Privacy Policy

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
  11. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLIY

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: [email protected]
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

  1. 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.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or
are trying to enter into with you (for example, to provide you with goods or services). In this case, we
may have to cancel a product or service you have with us but we will notify you if this is the case at the
time.

  1. 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.

  1. 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.
    Click here to find out more about the types of lawful basis that we will rely on to process your personal
    data.
    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.
    Purpose/Activity Type of data Lawful basis for processing including
    basis of legitimate interest
    To register you as a new customer (a) Identity
    (b) Contact
    Performance of a contract with you
    To process and deliver your order
    including:
    (a) Manage payments, fees and
    charges
    (a) Identity
    (b) Contact
    (c) Financial
    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests
    (to recover debts due to us)

(b) Collect and recover money owed
to us
(d) Transaction
(e) Marketing and
Communications
To manage our relationship with you
which will include:
(a) Notifying you about changes to
our terms or privacy policy
(b) Asking you to leave a review or
take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal
obligation
(c) Necessary for our legitimate interests
(to keep our records updated and to study
how customers use our
products/services)
To enable you to partake in a prize
draw, competition or complete a
survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to study how customers use our
products/services, to develop them and
grow our business)
To administer and protect our
business and this website (including
troubleshooting, data analysis,
testing, system maintenance,
support, reporting and hosting of
data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests
(for running our business, provision of
administration and IT services, network
security, to prevent fraud and in the
context of a business reorganisation or
group restructuring exercise)
(b) Necessary to comply with a legal
obligation
To deliver relevant website content
and advertisements to you and
measure or understand the
effectiveness of the advertising we
serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our legitimate interests (to
study how customers use our
products/services, to develop them, to
grow our business and to inform our
marketing strategy)
To use data analytics to improve our (a) Technical Necessary for our legitimate interests (to website, products/services, marketing, customer relationships and experiences
(b) Usage
define types of customers for our
products and services, to keep our
website updated and relevant, to develop
our business and to inform our marketing
strategy)
To make suggestions and
recommendations to you about
goods or services that may be of
interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications
Necessary for our legitimate interests (to
develop our products/services and grow
our business)
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.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or
access cookies. If you disable or refuse cookies, please note that some parts of this website may
become inaccessible or not function properly. For more information about the cookies we use, please
see [COOKIE POLICY].

CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the
legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.

  1. DISCLOSURES OF YOUR PERSONAL DATA
    We may share your personal data with the parties set out below for the purposes set out in the table
    ‘Purposes for which we will use your personal data’ above.
    • Internal Third Parties as set out in the [Glossary].
    • External Third Parties as set out in the [Glossary].
    • Digital marketing agencies, including but not limited to The Digital Fairy Limited
    • www.perfumeshopping.com
    • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
    Alternatively, we may seek to acquire other businesses or merge with them. If a change happens
    to our business, then the new owners may use your personal data in the same way as set out in
    this privacy policy.
    We require all third parties to respect the security of your personal data and to treat it in accordance
    with the law. We do not allow our third-party service providers to use your personal data for their own
    purposes and only permit them to process your personal data for specified purposes and in accordance
    with our instructions.
  2. INTERNATIONAL TRANSFERS
    We share your personal data within the Shaneel Group and use Mailchimp, a US company, to provide
    our email marketing services. This involves transferring your data outside of the European Economic
    Area (EEA).
    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is
    afforded to it by ensuring at least one of the following safeguards is implemented:
     We will only transfer your personal data to countries that have been deemed to provide an adequate
    level of protection for personal data by the European Commission. For further details, see European
    Commission: Adequacy of the protection of personal data in non-EU countries.
     Where we use certain service providers, we may use specific contracts approved by the European
    Commission which give personal data the same protection it has in Europe. For further details,
    see European Commission: Model contracts for the transfer of personal data to third countries.
     Where we use providers based in the US, we may transfer data to them if they are part of
    the Privacy Shield which requires them to provide similar protection to personal data shared
    between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
    Please contact us if you want further information on the specific mechanism used by us when
    transferring your personal data out of the EEA.
  3. DATA SECURITY
    We have put in place appropriate security measures to prevent your personal data from being

accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other third parties who have
a business need to know. They will only process your personal data on our instructions and they are
subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you
and any applicable regulator of a breach where we are legally required to do so.

  1. DATA RETENTION
    HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
    We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we
    collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting
    requirements. We may retain your personal data for a longer period in the event of a complaint or if we
    reasonably believe there is a prospect of litigation in respect to our relationship with you.
    To determine the appropriate retention period for personal data, we consider the amount, nature and
    sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
    personal data, the purposes for which we process your personal data and whether we can achieve
    those purposes through other means, and the applicable legal, regulatory, tax, accounting or other
    requirements.
    By law we have to keep basic information about our customers (including Contact, Identity, Financial
    and Transaction Data) for six years after they cease being customers for tax purposes.
    In some circumstances you can ask us to delete your data: see [your legal rights] below for further
    information.
    In some circumstances we will anonymise your personal data (so that it can no longer be associated
    with you) for research or statistical purposes, in which case we may use this information indefinitely
    without further notice to you.
  2. YOUR LEGAL RIGHTS
    Under certain circumstances, you have rights under data protection laws in relation to your personal
    data. Please click on the links below to find out more about these rights:
    • [Request access to your personal data].
    • [Request correction of your personal data].
    • [Request erasure of your personal data].
    • [Object to processing of your personal data].
    • [Request restriction of processing your personal data].
    • [Request transfer of your personal data].
    • [Right to withdraw consent].
    If you wish to exercise any of the rights set out above, please contact the DPO using the details provided
    above.
    NO FEE USUALLY REQUIRED
    You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
    However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
    Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your
right to access your personal data (or to exercise any of your other rights). This is a security measure
to ensure that personal data is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than
a month if your request is particularly complex or you have made a number of requests. In this case,
we will notify you and keep you updated.

