data and your privacy is our priority.

EU PRIVACY NOTICE FOR OUR WEBSITE AND APP USERS, CUSTOMERS AND BUSINESS CONTACTS

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA AND HOW TO CONTACT US

The following Privacy Notice is for the EU visitors of our websites, moyeclub.com, moyeagency.com (collectively, the “MoyeClub Sites”), our customers, account holders and business contacts.

It is our goal to bring you information tailored to your personal interests but, at the same time, protect your privacy. This Privacy Notice covers MoyeClub’s collection and use of any personal data that we gather when you are on the MoyeClub Sites and when you are using our services. This Privacy Notice does not cover personal data (if any) that may be collected on other sites linked to and from the MoyeClub Sites as well as the practices of third parties that MoyeClub does not control or own.

Questions, comments, and requests for information regarding this Privacy Notice, or our privacy practices in general, are welcomed and should be addressed to our Data Protection Officer, Janet Lau. Any queries and requests regarding this privacy notice may be emailed to moyeclub@gmail.com

2. DATA CONTROLLER

For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the “GDPR”), MoyeClub Limited, (referred to as “MoyeClub”, “we”, “us”, or “our”) will be the data controller responsible for any personal data we process.

3. OUR DATA PROTECTION OFFICER (DPO)

We have appointed a DPO for purposes of the GDPR. The contact details for our DPO are as follows:

By email:

moyeclub@gmail.com

4. WHAT PERSONAL DATA DO WE COLLECT AND WHY?

We may source, use and otherwise process your personal data in different ways. In all cases we are committed to protecting your personal data.

In each of the sections listed below, we describe how we obtain your personal data and how we treat it.

4.1 Website and App Users

We may collect personal data relating to our website and app users.

A – Sources of personal data

We may obtain your personal data from the following sources, depending on the website or app that you visit or the nature of our relationship with you:

1. from you directly (for example, at the time of subscribing to any services offered on our website or app, including but not limited to email mailing lists, placing an order, creating a site account, entering into a raffle or event invitations, interactive services, posting material or requesting further goods or services); and/or
2. from your device or browser.

If you contact us, we may keep a record of that correspondence.

B – Personal data that we collect and process

We collect the following categories of personal data relating to our website and/or app users:

1. operating system;
2. browser type;
3. IP address;
4. device token;
5. information on the use of our website (for example, pages visited, geographical location, time spent on the website, online transactions);
6. cookie data (for more information please see our Cookie Notice);
7. preferences regarding online marketing, browsing and account settings; and/or
8. body measurements (for example, height/weight, waist circumference, leg length, and fit preference)

C – Why do we collect your personal data and what are our lawful bases for it?

Where we use cookies or similar technologies we will seek your prior consent where required to do so by law.

Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.

D – How long do we keep your personal data?

We will retain your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of our services to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.

4.2 Account Holders

We may collect personal data relating to our website and app users.

A – Sources of personal data

We may obtain your personal data from the following sources:

1. from you directly (for example, at the time of subscribing to any services offered on our website or app, including but not limited to creating a site account, email mailing lists, placing an order, interactive services, entering into a raffle or event invitations, posting material or requesting further goods or services); and/or
2. from your device or browser.

If you contact us, we may keep a record of that correspondence.

B – Personal data that we collect and process

We collect the following categories of personal data relating to our account holders:

1. username;
2. email address;
3. name;
4. data of birth;
5. address;
6. country;
7. phone number;
8. gender;
9. company name;
10. operating system;
11. browser type;
12. IP address;
13. device token/ID;
14. information on the use of our website (for example, pages visited, geographical location, time spent on the website, online transactions);
15. cookie data (for more information please see our Cookie Notice); and/or
16. preferences regarding online marketing, browsing and account settings; and/or
17. body measurements (for example, height/weight, waist circumference, leg length, and fit preference)

C – Why do we collect your personal data and what are our lawful bases for it?

Where we use cookies or similar technologies we will seek your prior consent where required to do so by law.

Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.

D – How long do we keep your personal data?

We will retain your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of our services to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.

4.3 Individual Customers

We collect personal data related to individual customers.

