GDPR POLICY
Statement:
WICK DESIGNS is committed to protecting and respecting your privacy and we’ll only use your personal information to administer your account and to provide the products and services you requested from us. By interacting with WICK DESIGNS through our website, products and services, you consent to the use of information that is collected or submitted as described in this privacy policy. WICK DESIGNS may change or add to this privacy policy, so we encourage you to review it periodically.
WHAT INFORMATION WICK DESIGNS COLLECTS
WICK DESIGNS has a diverse range of business interests and operations and so an equally diverse range of Customers, Suppliers and Web Users. Accordingly, the type of Business Information that WICK DESIGNS processes depends on the particular business context and the purpose for which it was collected. It may include:
contact details (such as the individual’s name, job title, gender, work address, telephone numbers, email address, fax numbers and so on); details of an individual’s relevant experience and/or academic and professional qualifications (such as where the individual is employed by a vendor);
details of an individual’s business and other interests and opinions (such as where information is held in a Customer Relationship Management database); and/or,
information with respect to a Web User’s use of the WICK DESIGNS website, including the contents of web forms, contributions made to any discussion forums and browsing history, IP addresses, and their path through the WICK DESIGNS website;
Credit card details, credit worthiness, and other financial-related information, such as an individual’s bank account number and other relevant payment-related information collected in support of business transactions.
If WICK DESIGNS holds Business Information in more than one capacity (such as where an individual is a Customer, but also a Web User) then more than one of the purposes listed below may apply.
WICK DESIGNS advises those between the ages of 13 and 18 that they should consult with their parents prior to providing Personal Information.
WICK DESIGNS strongly disfavors the collection of Personal Information from children under the age of 13 (“Minor Children”), either directly or via a website which targets Minor Children or teenagers (or which is known to be frequented by Minor Children or teenagers). Any proposal to collect information from Minor Children must be approved in advance (following internal policies).
Note that it is acceptable to collect limited Personal Information from the Minor Child in order to seek parental consent (such as name and the contact information of his/her parents).
If collection of Personal Information of Minor Children is approved, the following additional requirements apply:
• Provide parental notice of WICK DESIGNS practices;
• Obtain prior verifiable parental consent for the collection, use, and/or disclosure of Personal Information from Minor Children, and store this consent for auditing and verification purposes. For any WICK DESIGNS websites which target Minor Children or which are known to be frequented by Minor Children parental consent must be obtained prior to collecting Personal Information or any personal identifier that permits the Minor Child to be contacted (such as a persistent identifier which permits sending instant messages to the Minor Child);
Provide a parent, upon request, with the ability to review the Personal Information collected from his/her child;
Provide a parent with the opportunity to prevent the further use of Personal Information about that child (e.g. a way to cancel membership);
Limit collection of Personal Information for a child's online participation in a game, prize offer, or other activity to information that is reasonably necessary for that activity; and
Establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of the Personal Information collected.
HOW WICK DESIGNS USES YOUR INFORMATION
Typically, WICK DESIGNS’s processing of Business Information is in connection with the following activities and business processes:
(a) Negotiating, concluding and performing contracts with Customers (including the provision of financial services and advice).
(b) Managing WICK DESIGNS accounts and records.
(c) Advertising, marketing and public relations (including direct marketing and personalized and targeted advertising). (d) Analyzing Web Users’ use of WICK DESIGNS websites, apps and related products and services.
(e) Market research and competitor analysis.
(f) Research and statistical analysis, including technological development.
(g) Negotiating, concluding and performing contracts with Suppliers.
(h) Communicating with individuals that are Customers, Suppliers, or Web Users.
(i) Operating the WICK DESIGNS website and apps.
(j) Supporting WICK DESIGNS’s corporate social responsibility activities.
(k) Legal and regulatory compliance, internal control evaluations (conducted by WICK DESIGNS’s internal and external audit service providers) and other internal investigations.
(l) Debt administration.
Suppression Requests
An individual may, at any time, request that WICK DESIGNS stop sending him/her direct marketing materials, even if he has previously consented to receive them.
Where an individual requests that WICK DESIGNS not send any further direct marketing communication, it is not generally necessary to delete such an individual’s information from WICK DESIGNS’s systems altogether. It is sufficient to “block” all outbound communications that would be covered by that individual’s request. All third party marketing lists which are to be used by WICK DESIGNS for direct marketing purposes must also be screened against the list of individuals who have opted-out.
