PRIVACY NOTICE

Last updated 07/29/2020

 

Thank you for choosing to be part of our community at Rafaelmorel.com (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at support@rafaelmorel.com

When you and more generally, use any of our services (the "Services", which include the ), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our ), as well as any related services, sales, marketing or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

 

1. WHAT INFORMATION DO WE COLLECT?


Personal information you disclose to us

In Short:  We collect information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the express an interest in obtaining information about us or our products and Services, when you participate in activities on the (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the , the choices you make and the products and features you use. The personal information we collect may include the following:

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.


Information automatically collected

In Short:  Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our .

 

We automatically collect certain information when you visit, use or navigate the . This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our and other technical information. This information is primarily needed to maintain the security and operation of our , and for our internal analytics and reporting purposes.

 

Like many businesses, we also collect information through cookies and similar technologies.

Klarna Privacy Policy

Last updated: March 13, 2020

 

Klarna is committed to letting you know how we will collect, use, store, share and protect your personal information when you transact with us. You accept this privacy policy (the “Privacy Policy”) whenever you access or use Klarna products, services, features, and technologies including the Klarna mobile app and www.klarna.com/us (the “Klarna Services”). Please read this Privacy Policy carefully. If you are a resident of California, you may have additional rights, described in our Additional Information for California Residents Section.

 

This Privacy Policy does not apply to information submitted or collected through websites maintained by other companies or organizations to which we may link or who may link to us. We are not responsible for the actions and privacy policies of third-party websites.

 

Additionally, if you use Klarna Credit, your non-public personal information will be subject to WebBank’s privacy notice and Klarna’s use of such information will be consistent with that privacy notice.

 

What type of information does Klarna collect?

Klarna collects two basic types of information from you in conjunction with your use of the Klarna Services (collectively, your “personal information”): (1) personally identifiable information; and (2) non-personally identifiable information.

Personally Identifiable Information is any information that can identify you. 

  • Examples include your name, e-mail address, telephone number, postal address, device identifiers, IP addresses, and financial account information that you provide, such as credit or debit card numbers. 

  • We may also collect personally identifiable information about you from third parties such as data vendors.

  • Aggregate and/or de-identified information is not considered personally identifiable information.

Non-personally identifiable information is information that does not identify you directly, but may be linkable to you.

  • Examples include demographic information and general location information.

  • If non-personally identifiable information is directly linked to personally identifiable information, it will be considered personally identifiable information while it is linked. For example, if your payment history and transaction history are linked to your name, then that information will be considered personally identifiable information and subject to heightened privacy and security restrictions, as reflected in this Privacy Policy.

 

How does Klarna Collect Information?

We collect information about you through:

  • Your interactions with or use of the Klarna Services;

  • Your contact with our customer support team; 

  • Third parties, such as data vendors;

  • Through our websites, using cookies, Clear GIFs, web beacons, mobile application plug-ins and similar technologies. 

Cookies are small files that are stored on your computer or device when you use the Klarna Services. Cookies record your preferences and the actions you take on your computer or device. We may also use web beacons and mobile application plug-ins, such as software development kits, application programming interfaces and similar technologies. We use these and other similar technologies for security, to monitor traffic, improve the Klarna Services, and make the Klarna Services easier to use and more relevant to you. We may also use these technologies to personalize your experience, deliver advertisements, and for research and marketing. 

 

Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with the Klarna Services to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage.

 

Third Party Analytics We may use automated devices and applications to evaluate usage of our Site. We use these tools to help us improve our Site, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. 

 

How do we use the personal information we collect?

We may use your personal information to:

  • Provide the Klarna Services and customer support

  • Process transactions and send notices about your transactions

  • Resolve disputes and collect payments and/or fees

  • Verify the accuracy of and authenticate your information

  • Detect, investigate and prevent potentially prohibited or illegal activities, such as fraud

  • Communicate about accounts or transactions and send information about features and enhancements 

  • Contact you by phone, text (SMS) or email

  • Communicate changes to our policies

  • Personalize content and experiences, including providing recommendations based on your preferences

  • Send offers or promotions for the Klarna Services

  • Provide advertising, including advertising based on your use of the Klarna Services or third-party websites 

  • Perform statistical, demographic and marketing analyses of users of the Klarna Services and their purchasing patterns

  • Conduct any other legitimate business activities not otherwise prohibited by law

 

How do we share personal information?

