Privacy Policy

Privacy Policy

 

At MB ASR JWLS (”ASR JWLS”, ”we”, ”us” or ”our”) confidentiality and data protection is a high priority. This privacy policy sets out the guidelines for ASR JWLS’ processing of your personal data and provides you with the information you have the right to receive according to applicable data protection law. You must read the privacy policy before submitting your personal data to ASR JWLS.

 

Data controller and contact information


The data controller for your personal data is:

MB ASR JWLS
M. K. Čiurlionio g. 44-11
Druskininkai, 66142
Lithuania
Company code.: 305710078

Phone: +3706 92 15566A

E-mail: hello@asrjwls.com

 

1. If you visit our website

This section sets out the policy of ASR JWLS’ processing of personal data regarding users of ASR JWLS’s website www.asrjwls.com

 

1.1 Cookies

 

Types of personal data


ASR JWLS uses cookies on our website and applications. ASR JWLS may collect, process and store the following personal data about you via cookies when you visit our website or applications:

  • IP address
  • Hardware, software and internet browser used to access our website
  • Date and time of your access to our website or applications
  • Time zone
  • Preferences and click behaviour
  • Browsing history

We use cookies to collect the personal data stated above. You can find more information regarding our use of cookies in our cookie information banner on our website.

 

Purposes of the processing
Your personal data may be processed for the following purposes:

  • Promotional marketing in general
  • Product and service development
  • Statistics and analysis


Legal basis
ASR JWLS will mainly process your personal data based on the following legal basis:

  • Legitimate interests: The processing of your personal data will be based on our legitimate interest in, for instance, conducting statistics, analysis, marketing activities (where consent is not required), as well as improving and developing our products and services (Article 6 (1) (f) of the GDPR).
  • Consent: In some cases, we need your consent, e.g. in order for us to place cookies on your devices (Article 6 (1)(a) of the GDPR).

 

Retention period
Your personal data will be deleted when it is no longer needed for one or more of the purposes mentioned above. Please refer to our cookie information banner on our website for information about the expiry of cookies placed on your device.

The personal data may, however, be processed and stored for a longer period of time if anonymised.

 

1.2 Chat, booking of private appointments and other inquiries

 

Types of personal data
When you use the contact form for booking of private appointments or otherwise contact or communicate with us, ASR JWLS collects, processes and stores the following personal data about you:

  • Name, email address, phone number
  • What your inquiry or the communication concerns
  • Date and time of your inquiry
  • Other personal data you submit as part of your inquiry or communication with us. We recommend that you do not submit sensitive personal data, unless it is strictly necessary in relation to your inquiry. If you submit sensitive or otherwise confidential personal data by email, we recommend that you use encryption.

Purposes of the processing
Your personal data may be processed for the following purposes:

  • Handling of your inquiry
  • General communication with you
  • Marketing in general
  • Customer service
  • Statistics and analysis


Legal basis
ASR JWLS will mainly process your personal data based on one or more of the following legal bases:

  • Legitimate interests: The processing of your personal data will be based on our legitimate interest in, for instance, conducting statistics, analysis and developing our products and services as well as our legitimate interest in promoting our brand and sending marketing material (where consent is not required) (Article 6 (1) (f) of the GDPR).
  • Contractual obligation: If your inquiry concerns conclusion of a (potential) contract with ASR JWLS, we process your personal data to make arrangements prior to the conclusion of the contract (Article 6 (1) (b) of the GDPR).

 

Retention period
Your personal data will be kept for 2 years from your last inquiry.

Anonymized personal data may, however, be kept for a longer period of time.

If you are a customer or employed with one of our business partners, we refer to section 2 and 4 below.

