Jelenew Incorporated (“JELENEW”, “we”, “our” and “us”) and our affiliates and subsidiaries take your privacy and the security of your personal information very seriously, and you must read this privacy policy (“Policy”) carefully to understand how we collect and process your personal information and click “accept” before you purchase our products or use our services. This Policy describes the type of information we collect relating to you and the ways we process and protect that information. This Policy is subject to modifications as our business grows, and your continuous use of our services means your acceptance of terms of the Policy. All references in this Policy to “App” include all of JELENEW’ s Apps. “Personal Information” or “Personal Data” as used in this Policy means information that can be used to identify you, directly or indirectly, alone or together with other information relating to you.
WHAT INFORMATION DOES JELENEW COLLECT RELATING TO ME?
We and our partners may collect necessary personal information relating to you when you purchase our products or use our services, including that you visit our websites, use our Apps, attend our events, visit our stores, communicate with us such as by e-mail, phone call or text message, interact with us through social media.
Personal Information:
•We may collect personal information of you necessary for selling products and providing services, including, but not limited to, your name, online account, physical or mailing address, telephone number or cellphone, and email address.
•If you create an account with us, we also collect your login and account information, including your username and password.
•When you purchase products from us, we will additionally collect your financial account, purchase details, billing address and shipping information.
•We may collect information about your personal preferences including marketing and cookie preferences.
•Third party devices may collect your health information, such as age, height, weight and heart rate when you choose to connect third party devices to our App. For example, Fitbit, Apple Watch, Garmin and other devices may collect your health information via our App to monitor your health conditions or sports activities.
Analytics Information:
We partner with Google Analytics to provide insight into our App, and to improve the relevance of advertisements you receive. Google Analytics’ Privacy Policy is available here: https://www.google.com/policies/privacy/.
We also partner with email service providers and marketing partners to better understand your interactions with our App and communications in order to personalize our marketing communications to you.
•Device Information: We collect information from and about the mobile phone and other devices that connect to your mobile phone, including GPS location, Bluetooth, Camera and Microphone when you choose to turn on, and device identifiers.
•Aggregate Information: Aggregate Information is information that does not identify you in any way. Aggregate Information may be collected when you visit our App, independent of any information you voluntarily enter. Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains. We may collect, use, store, and transfer Aggregate Information without subjecting to your consent.
•De-identified information: We may take then-available technologies and associated appropriate corporate measures to de-identify or encrypt your personal information to a degree that you are no longer to be identified with reasonable technical efforts. The de-identify information is not your personal information.
WHAT DOES JELENEW DO WITH THE INFORMATION IT COLLECTS?
We will only use your information for the purposes and by the means necessary for selling products and providing services set forth set forth in this Policy and provided in our Apps, unless you consent in prior to the process or transfer or the governing laws provide otherwise. We will not disclose or provide your Personal Information to third parties outside the scope other than as described in this Policy, unless you give us prior consent to do so. We do not sell or lease your information to third-parties.
•JELENEW’s use of your Personal, Analytics, and Device Information:
This information helps us operate our website, fulfill orders you place with us, and provide other services, including after-selling services, advertisements and technical support. We also use this information to suggest products and promotions to you, and to send you updates about our company, our events, and our initiatives.
•JELENEW’s sharing of Personal, Analytics, and Device Information:
We may share this information with our service providers to assist us with operating our App, selling our products and services, our advertising, and our technical support. We also share Personal Information with third parties to help us provide products and services to you such as fulfilling and delivering orders and processing payments. In these situations, you are using and directing us to intentionally disclose Personal Information so our products and services and your requests can be provided to you. If you place an international order through our App, your information will be shared with our third-party international reseller.
•Legal and Law Enforcement Requests:
We may disclose, at our sole discretion, your Personal, Analytics and Device information as required by law, or to comply with a legally binding request—such as a subpoena, warrant, or similar legally enforceable request for information.
We may also share and disclose your Personal, Analytics, and Device Information: (i) to investigate a possible crime, such as fraud or identity theft; (ii) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of JELENEW; (iii) when we believe it is necessary to protect the rights, property, or safety of JELENEW or other persons; or (iv) as otherwise required or permitted by law, including any contractual obligations of JELENEW.
