Privacy Policy

Clarion Events – Spirit of Christmas

Shop Privacy Policy – 04/11/2020 V1.1

 

1. Introduction

Spirit of Christmas Shop is owned by Clarion Events Limited and operated by ShowShoppa Ltd. Your purchases are made directly with the individual Sellers. Your privacy on the Internet is of the utmost importance to us. We want to make your experience online satisfying and safe.

IN THIS PRIVACY POLICY:

·  ‘we’, ‘us’ or ‘our’ means the Clarion Group entity with which you are interacting as detailed above. For example, the Clarion Group entity organising the event you are attending, or managing the website you are using. We will make it clear to you which entity this is;

·  ‘the site’ means the Clarion website you are visiting or engaging with; and

·  ‘you’ and ‘your’ means you, the person engaging with us, registering for our events or services or visiting our site.

BY VISITING THIS SITE OR OTHERWISE INTERACTING WITH US, WE WILL PROCESS YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY AND APPLICABLE DATA PROTECTION AND PRIVACY LAWS.

YOU CAN VIEW THE CLARION GROUP PRIVACY POLICY HERE

2. How you can contact us:

Group Address:     

FAO the Data Protection Officer, Clarion Events, Bedford House,
69-79 Fulham High Street, London, SW63JW, United Kingdom. 

Email: privacy@clarionevents.com

3. Information we may collect about you

Information you give us:

Because we gather certain types of information about our users, we feel you should fully understand our policy and the terms and conditions surrounding the capture and use of that information. This privacy statement discloses what information we gather and how we use it.  

For what Purposes we gather your Information:

Purchase and delivery of products and services.

We use your personal information to enable the Shop and individual Vendors, to take and handle orders, deliver products and services, process payments, and communicate with you about orders, products and services, and promotional offers.

When purchasing products your data will be processed by the Shopify Payments Service.

For more information please see the Shopify Privacy Policy

The Shopify Payments service (“Shopify Payments” or the “Payments Services”) is a: (i) payment account boarding; (ii) payment underwriting; and, (iii) payment data transmission service. Who is appointed to deliver information and instructions on your behalf to the Processor.

Neither Shopify Inc. nor Shopify International Limited is a bank, payment institution, or money services business, but are instead, respectively, a supplier of the Shopify Platform Services supplied under the Shopify Platform Terms and of the Payments Services.

The Processor is Stripe Payments Europe, Ltd., organized under the laws of Ireland, which is a technical services provider and may offer the services as an agent of one or more financial institutions in the United Kingdom (each, a “Financial Services Provider”).

The Processor’s role is to accept and process credit card, debit card and other types of payments (collectively “Cards”) with respect to sales of products and services through internet-based transactions (“Card Not Present Transactions" or “CNP Transactions”).

Provide, troubleshoot, and improve our shop services to you. We use your personal information to provide

functionality, analyse performance, fix errors, and improve usability and effectiveness of the shop products and services.

Recommendations and personalisation.

We use your personal information to recommend features, products, and services that might be of interest to you, identify your preferences, and personalise your experience.

Users may provide information through optional, voluntary submissions to receive our electronic newsletters, to participate in our message boards or forums, to email a friend, and from participation in polls, surveys and competitions.

Tracking Information.

We gather insight through aggregated tracking information, derived mainly by tallying page views throughout our sites (meaning data that is not identifiable to any individual user). This information allows us to better tailor our content to users’ needs and to help our suppliers, advertisers and sponsors better understand the demographics of our audience. Because we derive revenue mainly from online sales, providing such aggregated demographic data is essential. Under no circumstances do we divulge any information about an individual user to any third party.

Comply with legal obligations, Prevent Fraud and Reduce Credit Risks.

We process personal information to prevent and detect fraud and abuse in order to protect the security of our customers, our sellers, and others. The Shopify Payments Service may also use scoring methods to assess and manage credit risks.

Optional Voluntary Information:

We offer the following services, which may require voluntary submission of personal information by users:

"E‐mail this to a friend" policy

Our site users can choose to electronically forward a link, page, or documents to someone else by clicking "e‐mail this to a friend". The user must provide their email address, as well as that of the recipient. This information is used only in the case of transmission errors and, of course, to let the recipient know who sent the email. The information is not used for any other purpose.

Your participation on our Site may mean that we occasionally contact you with the opportunity to enter competitions. Entry to competitions is voluntary, and you are under no obligation to take up an invitation from us to enter. Should you choose to enter a competition, we will treat the information you provide with the same high standard of care as all other customer information, and use the information provided strictly within the entry terms of the competition and this Privacy Statement.

