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Privacy Policy
This is the privacy notice of Artier SCP, owner of Ballet Papier © brand.
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), when you're registered as a member of our Ballet Papier Club and in case you become our Ambassador (in any of the categories). We’ll also tell you about your privacy rights and how the data protection law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below:
1. WHO WE ARE AND IMPORTANT INFORMATION
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR PERSONAL DATA
4. HOW WE USE YOUR PERSONAL DATA
5. WHO WE SHARE YOUR PERSONAL DATA WITH
9. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
10. QUERIES, REQUESTS OR CONCERNS
11.THE INFORMATION WE COLLECT FROM CHILDREN
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HOW WE USE IT
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HOW AND WHEN WE COMMUNICATE WITH PARENTS
1. WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product, become a member of our Ballet Papier club, Ambassador Programme or take part in a competition.
For data related to children click here.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Data controller(s)
Artier SCP is the controller and responsible for your personal data (collectively referred to as "Artier SCP ","BP", "we", "us" or "our" in this privacy notice). Our contact details are:
- Email at info@balletapier.com
- Phone (+34) 931 27 75 06
- Letter to Artier SCP, Calle Camelias 83-85, 6to-1ra, 08024 Barcelona, Spain
Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes Title, First Name and Last Name.
• Contact Data includes Billing Address, Delivery Address, Email Address and Telephone Numbers.
• Financial Data includes payment card details:
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All Credit and Debit card transactions are processed by our third party processors WIX, Stripe and PayPal and our checkout process is secured by SSL technology. Please note that we will never ask for your Credit/Debit Card information by email.
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In Offline Payment, you’ll receive our bank account information and you’ll be the one who will make the transfer. We won’t ask you for your bank account details, and your financial data will be processed directly from your bank company to our bank company.
• Transaction Data includes details about payments to and from you and details of products you have purchased from us.
• Technical Data includes IP Address, Your Login Data, Browser Type and Version and the Operating System and Platform.
We may also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
In the case you're an adult and we selected you to enter the Ballet Papier Ambassador Programme (consult the terms for under age participants here), we will maintain direct contact with you by email and send you all the information and and we'll ask you for the specific information request needed.
In this case, legal identification information will be required for assures that both parties in the agreement can properly identify the parties that will enforce the contract.
This information is:
-Name and surname
-Nationality
-Number of legal identification document
This information will be used only and exclusively in order to carry out the Ambassador-Brand relationship, and will not be shared or sold to third parties, keeping it stored and encrypted only for as long as this relationship remains in force.
In the event that you decide to cancel the agreement before the end of the agreement term, you must send a written notification to BP and BP undertakes to delete all the information stored for this purpose within the next 30 business days from the communication.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
• Directly. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Apply for our products or services;
• Subscribe to our services or publications;
• Request marketing to be sent to you
• Accept and sign our Ambassadors Programme Agreement
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Analytics providers such as Google based inside the EU
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal.
• Identity and Contact Data from publicly available sources.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting our Data Representative at info@balletpapier.com
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us on info@balletpapier.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in detailed list below:
1.- To register you as a new customer
Type of data
(a) Identity
(b) Contact
Lawful basis for processing including basis of legitimate interest
-Performance of a contract with you
2.- To process and deliver your order including:
-Manage payments, fees and charges
- Collect and recover money owed to us
Type of data
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
3.- To manage our relationship with you which will include:
- Notifying you about changes to our terms or privacy policy
- Asking you to leave a review or take a survey
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
4.- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Type of data
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing including basis of legitimate interest
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation
5.- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Lawful basis for processing including basis of legitimate interest
-Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to grow our business and to inform our marketing strategy)
6.- To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Type of data
(a) Technical
(b) Usage
Lawful basis for processing including basis of legitimate interest
-Necessary for our legitimate interests (to define types of customers for our products and services to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
7.- To make suggestions and recommendations to you about goods or services that may be of interest to you.
Type of data
a) Identity
b) Contact
c) Technical
Lawful basis for processing including basis of legitimate interest
-Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We have established the following personal data control mechanisms:
• Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
• Opting out
You can ask us to stop sending you marketing messages at any time by emailing info@balletpapier.com at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product or service experience or other transactions.
• Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Company on info@balletpapier.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• External Third Parties Service for example:
• Providers acting as processors based in the EU who provide IT, system administration and financial services.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the EU who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors based in the Spain who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers including contact, identity, financial and transaction data for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact the Company by emailing info@balletpapier.com
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 30th January 2020 and historic versions can be obtained by contacting us.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
10. QUERIES, REQUESTS OR CONCERNS
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our data protection officer on info@balletpapier.com
11.THE INFORMATION WE COLLECT FROM CHILDREN: HOW WE USE IT, AND HOW AND WHEN WE COMMUNICATE WITH PARENTS
We recommend you to read all the previous points before reading this section.
Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with General Data Protection Regulation (GDPR)'s requirements, we will either delete the information or immediately seek the parent's consent for that collection.
Registration
In certain cases, children can register with our Site to create and view associated content and view other's content. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian's email address, the child's account username, and password. We instruct children under the age of 13 to input their parent or guardian's email address and to not use their first or last name when creating a username. BP will not require a child to provide more information than is reasonably necessary in order to participate in the online activity.
About the collection of parent email address
We instruct children under the age of 13 to insert their parent's or guardian's email address upon registration. An email confirming registration will be sent to the address used. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please contact us at info@balletpapier.com to provide us permission or request that we delete the child's account and any associated information. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
Content Generated by a Child
Certain activities and applications on our Site allow children to create or manipulate content and save it with BP through the Site. None of these activities require children to provide any personal information and therefore do not result in notice to the parent or require parental consent. We strongly advise children to never insert personal information in their created content.
The default viewing setting for BP websites that allow children to create or manipulate content, and any associated information, is set to "private," meaning only the user who created the content may view it, in some cases it is not. Users are permitted to share their content publicly with other users. When a user chooses to make his/her content public, an email is automatically sent to the user's registered email address, which, in the case of children, will be the parent or guardian's email address. The email will inform the recipient of the change in status of the content, and instruct the recipient on how to change its status.
About Verifiable Parental Consent and the Ambassador Programme
In the event that BP wishes to collect additional personal information from a child, we will first seek a parent or guardian's consent by email, as in the case the child has being selected to enter the Ballet Papier Ambassador Programme. In this case, we will maintain direct contact with the child’s parents or legal guardians and send them through email all the information and specific information request needed. We will never accept children to enter this programme without consent and constant supervision of the parent or guardians.
In this case, as it will be communicated by e-mail to the parents or guardians, information of legal identification of both the parents / guardians and the child in question will be required for assures that both parties in the agreement can properly identify the parties that will enforce the contract.
This information is:
-Name and surname of the child and parents or guardians
-Nationality of the child and parents or guardians
-Number of legal identification document of the child and parents or guardians
This information will be used only and exclusively in order to carry out the Ambassador-Brand relationship, and will not be shared or sold to third parties, keeping it stored and encrypted only for as long as this relationship remains in force.
In the event that the parents or legal guardians decide to cancel the agreement before the end of the agreement term, they must send a written notification to BP and BP undertakes to delete all the information stored for this purpose within the next 30 business days from the communication.
Comments Board
Certain activities associated with the use of the Site may allow users to communicate directly with other users by means of a comments board (like commenting our Ballet Papier Club posts). We strongly encourage children who use these interactive features on our Site never to provide personal information about themselves or any third party. However, it is the responsibility of parents to carefully supervise their children when their children participate in online activities. BP is not responsible or liable for its publication of any user-generated content or information or any harm that flows from the dissemination of such content.
The Site's comments board may be operated by a third party. In those instances in which users post comments while logged in, the user's username and email address will be shared with the third party. A link to the third party's terms and policies will be provided as well.
Anonymous Information
When children interact with us, certain information may automatically be collected, both to make our Site more interesting and useful, and for purposes of statistical analysis and system improvements. Examples include the type of computer operating system, the user's IP address or mobile device identifier, the web browser, the frequency with which the user visits various parts of our Site, and information regarding the online or mobile service provider. This information may be collected by BP or by a third party. This data is principally used for internal purposes only, in order to:
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determine usage patterns;
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customize content and improve the Site; and
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conduct research and analysis to address the performance of the Site.
In the event we collect (or allow others to collect) such information from children on our Site for purposes other than above, we will notify parents and obtain consent prior to such collection.
When Information Collected From Children Is Available To Others
BP may share or disclose personal information collected from children in a limited number of instances, including the following:
BP may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
BP may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency's request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) to enable us to take precautions against liability.
Parental Choices and Controls
At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete information may lead to deletion of an account and associated content, groups and challenges.
Where a child has registered for an account, we use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:
Parents can request access to and delete their child's personal information by logging on to the child's account through the applicable BP Site home page. Parents will need their child's username and password. The account login page explains how to recover a password if the child cannot recall it.
Parents can contact BP to request access to, change, or delete their child's personal information by sending an email to us at: info@balletpapier.com
In any correspondence such as e-mail or mail, please include the child's username and the parent's email address and telephone number. To protect children's privacy and security, we will take reasonable steps to help verify a parent's identity before granting access to any personal information.
Ballet Papier is a brand used by Artier SCP Registered address: Calle Camelias 83-85, 6to-1ra, 08024 Barcelona, Spain Registered number: J66940560. Registered in Barcelona, Spain.