Privacy Policy

PRIVACY POLICY STATEMENT

This document sets out the Privacy Policy of Xinis Limited and explains how we collect and use your personal information in connection with your relationship with us as a customer or potential customer including;

through your use of fullo-fonesie.com and any country top level domain name (the "Site"), or any Fullo Fonesie application that we make available from time to time ("Application")

by visiting Fullo Fonesie store

by interacting with our content and/or services or

by contacting our Customer Care Team.

This policy also applies to information held about suppliers and possible future suppliers, contacts and all other people we hold information about.

Please read the following carefully to understand our views and practices regarding your information and how we will treat it.

Please also refer to our Terms and Conditions.

You must be over 16 to register for a personal account, subscribe to Fullo Fonesie emails and/or place an order with Fullo Fonesie. The Site is not intended for children and we do not knowingly collect data relating to children.

Fullo Fonesie is a Secure Site that complies with the PCI standards. To ensure that this is a legitimate secure Site, please check the following:

That the original URL you are visiting comes from Fullo-fonesie.com
The status of the server certificate is valid, by checking here.

WHO ARE WE?

Fullo Fonesie is made up of Sunshine Agency Limited company. When we mention "Fullo-Fonesie", "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company 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.

Xinis Limited (trading as Fullo-Fonesie) is the controller and responsible for this Site.

Our Data Protection Officer is Rebecca Scott who can be contacted by emailing; dataprotectionofficer@fullo-fonesie.com.

We are a company registered in the United Kingdom under registration number 12580928 and our registered address is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.

INFORMATION WE COLLECT

By ‘information,’ we mean personal information about you that we collect, use, share, store and transfer in physical and electronic form. This information can be grouped together in the following categories:

Identity and Contact Information includes first name, last name, title, birthday, email address, telephone number, delivery address, billing address or any other information you provide within your personal preferences through your profile builder or to staff within our store

Financial Information includes bank account and payment card details

Transaction Information includes details about payments to and from you and other details of products and services you have purchased from us

Technical Information includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, language, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site or any Application

Profile Information includes first name, last name, title, birthday, email address, telephone number, delivery address, billing address, password, purchase and order history, your favourite products, wish list, brand preferences, contact with the Customer Care Team, and any other information you provide within your personal preferences through your profile builder

Usage Information includes information about how you use the Site or any Application and our products and services

Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences

Contact History means keeping a record of what you have said to us, for example, over the phone, by live chat, through a web form, by email, on social media or otherwise

Social Information means information collected if you choose to link your social media accounts with us.

HOW WE COLLECT INFORMATION ABOUT YOU

You may give us your information by filling in forms on the Site or any Application or in-store or by corresponding with us by post, phone, email, on social media or otherwise. This includes information you provide when you:

place an order;

receive a consultation or treatment;

request marketing to be sent to you;

contact our Customer Care Team;

enter a competition, promotion or survey; or

give us some feedback.

As you interact with the Site or any Application we may automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs and other similar technologies. We may also receive Technical Information about you if you visit other websites employing our cookies. Please see our Cookie Policy for further information.

We may also receive information about you from various third parties such as: analytics providers, advertising networks, search information providers and payment service providers.

HOW WE USE YOUR INFORMATION

We use your information in the following ways:

Identity & Contact Information

to deliver your purchases to you

to provide sports advice

to send you service messages by email, SMS or otherwise, such as order updates

to create and manage your Fullo-Fonesie account

to provide customer care and support, and handle returns

for security and to check your identity

to provide you with marketing (where we have the right to do so – see marketing section below)

to show you Fullo-Fonesie adverts as your browse the web

to direct you to the right part of the website

to communicate with you

to enrol you in your Corporate Partnership Scheme

Financial Information

to take payment, and give refunds

for fraud prevention and detection

Transaction Information

to provide products you order to you

to provide customer care and support, and handle returns

to find out what you, and other customers, like

Technical & Usage Information

to improve our Site and any Application and set default options for you (such as language and currency)

to keep our Site safe and secure

to find out what you, and other customers, like

Profile Information

to find out what you, and other customers, like

to make suggestions and recommendations to you about goods or services that may be of interest to you

to manage your participation in any loyalty scheme

to complete brand specific consultations

to provide sports advice

Marketing and Communications Information

to send you information by email, SMS, post, other otherwise, about our products and services

Contact History

to provide customer care and support

to train our staff

Social Information

to enable you to log-in to our Site simply and easily without having to create a separate account

to enable you to share products and services if you choose to

LEGAL BASIS FOR PROCESSING

Our processing of your personal information is necessary:

for the performance of contracts to which you will be a party to and in order to take steps at your request prior to you entering into those contracts;

for the purposes of legitimate interests pursued by us; or

in order to comply with a legal obligation to which we are subject.

In relation to any processing of special categories of personal information such as information about your health, we will generally rely on obtaining specific consent from you at the time unless there is otherwise a legal requirement for us to process such information.

LEGITIMATE INTERESTS

Where our processing is based on the legitimate interest grounds described above, those legitimate interests are: (i) collecting personal information to provide you with a smooth and efficient customer experience; (ii) running our business; (iii) to provide the products and services you have requested; (iv) to prevent fraud; and (v) for our own marketing, research and product development.