DOES JELENEW USE COOKIES OR BEACONS AND OTHER TECHNOLOGIES?
Most websites, including our website, use “Cookies” – which are electronic files that websites place on a visitor’s computer to store information that makes each visit to the site more efficient. We use both “session” and “persistent” cookies on our website. A session cookie stores information about you only while you are visiting our site, then is deleted when you leave our site. Persistent cookies store information about you, your preferences, and information about other websites you visit, and it remains on your computer or device after you leave our website. To remove cookies, you may configure your browser to clear all cookies, or configure it to reject unnecessary cookies whenever you visit a new website. Please consult your browser’s user guide for specific instructions on removing cookies.
“Beacons” are small graphic files with a unique identifier that are used to track a web or mobile site user’s online movements. Unlike cookies, beacons are embedded on websites or in email communications, not downloaded on your computer or device. We use beacons to better manage and track content on our website and our marketing campaigns, and to better understand your interactions with our website and communications. Additionally, if you sign up for our SMS text messaging program, beacons may be used to personalize your experience (e.g. send you personalized text messages such as shopping cart reminders).
“Pixel” is often used in combination with cookies and is placed on a website or within the body of an email. It tracks activities when you browse websites or open emails.
“SDK or API” means Software Development Kit or Application Programming Interface, which is a set of tools or interface for third-party developers to use in producing applications using a particular framework or platform. For example, when you log in our App using a third party account, such as Google, Facebook or Apple, we integrate the third party’s SDK enabling your login.
We may also use other technologies to collect, store or analyze your Personal, Analytics and Device information.
DOES JELENEW COLLECT PAYMENT CARD INFORMATION THROUGH ITS App?
We partner with Shopify to process credit and debit card transactions completed through our App. Your credit or debit card information is never shared with us, and at no point in any transaction do we have access to that information. You should consult Shopify’s privacy Policy and terms of use to learn more about how it processes credit and debit card transactions for us by visiting https://www.shopify.com/legal/privacy.
DOES JELENEW TRACK MY ACTIVITY ACROSS OTHER WEBSITES?
When you visit our website, we automatically collect the name of the website you visited from (called the “referring page”) and the name of the website you chose to visit immediately after ours (called the “exit page”), and information about other websites you have recently visited. Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser. When our website detects a Do Not Track signal from your browser, it will still collect referring and exit page information and other information when you visit our website. We also receive information from social media sources such as Facebook (https://www.facebook.com/policy.php).
CAN I CHOOSE TO STOP RECEIVING MARKETING MESSAGES FROM JELENEW OR CHANGE MY PERSONAL INFORMATION?
If you opt-in, or when you purchase our products, we may send you newsletters and other messages, including marketing emails, SMS text messages, and other communication about our products and services, and to alert you to relevant advertisements and other opportunities. You can always choose to stop receiving newsletters or other communications from us by clicking the “unsubscribe” link at the bottom of any JELENEW marketing message. To stop receiving SMS text marketing communications from us, you may text “STOP”, “END”, “CANCEL”, “UNSUBSCRIBE”, or “QUIT” to a text message from us. After texting STOP, END, CANCEL, UNSUBSCRIBE or QUIT to our short code you will receive one additional message confirming that your request has been processed. If you unsubscribe from one of our text message programs, you may continue to receive text messages from us through any other programs you have joined until you separately unsubscribe from those programs.
You can delete, change, or update your Personal Information at any time by contacting us at connect service@jelenew.com. We may require you to provide certain information to verify that it is you making the request. However, note we will not delete information that we are required to retain in order to comply with applicable laws and regulations, or that we are required to retain in order to complete transactions with you.
CAN CHILDREN USE JELENEW’S APP?
Our App is not directed at children under 13 or ages older or younger than 13 as the applicable laws of each state or other countries provide otherwise, and we do not knowingly collect Personal Information from children under 13 directly or from other online services or Apps targeted at children without prior notification and parents’ approval. If you are the parent of a child under the age of 13, and you believe he or she has shared information with us, please contact us at connect service@jelenew.com so we can remove their information from our systems.
