WHO is Responsible for the Processing of Your Personal Data?
WHAT Personal Data Do We Collect and WHEN?
We ask you for certain personal data to provide you with the products or services you request. For example, when you make purchases, contact our consumer services, request to receive communications, create an account, participate in our events or contests, or use our Platform. Additionally, when you request specific services in store, we may ask you to login to provide services that are then associated with your account (e.g. size, fit, preferences).
This personal data includes your:
- contact details including name, email, telephone number and shipping and
- billing address;
- login and account information, including screen name, password and unique user ID;
- personal details including gender, hometown, date of birth and purchase history;
- payment or credit card information;
- images, photos and videos;
- data on physical characteristics, including weight, height, and body measurements (such as estimated stride and shoe/foot measurements or apparel size);
- fitness activity data provided by you or generated through our Platform (time, duration, distance, location, calorie count, pace/stride); or
- personal preferences including your wish list as well as marketing and cookie preferences.
We collect additional personal data from you to enable particular features within our Platform. For example, your social network credentials to post content from our Platform to a social network. This personal data includes your:
- social network information, including credentials and any information from your public posts about BlackSHISHA or your communications with us.
- Device IDs, call state, network access, storage information and battery information.
- Cookies, IP addresses, referrer headers, data identifying your web browser and version, web beacons, tags and interactions with our Platform.
We comply with local laws and do not allow children to register on our Platform when they are under the legal age limit of the country in which they reside. We will ask for parental consent for children participating in BlackSHISHA experiences and events.
TOOLS to Manage What Personal Data We Collect
When using our Platform we also provide in-time notice or obtain consent for certain practices. For example, we will obtain consent to use your location or send push notifications. We may obtain this consent through the Platform or using the standard permissions available on your device.
In many cases, your web browser or mobile device platform will provide additional tools to allow you to control when your device collects or shares particular categories of personal data. For example, your mobile device or web browser may offer tools to allow you to manage cookie usage or location sharing. We encourage you to familiarize yourself with and use the tools available on your devices.
WHY and HOW Do We Use Your Personal Data?
We use your personal data in the following ways:
To Provide the Features of the Platform and Services You Request
When you use our Platform, we will use your personal data to provide the requested product or service. For example, if you make a purchase on BlackSHISHA.com or participate in an event or promotion, we will use the contact information you give us to communicate with you about the purchase, event or promotion. If you contact our consumer services, we will use information about you, such as delivery or payment information, or the product you have purchased to help you resolve a problem or question.
In many cases, to use particular features within our Platform you may need to provide BlackSHISHA with additional data or additional consent to use particular data in a certain way. Similarly, to share content on social media, you may be required to provide your social media account credentials to sign in.
To Communicate Information about our Products, Services, Events and for Other Promotional Purposes
When you consent, we will send you marketing communications and news concerning BlackSHISHA products, services, events and other promotions that may be of interest to you. You can opt-out at any time after you have given your consent.
If you are an existing customer of BlackSHISHA (for example, if you have placed an order with us), we may use the contact details you provided to send you marketing communications about similar BlackSHISHA products or services where permitted by applicable law (unless you have opted-out). In other cases, we ask for your consent to send you marketing information.
We may use the information that you provide to us as well as information from other BlackSHISHA products or services – such as your use of BlackSHISHA Platform, your visits to or purchases made in BlackSHISHA stores, your participation in BlackSHISHA events and contests – to personalize communications on products and services that may be interesting for you. In doing so, we may combine the information you provide to us with information that we create about your online activity, including internal insights and analysis.
To Operate, Improve and Maintain our Business, Products and Services
We use the personal data you provide to us to operate our business. For example, when you make a purchase, we use that information for accounting, audits and other internal functions. We may use personal data about how you use our products and services to enhance your user experience and to help us diagnose technical and service problems and administer our Platform.
To Protect Our or Others’ Rights, Property or Safety
For General Research and Analysis Purposes
We use data about how our visitors use our Platform and services to understand customer behaviour or preferences. For example, we may use information about how visitors to BlackSHISHA.com search for and find products to better understand the best ways to organize and present product offerings in our storefront.
We may also use your personal data in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.
To process your personal data, we rely on certain legal grounds, depending on how you interact with our Platform.
- When you purchase BlackSHISHA products from our Platform, we need your personal data to fulfil our contract with you. For example, we need your payment and contact details to deliver your order.
- When you use our Apps, we rely on your consent for processing and for certain limited purposes to fulfil our contract with you (for example, for in-App purchases).
- We also rely on other legal grounds, such as our legitimate interests as a business to process information about the effectiveness of our marketing campaigns, our products, services, events and other promotional initiatives; to operate, improve and maintain our business, products and services; to protect our or others’ rights, property or safety; and for general research and analysis purposes. When processing personal data for our legitimate interests, we take appropriate measures to ensure that the interests we pursue are balanced with your interests, rights and freedoms, which we are happy to explain upon request.
- We also process your personal data to comply with a legal obligation, or to protect your vital interests.
SHARING of Your Personal Data
BlackSHISHA shares your personal data with:
- BlackSHISHA entities for the purposes and under the conditions outlined above.
- Service providers processing personal data on BlackSHISHA behalf, for example to process credit cards and payments, shipping and deliveries, host, manage and service our data, distribute emails, research and analysis, manage brand and product promotions as well as administering certain services and features. When using service providers we enter into agreements that require them to implement appropriate technical and organizational measures to protect your personal data.
