www.HALMONLINE.com

EFFECTIVE DATE: JANUARY 2019

INTRODUCTION

As the owner of this Website, The Bag Atelier d/b/a HALM or HALM Online (“we” or “us”) know that your privacy is of the utmost importance. Our Privacy Policy details what information we collect from you through the Website, how we use it, and how we may disclose such information.

WHAT DATA WE COLLECT AND HOW WE DO IT

Email Addresses

We may collect your email address, but only if you provide it to us. For example, you may choose to provide us with your email address if you sign up for our email newsletter or create an account.

We will use your email address for the purposes for which you provided it to us, and also, from time to time, to send you emails regarding the Website or other products or services that we believe may be of interest to you. You may opt out of such email communications at any time by clicking the ‘unsubscribe’ button, which is included in every email.

We will not share your email address with any third parties, except for those situations described in this Privacy Policy or to which you directly give your consent.

If you are a resident of a country in the European Economic Area (“EEA”), please refer to the ‘Additional Information for EEA Residents’ section below. 

Personal Data

We may collect additional information from you when you register with our Website in order to place an order, create an account, or use other features. Such information could include your name, address, telephone number, post code, and password (if applicable) (“Personal Data”). When you use the Website, we may also collect other data that you provide voluntarily, such as comments. 

We may also collect information about you using other methods, including opinion polls, social media platforms, verification services, data services, and public sources. We may combine this information with your registration data in order to maintain a more thorough profile.

We may use third parties to provide the functionality to allow you to register for the Website. If so, the third party will also have access to your Personal Data. Otherwise, we will not provide any of your Personal Data to third parties, except if required to do so by law, to prevent fraud, or as otherwise described in this Privacy Policy.

We may use your Personal Data for our internal business purposes, such as creating a better user experience for the Website, including diagnosing and troubleshooting malfunctions, understanding how the Website is used, and making personalised recommendations for you.

Except as stated otherwise in this Privacy Policy or in our Terms or when required by law, we do not sell, publish, or disclose your Personal Data, including debit/credit card details, to third parties, except for payment processing. All payments processed through the Website are managed by Telr, our payment services provider (“PSP”).

If you are a resident of a country in the EEA, please refer to the ‘Additional Information for EEA Residents’ section below. 

Cookies and Similar Technologies

We may use the standard cookie features offered by major browsers applications and third-party providers, including Google Analytics features, or we may use internally developed cookies and tracking codes. 

Cookies allow us to store a small piece of data on the device a visitor uses to access our Website. A cookie may be catagorised as ‘persistent’ or ‘session’. A persistent cookie is stored by a web browser and remains valid until its set expiry date, unless it is deleted by the user before that date. A session cookie expires when the web browser is closed. You can remove persistent cookies by following the directions provided by your preferred Internet browser in its help directory. If you reject cookies, you may still use the Website; however, some functionality may be limited.

The data provide information about visits to the Website. We may also use similar technologies, like java scripts or etags, to analyse trends, administer the Website, track users’ movements around the Website, and/or to gather demographic information about our users as a whole.  

Google Analytics and Google Search Console

We use Google Analytics and Google Search Console to analyse the use of our Website. Google Analytics gathers information about our Website by using cookies. The data gathered is used to create reports about the use of our Website. Google’s privacy policy is available at: https://policies.google.com/privacy?hl=en.

THE PURPOSES FOR WHICH WE COLLECT DATA

We use the data collected from you to communicate with you, process your orders and otherwise facilitate your transactions, research how to improve our product offerings, and notify you of offers, promotions, and similar events. For example, you may receive email communications from us confirming your order, responding to your enquiries, and to notify you of service interruptions if we need to temporarily suspend our Website for maintenance. 

Any Reason Disclosed and Consented to During Collection

We may disclose your Personal Data for any other purpose we disclose to you, and to which you consent, at the time you provide the information.
Order Processing, Payment, and Delivery

If you make a payment for our Product(s) on the Website, the details you are asked to submit will be provided directly to our PSP via a secured connection. All credit/debit cards details and personally identifiable information will NOT be stored, sold, shared, rented or leased to any third parties. That information will be provided directly to our PSP whose use of your Personal Data is governed by their privacy policy. 

