1. The Proper Label ™ recognizes the importance of protecting the privacy of your personal data. We have instituted strict policies and security measures to protect the information you provide us.2. Who is responsible for the processing of your personal data?
The American company The Proper Label ™, Inc registered in the state of Delaware, (“The Proper Label ™”), is the controller of your personal data. The Proper Label ™’ affiliated companies (including other companies within the The Proper Label ™ Inc group) and selected suppliers may process your personal data on The Proper Label ™'s behalf and in accordance with The Proper Label ™’ instructions as stated below and are thereby processors of your personal data. You may contact The Proper Label ™ at any time, please find our contact details below.
Below is a summary of the categories of data that we process, the purposes of processing the data and on what legal basis we are processing your data. Our processing of your personal data partly depends on whether you have subscribed with us or not. The processing of personal data relating to customers that are not members is described in section 3.1 below. The processing of our members’ personal data is described in section 3.1 below.3. Customers (non-members)
3.1. Data collected when you shop in our webstore or use our online services
Contact details :
If you make a purchase online we will collect your name, address, e-mail address, telephone number, country of residence, date of birth, title (Ms./Mr. or other title) and social media account contact details (if any). Not all information is mandatory for making a purchase. We have marked mandatory information with the symbol (*) on our website. We will use your contact information to (i) process your purchase/orders and any returns, exchanges and complaints you may have relating to your purchase; and to (ii) communicate with you regarding your purchase and to answer and administer any questions or comments you may have regarding our products or services. The legal basis is that it is necessary to process your data in order for us to be able to fulfill our contractual obligations to you under the purchase agreement. We will retain your data for as long as necessary for this purpose. We may also process your contact details to keep you informed, via e-mail or other messenger services, of our special events, our proper newsletter or promotions. The legal basis is our legitimate interest of being able to market our products to our existing customers. We may use your contact details for direct marketing purposes for up to 12 months after your latest purchase subject to your ongoing right to opt-out. You are entitled to reject our marketing messages, that is, to opt out, at any time by clicking on the unsubscribe link included in each message or by contacting customer service at email@example.com.
Credit card details :
If you make a purchase online and choose to pay by credit card, you will provide your credit card information on our website to finalize your purchase. Your credit card details will be protected using Global Sign Encryption. The legal basis is that the processing is necessary in order for us to be able to fulfill our contractual obligations to you under the purchase agreement. We will retain your data for as long as necessary for this purpose.
Previous purchases and returns:
If you have signed up for an account we will store information regarding (i) your online purchases and returns, and (ii) your purchases and returns in physical stores, if you have provided your e-mail address to our personnel. Such information encompasses product, size, price and date of purchase. We will also store information regarding your recently viewed items. This will allow you to keep track of your purchases and returns, and recently viewed items, by logging into your personal account. The legal basis is our legitimate interest to provide you with the service of a personal account as requested by you when you signed up for the account. You may choose to deregister your account at any time. We will also save information on your contact details and previous purchases and returns during 36 months after the purchase to be able to administer returns and/or complaints. The legal basis is our legitimate interest to provide our customers with speedy and efficient service after the purchase.
Social Security number :
If you chose to apply for credit, allowing you to make your payment by invoice, you may be required to provide your social security number on our website. Your social security number will be directly transferred and available only to our payment service provider, which will process your social security number to be able to obtain a credit report and to facilitate your payment. The legal basis is that the processing is necessary for us to ensure accurate identification of our customers for invoice purposes and to fulfill our contractual obligations to you under the purchase agreement. It is our policy to retain your social security number only as long as reasonably necessary for this purpose.
3.2. Data collected when shopping in our "Prop up Store";When you shop in The Proper Label ™’ pop up stores, The Proper Label ™ may collect and store information regarding (i) your clothing and shoe size, (ii) your clothing preferences (such as preferred colors and style) and (iii) other shopping preferences, provided that you have shared this information with The Proper Label ™’ personnel on a voluntary basis. The Proper Label ™ may also store data regarding your purchases and returns in physical stores (product, size, price and date of purchase) if you have provided your e-mail address to The Proper Label ™’ personnel. This information is processed for the purpose of enhancing your future purchasing experience with The Proper Label ™ and to provide customized service, which is part of The Proper Label ™’ membership service. The Proper Label ™ may also use the information regarding your shopping preferences for the purpose of sending out invitations to special events/promotions and profiled marketing offers through e-mail or other messenger services. The legal basis for this is that the processing is necessary in order for us to be able to fulfill our contractual obligations to you under the Membership Policy.
