Privacy Notice

This Privacy Policy (“Privacy Policy”) describes the types of personal information that Electronic Commodities Exchange, L.P. (d/b/a Summerswaggear), as well as any of its parents, affiliates, or subsidiaries, (“Summerswaggear”, “us,” our” or “we”), may collect about you in the context of your use of use of, and access to, the Summerswaggear Website(s)s located at https://summerswaggear.com or on any other affiliated website where these terms appear (“Website”) and the features and functionality thereof (the “Service(s)”), the purposes for which we use the information, and the circumstances in which we may share such information.

When you visit the Website, we collect certain personal information about you. As used in this Privacy Policy, “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household.

COLLECTION OF PERSONAL INFORMATION

The categories below describe the personal information we collect about you and the sources from which we collect those categories of personal information.

Category	Description	Source of Information
Personal Identifiers	email address; telephone number; postal or delivery address	you
Account Information	name, email address, password, postal address, delivery address, phone number, employer	you
Device and/or Online Identifiers	IP address; session ID; session timestamps	you; devices associated with you; third party information providers
Internet, Browser, and Network Activity	clickstream website tracking information; data related to user browser activity, including browser visits, page views, visits, and unique visitors data; and cookies or other similar technologies	you; devices associated with you; third party information providers
Log Information	Information automatically recorded by our servers, including but not limited to, your Internet Protocol address, operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on the Website;	you; devices associated with you; third party information providers
Mobile Device Information	hardware model, operating system and version, unique device identifiers, and mobile network information	devices associated with you; third party information providers
Cookies and Other Tracking Technology Information	See section below entitled “Cookies and Other Tracking Technologies” for a description of what cookies or other tracking technology may be employed on the Website.	devices associated with you; third party information providers
Location data	Region, country and city/municipality	you; devices associated with you; third party information providers
Payment data	Payment card number, name on card, billing address, phone number, card security code and expiration date	you
Inferences drawn from other personal information	Inferences drawn from any of the information identified above to create a user profile reflecting user preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	you; devices associated with you; third party information providers

USE OF PERSONAL INFORMATION

We may use your information for the following purposes:

·      Sending you communications and administrative emails;

·      Personalizing and tailoring the features, performance and support of the Website;

·      Identifying you as a user on the Website;

·      For the performance of a contract between you and us;

·      Fulfilling orders you may place on our Website;

·      Sending you promotional/marketing information, advertising, newsletters, offers or other information from us;

·      Sending you promotional/marketing information, advertising, offers or other information from us related to our affiliate partners;

·      Providing support related to your account or orders you may place on the Website;

·      Providing you with opportunities and functionality that we think would be of particular interest;

·      Analyzing, benchmarking and conducting research on user data and interactions with the Website;

·      Processing services, maintaining user accounts, resolving disputes, preventing fraud and verifying your identity;

·      Monitoring, maintaining, administering and improving Website performance;

·      Protecting your, our, or third parties’ networks, systems, property, or physical safety;

·      Complying with requests from regulatory agencies, law enforcement, and other public and government authorities, as well as with relevant industry standards and policies;

·      Enforcing our contracts, terms, and conditions or otherwise exercising our legal rights; defending ourselves from claims; and complying with laws and regulations that apply to us or third parties with whom we work;

·      Aggregating the information collected via cookies and similar technologies to use in statistical analysis to help us track trends, analyze patterns and conduct research and product development;

·      Meeting our or third parties’ audit and compliance requirements; or

·      For any other purposes that we may specifically disclose at the time you provide or we collect your information.

Anonymized or Aggregated Information

We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual users) for various business purposes, where permissible under applicable laws and regulations.

How Long Your Personal Information Will Be Kept.

We will keep your personal information while you have an account with us or while we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;

• To show that we treated you fairly; or

• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

SHARING OF PERSONAL INFORMATION WITH OTHER ENTITIES

We may share personal information about you with other entities, including entities that provide services to us. We do not disclose your personal information collected through the Website to other entities, except as described in this Privacy Policy.

Applicable law requires that we identify the categories of personal information we share for business purposes. We disclose the following categories of personal information for business purposes: Personal identifiers, device and online identifiers, information about your internet, browser, and network activity, location data, payment data, and inferences drawn from other personal information.

We may share your information with the following types of entities or in the following situations:

Service providers: We engage service providers to facilitate our operation of the Website and provide the Services. These service providers analyze information about the Website and your use of the Website. Information disclosed for these purposes may include device and online identifiers, ISP information, session ID and /or session log data, information about your internet, browser, and network activity, and location data.

