About GDPR in General
GDPR stands for General Data Protection Regulation and is a new data protection regulation from the EU that will become law in all EU Member States on 25 May 2018. The GDPR will replace the current Personal Data Act (PDA). The Act is intended to protect individuals’ privacy and to modernise, harmonise and reinforce protection within the EU.
Each EU Member State has a supervisory authority that will monitor this. In Sweden this authority is the Privacy Protection Authority, formerly the Data Protection Authority. On their website there is more information and help that you can read to find out what you need to do.
Who we are
Pancho And Lefty is a clothing webstore curated and run by Mikko Engström and owned by The Denim Grocery, Stockholm AB. Our website address is: https://panchoandlefty.se. For any issues concerning your privacy, contact: firstname.lastname@example.org
Personal Data Controller
What Personal Data We Collect And Why We Collect It
We don’t collect any Personal Data from Visitors or Users when they use the Service, unless they provide such information voluntarily, for example, by ordering products from us.
When you order from our website, your personal order form data will be stored into our (Pancho And Lefty) database records. It will be stored there indefinitely but you have the right to ask it to be removed and we will do so. When you visit our site, we have Google Analytics tool and Jetpack Analytics in use, which both monitor your ip-address and, for example, where do you visit from and for how long do you visit our site. After you leave our site, no records of where you go next are not stored or known by us. We have these analytics tools in use to be able to provide better service for you, our customers.
The Information We Store When You Order
When you order from us, the following data is stored in our database to secure that the item/items you ordered really go to you or to the recipient you tell us to send it.
Your full name, Company name (not obligatory but if you type it in, it will be also stored in our records), Street Address and Country, Postcode, Town, E-mail address, Phone Number and possible personalised order notes you want to leave for us in the extra order comment section. If you want us to ship your order to another address than to your billing address, then we also store the extra shipping information on our records too. This includes the same information fields as above: Recipients full name, Company name (not obligatory but if you type it in, it will be also stored in our records), Street Address and Country, Postcode, Town, Phone Number and E-mail address.
Also, the information of the item/items you order will be stored in our database indefinitely. This means: the item name, size, color, brand name, price. If you are a frequent customer, your whole order history is stored in our database in order for us to be able to offer better service and products for you. Also, the automatically calculated shipping price for your location will be stored in our records. We also need to store someo of the information of the sold products for legal reasons, for example, the Swedish Bookkeeping Act.
About Your Payment Information
When you have completed your purchase on either one of those services, you will be securely redirected back to our site. We do not have any access to your personal payment information. We only know, if and when your payment is completed in order for us to be able to ship you the item/items you ordered from us. The same applies to the refund process.
Access to Personal Data
Only those at Pancho And Lefty who need access to the Personal Data to perform their work tasks are processing the Personal Data. Those people have entered into confidentiality agreements.
Subscriptions To E-mail List
When you have subscribed to our e-mail list you have agreed to receive information from us about our shop updates, such as product offers and more. At any time, you can remove yourself from the e-mail list and your e-mail information will be removed from our servers.
Pancho and Lefty will use the information you provide by joining our e-mail list in the e-mail subscription form to be in touch with you and to provide updates and marketing.
You can change your mind at any time by clicking the unsubscribe link in the footer of any email you receive from us, or by contacting us at email@example.com. We will treat your information with respect. By joining our e-mail list, you agree that we may process your information in accordance with these terms.
Personal Data Processor
In certain cases personal data will be processed by external parties acting as the Personal Data Processor for Pancho And Lefty. The Personal Data Processor (PDP) will process personal data on behalf of Pancho And Lefty and will be responsible for the technical and organisational security measures.
How Long We Retain Your Data
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information. We retain that data indefinitely.
What Rights You Have Over Your Data
- Right to access your data
You can request to receive an extract containing the data that we have about you. The extract will be sent free of charge in one copy on one occasion per year.
- Right of rectification.
You have the right to have rectified any wrong or incomplete information about yourself.
- Right to be forgotten
You have the right to request the removal of your personal data when the purpose of the processing is no longer current. The removal cannot be revoked/recreated and once the removal is complete, no person can be associated with the user account any longer. However, there may be legal obligations for Pancho And Lefty and The Denim Grocery AB as the Institution which prevent the immediate deletion of your personal data or parts of it. These obligations stem from accounting and tax legislation, but also from consumer rights legislation. In such a case, only the personal data that we are required to save in order to fulfil such legal obligations will be saved.
If you have an account on this site, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes. Also, if you want to request us to collect your personal data in an exported file more than in one copy per year, we will apply an extra fee minimum of 100€ per data collection request.
Right to Access Personal Data
You have the right to obtain from Pancho And Lefty confirmation as to whether or not Personal Data concerning you are being processed, and, where that is the case, access to the Personal Data.
You have the right to obtain from Pancho And Lefty the erasure of Personal Data concerning you and Pancho And Lefty has the obligation to erase Personal Data when the Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed or you have withdrawn consent on which the processing is based.
Restriction of Processing
You have the right to obtain from Pancho And Lefty restriction of processing if you have a particular reason for wanting the restriction. This may be if you have issues with the content of the information we hold or how we have processed your personal data. It can also be the case when Pancho And Lefty no longer needs the Personal Data.
Who We Collaborate With To Be Able To Provide Our Services For You
Our site webhotel is provided by Fsdata (https://fsdata.se/).
Our site has been built by Juxtalab Creative Solutions (juxtalab.com), and they have admin privileges of this site in order to provide scheduled maintenance updates to keep this site running smoothly. They have agreed into confidentiality agreements and only approved staff have access to the platform.
