Effective date 14 February 2018
TRUE NORTH COSMETICS hereby informs you that many kinds of information are collected either directly from you or by following your interaction with TRUE NORTH COSMETICS’ websites. We may also combine information available from other sources with information we collect directly. We collect this information in order to offer you our products and services in the best possible way; to create a smooth shopping experience; and to operate our websites effectively.
“TRUE NORTH” refers to TRUE NORTH COSMETICS including its affiliates (also referred to as “we”, “us” or “our” as the context may require).
The information we collect on our websites includes personal data and other information. Personal data means any information on a private individual where this person is identified or identifiable. Because we care about your privacy we treat information we collect with care and in compliance with applicable data protection and privacy laws.
What information we collect
We collect information either directly from you or automatically as described below.
We collect information which is needed in order to:
- Fulfill your orders when shopping at our web stores
- Register as a member on our website and application and sign in to your account
- Complete any other requests related to the use of our websites, mobile application, products or services
Information collected directly from you includes for example your name, date of birth or age, gender, language, email addresses, telephone number, mailing address, payment details, username, password and the consents and feedback that you provide on our websites.
Information we obtain from your use of our website and services
Information on your purchases
We collect information relating to your purchases and your other interactions with us. Such information includes for example details of ordered products and deliveries, credit card details, billing address and other transactional information. We may also keep record of contacts or communication you have with our Customer Service within the limits permitted according to applicable law. We may also use third party providers to process your payment, in which case you will be redirected to such third-party providers’ pages.
How we process and use your personal data
TRUE NORTH uses and processes personal data collected on its websites for the purposes described below. “Processing information here means the collection, recording, organization, use, transfer, disclosure, storage, manipulation, combination, protection, deletion and erasure of personal data.
We use your personal data to:
- Provide, personalize and improve the products offered to you, ensure the functionality of our services and operate our websites
- Process your orders and perform any contract between you and TRUE NORTH
- Identify you as well as prevent and investigate fraud and other misuse
- Communicate with you for marketing and research purposes (for instance to conduct market researcher to inform you about new products or promotions). Prior to using your personal data for marketing purposes, we will obtain your consent as requested in relevant applicable laws
We may combine information you have given us while interacting with our products and services in retail stores where our products are sold with information obtained from your interaction at TRUE NORTH websites, for instance as a member of the community.
How we share your personal data
We share your personal data with the parties indicated below and for the following reasons:
2. International transfers. Our services may be provided using resources and servers located in various countries, partly located outside of EU. Therefore, your personal data may be transferred across international borders outside the country where you use our services. In the case the personal data is transferred outside of EU/EEA, we will take care of the transfer on contractual measures (e.g. using European Commissions Standard Contractual Clauses) and also on that the transfer has an appropriate legal basis and that the data processing and secrecy fulfills the requirements in relevant laws.
3. Lawful requests. We may be required by mandatory legislation to respond to legal proceedings or lawful requests to disclose your personal data to certain authorities or third parties.
4. Protection of our interests and combating fraud. We may also disclose or otherwise process your personal data, in accordance with applicable laws, to defend TRUE NORTH ‘s legitimate interests (for example, in civil or criminal legal proceedings) and when combating fraud.
5. Mergers and acquisitions. In case of reorganization of our businesses (for example mergers and acquisitions), we may disclose your personal data to prospective or actual purchasers or their advisers.
Personal data of children
Product orders will only be accepted by us if the consumer is 18 years old or more. Therefore, we do not collect personal data of children.
Steps taken to safeguard your personal data
Only appointed personnel of TRUE NORTH and third party companies operating on behalf of TRUE NORTH or on TRUE NORTH’s assignment (referred to as “Authorized third parties”) are entitled to access or process customer personal data. All persons processing such data have a personal right of use granted by TRUE NORTH. Different levels of access have been created based on the type of data a person needs to access or process according to his/her job description. Our systems are firewall protected. Manually kept and processed documents which include customer personal data are stored in locked premises. Only specifically authorized personnel of TRUE NORTH or Authorized third parties are entitled to access or process such manually kept customer personal data. All TRUE NORTH personnel or personnel from Authorized third party who is granted access to customer personal data are required to keep such data confidential.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Your rights regarding your personal data
TRUE NORTH wishes to ensure that the personal data we possess is accurate and therefore encourages you to update your information in case of any changes. We also take necessary steps to delete incorrect or unnecessary personal data.
You can access and manage your profile and personal data from your own account. You will be required to sign in with your user name and password to access your own profile. If you cannot access personal data collected by TRUE NORTH via your own account pages, please contact our Customer Service.
You have a right to unsubscribe to our marketing messages and to request that we stop processing your personal data for direct marketing or market research purposes. In order to opt out from marketing messages, simply follow the opt-out link included in all marketing e-mails. Please note that TRUE NORTH may need some additional information in order to identify you and fulfill your request. Please also note that relevant applicable laws may contain restrictions and other provisions relating to your rights regarding your personal data. Finally, note that even if you have opted out from marketing and other communications from TRUE NORTH, we may still contact you or communicate with you to send you critical alerts relating to our products or services.
You have various choices in relation to your personal data. These include:
- Not to provide your data (though you will then not be able to order from our Web site).
- Not to provide optional data (as indicated in web forms).
- To withdraw your consent to use your personal data, as above.
- To update your personal data, in which case we will delete the old data (which will still remain available on our servers backups for 60 days)
- To update your preferences with regard to how we contact you.
- To change your browser settings to block cookies, be alerted when you receive a cookie or to disable cookies.
Cookies are small files, typically of letters and numbers, placed on your computer or device by a web server when you access certain websites. Cookies are stored in your web browser when you browse our websites.
- Allow you to have a seamless experience and move from page to page without signing in again
- Store your preferences
- Select and display targeted advertisements and recommendations
- Promote our products in our websites and in selected third party websites
- Collect site analytics and improve our websites.
TRUE NORTH may use web beacons (also called “pixel tags”) in connection with its web pages. Web beacons are electronic images placed on a website that typically help us access certain cookies on the website, enable us to count visitors on our websites and help us improve our services. Web beacons collect, for example, information about visits from your IP-address.
Our TRUE NORTH websites may use so called “flash cookies”, i.e. Flash Local Shared Objects to store data on your computer or device. These flash cookies are used in particular when our websites use Adobe Flash technologies and are used for similar purposes as browser cookies.
Who is the controller of your personal data
The controller of your personal data is:
TRUE NORTH COSMETICS AsP
How to contact us
In general privacy issues, in issues relating to your account or to opt out from marketing messages, please contact our Customer Service.