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Privacy & Cookies Policy

Privacy & Cookie Notice


1. Introduction In The Pearls Collection, we respect the privacy of individuals and we are committed to the security and protection of the personal information of the visitors to our website www.thepearls.com (“Users”). The present Privacy and Cookie Notice has been prepared based on the provisions of the applicable data protection legislation, including Art. 13/14 of Regulation (EU) 2016/679 (“General Data Protection Regulation”). It explains who we are, how we collect, share and use personal information about you, how our website uses cookies and how you can exercise your privacy rights. The present Notice forms an integral part of our Terms and Conditions of Use and of any other Policies adopted by us. This Notice relates solely to this website. Please note that other websites we, or our affiliate companies may have, may be subject to different Privacy Policies as described therein. We will always keep your personal data safe and comply with all applicable data protection provisions as each time in force according to the legislative framework. We shall not at any time, receive from you more personal data than what is necessary for each purpose for which they are collected, and we will not use or share your information with anyone except as described in this Privacy and Cookie Notice. We may update the present Notice at our discretion, from time to time, for example to comply with new obligations imposed by the applicable laws or technical requirements, and therefore we ask you to check periodically for the latest version of the Notice, as indicated in the “Last revised” Date at the bottom of the page. If there will be any significant changes made to the use of your Personal Information (as defined herein) in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by sending you an e-mail.


2. Personal Data We May Collect About You: Personal data is any information related to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly. Such data do not include information that is anonymous. We may collect and process various types of personal data about you, as described in this Notice, including: o Data collected directly by you: Personal data such as your name, surname, e-mail address, or other contact details about you that might be contained in communications you send to us for inquiries, complaints and other requests through our channels of communication (using our website contact form or by sending us an email at the available in our website e-mail address). Furthermore, we will receive your e-mail when you voluntarily fill in our form to receive a Newsletter from us. o Data collected automatically using cookies and other tracking technologies: Usage data about our users’ access and browsing behavior on our website that consist of personally identifiable information collected automatically, which can include among other data your browser type, version and language, your internet protocol (IP) address, operating system and time zone setting and location, your referral website, actions you take, patterns of page visits within our website. Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We may receive some of the aforementioned technical data from analytics providers such as Google. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors. For more details on the data we collect automatically, through cookies, – or other similar tracking technologies – by our Website or by the owners of third-party services used by this Website please see the Section 8 below.


3. For what purposes we collect information about you and on what legal basis? We respect and apply all the data protection principles imposed by the General Data Protection Regulation 2016/679 (indicatively: lawfulness, transparency, purpose limitation, data minimization, accuracy, storage time limitation, integrity, confidentiality and accountability). In general, whenever we process personal data, we do so on the basis of a lawful "justification" (or legal basis) for such processing. We may process Personal Data relating to our Users if one of the following applies: o If processing is necessary for our legitimate interests (or interests of a third party) that are not overridden by your interests and fundamental rights, including the operation, maintenance, security and the improvement of our Website and of the users’ experience, the performance of usage data analysis, the processing of your inquiries or the establishing, exercising or defending of legal claims. In these cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in “Your Rights” section below; o If processing is based on users’ prior explicit consent for one or more specific purposes. (e.g. where you provide us with your consent through this website to receive newsletters). o If processing is necessary for compliance with a legal or regulatory obligation to which we are subject (e.g. the disclosure of information to law enforcement or tax authorities). o If use of your Personal Information is necessary for the performance of any agreement, we have concluded with you and/or for any pre-contractual obligations thereof; In any case, we will gladly help to clarify the specific legal basis that applies to the processing, so if you would like to find out more about the legal basis for which we process Personal Information please contact us.


4. The Pearls Collection Newsletter When you visit our Website, you have the option to register in order to receive our Newsletter. By filling out our form, you give us your explicit consent to process your e-mail for the purpose of periodically sending you our newsletter that may contain news, updates, information about events or about our (or our affiliate Companies’) Products and Services that we provide. To protect privacy rights and to ensure you have control over how we manage marketing activities with you: o we will take steps to limit marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest to you; o If you no longer wish to receive The Pearls Collection newsletter you can ask us to stop sending marketing emails to you, by sending an email with your request at Alternatively, you can contact us at: contact@thepearls.com.
The withdrawal of consent does not affect the legality of the personal data processed up until the point of revocation.