We will only share your personal information with third parties as described in this Privacy Policy.

We may share your personally identifiable information with:

  • Service providers and affiliates who help with our business operations, including but not limited to, fraud prevention, account maintenance, customer service, marketing and technology services

  • Credit bureaus and collection agencies, as permitted by law

  • Merchants you order your goods or services from using the Klarna Services

  • Companies that we plan to merge with or be acquired by

  • Third parties, including governmental authorities and law enforcement, to (i) protect or defend the legal rights, interests or property of Klarna and any related entity of Klarna; (ii) protect the safety and security of our customers or members of the public; (iii) protect against fraud; or (iv) comply with applicable law, subpoena or legal process.

  • Other third parties with your consent or at your direction to do so.

  • Third parties for any legitimate business purpose not otherwise prohibited by law

 

We will not share or sell any personally identifiable information about you to our affiliates or non-affiliated third parties for their marketing purposes unless you have provided consent, except as set forth in the Klarna Terms of Service.

 

Email Connect service (available in the Klarna App)

If you connect to the Email Connect service, we will process order information (such as delivery tracking identifiers, supplier information and product information) related to purchases you have made, in order to provide you with delivery information and an overview of your purchases in the Klarna App.

We will not share data obtained through Email Connect with third parties, unless necessary to provide or improve the service to you. In particular, we will not transfer data to third parties for serving ads.

 

How do we protect personal information?

Klarna uses reasonable security measures to protect your personal information from unauthorized access and use in compliance with applicable law. These measures include computer safeguards and encrypted, secured files and buildings. We also maintain other physical, technical, administrative, and procedural safeguards to protect personal information, and access to personal information is limited to the employees who require it for their job functions. Please be aware that despite our efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

 

How can you restrict us from sharing your personal information?

Personally Identifiable Information: You may choose not to provide your personally identifiable information to us; however, you will not be able to use the Klarna Services.

You can also limit our use and sharing of your personal information in other ways, such as:

  • You may unsubscribe from marketing emails, but we will still be permitted to contact you for servicing and account-related purposes by clicking the “Unsubscribe” link in the email footer or by contacting Klarna Customer Service.

  • You can modify browser settings to decline cookies, but certain features of Klarna Services may not function properly or may be unavailable if you do. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.

  • For your mobile device, you can understand which third parties have currently enabled cookies on your mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative's website at http://www.networkadvertising.org/mobile-choices from your mobile device. On your mobile device you may also select “Limit Ad Tracking” (on iOS devices) or “Opt out of Interest-Based Ads” (on Android). Even if you disable tracking, keep in mind that you may still receive interest-based advertising, including from third parties with whom your information had been previously disclosed and that you may still receive advertising from third parties, although such advertising may not be based on your interests and preferences.

  • We use the information provided by Google Analytics to improve our Services. For more information regarding how Google collects, uses, and shares your information and how to opt out of certain uses please visit http://www.google.com/policies/privacy/partners/ and https://tools.google.com/dlpage/gaoptout.

  • Your browser or device may include “Do Not Track” functionality. Note that Klarna’s information collection and disclosure practices, and the choices that we provide to customers, will continue to operate as described in this Privacy Policy whether or not a Do Not Track signal is received.

 

Third-Party Links

The Klarna Services may contain links to third-party websites, including social media sites. By including a link to a third-party website, we do not endorse or recommend any products or services offered or information contained at the third-party website. Any access to and use of such linked websites is not governed by this policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites. If you decide to visit a third-party website via a link contained in or by the Klarna Services, you do so at your risk.

 

Children Under 13

Our products and services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted through the Services by contacting Klarna customer service. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

 

Governing Law and Notice to Non-US Users

The Klarna Services are directed to individuals located in the United States, and our policies are directed at compliance with those laws. If you are located outside the United States, you should NOT submit personal information to Klarna.  If you voluntarily submit personal information to us, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the United States.

 

Accessing, Correcting or Deleting Your Information   

You may request to access, correct, or delete any personal information that you have provided to us. You will not be permitted to examine the personal information of any other person or entity and may be required to provide us with personal information to verify your identity prior to accessing any records containing information about you. We may not accommodate a request to change or delete personal information if we believe doing so would violate any law or legal requirement or cause the information to be incorrect. To submit a request, email privacy@klarna.com, call 844-KLARNA1 (844-552-7621), or make a request through the chat feature in our Customer Service Web Portal.