Legal authorities, emergency responders and other legal requirements: We may disclose personal information to third parties as permitted by, or to comply with, applicable laws, regulations, or legal obligations, including but not limited to responding to a subpoena or similar legal process, protecting against fraud, cooperating with law enforcement or regulatory authorities, protecting and defending the rights or property of  Summerswaggear, preventing or investigating possible wrongdoing in connection with the Website/Services, protecting the personal safety of users of the service or the public, and protecting against legal liability. Information disclosed for these purposes may include personal identifiers, device and online identifiers, information about your internet, browser, and network activity, and location data.

For Business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

With Business partners: We may share your information with our business partners to offer you certain products, services or promotions.

With other users: when you share personal information or otherwise interact in the public areas of the Website with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through, e.g., a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.

Cookies and Other Tracking Technologies

We, our affiliates and/or other persons acting on our or their behalf use cookies and similar technology, such as web beacons (also known as clear GIFs or pixel tags), or similar technologies as they may develop over time to collect, use, and share information when you visit our online services or interact with us online, via email or through other electronic means

Cookies are small pieces of data sent from a website and stored on a device.  Cookies may enable us to capture and compile statistical information about how you use our online services, including information relating to your device’s IP address, the frequency of your visits, readership data (such as the average length of visits, which pages are viewed or shared during a visit or other interactions with our content, such as time spent viewing videos, PDFs read and links clicked), authentication information, acceptance or rejection of website terms, and periods of inactivity.  ​

Our online services also use web beacons.  Web beacons are invisible tags and may be placed on a webpage, in advertisements, or in an email or other message.  They usually work in conjunction with cookies, registering when a particular device visits a particular page.  For example, web beacons may count the number of individuals who visit our Website from a particular advertisement or who enroll in a service after viewing a particular advertisement.

“Clickstream” data (e.g., information regarding which of our Website pages you access, the frequency of such access, and your product and service preferences) may be collected by Summerswaggear itself, or by our service providers, using cookies, web beacons, page tags, or similar tools that are set when you visit the Website or when you view an advertisement we may have placed on another website. Clickstream data and similar information may be shared internally within Summerswaggear and used for administrative purposes to assess the usage, value and performance of our online products and services; to improve your experience with the Website; and as otherwise permitted by applicable law or regulation. This information may be processed by us for the purposes described above, or on our behalf by other entities, solely in accordance with our instructions.

How We Use These Technologies

We, our services providers, and third party business partners may use information collected from cookies, web beacons, and similar technologies for the following purposes:

to allow our online services to operate as you have requested;

to understand how our online services are accessed and used;

to recognize you when you return to our Website;

to assess the effectiveness of advertising and readership content;

to deliver marketing communications that may be of interest to you, including ads or offers tailored to you; and

for other purposes described above under “USE OF PERSONAL INFORMATION.”

We may combine the information that we collect through cookies, web beacons and similar technologies with other personal information we have collected from you from both online and offline sources.

We may work with service providers to promote our products and services both on the Website and other websites.  For example, if you visit a page on the Website or third-party websites that provides information about one of our products or services, a cookie may be placed on your browser or device that identifies the product or service you viewed.  This information allows us, our service providers, and our third-party business partners to deliver more relevant and tailored content, such as ads for that particular product or service.

Other than service providers, we do not allow unaffiliated third parties to collect personal information about your activities on the Website.  Nor do we serve ads promoting unaffiliated third party products or services on the Website.

Managing Your Preferences

Many web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies.  Unless you have adjusted your browser setting so that it will reject cookies, our system may issue cookies when you access or use our online services.  In the event you refuse to accept cookies by adjusting your browser setting, some or all areas of our online services may not function properly or may not be accessible.

Do Not Track Policy

Most browsers can be set to send signals to third party websites requesting them not to track the user’s activities.  At this time, we do not respond to “do not track” signals.  Consequently, our third party service providers may indeed track and collect information about your online activities over time while navigating to, from and on our online services, notwithstanding any “do not track” signals we may receive.

Our Security Procedures

Our goal is to protect your personal information submitted to us through our online services. We maintain reasonable physical, electronic, and procedural safeguards that comply with applicable law to guard nonpublic personal information about you against loss, misuse or unauthorized access, disclosure, alteration or destruction of the information you have provided to us through our online services. We have internal policies governing the proper handling of consumer information by personnel and requiring third parties that provide support or marketing services on our behalf to adhere to appropriate security standards with respect to such information. The security of your personal information is important to us, but please note that no method of transmission over the Internet, or method of electronic storage is perfectly secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Links to Other Websites

This Privacy Policy only applies to the use and disclosure of information we collect through our online services. Our online services may contain links to other websites belonging to third parties that are not affiliated with us. The inclusion of any link on our Website or otherwise in our online services does not imply our endorsement of the linked website or service. While we try to link only to websites that meet our standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites, or links posted on our online services. Information you disclose to other parties or through such sites is subject to the privacy and security practices and policies of those parties or websites.  We disclaim all liability, to the extent permissible, with regard to your access to such linked websites.  Access to any other websites is at your own discretion and we encourage you to read the privacy statements of each and every website or online services visited in order to learn how such third parties may treat your information.