- Third-party targeted advertising providers that provide personalization ad tailored advertising services to us. We use such services to match aggregated information that we hold with personal data in their database to create custom audiences and tailor advertising to your interests on the Internet, including social media, as permitted by applicable law. You may opt-out of personalized advertising and custom audiences by using the relevant settings in our Platform.
- To any other third party where you have provided your consent.
We may also transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).
When you use certain social features on our Platform, you can create a public profile that may include information such as your screen name, profile picture and hometown. You can also share content with your friends or the public, including information about your BlackSHISHA activity. We encourage you to use the tools we provide for managing BlackSHISHA social sharing to control what information you make available through BlackSHISHA social features.
PROTECTION and MANAGEMENT of Your Personal Data
Encryption & Security
We use a variety of technical and organizational security measures, including encryption and authentication tools, to maintain the safety of your personal data.
International Transfers of your Personal Data
We take measures to comply with applicable legal requirements for the transfer of personal data to recipients in countries outside of the EEA or Switzerland that do not provide an adequate level of data protection. We use a variety of measures to ensure that your personal data transferred to these countries receives adequate protection in accordance with data protection rules; this includes signing the EU Standard Contractual Clauses or verifying the recipient has adopted Binding Corporate Rules. Where personal data is transferred within BlackSHISHA, we use an intragroup data transfer agreement.
Retention of your Personal Data
YOUR RIGHTS Relating to Your Personal Data
You have the right to request: (i) access to your personal data; (ii) an electronic copy of your personal data (portability) and to have this information transmitted to another company; (iii) correction of your personal data if it is incomplete or inaccurate; or (iv) deletion or restriction of your personal data in certain circumstances provided by applicable law. These rights are not absolute. Where we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
If you like would to request a copy of your personal data or exercise any of your other rights, please use our BlackSHISHA Platform “Contact us” section.
Opting Out of Direct Marketing
If you have a BlackSHISHA account, you can opt-out of receiving BlackSHISHA marketing communications by modifying your preferences in the “view or change my profile” section of our Sites. You can also opt-out by modifying your email or SMS subscriptions by clicking on the unsubscribe link or following the opt-out instructions included in the message. You can also contact us using the contact details in the BlackSHISHA Platform “Contact us” section.
COOKIES and Pixel Tags
BlackSHISHA collects information, which may include personal data, from your browser when you use our Platform. We use a variety of methods, such as cookies and pixel tags to collect this information, which may include your (i) IP address; (ii) unique cookie identifier, cookie information and information on whether your device has software to access certain features; (iii) unique device identifier and device type; (iv) domain, browser type and language, (v) operating system and system settings; (vi) country and time zone; (vii) previously visited websites; (viii) information about your interaction with our Platform such as click behavior, purchases and indicated preferences; and (ix) access times and referring URLs.
Third parties may also collect information via our Platform through cookies, third party plug-ins and widgets. These third parties collect data directly from your web browser and the processing of this data is subject to their own privacy policies.
- Functional: These cookies are required for basic site functionality and are therefore always enabled. These include cookies that allow you to be remembered as you explore our Platform within a single session or, if you request, from session to session. They help make the shopping bag and checkout process possible as well as assist in security issues and conforming to regulations.
- Performance: These cookies allow us to improve our Platform’s functionality by tracking usage. In some cases, these cookies improve the speed with which we can process your request and allow us to remember site preferences you have selected. Refusing these cookies may result in poorly-tailored recommendations and slow site performance.
- Social media and Advertising: Social media cookies offer the possibility to connect you to your social networks and share content from our Platform through social media. Advertising cookies (of third parties) collect information to help better tailor advertising to your interests, both within and beyond our Platform. In some cases, these cookies involve the processing of your personal data. Refusing these cookies may result in seeing advertising that is not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on social media.
For a comprehensive and up-to-date summary of every third-party accessing your web browser (through BlackSHISHA Platform or otherwise), we recommend installing a web browser plugin built for this purpose. You can also choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings on each browser and device that you use. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to many features that make our Platform more efficient and some of our services will not function properly. There are also general resources for opting out of interest-based advertising available on the website of the Digital Advertising Alliance.
Similarly, you can adjust your advertising preferences on your mobile device at the device level. For example, to adjust your advertising preferences in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads.USING BlackSHISHA Platform with Third-Party Products and Services
Our Platform allows you to interact with a wide variety of other digital products and services. For example, our Platform can integrate with third-party devices for activity tracking, social networks, music streaming services and other digital services.
If you choose to connect your BlackSHISHA account with a third-party device or account, your privacy rights on third-party platforms will be governed by their respective policies. For example, if you choose to share your BlackSHISHA activity on third-party social media platforms, the policies of those platforms govern the data that resides there.
Our Platform may provide links to other (third-party) websites and apps for your convenience or information. Linked sites and apps have their own privacy notices or policies, which we strongly encourage you to review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.
QUESTIONS and Feedback
If you wish to provide feedback or if you have questions or concerns or wish to exercise your rights related to your personal data, please use our BlackSHISHA Platform “Contact us” section.
If you contact us with a privacy complaint it will be assessed with the aim of resolving the issue in a timely and effective manner. You also have the right to lodge a complaint with the relevant supervisory authority in the country in which you reside.