YOUR RIGHTS
Right to Know
You have the right to request that we disclose certain information to you about our collection of your personal information. Such information shall cover a limited period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the information that we have collected about you and the way that we process it.
Right to Access
We may provide you with a copy of your personal information in a machine readable way.
Right to Opt-Out
We do not sell your personal information, however, we are required to let you know that you have the right to opt-out of the sale of your personal information at any time if we ever engage in such activity.
Right to Delete
You have the right at any time to request that we delete your personal information. However, in some cases we cannot delete all or some of your personal information as required or permitted by applicable laws.
Right to Non-Discrimination
We will not discriminate against you for exercising your rights, such as denying you products and services, charging you different rates or prices including use of discounts or penalties, or suggesting or providing a different level of service or quality of products to you. We may offer you financial incentives such as programs, benefits, or other similar offerings, including payments to you as compensation, related to the collection, retention, or sale of your personal information. We also may offer price and services differences related to the collection, retention, or sale of your personal information.
How to contact us to exercise your rights:
To submit a request to exercise your rights, please contact us at connect service@jelenew.com. We will evaluate the request and provide information about how we will process your request and take further action where required to do so.
Verification of Requests and Authorized Agents
We may have to verify your identity when you contact us to exercise your rights. Our verification process may vary depending on the nature of your request. However, generally, we will verify your request by asking you to:
•Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.
•Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent to make a request on your behalf, unless you have provided the authorized agent with power of attorney, we may require that: (1) you provide your authorized agent signed permission to do so; (2) you verify your identity; and (3) you confirm that you have provided the authorized agent permission to submit the request. We may deny any request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf Your authorized agent may make a request on your behalf by contacting us at connect service@jelenew.com.
WHAT IF I LIVE OUTSIDE THE UNITED STATES?
If you are visiting us from the European Economic Area, Switzerland, or the United Kingdom, please see the “EUROPEAN USERS” section below. We are based in the US, and our App is operated there. If you are using our App from another country, the laws governing our App’s collection and use of personal information may be different from the laws of your country. If you decide to use our App, or share your Personal Information with JELENEW, you are agreeing to be governed by the laws of the US, and agree to the transfer of your information to the US.
Jelenew Incorporated (“JELENEW”, “we”, “our” and “us”) and our affiliates and subsidiaries take your privacy and the security of your personal information very seriously, and you must read this privacy policy (“Policy”) carefully to understand how we collect and process your personal information and click “accept” before you purchase our products or use our services. This Policy describes the type of information we collect relating to you and the ways we process and protect that information. This Policy is subject to modifications as our business grows, and your continuous use of our services means your acceptance of terms of the Policy. All references in this Policy to “App” include all of JELENEW’ s Apps. “Personal Information” or “Personal Data” as used in this Policy means information that can be used to identify you, directly or indirectly, alone or together with other information relating to you.
WHAT INFORMATION DOES JELENEW COLLECT RELATING TO ME?
We and our partners may collect necessary personal information relating to you when you purchase our products or use our services, including that you visit our websites, use our Apps, attend our events, visit our stores, communicate with us such as by e-mail, phone call or text message, interact with us through social media.
Personal Information:
•We may collect personal information of you necessary for selling products and providing services, including, but not limited to, your name, online account, physical or mailing address, telephone number or cellphone, and email address.
•If you create an account with us, we also collect your login and account information, including your username and password.
•When you purchase products from us, we will additionally collect your financial account, purchase details, billing address and shipping information.
•We may collect information about your personal preferences including marketing and cookie preferences.
•Third party devices may collect your health information, such as age, height, weight and heart rate when you choose to connect third party devices to our App. For example, Fitbit, Apple Watch, Garmin and other devices may collect your health information via our App to monitor your health conditions or sports activities.
Analytics Information:
We partner with Google Analytics to provide insight into our App, and to improve the relevance of advertisements you receive. Google Analytics’ Privacy Policy is available here: https://www.google.com/policies/privacy/.
We also partner with email service providers and marketing partners to better understand your interactions with our App and communications in order to personalize our marketing communications to you.
•Device Information: We collect information from and about the mobile phone and other devices that connect to your mobile phone, including GPS location, Bluetooth, Camera and Microphone when you choose to turn on, and device identifiers.