 

2. Customers

 

Types of personal data
When you purchase an item from ASR JWLS, we collect, process and store the following personal data about you:

  • Contact information such as name, email address, address and phone number
  • Billing address and shipping address
  • Payment information (including credit card information)
  • Order number
  • Time and date of your purchase
  • Information about your order, such as which items you have purchased or any special remarks you have submitted in relation to your order.
  • Delivery information, such as when your purchased items were delivered
  • Order/purchase history
  • Whether you return the purchased items and, if so, when you return them
  • Complaints or notices of defects

 

Purposes of the processing
Your personal data may be processed for the following purposes:

  • Fulfillment of orders
  • Customer service
  • Marketing in general
  • Statistics and analytics


Legal basis
ASR JWLS will mainly process your personal data based on one or more of the following legal bases:

  • Legitimate interests: The processing of your personal data will be based on our legitimate interest in providing customer service, conducting statistics and analysis for developing our products and services as well as our legitimate interest in promoting our brand and sending marketing material (where consent is not required) (Article 6 (1) (f) of the GDPR).
  • Contractual obligation: We process your personal data to fulfill the order you have placed with ASR JWLS (Article 6 (1) (b) of the GDPR).

 

Retention period
Your personal data will be kept for 3 years from your last purchase.

Any personal data included in bookkeeping records will be stored for 5 years as from expiry of the financial year at which time the data will be deleted.

 

3. If you subscribe to our newsletter or other marketing material

This section sets out the policy for ASR JWLS’ processing of personal data when you have subscribed to our newsletter or other marketing material.

 

Types of personal data
When you subscribe to our newsletter or other marketing material, ASR JWLS collects, processes and stores the following personal data about you:

  • Name and email address
  • Your consent
  • Your click behaviour in relation to marketing material we have sent you
  • IP address
  • Which items you may have abandoned in the webshop basket

Purposes of the processing
Your personal data may be processed for the following purposes:

  • Promotional marketing
  • Statistics and analysis


Legal basis

ASR JWLS will process your personal data based on one or more of the following legal bases:

  • Consent: Sophie Bille Brahe will only use your personal data in order to send you product information, newsletters and other marketing material if you have provided your prior and explicit consent hereto (Article 6 (1) (a) of the GDPR).
  • Legitimate interests: The processing of your personal data for statistics and analysis will be based on our legitimate interest in improving and developing our products and services (Article 6 (1) (f) of the GDPR).

 

Retention period
Your personal data will be retained for as long as your consent to receive newsletters is active.

You may revoke your consent by clicking the unsubscribe link in the bottom of each e-mail or by contacting us as described below. The revocation of your consent does not affect the legality of the processing prior to the withdrawal.

The documentation for your marketing consent will be kept for two years after revocation. This retention period is based on ASR JWLS’ legitimate interest in being able to document that direct marketing activities have been carried out in compliance with applicable legislation (Article 6 (1) (f) of the GDPR).

Anonymized personal data may be kept for a longer period of time.

 

4. Private Client Relations

 

This privacy policy applies for our processing of personal data in relation to private client relations marketing.

 

Types of personal data
ASR JWLS collects, processes, and stores your personal data for marketing purposes when you sign up for our private client relations marketing material. ASR JWLS may collect, pro-cess, and store the following types of your personal data:

  • Name, phone number and email address
  • Age and gender
  • Purchase history
  • Private appointment history
  • Ring size(s)
  • Preferences and wish list
  • Special occasions such as birthdays and anniversaries
  • Your consent
  • Your click-behaviour in relation to published material
  • IP address

We will obtain from your order history, your interaction with our marketing material, our correspond-ence and during private appointments.

 

Purposes of the processing
Your personal data may be processed for the following purposes:

  • Marketing and personal service in regard to care and maintenance of your purchases, guidance on styling and purchases, wish lists and sizes
  • Analytics and statistics
  • Documentation of your consent

 

Legal basis
ASR JWLS processes your personal data on one or more of the following grounds:

  • Consent: ASR JWLS processes your personal data for direct marketing and profiling, including for sending out newsletters, if you have given your prior and explicit consent to this (Article 6(1)(a) of the General Data Protection Regulation).
  • Legitimate interests: The processing of your personal data will, in connection with documentation of your consent and analysis and statistics, be based on our legitimate interests in being able to improve and develop our service (Article 6(1)(f) of the General Data Protection Regulation).

 

Retention period
Your personal data will be stored as long as your consent to receive newsletters is active.

You can always withdraw your consent by clicking on the unsubscribe link at the bottom of each email or by contacting us as described below. However, withdrawing your consent does not affect the legality of the processing that preceded the withdrawal.