  1. GLOSSARY
    LAWFUL BASIS
    Legitimate Interest means the interest of our business in conducting and managing our business to
    enable us to give you the best service/product and the best and most secure experience. We make
    sure we consider and balance any potential impact on you (both positive and negative) and your rights
    before we process your personal data for our legitimate interests. We do not use your personal data for
    activities where our interests are overridden by the impact on you (unless we have your consent or are
    otherwise required or permitted to by law). You can obtain further information about how we assess our
    legitimate interests against any potential impact on you in respect of specific activities by contacting us.
    Performance of Contract means processing your data where it is necessary for the performance of a
    contract to which you are a party or to take steps at your request before entering into such a contract.
    Comply with a legal obligation means processing your personal data where it is necessary for
    compliance with a legal obligation that we are subject to.
    THIRD PARTIES
    INTERNAL THIRD PARTIES
    Other companies in the Shaneel Group acting as joint controllers or processors who provide IT and
    system administration services and undertake leadership reporting.
    EXTERNAL THIRD PARTIES
    • Service providers who may also be acting as processors who provide IT and system administration
    services.
    • Service providers who may also be acting as processors who provide business support services.
    • Professional advisers who may also be acting as processors or joint controllers including lawyers,
    bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting
    services.
    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers
    based in the United Kingdom who require reporting of processing activities in certain
    circumstances.
    YOUR LEGAL RIGHTS
    You have the right to:
    Request access to your personal data (commonly known as a “data subject access request”). This
    enables you to receive a copy of the personal data we hold about you and to check that we are lawfully
    processing it. Request correction of the personal data that we hold about you. This enables you to have any
    incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy
    of the new data you provide to us.
    Request erasure of your personal data. This enables you to ask us to delete or remove personal
    data where there is no good reason for us continuing to process it. You also have the right to ask us to
    delete or remove your personal data where you have successfully exercised your right to object to
    processing (see below), where we may have processed your information unlawfully or where we are
    required to erase your personal data to comply with local law. Note, however, that we may not always
    be able to comply with your request of erasure for specific legal reasons which will be notified to you, if
    applicable, at the time of your request.
    Object to processing of your personal data where we are relying on a legitimate interest (or those
    of a third party) and there is something about your particular situation which makes you want to object
    to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also
    have the right to object where we are processing your personal data for direct marketing purposes. In
    some cases, we may demonstrate that we have compelling legitimate grounds to process your
    information which override your rights and freedoms.
    Request restriction of processing of your personal data. This enables you to ask us to suspend
    the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish,
    exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding
    legitimate grounds to use it.
    Request the transfer of your personal data to you or to a third party. We will provide to you, or a
    third party you have chosen, your personal data in a structured, commonly used, machine-readable
    format. Note that this right only applies to automated information which you initially provided consent
    for us to use or where we used the information to perform a contract with you.
    Withdraw consent at any time where we are relying on consent to process your personal data.
    However, this will not affect the lawfulness of any processing carried out before you withdraw your
    consent. If you withdraw your consent, we may not be able to provide certain products or services to
    you. We will advise you if this is the case at the time you withdraw your consent.
    INFORMATION ABOUT OUR USE OF COOKIES
    Our website uses cookies to distinguish you from other users of our website. This helps us to provide
    you with a good experience when you browse our website and also allows us to improve our site. By
    continuing to browse the site, you are agreeing to our use of cookies.
    A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your
    computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
    “Cookie Law” means all laws applicable from time to time to the operation of cookies including the
    relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and of
    EU Regulation 2016/679 General Data Protection Regulation (GDPR)
    All cookies used by and on our websites are used in accordance with current Cookie Law. We use the
    following cookies:
    • Strictly necessary cookies. These are cookies that are required for the operation of our website.

They include, for example, cookies that enable you to log into secure areas of our website, use a
shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors
and to see how visitors move around our website when they are using it. This helps us to improve
the way our website works, for example, by ensuring that users are finding what they are looking
for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This
enables us to personalise our content for you, greet you by name and remember your preferences
(for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited
and the links you have followed. We will use this information to make our website and the
advertising displayed on it more relevant to your interests. We may also share this information
with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and providers of external
services like web traffic analysis services) may also use cookies, over which we have no control. These
cookies are likely to be analytical/performance cookies or targeting cookies
You block cookies by activating the setting on your browser that allows you to refuse the setting of all
or some cookies. However, if you use your browser settings to block all cookies (including essential
cookies) you may not be able to access all or parts of our site.