3.3. Data collected when using The Proper Label ™ website servicesThe Proper Label ™ will store information regarding your recently viewed items when browsing The Proper Label ™’ website. This will allow you to keep track of your recently viewed items, by logging into your personal account. The legal basis for this is that the processing is necessary in order for us to be able to fulfill our contractual obligations to you under the Membership Policy. We will retain your data for as long as necessary for this purpose.
3.4 Newsletter SubscribersIf you have subscribed to one of our newsletters, we will process your name, email address, country and information on whether you are interested in womenswear or menswear for the purpose of sending out such newsletter. The legal basis for this processing is your consent. The newsletters may be sent to you until you unsubscribe to the newsletter service.
3.6 Customer serviceIf you have contacted The Proper Label ™ regarding a complaint, return or question, the e-mail or chat conversation will be stored for as long as it is necessary to administer your matter, including following up on the matter for a minimum of 12 months. Depending on the nature of the matter for which you are contacting us, the legal basis may be that our processing is necessary for us to be able to fulfill our obligations under the purchase agreement or Membership Policy, or that we have a legitimate interest of being able to communicate with individuals who contact our customer service.
3.7 Anonymized dataPlease note that we may also use anonymized data (i.e. by removing personally identifiable information) for internal analysis, feedback, marketing and demographic studies to analyze, profile and monitor customer patterns in order for us to be able to improve our products and services. Because anonymized data does not include any personal data, it may be sold to or shared with others, or used for any purpose at The Proper Label ™’ discretion.
4. Does The Proper Label ™ share your information with others?The Proper Label ™ does not sell or rent our customers’ personally identifiable data to any other entity. We may share your data with affiliated companies including other companies within the The Proper Label ™ group, joint ventures, franchisees and licensees, and may be transferred to any assignees or successors in interest.The Proper Label ™ may also share your data with selected suppliers so that they may perform functions on our behalf such as fulfilling orders and delivery of orders, processing payments, carrying out promotional services or data management, to maintain our website, to distribute e-mails, to send out our newsletter, to provide client communications and to manage our customer database. As necessary, the personal data you provide to us may be processed by these third parties, solely on The Proper Label ™’ behalf and in accordance with The Proper Label ™’ instructions as data processors. We do not authorize any of our suppliers to make any other use of your personal data. If The Proper Label ™' and/or its subsidiaries are subject to an actual or potential merger or acquisition or similar transaction, we may share your data with potential and actual buyer(s) and their financial and legal advisers, subject to such third parties undertaking appropriate confidentiality.
6. Transfer outside of the EU/EESWe may share your data with our selected suppliers, who may process your data in countries both inside and outside of the EU/EES when performing functions on our behalf as set out in section 4 above. If you have subscribed to membership with The Proper Label ™, we will share your contact details and information on previous purchases and shopping preferences with our affiliated companies both inside and outside of the EU/EEA (please see further under section 4). If you have subscribed to membership with The Proper Label ™, we will share your contact details and information on previous purchases and shopping preferences with our affiliated companies both inside and outside of the EU/EEA (please see further under section 4). Please note that countries outside of the EU/EEA may not provide an adequate level of protection for your personal data. The Proper Label ™ has however taken appropriate safeguards to ensure that the receiving parties of your data in countries outside of the EU/EEA shall provide an adequate protection of your data. Such safeguards may be that the receiving party has joined the Privacy Shield (if the receiving party is a company established in the United States) or that the receiving party has signed so called standard data protection clauses adopted by the EU Commission.