In addition, WICK DESIGNS shall screen its direct marketing lists against any recognized industry suppression lists that may be relevant (e.g. Do Not Call lists).
An individual’s request may be specific to a particular media (e.g. “no phone calls” or “no emails”) or general (“no marketing”). Any request from an individual for WICK DESIGNS to stop direct marketing to that individual shall be forwarded to the appropriate WICK DESIGNS Privacy Team (contact@WICKDESIGNS.com) so that the individual’s details and all relevant suppression files may be updated and his request complied with.
Obtaining Permission
An “opt-in” consent requires that an individual has given his or her prior, informed consent to receiving marketing communications before such communications are sent. Such consent is often obtained by requiring the individual to tick a box to indicate his consent, particularly when Business Information is collected online, although this is not the only way of obtaining consent. When considering consent it is useful to put yourself in the individual’s position. Did the individual regard the action he has just taken – ticking a box, signing a form, clicking “send” etc. as indicating his consent?
An “opt-out” consent requires that an individual is offered a free and easy means of choosing not to receive marketing communications.
WICK DESIGNS shall seek to obtain the consent of Customers to direct marketing in accordance with applicable laws and in a form that is consistent with the standard forms, website policies and other documentation that is accessible or received by individuals. Further details are available from contact@WICKDESIGNS.com.
Other Individuals Rights
Subject to applicable local law, an individual may also exercise rights to object to certain types of processing carried out by WICK DESIGNS, to access and seek erasure of Business Information processed by WICK DESIGNS. WICK DESIGNS will deal with any requests in accordance with
HOW WICK DESIGNS SHARES THE INFORMATION WE COLLECT
Cookies and Similar Technologies
WICK DESIGNS and its partners may use a variety of cookies and other tracking technologies, including technologies provided by third parties (collectively “Cookies”) to understand how its Web Users use its websites and services and to deliver personalized advertising and content. WICK DESIGNS will give notice to Web Users on its use of Cookies and will explain how to “opt-out” from WICK DESIGNS’s use of Cookies.
Sharing Business Information Within WICK DESIGNS
Like many large organizations, WICK DESIGNS has business processes that cross country borders. In addition, many of its business units share resources, such as information technology. Accordingly, there are many situations within WICK DESIGNS where one WICK DESIGNS Group Member has a need to process Business Information originally collected by another WICK DESIGNS Group Member (and vice-versa).
(a) Data Sharing between WICK DESIGNS Companies as Data Controllers
A WICK DESIGNS Group Member may share Business Information with another WICK DESIGNS Group Member in the following circumstances:
the Business Information shall be used and otherwise processed in a manner that is compatible with the purpose for which it was originally collected; and
the Business Information shall only be made available within WICK DESIGNS to appropriately authorized representatives who have a clear “need to know” in connection with their usual WICK DESIGNS role, such as those in a managerial position (with responsibility for the Customers or Suppliers concerned).
(b) Data Sharing where one WICK DESIGNS Group Member (a Data Processor) processes on behalf of another (a Data Controller)
This refers to a situation where one WICK DESIGNS Group Member is providing a data processing service to another WICK DESIGNS Group Member, such as centralized storage of data, application hosting, or managing a Customer Relations help-desk.
Where a WICK DESIGNS Group Member (the Data Controller) uses another WICK DESIGNS Group Member (the Data Processor) to process Business Information on its behalf that WICK DESIGNS Group Member (the Data Controller) shall:
use a WICK DESIGNS Group Member providing sufficient guarantees or assurances with respect to the technical and organizational security measures governing the processing;
instruct the WICK DESIGNS Group Member (either generally or specifically) regarding how to process the Business Information and require that WICK DESIGNS Group Member to comply with equivalent security and confidentiality obligations as the WICK DESIGNS Group Member (Data Controller) is subject to (including those referred to in this Policy); and
otherwise comply with the requirements of Part B, Section 6.
