PRIVACY AND COOKIE POLICY

We are transparent about what we do with your personal data, to help you to understand the implications of the way in which we use your data, and the rights you are entitled to in relation to your data.

We permanently make available for you all the information included in this Privacy and Cookies Policy, that you can check when you consider appropriate, and in addition, you will also find further information on how we use your data as you interact with us.

When we speak about our Platform, we refer, in general, to any of the channels or means you may have used to interact with us. The main ones are: our Website, www.newordinarypeople.com and our e-mail address [email protected].

1. WHO IS THE CONTROLLER OF YOUR DATA?

Your data controllers is New Ordinary People OÜ (“ the SELLER”): 

• E-mail address of the Data Protection Officer: [email protected]

In other words, the SELLER is Controller of the data. This means that we have regulated and are responsible for processing and protecting your personal data.

2. WHY WE PROCESS YOUR PERSONAL DATA

Depending on the purpose for which we process your data from time to time, as explained above, we need to process one or other data, which will in general be, depending on each case, as follows: 

• your identity data (for example, your name, surname, language and country from which you interact with us, contact data, etc.);
• economic and transactions information (for example, your payment or card data, information on your purchases, orders, returns, etc.);
• connection, geolocation and/or browsing data (if you interact with us from a Phone, for example);
• commercial information (for example, if you have subscribed to our newsletter),
• information about your tastes and preferences (when you ask for help for shopping on Whatsapp).

Remember that, when we ask you to fill in your personal data to give you access to any functionality or service of the Platform, we will mark certain fields as compulsory, since this is information that we need to be able to provide the service or give you access to the functionality in question. Please take into account that, if you decide not to make such data available to us, you may be unable to complete your user registration or may not be able to enjoy those services or functionalities. Depending on how you interact with our Platform, i.e., depending on the services, products or functionalities that you wish to enjoy, we will process your personal data for the following purposes:

Purpose

1. To manage your registration as user of the Platform If you decide to become a registered user of our Platform, SELLER need to process your data to identify you as a user of the Platform and grant you access to its various functionalities, products and services available to you as a registered user. You may cancel your registered user account by contacting us through Customer Support.
2. For the development, performance and execution of the purchase or services contract that you executed with Us on the Platform This purpose includes We will process your data, mainly:

• To contact you for updates or informative notices related to the contracted functionalities, products or services, including quality surveys and to be able to establish the degree of customer satisfaction with the provided service;
• To manage payment of the products that you purchase, regardless of the payment procedure used. For example if on purchasing any of our products through the Website, you opt to activate the functionality of save your card data for future purchases, we need to process the indicated data for activation and development of that functionality. Consent to the activation of this functionality enables your autocompleted payment data to appear in subsequent purchases so that you do not need to introduce them in 4 each new process, and these data will be deemed valid and effective for subsequent purchases. You may change or cancel your cards at any time through the section on payment information of your Website registered user account.
• Activate the necessary arrangements in order to control and prevent potential fraud against you and against us during the purchase process. If we consider that the transaction can be fraudulent, this processing may cause the blocking of the transaction.
• To manage potential returns after you have purchased and manage requests of availability information for articles, reservations of products through the Platform, depending on the availability of such options from time to time.
• For invoicing purposes and to make available to you the tickets and invoices of the purchases you have made through the Platform.
• To ensure that you are able to use other available functionalities or services, such as the purchase, management and use of the Gift Card or of the Gift Voucher.

3. For marketing purposes. SELLER will process your data, mainly, for:

• If and when you subscribe to our Newsletter, SELLER will process your personal data to manage your subscription, including to send customised information on our products or services through various means (such as e-mail or SMS).
• Accordingly, please take into account that this data processing implies analysis of your user or customer profile to establish your preference themes for the communication and therefore which products and services are most fit to your style when sending you information. For example, based on your preference for only the blog newsletter, SELLER won't send you any information about anything that isn't a blog post.
• Remember that you may unsubscribe from the Newsletter at any time through the "Newsletter" section of the Platform, in addition to through the instructions that we provide you with in each notice.
• To perform promotional actions (for example, for the organization of competitions or to send the list of items stored to the e-mail you designate).
• To disseminate in the Platform or through our channels in the social networks photographs or pictures that you shared publicly, provided that you expressly give SELLER your consent for the purpose.

4. Analysis of usability and quality to improve our services If you access our Platform, SELLER informs you that it will treat your browsing data for analytic and statistic purposes, i.e., to understand the manner in which users interact with the Platform and thus be capable of introducing improvements in the Platform. In addition, SELLER occasionally performs quality surveys and actions to know the degree of satisfaction of our customers and users and detect those areas in which we may improve.

