GDPR Privacy Notice
Louise K. Shaw (“Louise K. Shaw”)
GDPR Notice
Effective Date: 7 July 2023
This GDPR privacy notice (this “GDPR Notice”) is included in our Privacy Policy. It applies to the ‘personal data,’ as defined in the GDPR, of natural persons located in the European Economic Area (“EEA Individuals,” “you,” or “your”) processed by Louise K. Shaw. Any capitalised terms or other terms not defined herein shall have the meaning ascribed to them in the Louise K. Shaw Privacy Policy or if not defined herein or in the Privacy Policy, the GDPR. To the extent of any conflict between this GDPR Notice and any other provision of the Privacy Policy, this GDPR Notice shall control only for EEA Individuals and their data. If you are located elsewhere, please see our Privacy Policy here.
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The term “European Economic Area” (or “EEA”) shall mean the then-current member states and member countries of the European Union and European Economic Area, respectively, Switzerland, and, upon its withdrawal from the European Union, the United Kingdom.
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Controller Disclosure & Details: We are a data controller of personal data regarding the following categories of EEA Individuals: Visitors and Registered Users (collectively, “Customers”) and affiliate partners and vendor contacts (collectively, “Business Contacts”) for the purposes and under the legal bases described in the table below. Please note that, in some cases, the categories of data subjects above may overlap (e.g., Visitors and Registered Users using the Websites).
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DATA SUBJECT CATEGORY:
General (applies to all data subjects below)
Purpose & Legal Basis of Processing
Information Security: Our web servers will log your IP address and other information (e.g., browser information, operating system, request date/time, user agent string, referral and exiting URL) to maintain an audit log of activities performed. We use this information under our legitimate interests in tracking usage of the Websites, combating DDOS or other attacks, and removing or defending against malicious visitors.
DATA SUBJECT CATEGORY:
Customers
Purpose & Legal Basis of Processing
Direct Marketing: We will generally provide email marketing (e.g., our newsletter) pursuant to a Customer’s consent. In cases where a Customer buys or enters into negotiation for the sale of a product or service, email marketing shall be sent to such Customer pursuant to our legitimate interest in sending marketing communications to such Customer in the context of a sale.
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Rewards and Promotions: Louise K. Shaw, our promotional and marketing partners (e.g., affiliate partners), and customers’ legitimate interest in administering our rewards and promotional offerings. For example, after purchasing a Louise K. Shaw product or service, we share your name and email address with the referring affiliate partner only to the extent that such affiliate partners have offered you bonuses or rewards for following their referral link.
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Testimonials or Feedback: Our legitimate interest in using testimonials, feedback, or survey responses from Customers for marketing purposes, such as posting on the Websites or within sales decks, pitches, or other promotional content (e.g., email marketing).
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Executing Contracts and other Legal Documentation: We will process all personal data as necessary for the performance of contracts to which Customers are a party (such as our Terms of Use or Privacy Policy, or a purchase of our products or services) or to take requested steps to enter into such contracts.
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General Business Development: Our legitimate interest in furthering business relationships (such as by storing Customer information within a CRM or other database/file), ensuring customer satisfaction, and answering inquiries.
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Audience Measurement and Retargeting: Pursuant to a Visitor’s consent, we use an assortment of marketing and analytics cookies for purposes of audience measurement, retargeting, and creating relevant Visitor experiences (such as based on their interaction with our Websites).
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DATA SUBJECT CATEGORY:
Business Contacts
Purpose & Legal Basis of Processing
Affiliate Partners: We will process all personal data as necessary for the performance of contracts to which our affiliate partners are a party (e.g., our affiliate partner terms) or to take requested steps to enter into such contracts (e.g., completing our affiliate partner application).
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Vendor Contacts: When entering into vendor relationships, we will receive the personal information of contacts employed or otherwise associated with such vendors. We process such information in our legitimate interest in establishing and developing our vendor relationships.
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Controller’s EU Representative: Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Louise K. Shaw has appointed the European Data Protection Office (EDPO) as its GDPR representative in the EU.