•Aggregate Information: Aggregate Information is information that does not identify you in any way. Aggregate Information may be collected when you visit our App, independent of any information you voluntarily enter. Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains. We may collect, use, store, and transfer Aggregate Information without subjecting to your consent.
•De-identified information: We may take then-available technologies and associated appropriate corporate measures to de-identify or encrypt your personal information to a degree that you are no longer to be identified with reasonable technical efforts. The de-identify information is not your personal information.
WHAT DOES JELENEW DO WITH THE INFORMATION IT COLLECTS?
We will only use your information for the purposes and by the means necessary for selling products and providing services set forth set forth in this Policy and provided in our Apps, unless you consent in prior to the process or transfer or the governing laws provide otherwise. We will not disclose or provide your Personal Information to third parties outside the scope other than as described in this Policy, unless you give us prior consent to do so. We do not sell or lease your information to third-parties.
•JELENEW’s use of your Personal, Analytics, and Device Information:
This information helps us operate our website, fulfill orders you place with us, and provide other services, including after-selling services, advertisements and technical support. We also use this information to suggest products and promotions to you, and to send you updates about our company, our events, and our initiatives.
•JELENEW’s sharing of Personal, Analytics, and Device Information:
We may share this information with our service providers to assist us with operating our App, selling our products and services, our advertising, and our technical support. We also share Personal Information with third parties to help us provide products and services to you such as fulfilling and delivering orders and processing payments. In these situations, you are using and directing us to intentionally disclose Personal Information so our products and services and your requests can be provided to you. If you place an international order through our App, your information will be shared with our third-party international reseller.
•Legal and Law Enforcement Requests:
We may disclose, at our sole discretion, your Personal, Analytics and Device information as required by law, or to comply with a legally binding request—such as a subpoena, warrant, or similar legally enforceable request for information.
We may also share and disclose your Personal, Analytics, and Device Information: (i) to investigate a possible crime, such as fraud or identity theft; (ii) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of JELENEW; (iii) when we believe it is necessary to protect the rights, property, or safety of JELENEW or other persons; or (iv) as otherwise required or permitted by law, including any contractual obligations of JELENEW.
DOES JELENEW USE COOKIES OR BEACONS AND OTHER TECHNOLOGIES?
Most websites, including our website, use “Cookies” – which are electronic files that websites place on a visitor’s computer to store information that makes each visit to the site more efficient. We use both “session” and “persistent” cookies on our website. A session cookie stores information about you only while you are visiting our site, then is deleted when you leave our site. Persistent cookies store information about you, your preferences, and information about other websites you visit, and it remains on your computer or device after you leave our website. To remove cookies, you may configure your browser to clear all cookies, or configure it to reject unnecessary cookies whenever you visit a new website. Please consult your browser’s user guide for specific instructions on removing cookies.
“Beacons” are small graphic files with a unique identifier that are used to track a web or mobile site user’s online movements. Unlike cookies, beacons are embedded on websites or in email communications, not downloaded on your computer or device. We use beacons to better manage and track content on our website and our marketing campaigns, and to better understand your interactions with our website and communications. Additionally, if you sign up for our SMS text messaging program, beacons may be used to personalize your experience (e.g. send you personalized text messages such as shopping cart reminders).
“Pixel” is often used in combination with cookies and is placed on a website or within the body of an email. It tracks activities when you browse websites or open emails.
“SDK or API” means Software Development Kit or Application Programming Interface, which is a set of tools or interface for third-party developers to use in producing applications using a particular framework or platform. For example, when you log in our App using a third party account, such as Google, Facebook or Apple, we integrate the third party’s SDK enabling your login.
We may also use other technologies to collect, store or analyze your Personal, Analytics and Device information.
DOES JELENEW COLLECT PAYMENT CARD INFORMATION THROUGH ITS App?
We partner with Shopify to process credit and debit card transactions completed through our App. Your credit or debit card information is never shared with us, and at no point in any transaction do we have access to that information. You should consult Shopify’s privacy Policy and terms of use to learn more about how it processes credit and debit card transactions for us by visiting https://www.shopify.com/legal/privacy.