A – Sources of personal data

We may obtain your personal data from the following sources:

1. from you directly (over email, website, app or online forms);
2. from MoyeClub’s affiliates, where we have your permission to access it or are allowed to access it based on lawful grounds [see the list in Annex 1];
3. from third parties (for example, partner organisations, such as payment gateways, affiliate programs for order fulfillment); and/or

B – Personal data that we collect and process

We may collect the following categories of personal data relating to our existing or prospective individual customers:

1. name;
2. email address;
3. phone number;
4. residence address;
5. shipping address;
6. gender
7. shipping type
8. payment type
9. credit card details
10. product details
11. any feedback you submitted about your experience with us.
12. operating system
13. browser type
14. IP address;
15. device token/ID
16. information on the use of our website (for example, pages visited, geographical location, time spent on the website, online transactions);
17. cookie data (for more information please see our Cookie Notice);
18. preferences regarding online marketing, browsing and account settings; and/or
19. body measurements (for example, height/weight, waist circumference, leg length, and fit preference)

C – Why do we collect your personal data and what are our lawful bases for it?

Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.

D – How long do we keep your personal data?

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.

4.4 Representatives of our Existing or Prospective Corporate Customers, Business Partners, and Vendors

We may collect personal data related to employees, directors, authorized signatories, or other individuals associated with MoyeClub’s existing or prospective corporate customers, business partners, and vendors.

A – Sources of personal data

We may obtain your personal data from the following sources:

1. from you directly,
2. from a company that employs you, if you are an employee of our existing or prospective customer, business partner, or vendor,
3. from MoyeClub’s affiliates (please see the list in Annex 1);
4. during networking events that we have either hosted, or sponsored, or attended; and/or
5. [from publicly available sources (for example, your company website or social media sites, such as LinkedIn)]

B – Personal data that we collect and process

We may collect the following categories of personal data relating to our existing or prospective customers’, business partners’, and vendors’ employees, officers, authorised signatories, and other associated individuals:

1. name;
2. business address;
3. business email address;
4. business telephone number; and/or
5. job title

C – Why do we collect your personal data and what are our lawful bases for it?

Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.

D – How long do we keep your personal data?

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with your business relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.

5. WHO DO WE SHARE YOUR PERSONAL DATA WITH

We share personal data relating to our customers and other business contacts among affiliates, and also with trusted third party vendors and business partners. The purposes for these transfers are set out below. We do not sell your personal data to third parties.

Our Partner Organisations and Service Providers

We may disclose information about you to organizations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.

We may share your information with the following types of service providers:

1. technical support providers who assist with our website and IT infrastructure,
2. third party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;
3. third party content providers, including interactive and social media providers, where the provider hosts the content and may collect personal data through embed code;
4. freight company and order fulfillment services in order to facilitate for shipment of orders;
5. customs and governing bodies in order to abide to declaration of goods;
6. customer service companies in order to facilitate for the investigation of customer or account queries;
7. professional advisers such as solicitors, accountants, tax advisors, auditors and insurance brokers;
8. providers that help us generate and collate reviews in relation to our goods and services;
9. our advertising and promotional agencies and consultants and those organisations or online platforms selected by us to carry out marketing campaigns on our behalf and to measure the delivery and effectiveness of such advertisements (for example, client campaign tracking); and/or
10. service providers that assist us in providing our services.

Law enforcement or government bodies

We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.

Company Mergers and Takeovers

We may transfer your personal data to potential purchasers and their advisors, subject to appropriate confidentiality obligations, in the event we decide to dispose of all or parts of our business.

6. TRANSFERS OF PERSONAL DATA OUTSIDE THE EU/EUROPEAN ECONOMIC AREA

We share your personal data with our affiliates in the EU and outside the EU, including the United States. International transfers with MoyeClub affiliates outside the EEA, are governed by EU Commission-approved Standard Contractual Clauses for Controllers and, where relevant, for Processors.

Some of the vendors that we engage to are located outside the European Economic Area. Where the EU Commission did not recognize them as locations providing adequate protection for personal data, we sign the EU Commission-approved contract (so-called Standard Contractual Clauses) to protect your data.

7. YOUR RIGHTS

You are entitled to obtain information from us on how we handle your personal data, to see copies of all personal data held by us and to request that your personal data is amended, corrected or deleted from our systems. You can also limit, restrict or object to the processing of your data. Where you have provided information to us in a machine readable format, you have the right to request we transmit this information back to you or to another organisation.

We do not carry out any decision-making based solely on automated processing, including profiling.

If you gave us your consent to use your data, e.g. so that we can send you marketing emails or display personalised ads, you can withdraw your consent at any time. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your personal data before you withdraw your consent.

You can object to our use of your personal data where we stated we rely on our legitimate business interests to do so. We explained the legitimate interests we rely on in sections ‘Why do we collect your personal data and what are our lawful bases for it?’ above.

These rights are not absolute and are subject to various conditions under:

• applicable data protection and privacy legislation; and
• the laws and regulations to which we are subject.

If you are unhappy with how we have dealt with your request or concern, you have the right to file a complaint with the relevant data protection supervisory authority.