Polling:

We may offer interactive polls to users so they can easily share their opinions with other users and see what our audience thinks about important issues. Opinions or other responses to polls are aggregated and are not identifiable to any particular user. We may use a system to "tag" users after they have voted, so they can vote only once on a particular question. This tag is not correlated with information about individual users.

Surveys:

We may occasionally conduct user surveys to better target our content to our audience. We sometimes share the aggregated demographic information in these surveys with our sponsors, advertisers and partners. We never share any of this information about specific individuals with any third party.

·      Sensitive personal data

If collecting or storing sensitive personal data such as information relating to health, beliefs or political affiliation, we typically ask for your explicit consent. However, there are some situations where it will not be possible to request consent, such as if you have an accident at one of our events. If this does occur, we will ensure your privacy rights are protected.

·     Children’s personal data

Our products and services are not intended for children under the age of 13 and we do not knowingly collect personal data from this age group. If any information is collected from a child under the age of 13 without verification of parental consent, it will be deleted.

Usage tracking:

We track user traffic patterns throughout all of our sites. We break down overall usage statistics according to a user’s domain name, browser type, and MIME type by reading this information from the browser string (information contained in every user's browser).

We sometimes track and catalogue the search terms that users enter in our Search function, but this tracking is never associated with individual users. We use tracking information to determine which areas of our site’s users like and do not like based on traffic to those areas. We do not track what individual users read, but rather how well each page performs overall. This helps us continue to build a better service for you.

Cookies:

We may place a text file called a "cookie" in the browser files of your computer. The cookie itself does not contain Personal Information although it will enable us to relate your use of this site to information that you have specifically and knowingly provided. But the only personal information a cookie can contain is information you supply yourself. A cookie cannot read data off your hard disk or read cookie files created by other sites. ShowShoppa Ltd uses cookies to track user traffic patterns (as described above). Our advertising system delivers a one‐time cookie to better track ad impressions and click rates.

You can refuse cookies by turning them off in your browser. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. You do not need to have cookies turned on to use this site. However, you do need cookies to participate actively in message boards, forums, polling, surveys and competitions.

Use of Information:

We use any information voluntarily given by our users to enhance their experience in our network of sites or products, whether to provide interactive or personalised elements on the sites or to better prepare future content based on the interests of our users.

As stated above, we use information that users voluntarily provide in order to fulfil orders, send out electronic newsletters and to enable users to participate in polls, surveys, competitions, message boards, and forums. We send out newsletters to subscribers on a regular schedule (depending on the newsletter), and occasionally send out special editions when we think subscribers might be particularly interested in something we are doing. We never share newsletter mailing lists with any third parties, including advertisers, sponsors or partners.

When we use tracking information to determine which areas of our sites users like and do not like based on traffic to those areas, we do not track what individual users read, but rather how well each page performs overall. This helps us continue to build a better service for you. We track search terms entered in Search function as one of many measures of what interests our users. But we do not track which terms a particular user enters.

We create aggregate reports on user demographics and traffic patterns for advertisers, sponsors and partners. This allows our suppliers and advertisers to advertise more effectively, and allows our users to receive advertisements that are pertinent to their needs. Because we do not track the usage patterns of individual users, an advertiser or sponsor will never know that a specific user clicked their ad. We will not disclose any information about any individual user except to comply with applicable law or valid legal process or to protect the personal safety of our users or the public.

Security:

We operate secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised individuals have access to the information provided by our customers.

For Marketing

To keep in contact with you about other similar events or services of ours that may be of interest to you, send you newsletters, offers or other marketing emails that keep you up to date with our news, events and products that may be of interest or for research purposes to analyse the effectiveness of our products and offerings to you.

Depending on the nature of your interaction with us and applicable data protection laws, you may have actively given us your consent (i.e. opted in) or we may be entitled to rely on your implied consent or legitimate interests to market to you. The opportunity to opt out of future marketing will always be provided and you have the right to amend your marketing preferences at any time (see Your Rights in section 6). 

Legal Basis: It is our legitimate interest to keep you up to date on similar events and products of ours you have engaged with in the past.  Where we rely on legitimate interests in this way, we will always offer an unsubscribe options or a preference management tool on any marketing or research information we send you.

Third Party Content, Sites, and Contributions

SOME OF OUR WEBSITES MAY CONTAIN CONTENT AND LINKS TO OTHER WEBSITES OR APPS THAT ARE OPERATED BY THIRD PARTIES. WE DON’T CONTROL THESE THIRD PARTY WEBSITES OR APPS (INCLUDING WHETHER OR NOT THEY STORE COOKIES) AND THIS PRIVACY POLICY DOES NOT APPLY TO THEM. PLEASE CONSULT THE TERMS AND CONDITIONS AND PRIVACY POLICY OF THE RELEVANT THIRD PARTY WEBSITE OR APP TO FIND OUT HOW THAT SITE/APP COLLECTS AND USES YOUR INFORMATION AND TO ESTABLISH WHETHER AND FOR WHAT PURPOSE THEY USE COOKIES.