DOES JELENEW TRACK MY ACTIVITY ACROSS OTHER WEBSITES?
When you visit our website, we automatically collect the name of the website you visited from (called the “referring page”) and the name of the website you chose to visit immediately after ours (called the “exit page”), and information about other websites you have recently visited. Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser. When our website detects a Do Not Track signal from your browser, it will still collect referring and exit page information and other information when you visit our website. We also receive information from social media sources such as Facebook (https://www.facebook.com/policy.php).
CAN I CHOOSE TO STOP RECEIVING MARKETING MESSAGES FROM JELENEW OR CHANGE MY PERSONAL INFORMATION?
If you opt-in, or when you purchase our products, we may send you newsletters and other messages, including marketing emails, SMS text messages, and other communication about our products and services, and to alert you to relevant advertisements and other opportunities. You can always choose to stop receiving newsletters or other communications from us by clicking the “unsubscribe” link at the bottom of any JELENEW marketing message. To stop receiving SMS text marketing communications from us, you may text “STOP”, “END”, “CANCEL”, “UNSUBSCRIBE”, or “QUIT” to a text message from us. After texting STOP, END, CANCEL, UNSUBSCRIBE or QUIT to our short code you will receive one additional message confirming that your request has been processed. If you unsubscribe from one of our text message programs, you may continue to receive text messages from us through any other programs you have joined until you separately unsubscribe from those programs.
You can delete, change, or update your Personal Information at any time by contacting us at connect service@jelenew.com. We may require you to provide certain information to verify that it is you making the request. However, note we will not delete information that we are required to retain in order to comply with applicable laws and regulations, or that we are required to retain in order to complete transactions with you.
CAN CHILDREN USE JELENEW’S APP?
Our App is not directed at children under 13 or ages older or younger than 13 as the applicable laws of each state or other countries provide otherwise, and we do not knowingly collect Personal Information from children under 13 directly or from other online services or Apps targeted at children without prior notification and parents’ approval. If you are the parent of a child under the age of 13, and you believe he or she has shared information with us, please contact us at connect service@jelenew.com so we can remove their information from our systems.
YOUR RIGHTS
Right to Know
You have the right to request that we disclose certain information to you about our collection of your personal information. Such information shall cover a limited period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the information that we have collected about you and the way that we process it.
Right to Access
We may provide you with a copy of your personal information in a machine readable way.
Right to Opt-Out
We do not sell your personal information, however, we are required to let you know that you have the right to opt-out of the sale of your personal information at any time if we ever engage in such activity.
Right to Delete
You have the right at any time to request that we delete your personal information. However, in some cases we cannot delete all or some of your personal information as required or permitted by applicable laws.
Right to Non-Discrimination
We will not discriminate against you for exercising your rights, such as denying you products and services, charging you different rates or prices including use of discounts or penalties, or suggesting or providing a different level of service or quality of products to you. We may offer you financial incentives such as programs, benefits, or other similar offerings, including payments to you as compensation, related to the collection, retention, or sale of your personal information. We also may offer price and services differences related to the collection, retention, or sale of your personal information.
How to contact us to exercise your rights:
To submit a request to exercise your rights, please contact us at connect service@jelenew.com. We will evaluate the request and provide information about how we will process your request and take further action where required to do so.
Verification of Requests and Authorized Agents
We may have to verify your identity when you contact us to exercise your rights. Our verification process may vary depending on the nature of your request. However, generally, we will verify your request by asking you to:
•Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.
•Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent to make a request on your behalf, unless you have provided the authorized agent with power of attorney, we may require that: (1) you provide your authorized agent signed permission to do so; (2) you verify your identity; and (3) you confirm that you have provided the authorized agent permission to submit the request. We may deny any request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf Your authorized agent may make a request on your behalf by contacting us at connect service@jelenew.com.
WHAT IF I LIVE OUTSIDE THE UNITED STATES?
If you are visiting us from the European Economic Area, Switzerland, or the United Kingdom, please see the “EUROPEAN USERS” section below. We are based in the US, and our App is operated there. If you are using our App from another country, the laws governing our App’s collection and use of personal information may be different from the laws of your country. If you decide to use our App, or share your Personal Information with JELENEW, you are agreeing to be governed by the laws of the US, and agree to the transfer of your information to the US.
