1. Data Controller
Reima Europe Oy Karhumäentie 3, 01530 VANTAA, FINLAND
2. Contact person for register matters
Kristina Lagerroos c/o Reima Europe Oy Karhumäentie 3 01530 Vantaa Phone: +358 20 759 5800 Email: email@example.com
3. Name of the register
Reima.com customer register
4. The purpose and legal grounds for processing data
Legal grounds for processing personal data is the legitimate interest of Reima on the grounds of a customer relationship or other appropriate connection and the implementation of an agreement between Reima and Website user.
5. Description of personal data submitted by you and collected by Reima
We collect various information, including personal data, if you seek to place an order for a product to us on the Website or if you contact our customer service. We collect, store and process your personal data for processing your purchase on the Website and any possible later claims, and to provide you with our services.When you place an order we need your name, address, phone number and email address. If you need to get in touch with our customer service team via contact form at Reima.com, email, chat or through other means, that information you submit to us is also collected.There are also other instances where you’ll provide us with information. You can also create a user account and become a registered user, which allows you to save and review your contact and delivery information, order history, wish list and shopping cart. You may write and submit reviews about the products you have purchased, participate in Reima Test Patrol program, referral programs or sweepstakes, and doing this will also mean providing us with personal information.You can also create a user account and become a registered user by registering through your Facebook account. In this case you will share with us your public profile and email address from your Facebook account. Of this information we currently use only the e-mail address and name information to create your Reima user account. If you decide to subscribe our newsletter, we will use your email address to send you newsletters. Facebook will be able to tell you more about how they use and process your data whenever you connect with reima.com through them. You must only submit to us or the Website information and personal data which is accurate and not misleading and you must keep it up to date and inform us of changes.
6. Personal information we collect automatically
When you visit our Website, we may automatically collect certain information, which may also be categorized as personal data. This includes your IP address, the date and time you accessed our services, the hardware, software or internet browser you use and information about your computer’s operating system, like application versions and your language settings. We might also collect information about clicks and which pages you have been browsing and which products you have added to wish list or cart.
7. Usage of your personal data
The main reason for collecting information, including your personal data is that we cannot process your orders without such information. We also use your personal data to contact you and in case you have opted in to our marketing messages (e.g. newsletter or sms marketing), to inform you of our products and special offers. We collect the following personal data from you:
Visitor interaction events: Events, such as page views, add to cart or wishlist, order information and login data.
Customer data: This includes basic personal data details such as name, address, phone number, email address and order history, and data that you voluntarily provide us via your account, such as your kid’s first name and birthday. We also collect the communication data from various channels in case we communicate with you in.
Email interaction data: In case you have subscribed our newsletter, we collect related events such as delivery, open, clicks and other interactions with newsletters.
Your personal data will be used in the following ways:
Orders: We use your personal data to process and deliver your order. We may pass your name and address on to a third party in order to make delivery of the product to you (for example to our courier or supplier).
Customer service: Our customer service team uses your personal data for processing your questions, queries or claims regarding your orders, deliveries or other similar issues.
Chat service Giosg.com processes customer data on behalf of Reima with the help of online services. Customer data contain personal data, such as IP addresses and the content of the chat conversations. Most of the data is provided by the customer via the chat conversation. This data is used for engaging the customer, analytic purposes and developing Reima’s services. https://www.giosg.com/privacy-policy
Account administration: Website users can create a user account in Website. We use the personal data you give us to administer this account, so you can review your order history, create wish lists, save your cart, manage your personal settings or take advantage of special offers. Creating an account does not require subscribing to our Reima Friends newsletter, but by doing so you will hear about the special offers among the first ones. When you subscribe to our Reima Friends newsletter, a user account will be created for you.
Reima Test Patrol: Reima organizes product test groups called Reima Test Patrol, which requires a user account. Participating to Reima Test Patrol group requires opting in to our newsletters, through which we will also communicate about the Reima Test Patrol. You may unsubscribe from our newsletter at any given time via the link provided in the email footer, but then you can no longer participate in the Reima Test Patrol.
Reima Lab: We may also enable our customers to join and interact with us and with each other through our online research community Reima Lab. In Reima Lab we collect e.g. your experiences about the usage of our products, comments to prototype products and product development ideas. We use this information e.g. to develop better products and services and communication.
Reima Play: To be added only to Finland at this point
Marketing activities: We also use your personal data for marketing activities. These activities may include:
If you have subscribed to our Reima Friends newsletter, we use your contact information to send you newsletters that contain special offers, personalized product recommendations based on your browsing or purchase history and news about our products and services. If you have added your kid’s first name and birthday to your account, we may use this data for sending you personalized marketing messages that are targeted based on the kid’s age. These may include birthday greetings, tips for school or day care or age based product recommendations. You can remove your consent or kid’s data any time if you no longer want us to process it. You can unsubscribe from all email marketing through the "Unsubscribe" link included in each newsletter, or via my account page or by contacting customer service.