WordPress does not share any personal data with anyone.
About our site
Below you can read more about the tools we have in use on our site.
Jetpack Plugin Personal Data Information
Jetpack is a plugin built by Automattic.
This feature only records activities of a site’s registered users, and the retention duration of activity data will depend on the site’s plan and activity type.
Data Used: To deliver this functionality and record activities around site management, the following information is captured: user email address, user role, user login, user display name, WordPress.com and local user IDs, the activity to be recorded, the WordPress.com-connected site ID of the site on which the activity takes place, the site’s Jetpack version, and the timestamp of the activity. Some activities may also include the actor’s IP address (login attempts, for example) and user agent.
Activity Tracked: Login attempts/actions, post and page update and publish actions, comment/pingback submission and management actions, plugin and theme management actions, widget updates, user management actions, and the modification of other various site settings and options. Retention duration of activity data depends on the site’s plan and activity type. See the complete list of currently-recorded activities (along with retention information).
Data Synced (?): Successful and failed login attempts, which will include the actor’s IP address and user agent.
This feature is only accessible to registered users of the site who are logged in to WordPress.com.
Data Used: IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID and URL, Jetpack version, user agent, visiting URL, referring URL, timestamp of event, browser language, country code. Some visitor-related information or activity may be sent to the site owner via this feature. This may include: email address, WordPress.com username, site URL, email address, comment content, follow actions, etc.
Activity Tracked: Sending notifications (i.e. when we send a notification to a particular user), opening notifications (i.e. when a user opens a notification that they receive), performing an action from within the notification panel (e.g. liking a comment or marking a comment as spam), and clicking on any link from within the notification panel/interface.
Data Used: In order to check login activity and potentially block fraudulent attempts, the following information is used: attempting user’s IP address, attempting user’s email address/username (i.e. according to the value they were attempting to use during the login process), and all IP-related HTTP headers attached to the attempting user.
Activity Tracked: Failed login attempts (these include IP address and user agent). We also set a cookie (jpp_math_pass) for 1 day to remember if/when a user has successfully completed a math captcha to prove that they’re a real human. Learn more about this cookie.
Data Synced (?): Failed login attempts, which contain the user’s IP address, attempted username or email address, and user agent information.
Activity Tracked: Functionality cookies are set for a duration of 347 days to remember a visitor’s blog and post subscription choices if, in fact, they have an active subscription.
WordPress.com Secure Sign On
This feature is only accessible to registered users of the site with WordPress.com accounts.
Data Used: User ID (local site and WordPress.com), role (e.g. administrator), email address, username and display name. Additionally, for activity tracking (see below): IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID and URL, Jetpack version, user agent, visiting URL, referring URL, timestamp of event, browser language, country code.
Activity Tracked: The following usage events are recorded: starting the login process, completing the login process, failing the login process, successfully being redirected after login, and failing to be redirected after login. Several functionality cookies are also set, and these are detailed explicitly in our Cookie documentation.
Data Synced (?): The user ID and role of any user who successfully signed in via this feature.
Data Used: IP address, WordPress.com user ID (if logged in), WordPress.com username (if logged in), user agent, visiting URL, referring URL, timestamp of event, browser language, country code. Important: The site owner does not have access to any of this information via this feature. For example, a site owner can see that a specific post has 285 views, but he/she cannot see which specific users/accounts viewed that post. Stats logs — containing visitor IP addresses and WordPress.com usernames (if available) — are retained by Automattic for 28 days and are used for the sole purpose of powering this feature.
This feature is only accessible to registered users of the site who are also logged in to WordPress.com.
Data Used: Gravatar image URL of the logged-in user in order to display it in the toolbar and the WordPress.com user ID of the logged-in user. Additionally, for activity tracking (detailed below): IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID and URL, Jetpack version, user agent, visiting URL, referring URL, timestamp of event, browser language, country code.
Activity Tracked: Click actions within the toolbar.
Analysis cookies collect anonymous information on how our services are used, e.g. which pages are popular, if you receive an error message anywhere or which kind of device is used. For example, third party cookies for Google Analytics and Google Tag Manager.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
Go to your browser or device settings to learn more about how to adjust the settings for cookies. For example, you can choose to block all cookies, accept only first party cookies or delete cookies when you close your web browser.
Note that some of our services may not work if you block or delete cookies.
For tracking website visits, we use Google Analytics and Google Tag Manager, as well as Jetpack Analytics tool. Google Analytics trackind data is stored for 26 months. Read more about how Google Analytics analyze your data and see their privacy policies here and here.
How we protect your data
We make sure to protect your data the best we can and your data is stored only in highly protected places. We have many different data protection procedures in place, such as:
- Only approved staff have access to the platform
- Backups are done at predetermined intervals.
- Ensuring about the latest updates, for example, for the cms, the store platform and plugins
- Protecting personal data by employing techniques such as access restrictions, encryption, pseudonymization, backups, data minimization, and regular testing of all these techniques.
In which countries will processing of your personal data occur?
Your personal data will be processed within the EU/EEA.
What data breach procedures we have in place
We have multiple data breach procedures in place, such as:
- Notifying the appropriate supervisory authority no more than 72 hours after of becoming aware of a breach of users’ personal data, including the number of users whose data was exposed, the nature of the breach, and what actions are being taken to mitigate its effects.
- Communicating this information to the impacted users, especially if the data breach exposed any of their unencrypted personal data.
- Considering the needs of any law enforcement investigations before publicly announcing the breach.
Additional Notes and Contact
If you have any extra questions, please contact us at: firstname.lastname@example.org