WILL WE SHARE YOUR INFORMATION WITH THIRD PARTIES?

Except as expressly set out in this policy we will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

However, we share your information with the following categories of companies as an essential part of being able to provide our products and services to you, as set out in this Privacy Policy:

Companies in partnership with Fullo-Fonesie who may provide delivery services to you

Companies that help us fulfil your orders such as payment service providers, warehouses, order packers, and delivery companies

Professional service providers, such as marketing agencies, advertising partners and website hosts who help us run our business

Credit reference agencies, law enforcement and fraud prevention agencies, so that we can help tackle fraud

Companies approved by you, such as social media Sites (if you choose to link your accounts to us)

Your product and treatment preferences with specific brands

Competition winners on social media

We may also share your personal information with:

law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; and

other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.

We may provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you.

WILL WE TRANSFER YOUR INFORMATION OVERSEAS?

The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

When we, or our permitted third parties, transfer your information outside the European Economic Area, we or they will impose obligations on the recipients of that data to protect your information to the standard required in the EEA or otherwise require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we will put in place appropriate safeguards to ensure that your information remains adequately protected. If you would like more details about the safeguards that we rely on, please contact the Customer Care Team at contact@fullo-fonesie.com.

YOUR RIGHTS

At any time, you have the right:

to request access to or a copy of any information which we hold about you;

to rectification of your information, if you consider that it is inaccurate;

to ask us to delete your information, if you consider that we do not have the right to hold it;

to withdraw consent to our processing of your information (to the extent such processing is based on previously obtained consent);

to ask us to stop or start sending you marketing messages as described below in the marketing section;

to restrict processing of your information;

to data portability (moving some of your information elsewhere) in certain circumstances;

to object to your information being processed in certain circumstances; and

to not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your information.

Any request for access to or a copy of your information must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change. You can access, update or correct your personal account details by logging in your account on the Site.

DATA SUBJECT ACCESS REQUESTS

We would gladly assist in any data subject access requests free of charge.

Data subject access requests must be made in writing and we advise emailing DSAR@fullo-fonesie.com to ensure action is promptly taken.

Please include the following:

Full Name

Email Address

Billing Address

Details of the specific information you require and any relevant dates

We may ask for further information to identify you and ensure the personal data relates to the individual making the request.

We will respond within one month of receiving the information we require to carry out your request. Responses can be provided in either English, French or German.

To view all the ways to contact us please click here.

DATA SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. We use 256-bit SSL Software to encrypt your payment card information when you place an order on our secure server. For your added security all payment transactions are processed automatically by [another payments proccessor], and we are not party to your personal credit card or bank details. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

MARKETING

We may use your information 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.

You will receive marketing messages from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

We may also market to you if we have received your express consent to do so including where we have collected your details in connection with a competition or other promotion and you have agreed to receive marketing from us.

You can stop receiving marketing messages from us at any time.

You can do this:

By updating your preferences once connected to your account

By clicking on the ‘unsubscribe’ link within an email to unsubscribe from that specific email type

By contacting our Customer Care Team

Once you do this, we will update your profile to ensure that you don’t receive further marketing messages.

Stopping marketing messages will not stop service communications (such as order updates).

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside Fullo-Fonesie for marketing purposes.

ONLINE ADVERTS

We also engage in online advertising, also to keep you aware of what we’re up to and to help you see and find our products.

Like many companies, we target Fullo-Fonesie banners and ads to you when you are on other websites and apps. We do this using a variety of digital marketing networks and ad exchanges, and we use a range of advertising technologies like web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some Sites and social networks, such as Facebook’s Custom Audience service.

The banners and ads you see will be based on information we hold about you, or your previous use of the Site or any Application (for example, your Site search history, and the content you read on the Site) or on Site banners or ads you have previously clicked on.

HOW LONG WILL WE KEEP YOUR INFORMATION?

We will keep your information for as long as you have your account, or as long as is needed to be able to provide the services to you, or (in the case of any contact you may have with our Customer Care Team) for as long as is necessary to provide support-related reporting and trend analysis only.

If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions, we may also keep hold of some of your information as required, even after you have closed your account or it is no longer needed to provide the services to you.

Where we are permitted to send you direct marketing communications we may retain your contact information necessary for this purpose, (provided that you have consented to receiving them) for as long as you do not unsubscribe from receiving the same from us.

LINKS TO OTHER WEBSITES

This Privacy Policy only applies to Fullo-Fonesie. Where there are links to other websites these have their own Terms and Conditions and Privacy Policies that can be viewed on their respective websites.

HOW TO CONTACT US

Questions, comments and requests regarding this policy are welcomed and should be addressed to contact@fullo-fonesie.com. For all other enquiries please click here to view all the ways to contact our Customer Care Team. You can also send a letter by mail to: Xinis Ltd, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.

If you have any concerns about our use of your information, you also have the right to make a complaint to the data protection regulator in your country. If you are a UK resident, this is the Information Commissioner's Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.

CHANGES TO THIS POLICY

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you on the Site, within any Application or by email. Please check back frequently to see any updates or changes to our policy. This Privacy Policy was last updated on 22/04/2020.