When you participate in other promotional activities (such as sweepstakes or competitions), relevant information will be used to administer these promotions.
Communicating with you: We would need your personal data for getting in touch with you, for instance:
Responding to and handling any requests you have made.
Communicating about all the transaction related issues, e.g. order confirmation, shipping information, return and refund processing.
We are sharing your shipping information, including personal data with our warehouse and shipping partners, who will use it for delivering the order to you and might also need to contact you by phone in case of needing to arrange a new delivery time slot or method.
If you have left items in your shopping cart, we may email you with a reminder to continue with your order. This enables you to continue shopping without having to search for the products again.
Market research: You may be invited to take part in market research.
Product reviews: After ordering from Website, you may be invited to submit a product review. Your review can be displayed anonymously. By completing a product review, you agree that it can be displayed on the relevant product detail page on Website, on our social media accounts, or in our marketing communication.
Legal purposes: In certain cases, we may need to disclose your information, including personal data, to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding. We may also disclose your information and personal data in response to a subpoena, warrant, court order, or other legal process or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
8. Sharing your personal data with third parties
Your data is not shared or forwarded to third parties without your explicit consent. We only share your personal data with our service partners, which are required for handling the contractual relationship with Reima and you. In these cases, we strictly adhere to the specifications of the EU Data Protection legislation (EU 2016/679). The scope of the data transfer is restricted to a minimum:
Payment service providers: We use the payment service provider "Shopify Payments", 3rd Floor, Europa House, Harcourt Building, Harcourt Street, Dublin 2 If you choose a payment method offered through the payment service provider Shopify Payments, the payment will be processed by the technical service provider Stripe Payments Europe Ltd, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland, to whom we pass on the information you provide during the ordering process together with the information about your order (name, address, account number, bank code, possibly credit card number, invoice amount, currency and transaction number) in accordance with Art. 6 para. 1 lit. b DSGVO. The passing on of your data takes place exclusively for the purpose of payment processing with Stripe Payments Europe Ltd. and only insofar as it is necessary for this purpose. Further information on Shopify Payments' data protection can be found at the following internet address: https://www.shopify.com/legal/privacy Data protection information about Stripe Payments Europe Ltd. can be found here: https://stripe.com/en-pl/privacy.
In addition to the order processing, we may use service providers to process your personal data on our behalf, for instance when sending out newsletters. These service providers have confidentiality clauses and are not allowed to use your personal data for other purposes. We also may transfer personal data to service providers that are located outside the EU/EEA. When personal data is processed outside the EU/EEA by our service providers, we make sure that such service provider has committed to use the EU Commission’s standard contractual clauses and/or is bound by the Privacy Shield -principles.
9. Your personal data in our customer relationship marketing tool
We use software tools provided by Ometria Limited to analyse our customer data, including your personal data such as:
Visitor interaction events: Events, such as page views, key interactions and orders.
Ecommerce data: This Includes products, categories, and orders. These are synced directly with the client’s ecommerce platform database, ERP, data warehouse, or other system.
System data: This includes application user login data, such as email addresses and salted password hashes, and also API credentials for syncing with our ecommerce platforms and other marketing channels.
Email interaction data: Events such as delivery, open, clicks and other interactions with newsletters sent from the Ometria platform.
In addition to the analytical purposes, we use the above information for customer segmentation, as well as personalizing and automatizing our marketing for those who have opted in to our marketing.
Ometria is our processor and not a data controller. In delivering its services to us, its software is hosted through the following infrastructure: Ometria’s production systems are hosted by Amazon Web Services (AWS), on their Elastic Compute Cloud (EC2) service.
Ometria's email delivery technology is powered by Sparkpost Elite. Sparkpost, like Ometria, is hosted on AWS. All backups are saved to Amazon S3 with a secured bucket and ‘at rest’ data encryption using AES-256, one of the strongest block cyphers available.
Where data is transferred outside of the EEA, including to the US, Ometria has agreements in place with
AWS under what is known as AWS WS Data Processing Addendum and Model Clauses – further details of which can be found at: https://aws.amazon.com/compliance/eu-data-protection/ Sparkpost under the EU/US Privacy Shield framework – further details of which can be found at: https://www.privacyshield.gov/welcome.
