Welcome to the TINY INK Ltd. website, at the URL (the “Website”).
Data controller of the data collected and processed on the Site and within the Online Boutique
With reference to the processing of data collected and processed through the Site, you are informed that:
TINY INK Ltd. (hereinafter also just "TINY INK”) is the autonomous controller of the processing of personal data of users who visit the Site, including browsing data, marketing data, and profiling.
TINY INK is joint controllers of the data processing connected and correlated to the sales made through the Online Boutique within the Site and to the related pre and post-sales support activities.
Below you will find more specific information regarding the processing of data collected and processed through the Site.
1. Information about the Data Controller and the appointed Data Processors
The Data Controller is TINY INK Ltd with registered office at 179 Dien Bien Phu, Dakao, District 1, Hochiminh City, Vietnam.
2. Information and contact details of the Data Protection Officer
TINY INK has appointed its own Data Protection Officer (hereinafter also referred to as "DPO") who can be contacted by sending an email to the following address: email@example.com.
3. Type and purpose of the processing carried out on the Site
Different types of personal data are collected and processed through the Site, for different purposes, and in different ways. More specifically:
(b) personal data provided voluntarily by the user (such as, for example, e-mail address, personal details, password was given when completing the "My Account" registration form), or otherwise lawfully acquired during the user's interaction with the site, to respond to the user's requests and to provide the services, assistance and information requested regarding TINY INK products and brand. Please note that registration and access through social network profiles involve the disclosure of certain data (including First name, Last name, Email, and any other data relating to the user and present on the same social network) by the chosen social network. This data, as well as browsing data collected using cookies, will complement and enhance your profile and your customer record in order to allow TINY INK to know you better. In any case, this will only occur if you have previously accepted the disclosure of some of your data by the social media platform during the use of the registration function through a social network login and/or if you have authorized the use of analytical and marketing cookies through the methods present on the site. In some cases, social media also requests some feedback and information about the use of log-in. For more information, please refer to the relevant privacy documentation on the social media network;
(c) with the express consent of the user, TINY INK may process the user's personal data for marketing purposes, i.e. to send the user (using traditional tools and telematic tools such as newsletters, e-mails, text messages, MMS and smart messages) information and updates on products, sales, promotional campaigns, events and other initiatives promoted by TINY INK;
(d) with the express consent of the user, TINY INK may also process the user's personal data for the purpose of studying shopping habits and choices in order to make products and initiatives more in line with the tastes and demands of its customers.
1. the user's consent, if any, for the purposes referred to in point b) - with exclusive reference to social network logins - and in points d) and e);
2. the legitimate interest of both TINY INK in providing the services of the Site and of the user in browsing the Site properly and/or the legitimate interest of TINY INK in responding to any requests from customers.
Please note that, based on the principle of legitimate interest, TINY INK may contact you in order to offer you services and products similar to those you have previously purchased. Please also note that, based on current legislation, this type of contact (known as "soft spam") does not require consent. However, you may at any time ask for the processing to be discontinued and TINY INK will do so without delay.
4. Sources of personal data
The personal data collected by TINY INK is provided directly by the user, with the exception of the browsing data referred to in paragraph 2(a) above and data collected during registration and access via social network profiles, as described in paragraph 2(b) above.
5. Research of users' purchasing habits and choices
As described in paragraph 2 (d) above and with the express consent of the user, TINY INK may process the user's personal data for the purpose of studying the habits and choices of users in order to make TINY INK products and initiatives more responsive to the tastes and demands of its customers. With the help of automated tools, TINY INK will process data relating to the value and frequency of purchases ( including if the purchases were made during the sales period) as well as the type of products purchased (such as accessories, clothing, haute couture, ready-to-wear) over a specific period of time. The sole objective of this research is to offer customers and users products, services and initiatives that are better suited to their tastes and demands. In this respect, please note that research into the behavior of users and customers will be carried out in a non-intrusive manner.
As described in paragraph 2 (a) above and with the express consent of the user, TINY INK may process the user's personal data, using automated tools, to study cookies in order to monitor browsing on the Site and to suggest products and services in line with the browsing activity.
6. Methods that TINY INK use to process personal data
However, due to the nature of the online environment, such measures cannot completely limit or exclude any risk of unauthorized access or loss of data. To this end, it is recommended that you periodically check that your computer is equipped with adequate software to protect the network transmission of data, both incoming and outgoing (such as updated antivirus systems) and that the Internet service provider has taken appropriate measures to ensure the security of network data transmission (such as firewalls and spam filters).
On each purchase is made in the utmost security due to the use of the most advanced technological systems and coding (SSL).
7. Compulsory or optional nature of providing data
8. Categories of personal data recipients
TINY INK only discloses the personal data of Site users to the extent permitted by law and in accordance with the provisions set out below. In addition to that stated in point 2 b. above (i.e. Social media login), personal data may be disclosed to:
1. TINY INK employees and consultants, who act as authorized processors for the purposes of the internal organization of the company's activities;
2. companies in the same Group as the appointed data processors, in order to carry out contractual activities and services (such as the in-store collection service) as well as to carry out specific marketing activities (such as inviting the user to local events); and
3. companies that carry out specific technical and organizational services related to the Site (IT services and marketing services) for TINY INK as data processors.
Personal data may also be disclosed to:
1. the police or the courts, in accordance with the law and following a formal request by such parties, or where there are substantial grounds to believe that the provision of such data is reasonably necessary in order to (1) investigate, prevent, or take action regarding suspected illegal activities or assist the government's supervisory and monitoring authorities; (2) defend against any claims or allegations made by any third party, or protect the security of its website and the company; or (3) exercise or protect the rights, property, or security of TINY INK, companies in the same group, its affiliates, customers, employees, or any other party.
9. Data retention period
Personal data provided for marketing and profiling purposes are kept for the period necessary for the specific processing, also based on the particular sector of activity (luxury products) and bearing in mind the customer's interest in receiving updates about products, events and fashion shows organized by TINY INK.
10. User rights acknowledged by the privacy law
The user is entitled to obtain, at any time, confirmation from TINY INK as to whether or not Personal Data relating to him/her is being processed, whether the data is not yet registered, and the communication in intelligible form of the data undergoing processing. He/she is also entitled to obtain information about the source of the personal data; the purposes and methods of processing; the logic involved in any electronic data processing; details of the data controller and of the data processors; the names of the entities and categories of entities to whom your Personal Data may be disclosed or who may access your Personal Data, for example, as a data processor or any other party authorized to process the data. The user also has the right to request the updating, rectification or amendment of personal data, its erasure, anonymisation or restriction of personal data that has been processed unlawfully, including data whose retention is unnecessary for the purposes for which it has been collected or subsequently processed; confirmation that the actions referred to above and their content have been made known to those to whom the data was disclosed, unless this requirement proves impossible or involves means that are manifestly disproportionate to the protected right. The user also has the right to data portability.
However, the user has the right to object, in whole or in part, for legitimate reasons, to the processing of his/her personal data, even if relevant to the purpose of collection, to the processing of his/her personal data for the purpose of sending advertising or direct marketing materials or for carrying out marketing surveys or commercial communications and he/she also has the right to request the restriction of the processing of his/her personal data. The right of opposition may also be exercised specifically, with regard to one or more methods of sending marketing communications. The user also has the right to lodge a complaint with the relevant supervisory authority as well as the right to withdraw consent previously given.
The above rights may be exercised by contacting the DPO by sending an email to firstname.lastname@example.org.