INTRODUCTION 
Welcome to the Shaneel Group’s privacy policy.

The network of websites operated by the Shaneel Group includes, but is not limited to, those located at  www.shaneel.com, www.designerparfums.com, www.jenniferlopezbeauty.com,  www.parfumsscherrer.com, www.ghostfragrances.com, www.naomi-campbell-perfumes.com  and www.fragranceexpert.com
 
The Shaneel Group respects your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit them from) and tell you about your privacy rights and how the law protects you.
 This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here: [LINK]. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
 
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
 
1.  IMPORTANT INFORMATION AND WHO WE ARE  
 
PURPOSE OF THIS PRIVACY POLICY  
 
This privacy policy aims to give you information on how the Shaneel Group collects and processes your personal data through your use of its websites, including any data you may provide through the websites when you sign up to our newsletters, purchase a product or service or take part in a competition.
This website is not intended for children (i.e. people under the age of 18) and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
CONTROLLER  
The Shaneel Group is made up of different legal entities, details of which can be found here: www.shaneel.com/companies This privacy policy is issued on behalf of the Shaneel Group so when we mention Shaneel, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Shaneel Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.  Shaneel Enterprises Limited is the controller and responsible for this website.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
 
CONTACT DETAILS  
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of DPO: Mr Hetal Shah
Email address: dpo@shaneel.com
Postal address: Amertrans Park, Bushey Mill Lane, Watford, Herts, WD24 7JG
Telephone number: 01923 204450
 
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
 
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES  
We keep our privacy policy under regular review. This version was last updated on 18th September 2018. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
 
THIRD-PARTY LINKS  
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
 
2.  THE DATA WE COLLECT ABOUT YOU  
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
 
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.  We may, however, collect information about your health in certain circumstances, such as the reporting of an adverse reaction to a product.

3.  HOW IS YOUR PERSONAL DATA COLLECTED?  
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy, below, for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a)  analytics providers such as Google;
(b)  advertising networks such as Affiliate Window; and
(c)  search information providers such as Google and Bing.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal.

4.  HOW WE USE YOUR PERSONAL DATA  
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  
 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.





MARKETING  
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US  
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.
 
THIRD-PARTY MARKETING  
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
 
OPTING OUT  
You can ask us or third parties to stop sending you marketing messages at any time by updating your subscription preferences by clicking the opt-out link on any email you receive from us or third parties.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, product experience or other transactions.

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