Privacy Policy

Please note Qlupa S.L are the official owner of the Qlupa® brand globally. The official website is: www.Qlupa.com

This is the privacy notice of Qlupa (Registered trading name of Qlupa). In this document the terms, “we”, “our”, or “us” refer to the company called Qlupa.

Introduction

The following written text is a notice to inform you of our policy about all information that we record about you individually and or your ‘company’. The following written text sets out the conditions under which we may process any information that we collect from you, or any data that you provide to us via communication. This covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. We have created the privacy policy in compliance with the new GDPR General Data Protection Regulations that legally apply to businesses or organisations in the European Union. Or those outside the EU who offer goods and services (whether paid or not) to people living within the EU.
We regret to inform you that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party. Personal data is typically any information that can directly or indirectly identify a particular individual and can include: Name, Address, Email Address, last four credit card digits, National Insurance Number, Order reference number, Delivery tracking numbers ( these are unique to an order, and thus to a person), Location Data or IP Address. Sensitive personal data is considered to be information on race, health status, political beliefs, sexual orientation and political beliefs.
We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.
Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
With the new GDPR (General Data Protection Regulation) it’s your entitlement to have your personal data records corrected or removed from this website via submitting a written request.

What information we collect about you

We collect information about you when you provide it to us, when you use our Services or products, and when other sources provide it to us, as further described below.

The information you provide to us

We collect information about you when you input it into our web-page or otherwise provide it directly to us via written, verbal, telephone or email communication.

Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through our web-page. For example, you provide your contact information and, in some cases, billing information when you create an account to make a purchase from us.
The content you provide through our products: Where you engage our services to purchase products, you may also provide further data for us to provide additional services that may incur appointed business partners to become involved. This content includes any information about you that you may choose to include.
The content you provide through our websites: We collect other content that you submit to these websites. For example, you provide content to us when you provide feedback, social sharing, comments, forum interaction if applicable, reviewing products or when you participate in surveys. This also includes providing reviews and feedback for 3rd party services that are linked to the website.
The information you provide through our support channels: We also provide you with customer support, where you may choose to submit information regarding a problem you are experiencing with a product/service. If you chose to submit such information you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screen-shots, photographic evidence or information that would be helpful in resolving the issue.

Information we collect automatically when you use the Services

We collect information about you when you use our web-page, including browsing our websites and taking certain actions within the web-page.

Your use of our web-page: We keep track of certain information about you when you visit and interact with our website including interaction and page viewing data.
Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access our web-page. This device information includes your connection type and settings when you install, access, update or use our web-page. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services. We actively store tracking information for up to a period of 50 months so we can continually the website user experience based on this data. To use location and map direction services within the website we request your IP location and postcode data to perform these search tasks.
Cookies and Other Tracking Technologies: Our company in accordance with third-party partners, such as our advertising and analytic partners, use cookies and other tracking technologies (e.g., device identifiers, web beacons, and pixels) to provide functionality and to recognise you across different services and or devices.

Information on how we use the data collected

To provide a good service and personalise your experience: we use information about you to provide goods and services to you including processing transactions and providing customer support. To communicate with you about our goods and services: we use your contact information to send transactional communications to you via email, social posts, telephone, third-party messaging platforms, SMS text and or posted letters to provide customer support and/or technical advice. To display it on our website: our website (and/or third-party review site) allows you to post information with a view to that information being read, copied, downloaded, or used by other people. E.g. posting a message or review of our goods and services In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it. We do not specifically use this information except to allow it to be displayed or shared. We do store it, and we reserve a right to use it in the future in any way we decide. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no legal responsibility for their actions at any time. To communicate latest offers and developments within the company: We use your contact information to send promotional and informative newsletters to you. This may also include but is not limited to: contact by telephone, third-party messaging services, emails, social media posts, written letters and digital documents. This will only be done if you have expressly consented to receive these types of communications. To provide customer support: we use your information to resolve technical issues you encounter and to assist with any other enquiries you may have. When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have provided to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. This may include inputting the information into our company CRM customer relation management software database for example. We keep personally identifiable information associated with your messages, such as your name, telephone contact number, company name, email address and postal address so as to be able to track our communications with you to provide a premium quality service. To process a complaint: when we receive a complaint, we record all the information you have given to us and we use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint.

We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person. To process payment of your order with our company: payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it. At the point of payment, you are transferred to a secure page service on the website of our merchant gateway provider for security compliance reasons. That page may be branded to look like a page on our website, but it is not controlled by us. If providing card details over the phone to one of our Customer Care Representatives, the call recording will be masked to ensure that your details are not stored by us and will not be physically written or remembered. For security and safety: we use information about you and your account to verify accounts and activity and to monitor suspicious or fraudulent activity. For any other use you have consented to: we use your information where you have given us consent to do so for a specific purpose that is not listed in this policy e.g. we may request your written consent to publish and use imagery, feedback or written information that you have supplied on our website or incorporation in to a newsletter or any company literature/media publication. If you have consented to our use of information about yourself or company, you have the right to change your mind at any time but this will not affect processing that has already taken place. Please note once content has been distributed via printed material or online digital publishing we are unable to retract and or withdraw the information from circulation in the public domain.