Avenue Huart Hamoir, 71
1030 Brussels/Belgium
privacy@edpo.com
edpo.com/gdpr-data-request
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Controller’s UK Representative: Pursuant to the UK GDPR, Louise K. Shaw has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters of the UK GDPR:
EDPO UK at 8 Northumberland Avenue
London WC2N 5BY, United Kingdom
edpo.com/uk-gdpr-data-request
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Categories of Recipients: Louise K. Shaw personnel will process the categories of EEA Individuals’ (as listed above) information appropriately for sales, marketing, finance, and related purposes. Such EEA Individuals’ information (or a particular category of EEA Individual, as listed in the table above) is also disclosed to various categories of recipients to effectuate the purposes described in the table above, including companies providing technical assistance, order fulfilment, customer service, marketing assistance, payment processing, survey collection, promotional and marketing assistance, and business operations.
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Retention: Louise K. Shaw retains your data as necessary to fulfil the purposes set forth within this Notice and to the extent you have (or demonstrate an interest in) a relationship with Louise K. Shaw unless you request deletion of such data or such data is no longer relevant. Sometimes, we may have to retain data to comply with our legal obligations (e.g., accounting, finance, tax).
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Your GDPR Rights: As a natural person, you have a right to (i) request access to, correct and/or erasure your data; (ii) object to the processing of your data; (iii) restrict processing of your data; and (iv) request a copy of your data, or have a copy thereof sent to another controller, in a structured, commonly used and machine-readable format under the right of data portability. For any questions, complaints, or requests regarding this GDPR Notice, don't hesitate to contact our EU Representative EDPO directly.
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You can contact EDPO regarding GDPR matters by:
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Using EDPO’s online request form: https://edpo.com/gdpr-data-request/
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Writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
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You also have the right to complain about the processing of your data with an appropriate data protection authority and, as applicable, to exercise third-party beneficiary rights under Louise K. Shaw's Standard Contractual Clauses.
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Contact details for the EU data protection authorities can be found at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
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Objecting to Legitimate Interest/Direct Marketing: You may object to personal data processed according to your legitimate interest. In such case, we will no longer process your data unless we can demonstrate appropriate, overriding, legitimate grounds for the processing or, if needed, for establishing, exercising, or defence of legal claims. You may also object at any time to the processing of your data for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email. In such a case, your data will no longer be used.
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Transfer of Personal Data outside the EEA: We may transfer your data outside the EEA, including to our US data centres. We rely on appropriate Standard Contractual Clauses to ensure adequate protection for your data when transferred internationally.
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Disclosure to Public Authorities: Louise K. Shaw may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation, including, but not limited to, in response to court orders and subpoenas.
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Corporate Restructuring: In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal data, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments to the privacy and confidentiality of such personal data as outlined in this GDPR Notice.
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Updates to this GDPR Notice: If, in the future, we intend to process your data for a purpose other than that for which it was collected, we will provide you with information on that purpose and any other relevant information at a reasonable time before such processing. After such time, the relevant information relating to such processing activity will be revised or added appropriately within this GDPR Notice, and the “Effective Date” at the top of this page will be updated accordingly.
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How to Contact Us: Please reach out to our EU Representative EDPO directly using their online request form: https://edpo.com/gdpr-data-request/ or writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium for any questions, complaints, or requests regarding this GDPR Notice.
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Onward Transfer to Third Parties under the Data Privacy Framework Principles
Like many businesses, we contract with other companies to perform business-related services. We may disclose Information, including personal information in some cases, to certain types of third-party companies, but only to the extent needed to enable them to provide such services, including, without limitation, technical assistance, order fulfilment, customer service, marketing assistance, payment processing, survey collection, promotional and marketing assistance, and business operations. All such third parties function as our agents, performing services at our instruction and on our behalf according to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Policy and implemented by Louise K. Shaw. We may also disclose your information, including any personal information, to any of our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control with us to support the delivery of our products and services.
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Retention of Personal Information under the Data Privacy Framework Principles
We will retain the personal information processed according to the EU-U.S. Data Privacy Framework Principles and/or according to the Swiss-U.S. Data Privacy Framework Principles in a form that identifies you according to our data retention periods in Retention above or as subsequently authorised. We may continue processing your personal information for more extended periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research, and statistical analysis and subject to the protection of this Privacy Policy. After such periods have expired, we may either delete your personal information or retain it so that it does not identify you personally.
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How We Protect Personal Information under the Data Privacy Framework Principles
We take commercially reasonable steps to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in processing and the nature of such data and in compliance with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the personal information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Websites may not be secure, and you should take special care in deciding what information you send to us via email.
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