Detailed Information on the Processing of Your Personal Information

Our third-party service providers have access to your personal information only to perform their tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Social Logins & Content

Social login is a form of single sign-on that allows you to create a new account or sign into your account on our Website using your existing login information from a social-networking service such as Facebook, Google or Twitter instead of creating a new login account specifically for our Website. It is designed to simplify logins.  

You don’t have to use a social login. We offer registration that uses your email address instead and is not linked with an existing social-networking account.

If you register or access your account on our Website with a social networking service (or later link your account to one), we will collect certain information about you from that social networking service, and what we collect depends on your privacy settings with that social networking service.

Email Marketing

We may use third party email marketing service providers to manage and send emails to you. We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us. 

Payments

We may provide paid products and/or services within the Website. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. Third party services that we used or may use include, Paypal, Apple Pay services and their privacy policies, please visit their websites:

PROTECTING CHILDREN’S PRIVACY ONLINE

Our online services are not directed to or intended for individuals under 18 years of age.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

·       “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices

·       “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.

GDPR Privacy

Legal Basis for Processing Personal Information under GDPR

We may process personal information under the following conditions:

•                Consent – you have given your consent for processing personal information for one or more specific purposes.

•                Performance of a contract – provision of personal information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.

•                Legal obligations – processing personal information is necessary for compliance with a legal obligation to which we are subject.

•                Vital interests – processing personal information is necessary in order to protect your vital interests or of another natural person.

•                Public interests – processing personal information is related to a task that is carried out in the public interest or in the exercise of official authority vested in Summerswaggear

•                Legitimate interests: processing personal information is necessary for the purposes of the legitimate interests pursued by the Summerswaggear

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of your personal information and to enable you to exercise your rights under the GDPR.

You have the right under this Privacy Policy, and by law if you are within the European Economic Area (“EEA”), to:

•                Request access to your personal information. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal information directly within your account settings section. If you are unable to perform these actions yourself, please contact us by email at service@summerswaggear.com to assist you. This also enables you to receive a copy of the personal information we hold about you.

•                Request correction of the personal information that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.

•                Object to processing of your personal information. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal information on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

•                Request erasure of Your personal information. You have the right to ask us to delete or remove personal information when there is no good reason for us to continue processing it.

•                Request the transfer of Your personal information. We will provide to you, or to a third-party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please not that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

•                Withdraw Your consent. You have the right to withdraw your consent on using your personal information. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Website.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us by email at service@summerswaggear.com. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, if You are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

Contacting Our GDPR Data Protection Officer

We have designated a Data Protection Officer whom you have the right to contact with regard to all issues related to processing of your personal information and to the exercise of your rights under the GDPR.  You may contact our Data Protection Officer by email at service@summerswaggear.com.

EEA data subjects may contact the data protection officer with regard to all issues related to processing of their personal data and to the exercise of their rights under the GDPR.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify or supplement this Privacy Policy at any time. Therefore, we recommend that you review this Privacy Policy, updated and posted on this Website, regularly for changes. The effective date of this Privacy Policy, as stated above, indicates the last time this Privacy Policy was revised.

Your continued use of our online services after we have changed the Privacy Policy signifies your acceptance of the revised terms.  This Privacy Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information related to your use of the Website. Under certain circumstances (i.e., with respect to material changes to this Privacy Policy), we may also elect to notify you through additional means, such as by posting a notice on the Website or sending you an email. The revised Privacy Policy will be effective immediately upon posting to our Website.

OUR OTHER PRIVACY POLICIES OR NOTICES

This Privacy Policy provides a general statement of the ways in which Summerswaggear protects your personal information when you access and use this Website. You may, however, in connection with specific products or services offered by Summerswaggear, be provided with separate privacy policies or notices that describe the privacy practices associated with your use of those products or services.

CONTACT US

If you have any questions about this Privacy Policy, you can contact us:

By email:       service@summerswaggear.com

Address：Golden Cross House 8 Duncannon Street, Charing Cross, London, WC2N 4JF