Effective: 04.24.2021
Last Updated: 04.24.2021
The Exquisite Workers Privacy Policy is designed to help you better understand the information we collect and the different ways we may use or share it.
This Policy applies to your use of the Exquisite Workers' Services. By "Exquisite Workers' Services," we mean any of our websites, stores or other products or services that link to this Policy. Additional terms and conditions may also apply to your relationship with Exquisite Workers, LLC, depending on how you choose to interact with us. Please read this entire policy to make sure you fully understand it and confirm that you understand and agree to them, before using the Exquisite Workers' Services.
We collect, use and are responsible for certain personal information about you. When we do so we are compliant with the laws of the Spain, and subject to the General Data Protection Regulation which applies across the European Union (including in the United Kingdom and Switzerland), and we are responsible as "controller" of that personal information for the purposes of those laws.
- Your name and contact information, including email address and telephone number;
- Information to enable us to check and verify your identity, and whether you are of appropriate age to access content, e.g., your date of birth;
- Your gender information, if you choose to give this to us;
- Location data, if you choose to give this to us;
- Your billing information, transaction and payment card information, as applicable;
- Your interests and preferences;
- Your contact history, purchase history and saved items;
- Information from accounts you link to us, e.g. Facebook, Instagram, and/or other platforms;
- Information about how you use our website, IT, communication and other systems;
- Your responses to surveys, competitions, and promotions;
- Data, content, videos, photos, and any other information you provide via public posts, interactions, comments, and other chat or communication features.
This personal information is required to provide Services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing Services to you.
PERSONAL INFORMATION WE COLLECT ABOUT YOU
We collect most of this personal information directly from you, by email and/or via our website and apps. However, we may also collect information:
- From publicly accessible sources;
- From a Third Party with your consent, e.g., your bank or credit card provider. When you interact with Exquisite Workers on a website or app not controlled by Exquisite Workers, that website or app may allow Exquisite Workers access to certain information about you. For example, social networks may provide us with information from your profile on their services or other information that you agreed the social network or other party could provide to us. We may add this to the information we have already collected from you via our Service in order to improve it. We do not collect Personal Data automatically, but we may tie the information that we collect automatically to Personal Data about you that we collect from other sources or that you provide to us;
- From Log Files. This information includes IP addresses, browser type, Internet service provider ("ISP"), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Service, track users' movements around the Service, gather demographic information about our user base as a whole, and better tailor our Services to our users' needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.
- From Cookies. "Cookies" are small pieces of information that a website sends to your computer's hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Service. This type of information is collected to make the Service more useful to you and to tailor the experience with us to meet your special interests and needs;
- From Pixel Tag. "Pixel Tags" also referred to as clear Gifs, Web beacons, or Web bugs, are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user's computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users' Personal Data.
- Via our IT and Third-Party systems, automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email, and instant messaging systems;
- From our servers. To make our Service more useful to you, our servers (which may be hosted by a Third-Party service provider) collect information from you, including your browser type, operating system, Internet Protocol ("IP") address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session) and/or a date/time stamp for your visit;
- From Analytics Services. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Service. This includes Third-Party analytics services, including but not limited to Google Analytics ("Analytics Services"), that we engage to help analyze how Users use the Service. We may receive reports based on these Parties' use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Service. The information generated by the Cookies or other technologies about your use of our Service (the "Analytics Information") is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services' ability to use and share Analytics Information is restricted by such Analytics Services' Terms of Use and Privacy Policy. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.
HOW YOUR PERSONAL INFORMATION IS COLLECTED
As a general matter, we use and share the information we collect (either individually or in combination with other information collected as described in this Policy) to help us provide, improve, customize, analyze, and market the Exquisite Workers' Services where we have an appropriate basis to do so.
HOW AND WHY WE USE YOUR PERSONAL INFORMATION
1. Service Providers We MAY share personal information with service providers that we have engaged to help support the
Exquisite Workers' Services by performing certain Services on our behalf and under our instructions. For example, if you make a purchase on the
Exquisite Workers Services, we will generally share your billing information with a Third-Party payment processor to enable your transaction. Other common examples include partners that assist with cloud storage, email marketing of products and services, monitoring and securing the
Exquisite Workers' Services. These Service providers ARE NOT authorized by us to use or disclose personal information except as necessary to perform services on our behalf or comply with legal requirements.