5. With whom we might share personal information? We may share personal data and information we collect about our users, in accordance to the present Notice, with third parties in the context of the general operation and functioning of our website and always in a way that guarantees that your personal data and the information that we collect about you is not subject to any unlawful processing, i.e. is not being processed for purposes other than the following purposes: o With third-party subcontractors and/or our service providers who may provide on behalf of our Company technical, operational and marketing services, such as but not limited to hosting, technical support, and newsletter delivery services, data analysis or other support services from time to time, strictly for the purpose of providing their services to us, appointed, if necessary, as our Data Processors. For the same purpose, if you are our service provider we may collect contact details and other information about you or your company or organization where you provide services to The Pearls Collection; o With
our consultants (including financial, legal and other consultants) within the context of our Company’s lawful operation. o With our affiliate Companies, in order to support, integrate, promote, and improve our Website o With special successors: In the event that we undergo a business transition such as a merger, joint venture, acquisition by another company or sale of the whole or part of the Company assets, including personal information may be transferred to the successor entity/ in case of such change. If material changes to our privacy practices will occur as a result of the business transition, we will notify you and other users of the business transition prior to transferring your personal information. Furthermore, we will also respond to requests for personal data where required to do so by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.


6. Transfer of data outside of the European Economic Area (E.E.A.) We process your personal data at our operating offices and in any other place where the parties involved in the processing, such as our subcontractors, are located. As a result, depending on the User's location, data transfers may involve transferring of User's Data to a country other than their own. If you reside in the EU/EEA area in the context of and for the needs of the above-mentioned purposes, your personal data need to be transferred outside of the EU/EEA, for example to the USA, where our registered offices are. Whenever such data transfers take place this always happens in accordance with applicable law. By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC), which are accessible upon request, to provide an adequate level of data protection, we have established or confirmed that all data recipients will provide an adequate level of protection for your personal data.


7. Retention time (How long do we keep your data?) We will store your Personal Information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Privacy and Cookie Notice, or until a consent given by you gets revoked and you request their deletion (if this happens earlier), unless we are required to retain data for longer period of time for the performance of a legal regulatory, tax or accounting obligation or upon order of an authority. We generally, retain your personal data for three years from the end of our relationship or from the last contact from you. Notwithstanding the previous sentence: Once the retention period expires, Personal Data will be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.


8. Cookies Our Website uses cookies, therefore when you visit the website, a cookie may be installed in your device. A cookie is a small amount of data file that is sent to a user’s browser from a web server and stored on the user’s computer’s hard drive, in order to allow a website to recognize the user when he returns to the website using the same computer and web browser, either for the duration of his visit (a “session cookie”) or for repeat visits (a “persistent cookie”). The session cookies are stored in the user’s device until log out, until the user leaves a webpage or until the software (web browser) is disabled while the persistent cookies remain on the user’s device until deleted or once they reach a defined expiration date. Other similar files (or tracking technologies and services) work in the same way and we use the word ‘Cookie’ in this Notice to refer to all files that collect information in this way. Cookies set by the owner of a website are called “first party cookies”. Cookies set by other parties are called “third party cookies”. Third-Party Cookies, such as Google Analytics enable us to monitor and analyze web traffic and can be used to keep track of User
behavior and gain insights on the quality, performance and/or effectiveness of our Website. Strictly necessary cookies: are essential for the proper operation of the website, are used to help make our website work efficiently and enable you to browse around our website and use its features; Analytical/performance cookies used to analyze the way our website works and how we can improve and optimize it e.g. for statistical audience measuring to estimate the number of unique visitors, to detect the most preeminent search engine keywords that lead to a webpage or to track down website navigation issues. When certain types of cookies require your prior consent in order to be installed and used, you are asked through a relevant banner displayed on the front page of the website. If you choose not to enable or delete certain cookies, you will still be able to browse our website, but it will restrict some of the functionality of our website. We do not use automated decision-making without human intervention, including profiling in a way that produces legal effects concerning you or otherwise significantly affects you. Please see below the list of the First-Party and Third-Party Cookies we use and where you can find more information about them or the options to disable them: Source Source Type purpose Retention time Opt-out The Pearls Collection Strictly necessary cookies 6 Because strictly necessary cookies are essential to operate the website and its services, you cannot opt out. Google Analytics* Analytical/performance cookies 3 You may prevent Google from collecting and using data (cookies and IP address) by downloading and installing the browser plug-in here. *Google Analytics (Google Inc.) Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Service, to prepare reports on its activities and share them with other Google services. Next, no matter where the IP address originates from (Member States of the European Union, other parties to the Agreement on the European Economic Area, or elsewhere) Google anonymizes the last octet of the IP address (for IPv4 addresses) or the last 80 bits (for IPv6 addresses) (a process known as “IP masking”). Google does this because we have activated its “anonymizeIP” system for all countries. Finally, Google stores the anonymized data on servers in the USA. Google uses this information on our behalf for the purpose of evaluating your use of the touchpoint, compiling reports on website activity for us, and providing us with other services relating to touchpoint activity and internet usage. Google will not associate your IP address with any other data they hold. Follow these links for further information concerning the terms and conditions of our use of Google analytics External reference, the information that Google provide on data privacy and security, and Google’s data privacy notice.