3. HOW WE ARE LEGALLY PERMITTED TO PROCESS YOUR DATA?

The legal terms on which we are permitted to process your personal data also depends on the purpose for which we process them, as explained in the following description: 

1. To manage your Platform user registration. SELLER processes your data because this is necessary on the terms regulating the use of the Platform. In other words, for you to be able to register as a user on the Platform, SELLER needs to process your personal data, since it would otherwise be unable to manage your registration.
2. Development, performance and making of the purchase or services contract. We process your data because their processing is necessary for us to make the purchase or services contract with you. Certain processing of data related to the purchase process is activated only because you request or authorise it, as is the case of the storage of payment (card) data for future purchases. In these case, our processing of your data is supported by your own consent. We consider that we have a legitimate interest to carry out the necessary verifications to detect and prevent potential fraud when you make a purchase. We understand that the processing of these data is positive for all the participating parties when a purchase is paid and in particular for you, since this allows us to establish measures to protect you from fraud attempts by third parties.
3. Customer Service. We consider that we have legitimate interest in answering the requests or consultations raised by you through the existing different contact channels. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the consultations raised. When you get in touch with us, in particular, for the management of incidents related to your order or the product/service acquired through the Platform, the processing of your data is necessary to perform the purchase contract. When your consultation is related to the exercise of your rights on which we inform you below, or to claims on our products or services, we are legally permitted to process your data for compliance with our legal obligations.
4. Marketing. SELLER is legally permitted to process your data for marketing purposes due to the consent that you give it, for example when you accept receiving customized information through multiple channels, when authorizing or to publish your pictures on the Platform or on the social networks' channels. In order to show you customised information. SELLER considers that has a legitimate interest to conduct a profiling with the information that it has about you (such as your browsing, preferences or purchase history) and the personal data that you have provided it, such as the age range or language, since SELLER understands that the data processing of these data is also beneficial to you because it allows you to improve your user experience and access the information in accordance with your preferences.
5. Analysis of usability and quality. We consider that SELLER has a legitimate interest in analysing the Platform usability and the user's satisfaction degree, since we understand that that the processing of these data is also beneficial for your because the purpose is to improve the user experience and provide a higher quality service.

4. HOW LONG WILL WE KEEP YOUR DATA?

The time for which we will keep your data will depend on the purposes for which we process them, as explained below:

Time for which the data are kept

1. To manage your Platform user registration. SELLER will process your data for the time during which you remain a registered user (meaning, until you decide to unsubscribe). 
2. Development, performance and execution of the purchase or services contract. We will process your data for the time necessary to manage the purchase of the products or services that you buy, including potential returns, complaints or claims related to the purchase of the product or service in question. Sometimes, we will only process the data until the time when you decide, as is the case of payment (card) data that you requested us to store for future purchases. 
3. Customer Support.  We will process your data for the time necessary to meet your request or application.
4. Marketing. SELLER will process your data until you unsubscribe or cancel your subscription to the newsletter.
5. Analysis of usability and quality. SELLER will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey or until it anonymise your browsing data.

Notwithstanding the fact that we will process your data for the time strictly necessary to achieve the purpose in question, we will subsequently keep them duly stored and protected for the time during which liability may arise for their processing, in compliance with legislation in force from time to time. Once each of the potential actions is time-barred we will proceed to delete the personal data.

5. DO WE SHARE YOUR DATA WITH THIRD PARTIES?

To achieve the purposes mentioned in this Privacy and Cookies Policy, SELLER must give access to your personal data to third parties that provide us with support in the services that we offer your, i.e.:

• financial institutions, 
• anti-fraud detection and prevention entities,
• technological service providers, 
• logistic, transport and delivery partners and service providers,
• providers of customer support related services,
• advertising and marketing related partners and service providers.

For service efficiency purposes, some of these providers are located in territories outside the European Economic Area that do not offer a level of data protection comparable to that of the European Union, in other words, the United States of America. In such cases, we inform you that SELLER will transfer your data with adequate safeguards and always keeping your data safe:

• Some providers are certified Privacy Shield, which certification you may consult through the following link: https://www.privacyshield.gov/welcome
• With other providers, we have agreed Standard Contractual Clauses approved by the EU Commission, the content of which you may consult through the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contractstransfer-personal-data-third-countries_en

6. WHAT ARE YOUR RIGHTS WHEN MAKING YOUR DATA AVAILABLE TO US

We undertake to keep your personal data confidential and to ensure that you may exercise your rights. Bearing that in mind, we Joint Controllers have agreed that you may exercise your rights free of charge by writing us an email to a single e-mail address ([email protected]), simply informing us of the reason for your request and the right that you wish to exercise. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity. In particular, notwithstanding the purpose or legal basis we use to process your data, you have the following rights: 