Documentation of your marketing consent is kept for 2 years from the time you have withdrawn your consent to receive direct marketing material. The retention period is determined based on ASR JWLS’s legitimate interest in being able to document that direct marketing has been carried out in accordance with the applicable legislation (Article 6(1)(f) of the General Data Protection Regulation).

In addition, the information can be stored for a longer period in anonymised form.

 

Profiling
If you have provided your consent to receiving customized marketing material as described in this privacy policy, ASR JWLS may make use of profiling, meaning that ASR JWLS may organise marketing material for you for it to consider preferences and interests that you have indicat-ed, e.g. on the basis of information on click behaviour, previous purchases, age, gender and special occasions such as birthdays and anniversaries. The profiling will affect the marketing material you receive from ASR JWLS, as the purpose of such profiling is to target you and your interests and needs in the best possible way.

 

5. Contact persons at suppliers and other business partners

 

This section sets out the policy for ASR JWLS’ processing of personal data collected from owners of sole proprietorships or contact persons at suppliers and other business partners who collaborate with ASR JWLS.

 

Collection of personal data
ASR JWLS may collect, process and store personal data about you in the following instances:

  • When your company or the company you are employed with enters into an agreement with ASR JWLS
  • When you have shown an interest in ASR JWLS, e.g., by providing your business card to ASR JWLS
  • When you collaborate and communicate with ASR JWLS

 

Types of personal data
ASR JWLS
may collect, process and store the following personal data:

  • Name, email address, telephone number and similar identification data
  • Individual data, such as preferred language and home country
  • Organizational data, such as company name, company address, job position, business area, primary work location and country
  • Contractual data, such as purchase orders, invoices, contracts and other agreements between your company (or your employer) and ASR JWLS, that may include e.g., your contact information
  • Any feedback you provide if you participate in surveys or similar
  • Financial data, such as payment terms and bank account details

Such information may be provided directly by you (primarily via emails and other correspondence) or by a third party such as your employer.

 

Purposes of the processing
Your personal data may be processed for the following purposes:

  • Generally, to plan, perform and manage the business relationship, including any contracts
  • Administration, such as processing payments, evaluation of credit ratings, performing accounting, auditing, and billing
  • Completion of requests received from you
  • General communication
  • Statistics and analytics
  • Marketing
  • Market research
  • Dispute handling

 

Legal basis
ASR JWLS will mainly process your personal data based on the following legal bases:

  • Contractual obligation: The processing of your personal data will in some cases be necessary for the performance of a contract (Article 6 (1) (b) of the GDPR).
  • Legitimate interests: We may process your personal data pursuant to our legitimate interest in, for instance, to manage daily operations according to lawful and fair business practices, including planning, performing and managing the business relationship or our legitimate interest in e.g. statistics, analysis, marketing activities (where consent is not required), providing support as well as improving and developing our products and services. The processing may also be necessary for our legitimate interests in preventing fraud or establish, exercise, or defend legal claims (Article 6 (1) (f) of the GDPR).
  • Legal obligation: The processing of your personal data will in some cases be necessary to comply with legal obligations, such as our obligations to prevent illegal activity (Article 6 (1) (c) of the GDPR).

 

Retention period
Your personal data will be retained for 3 years from the end of the business relationship.

Any personal data included in bookkeeping records will be stored for 5 years as from expiry of the financial year at which time the data will be deleted. Anonymized personal data may be kept for a longer period of time.

 

6. If you apply for a job

 

This section sets out the policy for ASR JWLS’ processing of personal data in relation to recruitment.

 

Types of personal data
ASR JWLS may collect, process, and store the following personal data:

  • Personal data which you have disclosed in your job application and CV as well as any attachments
  • Personal data you disclose during any job interviews
  • Information about you, including information regarding your previous jobs, activities, competencies, performance, as well as your general appearance, which is publicly available on the internet, including on social media
  • Results of personality tests etc.
  • Criminal records
  • References from your previous and/or current employers
  • Credit information and rating if the position you have applied for involves financial responsibilities (e.g., bookkeeping or accounting)
  • Health information if the position you have applied for demands special requirements for your health

 

Purposes of the processing

  • Your personal data will be processed for the purpose of assessing whether we can offer you a position.