Where a WICK DESIGNS Group Member (the Data Processor) processes Business Information on behalf of a WICK DESIGNS Group Member (Data Controller), it shall:
process Business Information in accordance with the instructions of the WICK DESIGNS Group Member (Data Controller);
apply and maintain appropriate technical and organizational measures to protect Business Information from unauthorized access and to avoid its accidental loss, damage or destruction, in particular, where the processing involves the transmission of data over a network as more particularly set out in WICK DESIGNS’s IT Policies; and
otherwise comply with the requirements of Part B, Section 6.
Sharing Business Information with third party service providers
When considering engaging a third party service provider, WICK DESIGNS shall have regard to the following:
Due diligence. WICK DESIGNS shall select a third party service provider providing sufficient guarantees with respect to data security and the handling of Business Information generally.
Contractual obligations. WICK DESIGNS shall ensure that its contract with the third party service provider includes specific data privacy obligations.
Compliance monitoring. WICK DESIGNS shall take reasonable steps to monitor the third party service provider’s performance of the relevant security and processing obligations. In circumstances where the third party service provider acts as a data processor, WICK DESIGNS will remain legally responsible for the third party service provider’s processing of its Business Information.
Transfers. If engaging a third party service provider will or may involve Business Information being processed outside Europe then additional data privacy clauses must be included in WICK DESIGNS’s contract with the third party service provider.
Disclosure of Business Information outside WICK DESIGNS
WICK DESIGNS shall not disclose Business Information outside WICK DESIGNS except where it is necessary to do so:
to engage a third party service provider;
to protect an individual’s vital interests;
where required by law, regulation or court order to do so;
in connection with a legitimate request for assistance by the police or other law enforcement agency;
to seek legal advice from WICK DESIGNS’s external lawyers, as directed by WICK DESIGNS’s in-house counsel;
with respect to a legal dispute or administrative claim between WICK DESIGNS and a third party; to that third party and lawyers representing them;
to engage professional advisers (e.g. bankers, lawyers, accountants, external auditors) and liaise with potential buyers and vendors in connection with the disposal or acquisition by WICK DESIGNS of a company or a company’s assets;
to engage external auditors to validate WICK DESIGNS’s financial accounts.
In addition, where sharing involves or may in the future involve Business Information being transferred outside Europe, WICK DESIGNS may only transfer such Business Information where one of the following conditions applies:
the third party will process the Business Information in accordance with a European Commission decision finding that the country provides adequate protection (e.g. the laws of Argentina or Canada will apply to the data processing by the third party);
the third party signs data privacy clauses that have been approved by a competent data protection authority;
the individuals have been given an opportunity to object, after having been informed of the purposes of the transfer, the categories of recipients and the fact that the countries to which the data is being transferred may have different data privacy standards;
if the transfer involves Sensitive Personal Information, the individuals have given their explicit consent to the transfer, where required; or the transfer is otherwise permitted under the European Data Protection Laws.
PRIVACY POLICY FOR CALIFORNIA RESIDENTS
In these California Consumer Privacy Act Disclosures ("CCPA Disclosures"), WICK DESIGNS disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 ("CCPA") and supplement the disclosures in our Privacy Policy. These CCPA Disclosures are addressed to California residents, are effective January 1, 2020, and were last updated January 31, 2022.
I. Who and what information is subject to these CCPA Disclosures?
California residents are protected as “consumers” by the CCPA with respect to personal information. A number of statutory exceptions apply under the CCPA. As a result some of these CCPA Disclosures do not apply to the following:
personal information reflecting a written or verbal communication or a transaction between the business and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency and whose communications or transaction with the business occur solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency.
personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business.
personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file.
personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of administering those benefits.
II. Accessibility
Consumers who need to access this Notice in an alternative format due to having a disability, please contact contact@WICKDESIGNS.com
III. CCPA Notice at Collection
In this CCPA Notice at Collection, we explain the categories of personal information we collect from consumers who use our website located at www.WICKDESIGNS.com that directly link to our Privacy Policy (collectively, our “Site”) and consumers whose information we collect for outreach purposes, and the purposes for which we use such information.
Information You Actively Submit: If you create an account, fill out a form, send an email to our team, or otherwise send us information through the Site, we collect personal information about you, which may include the following:
Contact Data, which may include your name, country, postal address, email address, job information, telephone number and similar information;
Account Data, which may include your Contact Data, username, password and other login information and other information you upload to your account;
Social Media Data, which may include your social media account name, media interactions with us (e.g., if you “like” or “share” something you see on our social media platforms), and forum posts; and
Correspondence Data, which may include your requests, comments, survey responses, and any other information you actively provide to us.