 

Changes to this Policy

This policy is current as of the Last Updated date set forth above. We may change this policy from time to time, so please be sure to check back periodically. We will post any changes to this policy on the Klarna Services. If we make any changes to this policy that materially affect our practices with regard to the personal information we have previously collected from you, we will aim to provide you with notice in advance of such change by highlighting the change on our web site.

 

How can you contact Klarna?

If you have questions about the privacy aspects of our services or would like to make a complaint, please contact Klarna customer service.

 

Additional Options and Rights – California Residents Only

California provides consumers with additional rights as related to their personal information.  Klarna will not discriminate against you because you exercise any of the rights as described in this section. These rights do not apply, however, to any non-public personal information that Klarna collects or discloses in providing a financial product or service.    

Categories of Data Collected, Sold, and Disclosed

Please see our Notice of California Consumer Data Collection and Sharing Practices.

Sale of Personal Information to Third Parties

You have the right to opt-out of the sale of some types of personal information. At present, Klarna does not sell personal information to third parties. Please note that your right to opt-out does not apply to our sharing of data with service providers, who are parties who are engaged to perform a function on our behalf and are contractually obligated to use the data only for that function. If our practices change in the future, we will provide you with the opportunity to opt-out before any such sale.

Access to Personal Information

You have the right to request from us access to personal information collected about you and information regarding the source of the data, the purposes for which we collected it, and the third parties and service providers with whom we shared it. To protect our customers’ personal information, we are required to verify your identify before we can take action on your request.

To submit a request, email privacy@klarna.com, call 844-KLARNA1 (844-552-7621), or make a request through the chat feature in our Customer Service Web Portal.

Erasure of Personal Information

You have the right to request in certain circumstances that we delete any personal information that we have collected directly from you. To protect our customers’ personal information, we are required to verify your identify before we can take action on your request. We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

To submit a request, email privacy@klarna.com, call 844-KLARNA1 (844-552-7621), or make a request through the chat feature in our Customer Service Web Portal.

Participation in Data Sharing for Financial Incentive

At this time, we do not offer consumers any financial incentives to share data with us. If that changes, we will seek your consent prior to sharing data.

 

Notice of California Consumer Data Collection and Sharing Practices

 

The California Consumer Privacy Act (“CCPA”) requires us to disclose certain information about our data collection and sharing practices to California residents, and to align this information to certain categories of personal information as enumerated in the law:

  • The specific pieces of personal information and the categories of personal information we have collected about consumers in the past 12 months.

  • The business or commercial purpose for collecting that personal information.

  • Whether we “sell” that category of information to third parties. An external party may be considered a third party in the below chart either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using personal information for other purposes. To “sell” data means to sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.

  • Whether we disclose that category of information to “service providers,” which are external parties that we engage for business purposes and is restricted from using personal information for any purpose that is not related to our engagement. 

Klarna does not engage in the practice of providing data to third parties in return for a financial benefit to us. 

As a California resident, you may be entitled to additional rights regarding the collection and sharing of your data described in this Policy.

 

The following table summarizes the personal information we collect or create and how we share with external parties. This table describes our practices generally; not all individual pieces of your personal information may be shared.


Klarna does not sell personal information and will not sell personal information, except as described in this Privacy Policy. If we ever decide to sell personal information, we will provide you with notice and a right to opt-out of such sale.

 

Data Fields

Method of Collection

Purpose of Collection (in addition to the purposes listed below)

Shared with Service Providers

(A) Personal Identifiers

Name

Consumer provides when creating account or completing transaction

To provide advertisements and discounts for third party goods and services.

Yes

 

Phone Number

Consumer provides when creating account or completing transaction

 

Yes

 

Email Address

Consumer provides when creating account or completing transaction

To provide advertisements and discounts for third party goods and services.

Yes

 

Contact Address

Consumer provides when creating account or completing transaction

To provide advertisements and discounts for third party goods and services.

Yes

 

Account Number

We generate and assign to consumer account

To provide advertisements and discounts for third party goods and services.

Yes

 

Online Handle, user name or identifiers

Consumer creates when creating account

To provide advertisements and discounts for third party goods and services.

Yes

 

IP Address

Automatically when consumer visits website

To provide advertisements and discounts for third party goods and services.