• To request access to your personal data that we hold. We remind you that where you are a Platform registered user you may also consult this information in the relevant section of your online account.
• To request that we rectify the personal data that we hold. Please bear in mind that if you are a registered user on the Platform, you may also access the relevant personal data section of your online account to change or update your personal data. In any case, please take into account that, on actively making your personal data available to us through any procedure, you guarantee that they are true and accurate and you undertake to notify to us any change or modification of your data. You will be liable for any loss or damage caused to the Platform or to the person responsible for the Platform or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms. Please remember that, as a general rule, you must provide us only with your own data, not with those of third parties, other than to the extent otherwise permitted in this Privacy and Cookies Policy.
• To request that we erase your personal data to the extent that they are no longer necessary for the purpose for which we need to keep processing them, as we have explained above, or when we are no longer legally permitted to process them.
• To request that we cancel or limit the processing of your personal data, which entails that in certain cases you can request us to temporally suspend the processing of the data or that we keep them longer that necessary. If you have given us your consent to process your data for any purpose, you also have the right to withdraw such consent at any time.
• When we are legally permitted to process your data due to your consent or to for the purposes of a contract, you will also have the right to request the portability of your personal data.
• In addition, where the processing of your data is based on our legitimate interest, you will also have the right to object to the processing of your data.

Finally, we inform you that you have the right to file a claim before the responsible data protection regulatory authority, in particular, before the Estonian Data Protection Authority:(http://ec.europa.eu/justice/article-29/structure/data-protection authorities/index_en.htm).

7. WHAT HAPPENS WHEN YOU PROVIDE US WITH DATA OF THIRD PARTIES?

We offer functionalities or services that require us to process the personal data of a third party that you must provide, such as in the case of activation and sending of the Gift Voucher or the management of the application for the Gift Voucher. If you provide us with personal data of third parties, you confirm that you informed them of the purposes and of the manner in which we need to process their personal data.

8. CHANGES TO THE PRIVACY AND COOKIES POLICY

We may amend the information contained in this Privacy and Cookies Policy when we consider this appropriate. Should we do so, we will notify you by various procedures through the Platform or we may even send you a notice to your e-mail address when the change in question is relevant to your privacy, for you to be able to review the changes, assess them and, as the case may be, object or unsubscribe from ay service or functionality. In any case, we suggest you to review this Privacy and Cookies Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our Website.

9. INFORMATION ON COOKIES

All the cookies we use are anonymous. We believe in your data security and even if profiling is nice for marketing, we choose not to use any profiling on our website.

But we do use cookies and similar devices to facilitate your browsing in the Platform, understand how you interact with us.

Cookie Policy

In this Cookie Policy you will find information on how we use cookies and similar devices installed on the terminals of our customers and users. The use of cookies may sometimes be related to personal data processing, therefore we recommend you consult our Privacy Policy, available on our Platform, if you would like information on how we use the personal data of our customers and users, how to exercise your rights, or the terminology we use to refer to our Website.

What is a Cookie?

A cookie is a small text file that a website, app or other platform stores on your computer, tablet, smartphone or any other similar device, with information on your browsing and use, like a tag that identifies your device. Cookies are necessary, for example, to facilitate browsing and understand how users interact with platforms so they can be improved. They are also useful to provide advertising according to user preferences, as well as for other purposes detailed below. Cookies do not damage your computer or device. By “Cookies” we are also referring to other, similar technologies used to install and/or collect information on or from your devices such as flash cookies, web beacons or bugs, pixels, HTML5 (local storage), and SDK technologies for apps. The term Cookies also applies to the use of fingerprinting, in other words, techniques used to combine information that helps us identify your device. These technologies sometimes run alongside cookies to collect and store information, either to provide you with certain features or services on our Platform or to display third-party advertising according to your browsing. This explanation is a general overview of what Cookies means and is for informational purposes only. The specific Cookies we use are detailed in section below.

What type of Cookies are there?

Please check this section which provides an overview of the type of Cookies that can be used in an online environment.

Cookies can be classified as follows, depending on the owner: 

1. First-party cookies: Are sent to the user’s computer or device from a computer or domain managed by the editor, and which provides the platform or service requested by the user.
2. Third-party cookies: Are sent to the user’s computer or device from a computer or domain not managed by the editor, but rather by another entity that processes data obtained from the cookies.