Affiliate and business partner information

This is information given to us by you in your capacity as an affiliate of us or as a business partner. It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals if applicable. It also includes information that allows us to transfer commission to you should this be relevant. The information is not used for any other purpose. We undertake to preserve the confidentiality of the information and of the terms of our relationship. We expect any affiliate or partner to agree to reciprocate this policy. Use of information we collect through automated systems when you visit our website

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that the overall user experience can be continually improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use. This website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use. When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose. If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website. We use cookies in the following ways:

To keep you signed in our site
To track how you use our website
To record whether you have seen specific messages we display on our website
To record your answers to surveys and questionnaires on our site while you complete them
To record the conversation thread during a live chat session with our support team

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our websites, such as the type of computer, operating system or device and the screen resolution. This also includes website behaviour, demographics, interests and acquisition data. We use this information in aggregate to assess the popularity of the web-pages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve you an advert for our products or services when you visit some other website. We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information. Information we process because we have a contractual obligation to you When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract, we must process the information you give us. Some of this information may be personal information. We may use it in order to:

Sell products or services to you (private individual) or your company
Provide you (private individual) or your company with our goods and services
Verify your identity for security purposes
Provide you with suggestions, information, technical data and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. Additionally, we may aggregate this information in a general way and use it to provide class information, for example, to monitor our performance with respect to a particular service we provide. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

The Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking for your agreement to our use of cookies. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail, write a comment, or add a thread within a forum to which you would reasonably expect us to reply. Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example, to monitor the performance of a particular page on our website. If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us at customerservices @ Qlupa.com or by sending a message via the Contact Us page of this website. However, if you do so, you may not be able to use our website or our services further.

Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to:

Whether the same objective could be achieved through other means
Whether processing (or not processing) might cause you harm

For example, we may process your data on this basis for the purposes of:

Responding to unsolicited communication from you to which we believe you would expect a response
Record-keeping for the proper and necessary administration of our business
Protecting and asserting the legal rights of any party
Insuring against or obtaining professional advice that is required to manage business risk
Protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This could also include a debt agency in the pursuit of any outstanding funds owed to the company for any services or products provided that remain unpaid. This may include your personal information.

Disclosure and sharing of your information

Sharing with third parties We share information with third parties that help us operate, provide, improve, integrate, customise, support and market our services or products.

Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, re-marketing, e-marketing, shopping functionality, social interaction, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information. All third party vendors are carefully sourced and must be compliant with EU General Data Protection Regulation (GDPR) requirements.
The company currently works with third parties who provide consulting, marketing, sales, support and technical services to deliver and implement customer solutions.
With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.

Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to: 1) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, 2) Enforce our agreements, policies and terms of service, 3) Protect the security or integrity of our products and services, 4) Protect our company and or website, our customers or the public from harm or illegal activities, or 5) Respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

Credit reference: to assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
Qlupa® Ltd is a global company and personal data collected by this Web Site may be transferred among our various divisions and affiliated companies around the world located inside or outside the European Economic Area (EEA), as well to data processors outside of the Qlupa® Ltd. By submitting data on this Web Site, you consent to such transfer.
Data may be processed outside the European Union: our websites are hosted in the UK. We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business. Accordingly, data obtained within the UK or any other country could be processed outside the European Union. Please note that certain website services from 3rd party vendors may be supplied and facilitated by companies operating outside of the European Union
Our Suppliers and/or Agents: where you have entered into a contract with us for the supply of goods and services, we may need to share your information with our Suppliers and/or Agents to ensure fulfilment of this contract.

For example, if you enter into a contract and purchase a product or service, it will be necessary for us to provide our couriers or company representatives with certain information (delivery address and contact details), to fulfil the contract. The information will only be shared if it is necessary to the fulfilment of the contract.

Access to your own information

Access to your personal information: at any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website. To obtain a copy of any information that is not provided on our website you may send us a request at customerservices @ Qlupa.com. After receiving the request, we will provide an approximate time when you can expect to receive the information, and whether we require any fee for providing it to you.

Removal of your information: If you wish us to remove personally identifiable information from our website and/or database, you may contact us at customerservices @ Qlupa.com. This may limit the service we can provide to you.
Verification of your information: when we receive any request to access, edit or delete personally identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information in accordance with the EU General Data Protection Regulation (GDPR).
Responding to your requests: we will endeavour to deal with your subject access request without undue delay and in any event within one month of receipt of your request. However, if the work involved is particularly complex or if numerous requests are made then we may extend this period by up to six additional months dependent on complexity and in the event of no additional resources being available due to exceeding current demands. In this case, we will inform you about the extension and explain the reasons. to specify your opt-out preferences.