 

Legal basis
ASR JWLS will mainly process your personal data based on the following legal bases:

  • Request to enter into an employment contract with us: We may process your personal data on the basis of your request to enter into an employment contract with ASR JWLS (Article 6 (1) (b) of the GDPR).
  • Legitimate interests: We may process your personal data on the basis of our legitimate interests in carrying out further assessments of whether we want to hire you, including on the basis of personality tests, publicly available information on the internet and – if the position entails a financial responsibility – credit information and rating (Article 6 (1) (f) of the GDPR).
  • Consent: In exceptional cases and only when no other legal basis can be applied, Sophie Bille Brahe may ask separately for your consent to process your personal data (Article 6 (1) (a) and 9 (2) (a) of the GDPR and s. 8 (3) of the Danish Data Protection Act). ASR JWLS will, for instance, only take references from your previous and/or current employers or collect your health information or criminal records if you have consented to this.

 

Retention period
If you are offered a position with ASR JWLS, your application and additional relevant personal data obtained during the recruitment procedure will be stored in your employee file.

If you are not offered a position, we will store your application and any additional personal data obtained during the recruitment procedure for a period of 6 months following our rejection, unless you have provided your consent to the storage hereof for a longer period.

If we have collected your criminal records, we will delete them immediately after we have received and reviewed them.

 

7. If you visit our profiles on social media

 

This section sets out the policy for ASR JWLS’ processing of personal data collected via ASR JWLS’ profiles on social media.

ASR JWLS and the providers of social media are joint data controllers for the processing of your personal data collected when you visit ASR JWLS’ profile on social media. ASR JWLS complies with the guidelines of the European supervisory authorities concerning joint data controllership and, using the applicable tools the best way possible, ASR JWLS attempts to ensure that you receive information on the processing of your personal data when you visit ASR JWLS’ profiles on social media.

 

Collection of personal data
Depending on your conduct on the social media, ASR JWLS and the provider of the social media in question may retrieve the following personal data about you:

  • Your “likes” or other reactions expressed on ASR JWLS’ profile
  • Comments left by you on ASR JWLS’ profile
  • Your visits to ASR JWLS’ profile
  • Age, gender, relationship status, place of work, lifestyle, geographical information and fields of interest


Purpose of the processing
ASR JWLS may process your personal data for the following purposes: 

  • To communicate with you if you comment on our posts or send us a direct message
  • Improve our products and services, including our profiles on social media
  • Statistics and analytics

 

Legal basis
ASR JWLS will mainly process your personal data based on the following legal bases:

  • Legitimate interests: We may process your personal data on the basis of our legitimate interests in being able to improve ASR JWLS’ products and services (Article 6 (1) (f) of the GDPR).

The providers of the social media process, among other things, your personal data to enable them to improve their advertisement system and to provide ASR JWLS with statistics, which the provider, for example, works out on the basis of your visit to ASR JWLS’ profile on the social media in question, with a view to advertising and customising the activities on the profile. The providers of the social media process your personal data as a consequence of their legitimate interests, including their interest in providing innovative, customised, secure and profitable services (Article 6 (1) (f) of the GDPR).

  • Consent: The providers of social media may also processes your personal data in accordance with your consent, which you are entitled to withdraw at any point in time via the settings on the website of the social media in question (Article 6 (1) (a) of the GDPR).


Retention period
Your personal data will be retained by ASR JWLS for two years from your interaction with ASR on social media. ASR JWLS does not delete reviews, comments, likes or other interactions you leave publicly on our profiles. You may delete such expressions or interactions by removing your review, comment, like or other interaction from our profile.

Please refer to the privacy policy of the provider of the relevant social media for information on their retention of your personal data.

Anonymized personal data may be kept for a longer period of time.

 

Who do providers of social media share your personal data with?
The providers of social media may, among other things, share your personal data with the following categories of recipients:

  • Other undertakings in the group which the provider of the social media in question is a part of
  • Externally with partners providing analytical services
  • Advertisers
  • Other individuals using our profile on the social media in question
  • Surveying partners
  • Researchers and academics

For more information on the parties with whom the providers of social media share your personal data, we refer to the providers’ general privacy policies.

Your personal data may be transferred by the providers of social media to recipients outside the EU/EEA in accordance with the European data protection standards applicable from time to time. You may read more in the providers of social media’s general privacy policies.