2. Affiliates
We MAY share personal information we collect with
Exquisite Workers' partners and subsidiaries to support the
Exquisite Workers' Services worldwide.
3. Marketing & Business Partners We MAY share certain limited information, such as device identifiers, with marketing & business partners for purposes of executing and optimizing campaigns, and gauging the effectiveness of advertising and other marketing & business strategies solely on
Exquisite Workers's behalf. When
Exquisite Workers provides your information to these business partners and publishers, their use and disclosure of the information is governed by limitations in our agreements with them. However, they also provide their end users with privacy notices or policies that govern their use of your information. Personal information you share with them or that is not provided by
Exquisite Workers will be subject to the developers' and publishers' privacy notices and policies, and MAY NOT be subject to this Policy.
4. Corporate Restructuring We MAY share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
5.
As Legally Required Regardless of any choices you make regarding your Personal Data (as described below), we may also disclose information about you: (i) if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (iii) if necessary to protect the vital interests of another individual (such as to prevent death, bodily harm, or serious damage to property); (iv) to comply with relevant laws or to respond to subpoenas or warrants served on
Exquisite Workers; (v) to protect or defend the rights or property of
Exquisite Workers or users of the Service; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
6. Other Disclosures We MAY also disclose your Personal Data, to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent.
Exquisite Workers only uses the personal information we collect to help provide, support, and improve the
Exquisite Workers' Services as described in this Policy. WE DO NOT SELL YOUR PERSONAL DATA.
1. Our reasons- To provide Services to you;
- For the performance of our Agreement to provide Services to you or to take steps at your request before entering into an Agreement;
- To prevent and detect fraud against you or Exquisite Workers;
- For our legitimate interests or those of a Third-Party;
- To comply with our legal and regulatory obligations;
- To identify our customers and verify their identity;
- Ensuring business policies are adhered to, eg policies covering security and internet use;
- For our legitimate interests or those of a Third-Party, i.e., to make sure we are following our own internal procedures so we can deliver the best Service to you;
- Operational reasons, such as improving efficiency, training and quality control;
- Ensuring the confidentiality of commercially sensitive information;
- To help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures;
- To prevent unauthorized access and modifications to systems;
- For our legitimate interests or those of a Third-Party, i.e., to prevent and detect criminal activity that could be damaging for us and for you;
- To update and enhance customer records;
- To execute Marketing of our Services and those of selected Third-Parties to:- existing and former customers; - Third-Parties who have previously expressed an interest in our Services; - Third-Parties with whom we have had no previous dealings;
- To send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Exquisite Workers.
- To respond to your inquiries related to employment opportunities or other requests.
2.
Promotional Communications We may use your personal information to send you updates (by email, text message, telephone, mail, or in-app) about our Services, including exclusive offers, promotions or new Services. We have a legitimate interest in processing your personal information for promotional purposes (see above "How and why we use your personal information"). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. You have the right to opt-out of receiving promotional communications at any time by:
- contacting us;
- using the "unsubscribe" link in emails;
- updating your marketing preferences on our website.
We MAY ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
WHAT WE USE YOUR PERSONAL INFORMATION FOR
We routinely share personal information with:
- Third-Parties we use to help deliver our services to you, e.g., payment service providers;
- Third-Parties that use the information to perform services on our behalf and/or help us run our business. These Third-Parties provide a variety of services to us, including without limitation: sales, marketing, website hosting, provision of content and features, advertising, analytics, research, data storage, security, fraud prevention, bug reporting, crash reporting, in-app chats, user surveys, and other services;
- Third-Parties approved by you, e.g., social media sites you choose to link your account to or Third-Party payment providers;
- Our insurers and brokers;
- Our bank(s);
- Third-Parties we use to collect and analyze data for compliance, website improvement, and for scientific research, including but not limited to data science teams and data visualization tools.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only access, process, store, or use your personal information in furtherance of providing services to us and to you. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We MAY also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this MAY NOT always be possible. The recipient of the information will be bound by confidentiality obligations.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
Information may be held at our offices, Third-Party agencies, service providers, representatives and agents as described above (see above: "Who we share your personal information with"). Some of these Third-Parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: "Transferring your personal information out of the EEA".