10. Your personal data in our refer-a-friend programme
Our existing customers can recommend Reima to their contacts who are new to Website to receive benefits (such as vouchers to Reima.com) both for themselves and the contacts. Our refer-a-friend programme is operated on our behalf by UK/London based company Mention Me Limited as our data processor. We will share some of your data (including email address, name and order details) with Mention Me to enable you to participate in our refer-a-friend programme. This is done for the purposes of:
Enrolling customers onto our refer-afriend programme;
Monitoring the programme and safeguarding against gaming or fraudulent use of the programme;
Communicating with customers in connection with operation of the programme and delivery of rewards;
Reporting on the performance of the programme
11. Cross-device tracking
Reima may utilize, from time to time, cross-device tracking, which enables Reima to track user behavior across multiple devices. As part of cross-device tracking, Reima may combine data collected from a particular browser or mobile device with another computer or device linked to the computer or device from which the data was collected.
In order to optimize the content of the Reima Friends newsletter, Reima may combine the browsing data and purchases made from different computers and devices. If you do not want Reima to combine such data for newsletter generation, you can unsubscribe from the Reima Friends newsletter.
12. Personal data in social media
When you use or interact with any of our social media channels (like Facebook), we may collect, record and retain certain automatically collected data regarding your activities on those social media channels, such as the frequency of your visits. For example, if you choose to use the Facebook “like” button to indicate you like any of our pages or apps, or if you tag any of your social media contacts or link to them in any content you post, we will record this information. This is most likely to be non-personally identifiable information but may also include personally identifiable information depending upon your settings on those channels.
Any content you put or add on any of our social media channels will be data provided directly by you, which may be personally identifiable information depending upon the content. We will collect, record and use that content and any other information you provide when putting or adding it to any of our social media channels (including any information that you have permitted those social media channels to share with us or that is allowed by your user settings on those sites).
Finally, any additional information about you that you need to provide when you use a particular social media channel or app will be explained in the terms and conditions for that social media channel or app.
13. The period for with your personal data will be stored by us
We retain the information you provide, including your personal data either while your account is in existence, or as needed to be able to provide our services to you, or (in the case of any contact you may have with our customer service team) for as long as is necessary to provide support-related reporting.
If legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Online Shop Terms of Service and Delivery, we may also retain some of your information for a limited period of time as required, even after you have closed your account or it is no longer needed to provide the services to you.
14. Your rights regarding your personal data
With respect to the personal data relating to you we commit to giving you the ability to do all of the following:
Profiling. With regard to a personal special situation, you have the right to prohibit your profiling and other processing activities which company may direct on your personal data to the extent that the grounds for the processing of information is the customer relationship between Reima and you. You may present your request for the prohibition at
firstname.lastname@example.org. In connection with the request, you must identify the special situation on the basis of which you object the processing of data. Company may refuse to implement the request for prohibition on statutory grounds.
Data Requests, Correction, Removal: If you wish to receive a copy, access or correct any personal data we hold about you, or to request that we delete any information about you, you may contact customer service team via the e-mail address or address given below. Your request will be dealt with as soon as possible.
Opting out from Commercial Communications: If you receive commercial emails from us, you may unsubscribe via the unsubscribe link provided in each newsletter or via contacting email@example.com.
Consent withdrawal or modification: You can withdraw or modify your consent (to the extent you have given such a consent) for collection and processing of the information you provide at any time via the e-mail address or address given below.
Official complaint: You are also entitled to object or request restriction of the processing of your personal data and you have the right to lodge a complaint with a supervisory authority in accordance with rules defined in General Data Protection Regulation EU 2016/679 (from 25.5.2018 onwards). However, we highly encourage you to work with us in good faith and contact us first.
You may also have choices available to you through the device or software you use to access the Website. For example, the browser you use may provide you with the ability to control cookies or other types of local data storage, or your mobile device may provide you with choices around how and whether location or other data is shared with us. In particular, if online advertisements are not to your liking, we would encourage you to find out more about the Do Not Track browser setting. To learn more about these choices, please refer to your device or software provider.
If you have any further questions regarding the collection, processing or use of your personal data, please contact our customer service team at firstname.lastname@example.org. The same applies to information, blocking, deletion and rectification requests regarding your personal data as well as for revocations.
15. Tools and more
You can object to the processing. You have the right to object to reasons arising from your particular situation. To object, please send an email to email@example.com.
16. Children’s personal data
Parents, you can learn more about how to protect children's privacy on-line visiting: https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online.
17. Contacting us
Both the personal data you provide to us, and the information we collect, is controlled by Reima Europe Oy, including for the purpose of the General Data Protection Regulation (EU 2016/679) and any other applicable laws.
We are always happy to hear from our customers (especially if you feel we’ve let you down or fallen short of your expectations). If you have any questions or feedback about this statement, or if you would like us to stop processing your information, please do not hesitate to contact a customer service team, who will be delighted to answer any questions you may have. You can either either contact our customer service team via firstname.lastname@example.org, or, write to us at:
Reima Europe Oy
https://www.reima.com/int/contact Karhumäentie 3 01530 VANTAA Finland