Yes

(B) Additional Personal Identifiers

Credit/Debit card Number

Consumer provides when creating account

To provide advertisements and discounts for third party goods and services.

Yes

 

Age

Consumer provides date of birth when creating account

To provide advertisements and discounts for third party goods and services.

Yes

(D) Commercial Information

   

Actual and considered transactions are stored in consumer profile

To provide advertisements and discounts for third party goods and services.

Yes

(F) Internet or other electronic network activity information

   

Automatically when consumer visits website or uses the Services

To provide advertisements and discounts for third party goods and services.

Yes

(H) Audio, electronic, visual, thermal, olfactory, or similar information

 Voice recordings

Telephone interactions with customer service may be recorded

 

Yes

 

 

Email and chat communications

Emails sent by consumer to any Klarna email address; chat communications with Klarna Customer Service; Emails accessed while enrolled in the Email Connect Service

 

Yes

(K) Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics

   

Inferences may be generated through a series of computer processes

To provide advertisements and discounts for third party goods and services.

Yes

 

All listed categories of personal information are collected for the following business purposes (in addition to purposes included in the table above):

  • To enable or effect, directly or indirectly, a commercial transaction involving the Klarna Services.

  • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

  • Undertaking internal research for technological development and demonstration.

  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

  • Debugging to identify and repair errors that impair existing intended functionality.

 

 

All non-public personal information that we collect (except through a Klarna Credit account with WebBank) is subject to the following Consumer Privacy Notice:

 

                                                                                                    Rev. Jan 2020                                                                                                    

FACTS 

WHAT DOES KLARNA DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information.  Federal law gives consumers the right to limit some but not all sharing.  Federal law also requires us to tell you how we collect, share, and protect your personal information.  Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us.  This information can include:

  • Social Security number and payment history

  • Transaction history and credit history

  • Credit scores and account balances

How

All financial companies need to share customer’s personal information to run their everyday business.  In the section below, we list the reasons financial companies can share their customer’s personal information; the reasons Klarna chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Klarna share?

Can you limit this sharing?

For our everyday business purposes—
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes—
to offer our products and services to you

Yes

No

For joint marketing with other financial companies

No

We don’t share

For our affiliates’ everyday business purposes—
information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes—
information about your creditworthiness

No

We don’t share

For our affiliates to market to you

No

We don’t share

For nonaffiliates to market to you

No

We don’t share

Questions:

 

Call 1-844-552-7621 or go to www.klarna.com

 

Who is providing this notice?

Klarna, Inc.

How does Klarna
protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law.  These measures include computer safeguards and secured files and buildings.

How does Klarna
collect my personal information?

We collect your personal information, for example, when you

  • Open an account or use your credit or debit card

  • Pay your bills or apply for a loan

  • Give us your contact information

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only

  • sharing for affiliates’ everyday business purposes—information about your creditworthiness

  • affiliates from using your information to market to you

  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.  See below for more on your rights under state law.

Affiliates

Companies related by common ownership or control.  They can be financial and nonfinancial companies.

  • Our affiliates include companies with a Klarna name, and financial companies such as Klarna Bank, AB, Sofort GmbH, BillPay GmbH

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Klarna does not share with non-affiliates so they can market to you

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • Klarna doesn’t jointly market

 

California Residents: We will not share personal information that we collect about you with nonaffiliated third parties without your authorization except as permitted by law.

 

Vermont Customers: We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be found at www.klarna.com/us/legal or call 1-844-552-7621.

 

 

2. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
     

  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
     

  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
     

  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
     

  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

  • Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

  • Other Users. When you share personal information or otherwise interact with public areas of the , such personal information may be viewed by all users and may be publicly made available outside the in perpetuity. If you interact with other users of our and register for our through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our , and view your profile.

 

3. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

 

4. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short:  If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our offers you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant . Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

 

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short:  We may transfer, store, and process your information in countries other than your own.

Our servers are located in. If you are accessing our from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in and other countries.

If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

 

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 5 years

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the , you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the . If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@rafaelmorelstudio.com.

 

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

 

 

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

 

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with , you have the right to request removal of unwanted data that you publicly post on the . To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the , but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).  

 

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short:  Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@rafaelmorel.com.

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.

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© 2010 - 2020 Rafael Morel - Rafael Morel New York  S.p.A. - All rights reserved. SIAE LICENCE # 1974/9/1776 and 3594/I/1738