For information of who ASR JWLS shares your personal with, please refer to section 7 below.

 

8. If you visit our studio

 

This section sets out the policy for ASR JWLS’ processing of personal data collected from video surveillance when visiting our studio.

 

Collection of personal data
ASR JWLS has installed video surveillance in certain areas of our studio, such as our showroom. These areas are clearly marked with signs.

The video surveillance is monitored (live streaming) by ASR JWLS’ customer service team and is recorded. Recordings which will only be accessed in case of suspicion of criminal offences, violation og internal guidelines or in relation to internal/external audits.

The recordings may be disclosed to the Police for criminal investigations if the personal data are processed for the purpose of safeguarding public or private interests which clearly override the interests of secrecy, cf. Article 6(1)(f) of the GDPR or if the disclosure is otherwise required by law, cf. Article 6(1)(c) of the GDPR. If disclosure is necessary for other purposes than the above mentioned, we will ask you to consent to such disclosure if you are part of the recordings, cf. Article 6(1)(a) of the GDPR.

 

Types of personal data

  • Image and audio material from the video surveillance.
  • Location of the camera
  • Date and time of the recording

 

Purposes and legal basis of the processing
The purpose of the video surveillance is security, including prevention of crime, and to ensure safety for our employees and third parties, and compliance of our internal rules, cf. Article 6 (1) (f) of the GDPR.

 

Retention period
Recordings from video surveillance which has been conducted for the purposes of preventing crime are deleted or anonymized no later than 30 days after the recording has taken place, unless is it necessary for ASR JWLS to keep the recordings for the purpose of dealing with a specific dispute, e.g. in relation to solving a crime.

 

9. Disclosure to other data controllers and sharing with data processors

 

To fulfil the purposes described above we may provide access to your personal data for third parties who, on the basis of a contractual relationship with ASR JWLS, provide relevant services, e.g. IT-providers, email providers and marketing providers. Such service providers will only process personal data in accordance with our instructions pursuant to the data processor agreements entered into.

In connection with ASR JWLS’ development, the company structure may change, e.g. through a full or partial sale of ASR JWLS. In case of a partial hand over of assets containing personal data, the legal basis for the related disclosure of personal data is, as a general rule, Article 6 (1) (f) of the GDPR, as Sophie Bille Brahe has a legitimate interest in handing over part of its assets as well as making commercial changes.

Aside from above, it is a general rule that your personal data is not disclosed to a third party without your permission. However, under certain circumstances and in accordance with applicable law, we may need to disclose your personal data to

  • Police
  • Lawyers
  • Auditors
  • Courts
  • Public authorities
  • Prospective buyers
  • Affiliated companies

If your personal data is transferred to data processors or data controllers established in countries outside the EU/EEA which does not have an adequate level of protection, such transfer will be based on the EU Commission’s standard contracts or binding corporate rules.

 

10. Your rights

 

  • You have the right to access the personal data we process about you
  • You have the right to object to our collection and further processing of your personal data
  • You have the right to have your personal data rectified and deleted, with certain statutory exceptions, including the Bookkeeping Act
  • You have the right to request us to restrict the processing of your personal data
  • Under certain circumstances you may also request to receive a copy of your personal data as well as the transmission of your personal data which you have provided us with to another data controller (data portability)
  • You may, at all times, withdraw any consent you may have given. We will then delete your personal data, unless we can continue the processing on another basis. Our newsletter can be unsubscribed by clicking the link at the bottom of the newsletter

11. Questions or complaints

 

If you have any questions in relation to this privacy policy or if you wish to make a complaint in connection to our processing of your personal data, please contact us:

 

MB ASR JWLS

K. Čiurlionio g. 44-11 Druskininkai, 66142 Lithuania

Company registration no.: 305710078

e-mail: hello@asrjwls.com

 

If your complaint is not resolved by us and you wish to proceed with the case, you can send your compliant to the supervisory authority in your country.

 

 12. Changes to the privacy policy

 

We reserve the right to make changes to this privacy policy from time to time. When updated, the date at the bottom of the privacy policy will be updated accordingly. The, at all times, applicable privacy policy will be available at our website.

 

2024 05 22

 

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