Privacy PolicyPrivacy Policy

This Privacy Policy is for the website https://www.closely-official.com (hereinafter, the “Website”), and is served by Closely AB, a company organized under the laws of Sweden, with registration number 556971-2002 and its registered address at Stenkolsgatan 5, 41707 Göteborg, Sweden. 

HOW TO CONTACT US

If you have any questions about this Privacy Policy and/or have any enquiry relating to your Personal Data, please contact us via email on customerservice@closely-official.com or send us a letter to Data Privacy, Closely AB, Stenkolsgatan 5, 41707 Göteborg, Sweden. 

LAWS AND REGULATIONS

The information we gather, use and process are collected in accordance with: The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, or “GDPR”) The Swedish Data Protection Act (Personuppgiftslag 1998:204).

PRINCIPLES

This Policy is based on the following principles: Personal data shall be processed lawfully, fairly and transparently; Personal data shall only be collected for specific, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; Personal data shall be adequate, relevant and limited to what is necessary for processing; Personal data shall be accurate and, where necessary, kept up to date with every effort to erase or rectify without delay; Personal data shall be kept in a form such that the data subject can be identified only as long as is necessary for processing; Personal data shall be processed in a manner that ensures the appropriate security; Personal data shall not be shared with third parties except when necessary in order for them to provide services upon agreement; Data subjects must easily exercise their rights.

WHAT PERSONAL INFORMATION ARE COLLECTED?

Personal information is data that can be used to identify or contact you. Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”. If we do collect personal data, we will nevertheless never collect sensitive personal data about you. The EU’s General Data Protection Regulation (GDPR) defines sensitive personal data as “categories of personal data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.” We are committed to ensuring that the information we receive and use are appropriate for the below purposes.

A. WHEN YOU SIGN UP FOR A NEWSLETTER

We may collect and process the following information: Email address, Full name, We use the above information from the following purposes: So you can receive updates about the Closely project So you can receive marketing communication via email or SMS So we can send you surveys about our services and products So we can notify you about changes to our services The legal grounds to process your personal data are: The processing of your personal data is necessary for the contact between you and Closely (to fulfill your application and subscriptions), for compliance with our legal obligations and our legitimate interests*

B. WHEN YOU INTERACT WITH OUR WEBSITE

We may collect and process the following information: Email address, Information gathered when you visit our website We use the above information from the following purposes: So you can sign up to our newsletters and receive information, news and offers about our products So we can provide, update, maintain, improve and protect our website, business and services So we can deliver relevant website content and online advertisements. The legal grounds to process your personal data are: The processing of your personal data is based on your consent (when you sign up for our NL) or based on our legitimate interests*

C. WHEN YOU APPLY FOR EMPLOYMENT

We may collect and process the following information: Name, Email address, Telephone number, Correspondence history, curriculum vitae, personal letter, information, ID documentation We use the above information from the following purposes: So you contact, communicate with us So we can manage, administrate all your queries So we can verify your identity when you request further information based on your rights The legal grounds to process your personal data are: The processing of your personal data is necessary for the contract between you and us, and based on our legitimate interests*

D. WHEN YOU APPLY TO BECOME A TESTPILOT

We may collect and process the following information: Contact details such as email address, full name, telephone number, address, your written replies and information submitted in the application. We use the above information from the following purposes: So we can smoothly and perfectly manage the application (contact applicants, recommend best product for test-report, deliver merchandise for evaluation, deliver discount-code/voucher) The legal grounds to process your personal data are: The processing of your personal data is necessary for the contract between you and us *When we rely on the ‘legitimate interests’ condition, Closely will always meet the following requirements: We must process the information for the purposes of our legitimate interests or for those of a third party to whom we disclose it; The above interests must be balances against your interests. The “legitimate interests” condition will not be met if the processing is unwarranted because of its prejudicial effect on your rights and freedoms, or legitimate interests. Closelys’s legitimate interests do not need to be in harmony with those of the individual for the condition to be met. However, where there is a serious mismatch between competing interests, your legitimate interests will always come first.

MARKETING COMMUNICATIONS

If you sign up or willingly give us your email address, you will receive marketing messages by email and/or SMS. These marketing messages are only meant to inform you about our current and next offers. You can of course decide to unsubscribe from us at any time. How do you unsubscribe from marketing communications? 1. NEWSLETTER By clicking on the unsubscribe link at the end of the email By contacting our Customer Care Service 2. TEST PILOT By clicking on the unsubscribe link at the end of the email communications sent By contacting our Customer Care Service

SHARING YOUR INFORMATION

We will never sell your personal data to any third party. However, we may share your personal information with companies who are experts in their field and assist us in operating the website, conducting our business or servicing you. Do not worry though! Each of our service providers have been selected by us for their ability to provide the particular services needed, including their ability to handle your personal information. All those providers provide sufficient guarantees to implement the technical and organizational measures necessary to meet the requirements of the GDPR and our own. We share your personal information in the following cases: To any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries; If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Closely, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; If we are processing it on behalf of a customer; To companies for the performance of any contract we enter into with you or them and that help us provide our services adequately such as, payment service providers, delivery companies or our warehouse. To other professional services companies such website hosts, advertising/marketing agencies and analytics or search engine providers helping us run, improve and optimize the Website or helping us store your data. With your expressed consent.

