HAVE CUSTOMERS IN EUROPE]

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

[INCLUDE ALL THAT APPLY TO YOUR BUSINESS]

• Your consent;
• The performance of the contract between you and the Site;
• Compliance with our legal obligations;
• To protect your vital interests;
• To perform a task carried out in the public interest;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We [DO/DO NOT] engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

• Temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a small number of hours.
• Temporary blacklist of credit cards associated with blacklisted IP addresses. This blacklist persists for a small number of days.

Selling Personal Information

[INCLUDE THIS SECTION IF YOUR BUSINESS IS SUBJECT TO THE CALIFORNIA CONSUMER PRIVACY ACT AND SELLS PERSONAL INFORMATION AS DEFINED BY THE CALIFORNIA CONSUMER PRIVACY ACT]

Our Site sells Personal Information, as defined by the California Consumer Privacy Act of 2018 (“CCPA”).

[Insert:

• categories of information sold;
• IF USING SHOPIFY AUDIENCES: information about your use of the Site, your purchases, and the email address associated with your purchase
• instructions on how to opt-out of sale;
• whether your business sells information of minors (under 16) and whether you obtain affirmative authorization;
• if you provide a financial incentive to sell information, provide information about what that incentive is.]

 

Your rights

[INCLUDE FOLLOWING SECTION IF YOUR STORE IS LOCATED IN OR IF YOU HAVE CUSTOMERS IN EUROPE]

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above. [OR INSERT ALTERNATIVE INSTRUCTIONS FOR SENDING ACCESS, ERASURE, CORRECTION, AND PORTABILITY REQUESTS]

Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

[INCLUDE FOLLOWING SECTION IF YOUR BUSINESS IS SUBJECT TO THE CALIFORNIA CONSUMER PRIVACY ACT]

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above. [OR INSERT ALTERNATIVE INSTRUCTIONS FOR SENDING ACCESS, ERASURE, CORRECTION, AND PORTABILITY REQUESTS]

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address above.

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