Information Automatically Submitted on our Site: When you use our Site, your browser and computer or device automatically provide to us certain technical information about your software and hardware and how you arrived at our Site, including the following:
Technical Data, which includes your browser type and version, device type, your internet protocol (IP) address, your location, and similar information;
Usage Data, which includes the URL that refers you to our Site, the pages you visit as you navigate through our Site (clickstream data), how long you stay on those pages, and the hyperlinks you click on. This information is collected using various technologies including server logs, cookies, web beacons, and other tracking technologies described in greater detail in our cookie policy.
Information from Other Sources: We may collect personal information through other sources such as third party data providers, social media platforms and joint marketing partners to help us offer our services to you. Such personal information consists of Contact Data and Social Media Data.
How We Use Your Personal Information: We use the following categories of personal information for the following purposes:
Contact Data to communicate with you, including responding to your queries, sending you service emails if you become a member of our communities as part of your ongoing membership, and contacting you to administer rewards such as sweepstakes and contests.
Account Data to create and manage your account, enable you to use online interactive forums that we may offer, and provide requested services and information to you.
Social Media Data to interact with you through social media platforms.
Correspondence Data to respond to any specific comments or questions you may have, and consider any survey feedback you provide to help improve our services.
Technical Data and Usage Data to provide, maintain, monitor, secure, debug, customize and optimize our online services to and for you, provide you with customer service and technical assistance, and develop and improve our products and services.
We also use your personal information for the following purposes (collectively, the “General Processing Purposes”), as permitted by applicable law:
Performance of Contracts: To perform our obligations and exercise our rights under our Terms of Use and any other agreement that you conclude with us.
Compliance with Laws: To comply with any legal obligations that apply to us and respond to requests from government authorities.
Protection of Legal Interests: To protect the legal interests, health or safety of a user, us, or other third parties, such as in the event of a complaint or dispute.
Marketing Activities: To provide you with marketing and sales communications, invites and updates that we believe you may be interested in, and tailor the content of those communications based on our understanding of your preferences.
Merger or Sale: In the event that we, or some or all of our assets are acquired by or merged with a third-party entity or in connection with a merger, acquisition, sale, or other change of control, we may transfer some or all of the personal information that we have collected about you to another organization as part of that transaction. If we intend to transfer your personal information in connection with such a transaction, we will proceed as permitted or required by applicable law.
IV. CCPA Privacy Policy
Beyond the disclosures in the preceding “Notice At Collection” segment, we are providing additional disclosures about consumer rights and our personal information handling practices in the preceding twelve months.
1. Right to Know About Personal Information Collected, Disclosed, or Sold
This CCPA Privacy Policy describes personal information we generally collect, use, disclose and sell about California residents. You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise the right to know, please fill in this form or submit an email request to contact@WICKDESIGNS.com and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.
We will ask that you provide certain information to verify your identity. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
2. Our Personal Information Handling Practices
We have set out below categories of personal information we have collected about California residents in the preceding 12 months and, for each category of personal information collected, the categories of sources from which that information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties with whom we shared the personal information.
3. Disclosures of Personal Information, No Sale
Over the preceding 12 months, we disclosed certain categories of California residents’ personal information to the categories of third parties as shown in the table above. We do not and will not sell California residents’ personal information. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
4. Right to Request Deletion of Personal Information
You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please fill in this form or submit an email request to contact@WICKDESIGNS.com and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.
We will ask that you provide certain information to verify your identity. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once we have verified your identity, we will ask you to confirm that you wish to have your personal information deleted. Once confirmed, we will respond to your request in accordance with the CCPA.
If we deny your request, we will explain why.
5. Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal information by a business. We do not, and will not, sell your personal information.
6. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code §1798.125.
7. Authorized Agent
You can designate an authorized agent to make a request under the CCPA on your behalf if:
The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in Sections 2 and 3 above:
Email a copy of your written declaration authorizing the authorized agent to act on your behalf to contact@WICKDESIGNS.com; and
Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
8. Contact for More Information
If you have questions or concerns regarding our privacy policy or practices, you may contact us using the following details:
Email address: contact@WICKDESIGNS.com