We will not charge a fee for dealing with your request unless it is manifestly unfounded or excessive. If we charge a fee, we will inform you of this and explain the reasons for doing so to gain your written authorisation and consent prior to starting. When a payment is deemed necessary to complete your request we will require full payment prior to starting the agreed request. We will explain what steps have been taken in dealing with your request i.e. we will set out the source of your personal information we have gathered. If you are not satisfied with our actions, you can outline your dissatisfaction by email to us at customerservices @ Qlupa.com. If you remain dissatisfied, you have the right to refer the matter to the Information Commissioner Office (ICO) or seek recourse through the courts within the United Kingdom. Other matters Use of site by children: we do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with the consent and full supervision from a parent or legal guardian. Encryption of data sent between us: we use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust marks in your browser’s URL bar or toolbar. You can also verify this by ensuring that the URL starts with https:// (as opposed to http://) How you can complain: If you are not happy with our privacy policy or have any complaints then you should inform us in writing by sending an email message to: customerservices @ Qlupa.com. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration. If you are in any way dissatisfied with how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/ Retention period for personal data: except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

To provide you with the services you have requested;
To comply with other law, including for the period demanded by our tax authorities;
To support a claim or defence in court.
When you have requested a customer account to be set up so we can provide an order history summary.
Whilst you have an active account on the website and not closed or requested closure by contacting our customer service department.

Compliance with the law: our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you. However, ultimately it is your choice as to whether you wish to use our website. We endeavour to be fully compliant with the EU General Data Protection Regulations (GDPR) and protect your personal data. Review of this privacy policy: we may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records. If you have any question regarding our privacy policy, please contact us. We reserve the right, at our sole discretion, to change, modify, add or remove portions from this Privacy Policy at any time. Your continued use of the Web Site following the posting of changes to these terms means you accept these changes. If you have any questions about this Privacy Policy please contact

Malware, Trojans & Virus Threats

We take all appropriate organisational and technical security measures to protect your personal data and has thus, implemented necessary security measures in order to safeguard your data. However, in the event of your personal data being compromised due to a malware, hacking, security vulnerability, trojan or virus threat attack we will not be legally responsible for this action and the perpetrator will be fully accountable including any claims for compensation and or damages. If you suspect that your personal data has been compromised by directly or indirectly using this website please report this by contacting the company immediately via telephone or email. In order to protect your own personal data when entering information into input fields on this website, we recommend ensuring your device is protected by a suitable security application that is updated to the latest version.

Outsourcing of services

When we have to outsource some or all of our data processing requirements to hosted (including cloud-based) services in the capacity of the controller. We carefully select a third-party provider or processor that gives sufficient guarantees about its security measures. To make sure they have appropriate security arrangements in place by conducting an assessment. All third party service providers or processors are under full obligation to erase data and dispose of or recycle any ICT equipment that may contain your personal data to ensure the information can no longer be accessed.

Website plugins and 3rd party services disclosure

On this website we use the following plugins, 3rd party software and vendor services. We have professionally assessed these 3rd party providers before implementation in accordance with GDPR (General Data Protection Regulation) to protect your personal data. However, even though we have conducted a risk assessment to protect your data when using these services we cannot guarantee a breach could occur and the processor will be fully legally liable due to these circumstances. We currently use tracking session cookies to provide abandoned cart notifications once the customer/site visitor has entered their email address during checkout but the payment transaction process remains incomplete. Google Analytics and Adwords are connected to the website to collect and analyse users so we can improve the visitor experience. This also includes the implementation of re-marketing Google Adword campaigns and advanced analytical reporting by recording user sessions with Google Tag Manager. Users can sign-up to the mailing list on the website and all email marketing activity is conducted by MailChimp or a similar provider with user details ‘personal data’ stored on these online platforms via password protection. All orders on this website are stored in the admin area even when a guest checkout is conducted allowing us to process the order and despatch the goods. Customers creating an account can access their order history and all details will remain present if this is not requested. We also use a 3rd party plugin to generate PDF invoice and packaging slips that are stored in the website database and cleared / deleted every 3 months. The website is protected by security software and the name will not be disclosed to reduce the risk from hackers. Implemented on the website we use Search Engine Optimisation plugins to monitor activity and visitor statistics allowing us to continually improve the user experience, this information is never disclosed and remains strictly private. Any live chat sessions are conducted by 3rd party software that is out of our control, however, we have professionally assessed the suitability of the application in relation with GDPR (General Data Protection Regulation) and any communication threads can be sent via email up to a period of two weeks after the conversation before deletion. The website is fully backed up and archived every 4 hours to the hosting server via encryption and remotely via a 3rd party plugin connecting with Google Drive. We have not named any of the plugins or software providers to reduce the risk of hacking or security vulnerability exploits.