TRANSFERS OF YOUR INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA

Where a third-party provider is located outside the European Economic Area, we will always ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws or with companies that are Privacy Shield Certified.

TO ACCESS WHAT PERSONAL INFORMATION IS HELD IDENTIFICATION WILL BE REQUIRED

Where you request access to your information, we are required to use all reasonable measures to verify your identity before doing so. These measures only exist to protect your information and to reduce risk of identity fraud, theft or unauthorized access to your information. We therefore kindly ask you to send us original or certified copies of the following documentation: passport, identity card, birth certificate or driving license. One of those above documents is required in order to request personal information. We will endeavour to respond within one month. If you want to exercise one of the above rights, please contact us either via email or using the contact details provided below in the paragraph "How to contact us".

HOW LONG DO WE KEEP YOUR INFORMATION?

We will hold your personal data for as long as you are you have an account and for as long as is necessary to comply with our legal/ regulatory obligations, resolve disputes, prevent fraud and abuse or enforce our terms and conditions. When we no longer need to retain your personal data, it will be deleted or be anonymized so that you can no longer be identified from it. We securely destroy all financial information once we have used it and no longer need it.

HOW YOUR PERSONAL INFORMATION IS SECURED?

Closely will use all reasonable efforts to protect your personal information. We are using the latest industry standards and security measures such SSL/TLS encryption for protection of user data and personal information. Our goal is to have all appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing and using personal data. We have safeguard processes in place in order to ensure the ongoing confidentiality, integrity, availability and resilience of our or third parties processing systems and services as well as the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident. Your data is always store in secure environments and we provide training to our Staff on data protection best practices and require them to enter into a confidentiality agreement. You can access and edit personal information after signing into your account. To sign in, you are required to know your login credentials - email address and password. There is no way to access personal information without knowing the login credentials, therefore no unauthorized party can access it. We therefore ask you to keep your password secret and to not share it with any person (even a friend!). Please, immediately inform us if you know or suspect to have lost your login or that someone else is accessing your account.

LINKS TO OTHER WEBSITES OR SOCIAL MEDIA

Our site or newsletters may contain on occasion links to and from other websites of our partners, advertisers and affiliates. Please note that this Privacy Policy only applies to this website. If you visit any of these websites, we therefore suggest you to read their own privacy policy as we do not accept any responsibility or liabilities for these policies.

Cookies, Web Beacons, and How We Use Them

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

A "web beacon" or "pixel tag" or "clear gif" is typically a one-pixel image, used to pass information from your computer or mobile device to a website.

We use cookies and web beacons to keep track of what you have in your shopping cart and to remember you when you return to the website as well as to identify the pages you click on during your visit to our site and the name of the website you visited immediately before clicking to the Luma website. We use this information to improve our site design, product assortments, customer service, and special promotions. You can, of course, disable cookies and web beacons on your computer by indicating this in the preferences or options menus in your browser. However, it is possible that some parts of our website will not operate correctly if you disable cookies. We may also use web beacons, and other technologies, to help track whether our communications are reaching you, to measure their effectiveness, or to collect certain non-personal information about your computer, device, or browser in order to allow us to better design future communications to you.

We may contract with third parties who may use cookies and web beacons and collect information on our behalf or provide services such as credit card processing, shipping, promotional services, or data management. We call them our Customer Care Partners. These third parties are prohibited by our contract with them from sharing that information with anyone other than us or our other Customer Care Partners.

List of cookies we collect

The table below lists the cookies we collect and the information they store.

COOKIE name COOKIE Description
CART The association with your shopping cart.
CATEGORY-INFO Allows pages to be displayed more quickly.
COMPARE The items that you have in the Compare Products list.
CUSTOMER An encrypted version of your customer id.
CUSTOMER-AUTH An indicator if you are signed into the store.
CUSTOMER-INFO An encrypted version of the customer group you belong to.
CUSTOMER-SEGMENT-IDS Stores your Customer Segment ID
EXTERNAL-NO-CACHE A flag that, indicates whether caching is on or off.
FRONTEND Your session ID on the server.
GUEST-VIEW Allows guests to edit their orders.
LAST-CATEGORY The last category you visited.
LAST-PRODUCT The last product you looked at.
NEWMESSAGE Indicates whether a new message has been received.
NO-CACHE Indicates whether it is allowed to use cache.
PERSISTENT-SHOPPING-CART A link to information about your cart and viewing history if you have asked the site.
RECENTLYCOMPARED The items you recently compared.
STF Information on products you emailed to friends.
STORE The store view or language you have selected.
USER-ALLOWED-SAVE-COOKIE Indicates whether a customer authorized cookies.
VIEWED-PRODUCT-IDS The products that you recently looked at.
WISHLIST An encrypted list of products added to your wish list.
WISHLIST-CNT The number of items in your wish list.
COUNTRY The active website country

 

CHANGES TO OUR PRIVACY POLICY

We keep our Privacy Policy under regular review. We will post any updates on this webpage. If significant changes are made, we will directly contact you by email so you can review the changes. Please check back frequently to see any updates or changes to our Privacy Notice. In the event that Closely has not correctly responded to your request, you have the right to lodge a complaint to a Supervisory Authority. Closely’s Supervisory Authority is The Swedish Data Protection Authority (DPA). You will find their contact information here: https://www.datainspektionen.se/in-english/contact-us/

The Privacy Policy was last updated 30 September, 2020.

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