EUROPEAN USERS
This section applies to all Personal Information (referred to as “personal data” in this section) collected by us from visitors and customers in the European Economic Area (“EEA”), the United Kingdom, Switzerland that are using our App. The processing of personal data is governed by the General Data Protection Regulation (“GDPR”) in the EEA, and similar data privacy laws in the United Kingdom and Switzerland. These laws require us to provide certain information regarding our processing of your personal data.
•Our Processing of personal data：
JELENEW may act as the data controller or processor of personal data you provide to us as the case may be under GDPR, and the purposes of our processing of personal data are described in this Policy and outlined below. For example, we are data controller in terms of your contact information, and the shipping services, as the processor, must use your contact information to deliver the products that you have purchased. We may also process personal data on other bases permitted by the GDPR and applicable laws. In general, we process personal data on the following legal grounds:
•Providing our products and services to you or performing a contract we have with you: In certain circumstances, we need your personal data to comply with our contractual obligation to deliver products you order from us. For example, if you buy our products through our App, we need your name and contact details so that we can communicate with you and deliver the products to you. In this case, your personal data is necessary to provide you with the products that you order. If you do not provide your personal data we will not be able to provide you with the requested products and services.
•When the processing is necessary for purposes of our legitimate business interest in conducting our business: For example, we have a legitimate interest in communicating information about our company and (subject to marketing authorizations) our commercial products, events, and company initiatives; and improving our App content and functionality. We take into account any risks to your fundamental rights and freedoms in assessing these purposes (including your right to privacy);
•When the processing is necessary for us to comply with our legal obligations; and
•When you give us the consent to process your personal data.
•Categories of personal data:
All categories of personal data collected and processed by us are described in this Policy.
•Recipients of personal data:
We use various service providers to manage our App, help us fulfill product orders, and assist us as described in this Policy. Our service providers change from time to time. Note that we require our service providers to treat your personal data in a manner that is consistent with this Policy. If you would like specific information about our service providers who have received your information, please contact us at connectservice@jelenew.com and we will provide that information to you. Additionally, your information will be shared with international resellers, when you make an international order on our App.
•Transfers of personal data outside of the EEA:
JELENEW is based in the US. and that’s where we process personal data. When you provide personal data to us, we transfer that personal data to the US. We treat the personal data of EEA users in accordance with this Policy. We take appropriate steps to protect your privacy and implement reasonable security measures to protect your personal data in storage. We also enter into contracts with our data processors that require them to treat personal data in a manner that is consistent with this Policy.
•Personal data retention:
We retain personal data so long as it is necessary for the purpose for which it was collected, and delete personal data after it is no longer needed for these purposes. This does not affect your right to request that we delete your personal data before the end of its retention period. We may archive personal data (which means storing it in inactive files) for a certain period of time prior to its final deletion, as part of our ordinary security measures and business continuity procedures.
•Your rights:
Right to access:
You have the right to access to your personal data and the following information:
(a) the purposes of the processing;
(b) the categories of personal data concerned;
(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, including recipients in third countries or international organizations;
(d) the period for which the personal data will be stored;
(e) rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
(f) the right to lodge a complaint with a supervisory authority;
(g) information that we collect from other sources other than you;
(h) the existence of automated decision-making, including profiling.
•Right of obtaining copies:
You have the right to request a copy of your personal data under our process. For any further copies requested by you, we will charge a reasonable fee based on administrative costs. Your right to obtain a copy shall not adversely affect the rights and freedoms of others.
•Right to rectify:
You have the right to obtain from us the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
•Right to erase (‘right to be forgotten’):
You have the right to obtain from us the erasure of personal data concerning you. We will assess under the context and following applicable laws to decide whether or not to erase your personal data. Where we have made the personal data public, we, taking account of available technology and the cost of implementation, may take reasonable steps, including technical measures, to inform interested parties which are processing your personal data.