9. Security We take and maintain appropriate technical and organizational security measures designed to prevent and reduce the risk of unauthorized access, disclosure, modification, or accidental destruction of personal information, appropriate to the nature of the information concerned. We also require our service providers to comply with strict data privacy and security requirements. While we take reasonable steps to protect your personal data, as the security of information depends in part on the security of the computer you use to communicate with us and the security you use, you accept the inherent security implications of dealing on-line over the Internet and will not hold us or our data processors responsible for any data breach unless it is due to our negligence. For the best possible protection of your personal data outside the limits of our control, your device should be protected (such as by updated antivirus systems) and your internet service provider should take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).


10. Your rights Our website Users residing in the European Economic Area may exercise certain rights regarding their personal data processed by us: Right of information We must provide you with all the necessary information regarding the processing of your personal data (including as to what data are being processed, for what purposes, how long the data will be stored) in a concise, transparent, easy to understand and easily accessible format, using clear and plain language. Right of access You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed and, where that is the case, you have the right of access to such personal data and obtain a copy of the data undergoing processing, or of related information regarding such processing if not covered within the present Notice. Right to rectification You have the right to verify the accuracy of your data and request from us the rectification of inaccurate personal data concerning you and the completion of incomplete information about you Right to erasure You have the right, under certain circumstances, to request the erasure of your personal data, subject to our obligation to retain such data for a specific period of time as required by law. Right to restriction of processing You have the right, under certain circumstances, to request from us the restriction of your processing. Right to object to processing You have the right to object, at any time to processing of personal data concerning you. We, in that case, shall no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms as data subject or for the establishment, exercise or defence of legal claims. Right to obtain human intervention in automated individual decision-making processing You have the right to request from us to not be subject, if applicable, to a decision process based solely on automated processing including profiling, which produces legal effects concerning you or significantly affects you. Right to data portability You have the right to request from us to receive your personal data in a structured, commonly used and machine-readable or to be transmitted to another provider without hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, or a contract which the User is part of or on pre-contractual obligations thereof. Right to withdraw consent You have the right at any time to withdraw your consent whenever consent is the legal basis for processing your personal information Right to lodge a complaint You have the right to lodge a complaint with a data protection supervisory authority if you consider that the processing of your personal data infringes applicable law. However, we would appreciate if we are offered the opportunity to deal with your concerns before you approach the data protection authority and so please contact us before, using the contact information mentioned in the present Privacy and Cookie Notice. Exercising your Rights: For further information regarding your rights, or in order to exercise any of your rights, please contact contact@thepearls.com These requests can be exercised free of charge and we will reply as soon as possible. In general, we reply to your requests within one (1) month of when we received the request, but if the request requires more time then we will inform you accordingly (within one month). Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.


11. Children’s privacy We will not knowingly collect, any personal information from any person under the minimum legal age depending the relevant data protection legislation limits on the country of his/her residence. If you are younger than the minimum legal age please do not use or provide any information on this website or thorough any of its features, and do not give any information about you to us, including your name, your address, your phone number or your e-mail address. If we find that we have collected or received personal data from a child younger than the minimum legal age we will delete such information, unless consent or authorization has been given by the child’s guardian.


12. Data Breaches We will report any unlawful data breach of this website to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen. If you have any complaints or questions regarding the processing of your personal data please contact contact@thepearls.com
Last revised: 16/09/2019