WHERE YOUR PERSONAL INFORMATION IS HELD
We will keep your personal information while we are providing Services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly;
- To keep records required by applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.
We will not retain your personal information for longer than necessary for the purposes set out in this Policy.
HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
To deliver Services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:
- With our offices outside the EEA;
- With your and our service providers located outside the EEA;
- If you are based outside the EEA;
- Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law. The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: Switzerland. These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.
TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE EEA
We seek to provide you with meaningful choices about the personal information you share with
Exquisite Workers, as well as the ways we may use or share that information. We will generally only ask you for personal information that is necessary to provide the
Exquisite Workers' Services you request. You can choose not to give us personal information we request, but if you decide not to, you MAY NOT be able to access certain parts of the
Exquisite Workers' services and some features may not work as intended. We MAY also seek your prior consent to process your information in certain ways. You are not required to provide consent if you do not want your personal information to be processed for the requested purposes, and may withdraw your consent at any time. Any withdrawal of consent is only effective on a going-forward basis and will not impact processing we undertook while relying on your consent. We provide you with the ability to request access to, and correction or deletion of, your personal information.
You have
several choices regarding the use of information on our Services:
- Email Communications. We will periodically send you free, opt-in newsletters and e-mails that directly promote the use of our Service. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly. Despite your indicated e-mail preferences, we may send you occasional service related communications, including notices of updates to our Terms of Use or Privacy Policy.
- If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser's technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know by contacting us (see below: "How to contact us").
YOUR CHOICES AND CONTROLS
EEA and UK Residents. If you are an EEA or UK resident, you MAY have:
a) The right of access. The right to be provided with a copy of your personal information; b) Rectification. The right to require us to correct any mistakes in your personal information; c) To be forgotten. The right to require us to delete your personal information, in certain situations; d) Restriction of processing. The right to require us to restrict processing of your personal information, in certain circumstances, e.g., if you contest the accuracy of the data; e) Data portability. The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations; f) To object. At any time to your personal information being processed for direct marketing (including profiling) and in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests; g) Not to be subject to automated individual decision-making, (including profiling) that produces legal effects concerning you or similarly significantly affects you.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the Spanish Information Commissioner's Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- Email, call, or write to us (see below: "How to contact us");
- Let us have enough information to identify you (e.g., your full name and email address);
- Let us have proof of your identity (e.g., a copy of your driver's license or passport / ID); and
- Let us know what right you want to exercise and the information to which your request relates.
EEA and UK residents may contact
Exquisite Workers's data protection officer with any questions or concerns about our handling of personal information at
hello@exquisiteworkers.com. EEA and UK residents also have the right to lodge a complaint with a data protection authority if they have concerns about
Exquisite Workers' handling of personal information.
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way. We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through on Service. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
However, no security system is impenetrable and we cannot guarantee the security of our Service 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
KEEPING YOUR PERSONAL INFORMATION SECURE
We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Exquisite Workers and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us (see below: "How to contact us").
This privacy notice was published on 4/24/2021 and last updated on 4/24/2021. This Policy may be updated periodically to reflect changes in our personal information practices or relevant laws. We will indicate at the top of this Policy when this policy was last updated. Please review this policy every time you access or use the Exquisite Workers' Services to make sure that you have reviewed the most recent version.
CHANGES TO THIS PRIVACY NOTICE
Please contact us by email if you have any questions about this Privacy Policy or the information we hold about you, complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address:
Exquisite Workers, LLC
28, Quevedo Street
Barcelona, Spain, 08012
Hello@exquisiteworkers.com If you would like this notice in another format (e.g.,: audio, large print, braille) please contact us (see above: "How to contact us").
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
- To comply with our legal and regulatory obligations. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
- For the performance of our agreement to provide services to you or to take steps at your request before entering into an Agreement;
- For our legitimate interests or those of a third party;
- Where you have given consent.