•Right to restrict:
You have the right to restrict the process where one of the following applies:
(a) the accuracy of the personal data is contested;
(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
(c) we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
(d) you have objected to processing pending the verification whether the legitimate grounds of us override those of you.
•Right to data portability:
You have the right to receive the personal data concerning you, where the technology and costs permit, in a structured, commonly used and machine-readable format and have the right to transmit those data to third parties subject to laws applicable and shall not adversely affect the rights and freedoms of others.
•Right to object and automated individual decision-making:
You have the right to object to processing of personal data concerning you which is based on automated individual decision-making, including profiling and for the purpose of direct marketing purposes, subject to compelling legitimate grounds for the processing which may override the interests, rights and freedoms of you.
•Our response:
We will provide information on action taken on your requests under this Policy to you without unduly delay and in any event within three months of receipt of the request.
•Fees to exercise your rights:
Where your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee based on administrative costs, or refuse to act on the request.
WHAT IF I FOLLOW A LINK TO A THIRD-PARTY WEBSITE?
Our website and our social media posts may contain links to third-party websites. Those websites are governed by their own privacy and data use practices and policies. We do not have control over the privacy practices of the advertisers or other third-parties operating these websites, and we have no control over how these third parties collect or use the information you chose to share with them.
HOW DOES JELENEW PROTECT MY INFORMATION?
We take the security of your personal information very seriously. We use reasonable administrative, physical, and technical safeguards to secure the personal information you share with us. Despite these safeguards and our additional efforts to secure your information, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third-parties will not be able to defeat our security, and improperly collect, access, steal, or modify your personal information. In case of any incident or breach of data security, we, following applicable laws, will notify you of the incident and your personal data under treat, our remedial measures, the actions that you may take to reduce the adverse effect.
WILL JELENEW CHANGE THIS PRIVACY POLICY?
Each time you use our App the current version of this Policy will apply. This Policy may be amended from time to time for any reason, and we will post a new Policy on this page as indicated by the “last updated” date below. You should consult this Policy regularly for any changes. We will obtain your prior consent should the purposes or means of the our processing change substantially.
HOW DO I CONTACT JELENEW?
For questions about this Policy or about our privacy and information security practices generally, you can contact us at connect service@jelenew.com
Last updated: June 7, 2022
EUROPEAN USERS
This section applies to all Personal Information (referred to as “personal data” in this section) collected by us from visitors and customers in the European Economic Area (“EEA”), the United Kingdom, Switzerland that are using our App. The processing of personal data is governed by the General Data Protection Regulation (“GDPR”) in the EEA, and similar data privacy laws in the United Kingdom and Switzerland. These laws require us to provide certain information regarding our processing of your personal data.
•Our Processing of personal data：
JELENEW may act as the data controller or processor of personal data you provide to us as the case may be under GDPR, and the purposes of our processing of personal data are described in this Policy and outlined below. For example, we are data controller in terms of your contact information, and the shipping services, as the processor, must use your contact information to deliver the products that you have purchased. We may also process personal data on other bases permitted by the GDPR and applicable laws. In general, we process personal data on the following legal grounds:
•Providing our products and services to you or performing a contract we have with you: In certain circumstances, we need your personal data to comply with our contractual obligation to deliver products you order from us. For example, if you buy our products through our App, we need your name and contact details so that we can communicate with you and deliver the products to you. In this case, your personal data is necessary to provide you with the products that you order. If you do not provide your personal data we will not be able to provide you with the requested products and services.
•When the processing is necessary for purposes of our legitimate business interest in conducting our business: For example, we have a legitimate interest in communicating information about our company and (subject to marketing authorizations) our commercial products, events, and company initiatives; and improving our App content and functionality. We take into account any risks to your fundamental rights and freedoms in assessing these purposes (including your right to privacy);
•When the processing is necessary for us to comply with our legal obligations; and
•When you give us the consent to process your personal data.
•Categories of personal data:
All categories of personal data collected and processed by us are described in this Policy.
•Recipients of personal data:
We use various service providers to manage our App, help us fulfill product orders, and assist us as described in this Policy. Our service providers change from time to time. Note that we require our service providers to treat your personal data in a manner that is consistent with this Policy. If you would like specific information about our service providers who have received your information, please contact us at connectservice@jelenew.com and we will provide that information to you. Additionally, your information will be shared with international resellers, when you make an international order on our App.