7. Your data subject rightsIn this section 7, we have summarized your data subject rights to request access, portability, rectification, erasure of your personal data, to restrict the processing of your personal data, to object to processing, and your right to lodge a complaint with the supervisory authority. If you want to exercise your rights, please send us an email at firstname.lastname@example.org Please note however that if you want to lodge a complaint with the supervisory authority, you need to contact the authority directly. If you have signed up for a membership with The Proper Label ™ you will also be able to access, rectify and erase some of your data by logging in to your private account. Login to your account Notwithstanding anything to the contrary herein, The Proper Label ™ reserves the right to keep and process your personal data in accordance with this policy to the extent necessary to perform our contractual obligations to you, and to the extent we are required to process your data by law or in order to defend ourselves in a dispute, to prevent fraud or abuse, or to enforce our Terms and Conditions.
Right of accessYou have the right to obtain confirmation of whether personal data concerning yourself are being processed and, where that is the case, access to the personal data and information regarding, inter alia, the purpose of processing, the categories of personal data concerned, the categories of recipients to whom your data have been or will be disclosed, and the envisaged period of time for which personal data will be stored (or the criteria for determining this).
Right of rectificationYou have the right to request rectification of inaccurate personal data concerning yourself, and to complete incomplete data.
Right of erasureUnder certain circumstances you are entitled to request that we erase your personal data or restrict our processing of your data, namely in the following events. When it is no longer necessary for us to process your data taking into consideration the purposes for which it was collected. When our processing is based on your consent and you have withdrawn your consent, and there is no other legal basis for the processing of your data. When our processing of your data is based on a legitimate interest legal basis and you object to such processing, and there is no overriding legitimate ground for our processing. When you have objected to our processing of your data for direct marketing purposes. When your personal data has been unlawfully processed. When the personal data must be erased for compliance with a legal obligation that applies to us. When the personal data collected concerns a child (under 13 years of age) in relation to the offer of information society services.
Right to objection - direct marketing and profilingYou have the right to object at any time to our processing of your personal data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing. If you object to our processing of your personal data for direct marketing purposes, including profiling, we will cease such processing of your data.
Data portabilityIf our processing is based on your consent or if the processing is necessary for our performance of a contract with you, you have the right to request that the data which you have provided to us shall be provided to you in a structured, commonly used and machine-readable format and you also have the right to transmit such data to another controller.
Right to lodge a complaint with supervisory authorityPlease note that if you consider the processing of your data to be in violation of applicable data protection laws, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence or the place of the alleged infringement.
8. How do I unsubscribe from The Proper Label ™ newsletters and emails?If you do no longer wish to receive our newsletters or other emails, you can unsubscribe as indicated in the particular communication, i.e. by using the unsubscribe link which is included on all newsletters and other emails. You may also contact us at email@example.com
9. How long do we keep your data?We will retain your personal information for as long as necessary in relation to the purposes for which the data was collected or otherwise processed. Under section 3 above, we have specified the retention time, or the criteria for determining the retention time, for our processing of data in relation to the different purposes the data is being processed. In addition to the retention time stated under section 3 above, please also note the following. Members: If you have not made any purchases, logged in to your account or used any of our services during a consecutive period of 36 months, we will terminate your membership and consequently we will not use your data for any membership services or marketing purposes thereafter. In such case we will delete your data unless we need to keep it for other purposes that are legally justifiable. We will retain your personal information as necessary to comply with applicable legal obligations, to resolve disputes, and to enforce our agreements. Statutory obligations to retain data further remain unaffected.
10. Is it mandatory to provide personal data?When you purchase our products online, or sign up for a membership with The Proper Label ™, we will inform you which data is mandatory by marking certain fields with a symbol (*). The provision of mandatory data is necessary for The Proper Label ™ to be able to fulfill our contractual obligation to you, for example processing your order, or fulfilling the membership services requested by you. When you purchase our products in our physical stores, you do not have to provide any personal data. Please note however that if you chose to receive a digital receipt, it is mandatory that you provide your e-mail address or otherwise we will not be able to send you the digital receipt.
11. Children's privacy and legal purchase ageChildren should always ask parents for permission before providing any personal information online. No information should be submitted to The Proper Label ™ by any person under the age of 16 without the consent of a parent or guardian. Unless otherwise disclosed during collection, The Proper Label ™ does not knowingly collect any personally identifiable information about persons under the age of 16, provide any personally identifying information about such persons under the age of 16, regardless of its source, to third parties, and does not knowingly use such information for any marketing or promotional purposes.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at firstname.lastname@example.org