4. How we look after your data and how long we keep it for

WE USE A VARIETY OF TECHNOLOGICAL AND OPERATIONAL SECURITY MEASURES TO PROTECT YOUR INFORMATION AGAINST ANY UNAUTHORISED ACCESS TO, UNLAWFUL USE OF, AND MODIFICATION AND DESTRUCTION OF ANY PERSONAL DATA WE STORE.

WE WILL RETAIN YOUR INFORMATION FOR AS LONG AS IS NECESSARY TO PROVIDE YOU WITH THE SERVICES THAT YOU HAVE REQUESTED FROM US, OR FOR AS LONG AS THE LAW OTHERWISE PERMITS.  WHERE YOU HAVE NOT PARTICIPATED, ATTENDED OR REGISTERED TO ATTEND OR PARTICIPATE IN ONE OF OUR EVENTS, OR OTHERWISE ENGAGED WITH US IN FOUR YEARS, WE WILL DELETE YOUR DATA, UNLESS WE HAVE AN OBLIGATION TO RETAIN IT FOR LONGER (FOR EXAMPLE FOR TAXATION PURPOSES).

TRANSMISSION OF INFORMATION OVER THE INTERNET CAN BE INSECURE, AND ALTHOUGH WE EMPLOY MEASURES TO PROTECT YOUR INFORMATION FROM UNAUTHORISED ACCESS WE CANNOT ALWAYS GUARANTEE THE SECURITY OF INFORMATION SENT OVER THE INTERNET.

5. Where we store your information

WHERE YOU ARE INTERACTING WITH A CLARION ENTITY LOCATED INSIDE THE EU, OUR SERVERS ARE SITUATED INSIDE THE EUROPEAN ECONOMIC AREA (EEA) AND ALL OF THE INFORMATION THAT WE COLLECT ABOUT YOU WILL BE STORED ON THESE SERVERS.

IN CERTAIN CIRCUMSTANCES YOUR INFORMATION MAY BE PROCESSED OUTSIDE OF THE EEA SUCH AS WHEN ANOTHER CLARION GROUP ENTITY ASSISTS US WITH THE SERVICES YOU HAVE REQUESTED FROM US, OR WE ENGAGE THIRD PARTIES BASED OUTSIDE OF THE EEA.  THIS COULD ALSO BE FOR EXAMPLE WHERE YOU HAVE SIGNED UP TO EXHIBIT, SPONSOR OR ATTEND AN EVENT OUTSIDE THE EEA.  IN SUCH CIRCUMSTANCES, WE WILL TAKE ALL STEPS NECESSARY TO ENSURE THAT ANY OF YOUR INFORMATION IS ADEQUATELY PROTECTED AND PROCESSED IN ACCORDANCE WITH THIS PRIVACY POLICY, AND WHERE NECESSARY, WE PUT IN PLACE RELEVANT SAFEGUARDS TO ENSURE THE SAFE PROCESSING OF YOUR DATA. 

Some Clarion Websites, products and services are operated out of the United States. If you are located in another jurisdiction, please be aware that information you provide to us, in relation to such websites, products and services, may be transferred to, stored and processed in the United States.

By using these Websites or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws are not as comprehensive as those in the country where you reside or are a citizen, such as the European Union. You understand that the U.S. government can obtain access to the Personal Data you submit if necessary for investigative purposes (e.g., terrorism investigation). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We use appropriate and suitable safeguards such as EU Standard Contractual Clauses (EU Model Clauses) for transferring your Personal Data to the U.S.

6. Your rights in relation to your Personal Data

THE CLARION GROUP OPERATES IN COUNTRIES WITH DATA PROTECTION LAWS THAT MAY PROVIDE INDIVIDUALS WITH THE RIGHT TO BE ABLE TO ACCESS AND CONTROL THEIR INFORMATION. WE WILL ALWAYS ENABLE YOU TO EXERCISE THE RIGHTS PROVIDED BY THE APPROPRIATE DATA PROTECTION LAWS.

6.1            YOUR EU DATA SUBJECT RIGHTS

IF YOU ARE A RESIDENT OF THE EUROPEAN ECONOMIC AREA (EEA), WE COLLECT AND PROCESS PERSONAL DATA ABOUT YOU ONLY WHERE WE HAVE A LEGAL BASIS FOR DOING SO UNDER APPLICABLE DATA PROTECTION LAW, INCLUDING UNDER THE EUROPEAN GENERAL DATA PROTECTION REGULATION (GDPR). THE LEGAL BASES WILL DEPEND ON THE PURPOSE FOR WHICH WE PROCESS YOUR PERSONAL DATA AS GENERALLY DESCRIBED IN SECTION 4.