•Transfers of personal data outside of the EEA:
JELENEW is based in the US. and that’s where we process personal data. When you provide personal data to us, we transfer that personal data to the US. We treat the personal data of EEA users in accordance with this Policy. We take appropriate steps to protect your privacy and implement reasonable security measures to protect your personal data in storage. We also enter into contracts with our data processors that require them to treat personal data in a manner that is consistent with this Policy.
•Personal data retention:
We retain personal data so long as it is necessary for the purpose for which it was collected, and delete personal data after it is no longer needed for these purposes. This does not affect your right to request that we delete your personal data before the end of its retention period. We may archive personal data (which means storing it in inactive files) for a certain period of time prior to its final deletion, as part of our ordinary security measures and business continuity procedures.
•Your rights:
Right to access:
You have the right to access to your personal data and the following information:
(a) the purposes of the processing;
(b) the categories of personal data concerned;
(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, including recipients in third countries or international organizations;
(d) the period for which the personal data will be stored;
(e) rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
(f) the right to lodge a complaint with a supervisory authority;
(g) information that we collect from other sources other than you;
(h) the existence of automated decision-making, including profiling.
•Right of obtaining copies:
You have the right to request a copy of your personal data under our process. For any further copies requested by you, we will charge a reasonable fee based on administrative costs. Your right to obtain a copy shall not adversely affect the rights and freedoms of others.
•Right to rectify:
You have the right to obtain from us the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
•Right to erase (‘right to be forgotten’):
You have the right to obtain from us the erasure of personal data concerning you. We will assess under the context and following applicable laws to decide whether or not to erase your personal data. Where we have made the personal data public, we, taking account of available technology and the cost of implementation, may take reasonable steps, including technical measures, to inform interested parties which are processing your personal data.
•Right to restrict:
You have the right to restrict the process where one of the following applies:
(a) the accuracy of the personal data is contested;
(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
(c) we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
(d) you have objected to processing pending the verification whether the legitimate grounds of us override those of you.
•Right to data portability:
You have the right to receive the personal data concerning you, where the technology and costs permit, in a structured, commonly used and machine-readable format and have the right to transmit those data to third parties subject to laws applicable and shall not adversely affect the rights and freedoms of others.
•Right to object and automated individual decision-making:
You have the right to object to processing of personal data concerning you which is based on automated individual decision-making, including profiling and for the purpose of direct marketing purposes, subject to compelling legitimate grounds for the processing which may override the interests, rights and freedoms of you.
•Our response:
We will provide information on action taken on your requests under this Policy to you without unduly delay and in any event within three months of receipt of the request.
•Fees to exercise your rights:
Where your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee based on administrative costs, or refuse to act on the request.
WHAT IF I FOLLOW A LINK TO A THIRD-PARTY WEBSITE?
Our website and our social media posts may contain links to third-party websites. Those websites are governed by their own privacy and data use practices and policies. We do not have control over the privacy practices of the advertisers or other third-parties operating these websites, and we have no control over how these third parties collect or use the information you chose to share with them.
HOW DOES JELENEW PROTECT MY INFORMATION?
We take the security of your personal information very seriously. We use reasonable administrative, physical, and technical safeguards to secure the personal information you share with us. Despite these safeguards and our additional efforts to secure your information, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third-parties will not be able to defeat our security, and improperly collect, access, steal, or modify your personal information. In case of any incident or breach of data security, we, following applicable laws, will notify you of the incident and your personal data under treat, our remedial measures, the actions that you may take to reduce the adverse effect.
WILL JELENEW CHANGE THIS PRIVACY POLICY?
Each time you use our App the current version of this Policy will apply. This Policy may be amended from time to time for any reason, and we will post a new Policy on this page as indicated by the “last updated” date below. You should consult this Policy regularly for any changes. We will obtain your prior consent should the purposes or means of the our processing change substantially.
HOW DO I CONTACT JELENEW?
For questions about this Policy or about our privacy and information security practices generally, you can contact us at connect service@jelenew.com
Last updated: June 7, 2022