The PSP we work with is Telr. Their privacy policy can be viewed at https://telr.com/legal/privacy-policy/. 

To deliver your order, we use third-party courier services with whom we may share your Personal Data for the sole purpose of completing your order. We recommend that you review the third-party courier service’s privacy policy to familiarise yourself with their processes and procedures.

Preserve and Protect Our Rights

If we believe that the disclosure of your Personal Data is required in order to protect our rights, property, or safety, or those of our customers, employees, and/or other groups or individuals, we may proceed to do so, in accordance with the applicable law of the UAE. 

These disclosures could include the release of your Personal Data to other private companies or organisations to prevent actual fraud and/or reduce the risk of fraud. We may also disclose your Personal Data in order to apply or enforce our Terms, agreements, for billing, and/or for collection.

Promotional Communications

We may send promotional emails and newsletters to you if you have registered on our Website and/or opted in to receive such emails (“Promotional Communications”). You may opt-out of Promotional Communications by using the ‘unsubscribe’ link included in all emails and following its instructions or by emailing us at hello@halmonline.com. 

Required by Law

We may disclose your Personal Data to courts, law enforcement, and/or governmental agencies in order to comply with any court order, law, or legal process; or in response to any governmental or regulatory agency’s request.

Sale of Business or Assets

In the event the Website is transferred, assigned, or licensed to another entity or we are involved in a merger, acquisition, reorganisation, divestiture, dissolution, or the sale or transfer of some or all of our assets (whether voluntarily or involuntarily), your Personal Data may be among those assets transferred.
Service Providers

Like most websites, we contract with various professionals and companies (“Service Providers”), such as web development firms, payment portals, etc., to perform specific tasks and functions associated with the Website. We may share your Personal Data with these Service Providers for the sole purpose of completing the tasks, functions, and other obligations for which we have contracted with them. These Service Providers are not authorised to use your Personal Data for any other purpose. You agree not to hold us liable for a Service Provider’s misuse of your Personal Data.

HOW WE PROCESS YOUR DATA 

We may process your Personal Data using suitable electronic or automated methods and computerised tools, or manually using hard copy, exclusively for the purposes for which it has been gathered and ensuring the security and confidentiality of any processed information.

Your Personal Data will be processed only by our internal staff who are authorised to do so or by third parties to the extent necessary to use the information for the purposes stated above. These third parties will act on our behalf as data processors (e.g., service providers, IT technicians, and other suppliers appointed by us to carry out certain services).

LINKS

Third-Party Websites

We may maintain links to other websites on our Website, and other websites may maintain links to our Website. This Privacy Policy only applies to our Website and not to other websites accessible from our Website, or that you may use to access our Website. If you use a link on our Website to access other websites, we are not responsible for the privacy policies or content of those sites. We advise you to review the privacy policies of other sites to understand their processes and practices.

Social Media Widgets

Our Website includes social media widgets for Facebook and Instagram. Social media widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it. 

ACCESSING AND CHANGING YOUR ACCOUNT

Upon your request, we will provide you with information about whether we hold any of your Personal Data. In certain circumstances, we may be required by law to retain your Personal Data, or we may need to retain your Personal Data to continuing providing you a service or to complete your order. The information provided below details how you can access, correct, or request deletion of your Personal Data.

Access to Order Information

You will have access to information about your order, which may include details about the status of your order, information you provided to process your order, payment information, and contact information.

Access to and Ability to Update Personal Data

You may visit your account profile at any time by logging into your account on the Website at the following URL: https://www.halmonline.com/login. If you wish to delete your Personal Data from our records, you may terminate your account by contacting us at hello@halmonline.com or +971 50 457 3656. We will respond to your request within 30 days. 