YOU HAVE THE RIGHT TO:

·        REQUEST ACCESS TO YOUR PERSONAL DATA

·        REQUEST CORRECTION OF YOUR PERSONAL DATA

·        REQUEST ERASURE OF YOUR PERSONAL DATA

·        OBJECT TO PROCESSING OF YOUR PERSONAL DATA

·        REQUEST RESTRICTION OF PROCESSING YOUR PERSONAL DATA

·        REQUEST TRANSFER OF YOUR PERSONAL DATA

·        RIGHT TO WITHDRAW CONSENT

IF YOU WISH TO EXERCISE ANY OF THE RIGHTS SET OUT ABOVE, PLEASE CONTACT THE DPO (DETAILS BELOW).

IF YOU BELIEVE WE HAVE NOT COMPLIED WITH ANY APPLICABLE DATA PROTECTION LAW YOU CAN LODGE A COMPLAINT WITH THE UK DATA PROTECTION AUTHORITY.  IN THE UK, THE RELEVANT AUTHORITY IS THE INFORMATION COMMISSIONERS OFFICE, YOU CAN FIND THEIR DETAILS AT WWW.ICO.ORG.UK

We note that we are a “controller” for those services where we make decisions on how personal information is used in connection with our services, and we are a “processor” for those services where we only use personal information as allowed by our customers.

UK & EU Data Subjects – How to contact us:

Group Address:      FAO the Data Protection Officer, Clarion Events, Bedford House,
69-79 Fulham High Street, London, SW63JW, United Kingdom. 

Email:                   privacy@clarionevents.com

Clarion Events Companies outside the EU

·            Synergy B.V. and Clarion Events Limited act as the EU/UK Representatives for Clarion Events Inc. where non-UK & EU events are processing EU & UK Data. Where you believe that we have not complied with our obligation under this Privacy Policy or European data protection law, you have the right to make a complaint to any EU or UK Data Protection Authority, such as the UK Information Commissioner’s Office www.ico.org.uk.

6.2            CALIFORNIA PRIVACY RIGHTS

This section explains the rights of certain natural persons residing in the State of California (each, a “consumer”) may have under the California Consumer Privacy Act 2018 and such rules and regulations as may be adopted from time to time implementing and interpreting such Act (collectively, “CCPA”). The use of the term “personal information” does so as CCPA defines it, to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal information does not include publicly available, deidentified, or aggregate consumer information (which are all defined in CCPA). Also, the definition of “personal information” does not currently apply to the collection of personal information from job applicants, employees (whether you are our employee or any employee of our customers), business owners, directors, officers, medical staff or contractors.

Where we act as a “business” under CCPA (meaning we determine the manner and reasons for why we process your personal information), we may be required to disclose additional information regarding the categories of personal information we collect, the sources where we obtain that information, the purposes for why we collect that information, who we share that information with, as well as whether we sell that personal information – all of which depends on the specific service being provided.

Depending on your relationship with us, we may have collected each of the above categories of Personal Information about you. In addition, we may have shared one or more of these categories of Personal Information with third parties during the preceding 12 months for the business purposes described in this Privacy Policy.

California Residents - How to contact us:

If you are a resident of California and are not a job applicant, employee/contractor, or employee/contractor of another company interacting with us in your job role, you have the right to request what category of personal information we collect about you, how we use that personal information, and the categories of third parties we disclose that personal information.

You also have the right to request that we delete your information.

To make a request, you can contact us at +1 203 344 7118​ and ask for the US Data Privacy Officer or by email to our Data Privacy Officer at usprivacy@clarionevents.com  

or in writing to: Clarion Events Inc, Attention: Data Privacy Officer, Clarion Events, Inc. Suite 125, 35 Nutmeg Drive, Trumbull, Connecticut, 06611, United States.

Please provide us enough information to verify your identity. We will use information you provide to us to verify your request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as, for example, a copy of your driver’s license and/or a recent utility or credit card bill.

California residents also have certain rights regarding the “sale” of “personal information” (as such terms may be defined by CCPA). California residents have the right to opt out of such “sale” of their “personal information” in accordance with CCPA by sending an email to our Data Privacy Officer at usprivacy@clarionevents.com or in writing to: Clarion Events Inc, Attention: Data Privacy Officer, Clarion Events Inc., Attention: Data Privacy Officer, Clarion Events, Inc. Suite 125, 35 Nutmeg Drive, Trumbull, Connecticut, 06611, United States.

We will not discriminate against you because you have exercised any of your privacy rights under the CCPA.

 

7. Your Consent and Changes to this Privacy Policy

By using this site, you consent to the collection and use of this information. If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.