Draft. Text in [BRACKETS] still has to be filled in, and the page should be reviewed by a lawyer before it is published.
Privacy Policy
Last updated: [DATE]
This policy explains what personal data we collect when you visit get-kisora.com or buy from us, why we use it, who we share it with and what rights you have.
1. Who is responsible
The controller of your personal data is [COMPANY NAME] (“Kisora”, “we”, “us”); our address is on the Contact & Legal Notice page. For any privacy question or request, contact us at [SUPPORT EMAIL].
2. What we collect and why
When you visit the website
- Technical data: your IP address, browser and device type, the page you visited and the time of the visit. Our hosting provider needs this to deliver the website and to protect it against attacks. We use it on the basis of our legitimate interest in running a secure website.
- Advertising click data: if you reach us through an online ad, the link may contain a click reference (for example
cid=...). We use it to measure which ads lead to purchases, on the basis of our legitimate interest in measuring our advertising. [If required in your country, we only use it with your consent.] - Fonts and videos: our pages load fonts and product videos from external services. Your browser connects to these services, which therefore receive your IP address.
[We do not currently use analytics or advertising cookies on this website. If we add them, we will ask for your consent first where the law requires it and update this policy.]
When you place an order
- Contact and delivery details: name, email address, phone number (optional) and delivery address, so that we can process, deliver and support your order. Legal basis: performance of our contract with you.
- Order details: products, prices, order and delivery dates. We must keep these records for tax and accounting purposes. Legal basis: legal obligation.
- Payment details: payments are processed by our payment provider. We do not see or store your full card details; we only receive confirmation of payment and limited information such as the card type and last four digits.
When you contact us
When you email us, we use your message and contact details to answer you. Legal basis: our legitimate interest in answering enquiries, or the performance of your contract if your question is about an order.
Marketing
We only send you marketing emails if you have agreed to receive them. You can unsubscribe at any time using the link in each email. [We currently do not send marketing emails.]
3. Who we share your data with
We only share your data where it is needed for the purposes above, with these types of recipients:
- service providers that host and secure our website and deliver its images, fonts and videos;
- services that measure which of our ads lead to purchases;
- our payment provider;
- our production and fulfilment partner, carriers and local delivery services, to ship your order and clear customs;
- our email and customer service providers;
- tax advisers, authorities and courts, where the law requires it.
Our service providers may only use your data for the services they provide to us.
We do not sell your personal data.
4. International transfers
Some of these providers are located outside your country. In particular, your orders are shipped from China, so the details needed for delivery (name, delivery address, phone number and the products ordered) are sent to our fulfilment partner and carriers there; other providers are located in the United States. Where data is transferred outside the UK or the European Economic Area, we protect it with appropriate safeguards, such as the EU Standard Contractual Clauses, the UK International Data Transfer Addendum or the EU–US Data Privacy Framework, and we only share the data that is needed.
5. How long we keep your data
- Order and invoice records: [7 years / the period required by tax law].
- Customer service emails: [2 years] after the matter is closed.
- Technical server logs: [up to 30 days], unless needed to investigate a security incident.
- Marketing consent: until you withdraw it.
6. Your rights
Depending on where you live, you have the right to:
- access the personal data we hold about you;
- have incorrect data corrected;
- have your data deleted, unless we must keep it by law;
- restrict or object to our use of your data, in particular where we rely on legitimate interests;
- receive your data in a portable format;
- withdraw your consent at any time, without affecting earlier use.
To use any of these rights, email [SUPPORT EMAIL]. We will answer within one month (or the period required by your local law).
You can also complain to a data protection authority, for example the Information Commissioner’s Office in the UK, the authority in your EU country, the Office of the Privacy Commissioner of Canada, the Office of the Australian Information Commissioner or the Office of the Privacy Commissioner in New Zealand.
California residents: you have the right to know what personal information we collect, to request its deletion or correction, and not to be discriminated against for using these rights. We do not sell personal information [and do not share it for cross-context behavioural advertising].
7. Security
We use encrypted connections (HTTPS) and work with providers that protect your data with appropriate technical and organisational measures. Payment data is handled only by our payment provider.
8. Children
Our shop is not intended for children under 16, and we do not knowingly collect their data.
9. Changes to this policy
We may update this policy when our services or the law change. The date at the top shows when it was last updated.