Data Retention

At a minimum, we will retain your Personal Data, and any other information, for as long as required to provide you with our products and services, and as necessary to comply with our legal obligations, resolve disputes, and/or to preserve or enforce our rights. 

SECURITY FOR THE PERSONAL DATA WE COLLECT

We take reasonable steps using various hardware and software methodologies to protect your Personal Data and prevent its misuse, destruction, alteration, or unauthorised disclosure. We have implemented physical, electronic, and managerial procedures to safeguard and secure the information we collect. Debit/credit card and Personal Data are transmitted by secure servers (SSL); however, you are ultimately responsible for safeguarding this information. You are responsible for keeping your account information confidential and assume any risk associated with using our Website to transmit information, including Personal Data. Therefore, we recommend that you not share any password or login information used for the Website with anyone.

There is no completely secure method of information transmission on the internet, and we do not guarantee the security of any information, including your Personal Data, transmitted by, from, to, or through the Website. We disclaim liability for the theft, loss, interception of, or unauthorised access or damage to, your Personal Data, other data, or communications by using our Website. You acknowledge that you understand and assume these risks.

Our Website may contain links to other sites that are operated third parties. If you click on a third-party link, you will be directed to a third-party site and away from our Website. We strongly advise that you review the privacy policy for every third-party site. We have no control over and assume no liability or responsibility for the content, privacy policies, or practices of any third-party sites, services, or products.

ADDITIONAL INFORMATION FOR EEA RESIDENTS

If you are a resident of the EEA, below is additional information regarding your rights and our responsibilities regarding the processing of your Personal Data.
User Rights

If you are a resident of the EEA, you have the following rights with respect to how we process your Personal Data.

- You have the right to request a copy of the Personal Data that we have about you.

- You have the right to request that we correct information about you, if you believe it to be inaccurate.

- You have the right to request that we erase or refrain from using your Personal Data; however, this is not an absolute right, and, in some situations, we may decline to erase or limit our usage of your data. For example, we may decline your request if we have an on-going business relationship with you or we are legally required to retain your Personal Data. If we cannot fulfill your request, we will inform you and include the reasons for our decision.

To exercise your rights, please contact us at hello@halmonline.com or +971 50 457 3656.

If you are located in the EEA, you also have the right to raise any objections regarding the processing of your Personal Data and to raise any concerns you may have about our processing of your Persona Data. You may make your objection or raise your claim by contacting us at hello@halmonline.com or +971 50 457 3656.

We sincerely hope to satisfactorily resolve any concerns you have about your privacy; however, if we are unable to do so, you also have the right to file a complaint with your data protection supervisory authority, which you can find at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

CHANGES TO OUR PRIVACY POLICY

We may amend our Privacy Policy from time to time and at our sole discretion. We encourage all users to check our Privacy Policy regularly in order to remain informed regarding its provisions. Any changes or modifications to this Privacy Policy become effective on the day they are posted on the Website. The Privacy Policy currently in force is the one posted on our Website.

DATA CONTROLLERS

For the purpose of managing and executing your online purchases through our Website, the Data Controller is The Bag Atelier. You can contact the Data Controller by writing to HALM, Office A102, Building 7, Dubai Design District, Dubai, United Arab Emirates, or by sending an email to hello@halmonline.com. 

GOVERNING LAW AND JURISDICTION

This Privacy Policy is incorporated into and is a part of the Terms, and is governed by the laws of the UAE, irrespective of any conflict of laws principles. The UAE is our country of domicile. You irrevocably agree to waive any claim you may have regarding jurisdiction, inconvenient forum or venue, and agree to the personal and exclusive jurisdiction of the Courts of the UAE in the Emirate of Dubai whose judgment is full and final.

CONTACTING US

If you have any questions about this Privacy Policy, or the practices of our Website, please contact us at hello@halmonline.com.

Or write to us at:

HALM, Office A102, Building 7, Dubai Design District, Dubai, United Arab Emirates, or by sending an email to hello@halmonline.com.