Cookies can be classified as follows, depending on the purpose:

1. Strictly necessary cookies (technical): The cookies that allow the user to browse a website, platform or app, and use the various options or services on it. For example, control traffic, identify data or session, access restricted access sections or content, remember the elements of an order, complete an order purchase process, manage payment, control fraud related to service security, use security elements during browsing, complete an application to register or participate in an event, store content for publishing videos and audio, enable dynamic content (for example, loading animation of a text or image) and share content on social media. As they are strictly necessary, technical cookies are downloaded by default when they are needed to display the platform or provide the service requested by the user.
2. Functionality or customisation cookies: These cookies are needed to remember information so that the user can access the service or platform with specific characteristics that can differentiate their experience from that of other users. For example, language, number of results displayed when the user runs a search, appearance or content of the service based on the type of browser used, or the region from where the service is accessed, etc. Not accepting cookies may cause slow website performance or poorly adapted recommendations.
3. Analysis cookies: These cookies can quantify the number of users, sections visited on the platform and how users interact with it to carry out statistical measurement and analysis on use, in order to implement improvements based on the analysis of data on how users use the platform or service. 
4. Behavioural advertising (profiling) cookies: Are those which store information on user behaviour obtained from continuous observation of their browsing habits, which allows us to develop a specific profile for displaying advertising adapted to these habits. These cookies allow for the most effective management possible of any advertising space the editor has included directly or in collaboration with third parties

What are Cookies used for on our Platform?

Cookies are an essential part of our how Platform works. The main goal of our Cookies is to make your browsing experience as easy and efficient as possible. For example, they are used to remember your preferences (language, country, etc.) when browsing and during future visits. We also use our Cookies to continuously improve our services and Platform, and to offer customised advertising according to your browsing habits.

Information collected on Cookies also allows us to improve our Platform by making estimates on statistical data and patterns of use (number of visits, most visited sections, visit time, etc.), gain a statistical understanding of how users interact with the Platform so as to improve our services. In any case, the Cookies we use never store sensitive information such as passwords, credit or debit card details, etc.

The cookies you'll find on our site are related to the following websites:

Giphy is a GIF image library we use in our website to make our content easier to navigate and more fun. When embeding the GIFs, Giphy adds it's own cookies to the page. You can find information about their Data processing on their Policy: https://support.giphy.com/hc/en-us/articles/360032872931

YouTube is a video content display service operated by Google Inc. that allows this site to integrate such content within its pages. The data collected by this service are cookies and user usage data. For more information on the logic and methods of processing data collected through these applications, the user is invited to consult the privacy notices of the provider: Google Inc.: https://policies.google.com/privacy

In detail:

Technical cookies (always accepted):

Name: preferred_location
Provider: newordinarypeople.com
Duration: session
Type: first-party (technical language prefer functionality)

Name: cookielawinfo-checkbox-non-necessary, cookielawinfo-checkbox-non-necessary, viewed_cookie_policy, CookieLawInfoConsent
Provider: newordinarypeople.com
Duration: session
Type: first-party (technical cookie banner functionality)

Name: wordpress_sec_, wordpress_logged_in_, tk_ai
Provider: newordinarypeople.com
Duration: session
Type: first-party (technical e-commerce functionality)

Name: __cfduid, __cf_bm
Provider: newordinarypeople.com
Duration: 30 days
Type: first-party (security)

Name:_clck
Provider: newordinarypeople.com
Duration: 1 year
Type: first-party (technical functionality)

How can I manage the use of Cookies on this Platform?

In the Cookies settings panel, available at all times on our Platform, you can find all the information on the Cookies used by this Platform, along with information on the purpose, duration and management (first or third-party) of each Cookie, so you can enable or disable the use of Cookies that are not strictly necessary for Platform functioning. Alternatively, if you are browsing the Internet, you can disable the use of Cookies on your browser. You can prevent the use of Cookies at any time. Please remember that both managing the Cookies settings panel and opting to reject Cookies is specific to each browser you are using. Therefore, if you configure Cookies one way on one device and want your option to apply equally to another device, you must enable the same option on the other device. Additionally, regarding third-party Cookies used to provide advertising based on your interests, please note that certain third parties may be members of some of the following self-regulatory programmes for online behavioural advertising, with the relevant voluntary exclusion options:

Network Advertising Initiative (NAI) – http://www.networkadvertising.org/choices/ 

Who uses the information stored on Cookies?

The information stored on our Platform Cookies is only used by us, except those identified in section 4 and section 5 as “Third party cookies”, which are used and managed by external entities to provide us services aimed at improving our services and the user experience when browsing on our Platform. More information in the Cookies settings panel available at all times on our Platform. For more detailed information on how we process your personal data in collaboration with third parties and on data subject to international data transfers, please read the privacy policies/privacy settings of these third-party collaborators, available on their platforms.

Legal references
This information is drawn up in accordance with the principles of EU Regulation 2016/679 and Recommendation 2/2001 of the Working Party established by Article 29 of Directive 95/46/EC.