Privacy Policy

Privacy Policy
==============

Effective date: May 19, 2018

Bitzal Trading (“us”, “we”, or “our”) operates the
https://www.naughtytoy.co.uk website (the “Service”).

This page informs you of our policies regarding the collection, use, and
disclosure of personal data when you use our Service and the choices you have
associated with that data.

We use your data to provide and improve the Service. By using the Service, you
agree to the collection and use of information in accordance with this policy.
Unless otherwise defined in this Privacy Policy, terms used in this Privacy
Policy have the same meanings as in our Terms and Conditions, accessible from
https://www.naughtytoy.co.uk/terms-conditions/

Definitions
———–

* Service

Service is the https://www.naughtytoy.co.uk website operated by Bitzal
Trading

* Personal Data

Personal Data means data about a living individual who can be identified
from those data (or from those and other information either in our
possession or likely to come into our possession).

* Usage Data

Usage Data is data collected automatically either generated by the use of
the Service or from the Service infrastructure itself (for example, the
duration of a page visit).

* Cookies

Cookies are small pieces of data stored on your device (computer or mobile
device).

* Data Controller

Data Controller means the natural or legal person who (either alone or
jointly or in common with other persons) determines the purposes for which
and the manner in which any personal information are, or are to be,
processed.

For the purpose of this Privacy Policy, we are a Data Controller of your
Personal Data.

* Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who
processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process
your data more effectively.

* Data Subject (or User)

Data Subject is any living individual who is using our Service and is the
subject of Personal Data.

Information Collection And Use
——————————

We collect several different types of information for various purposes to
provide and improve our Service to you.

Types of Data Collected
~~~~~~~~~~~~~~~~~~~~~~~

Personal Data
*************

While using our Service, we may ask you to provide us with certain personally
identifiable information that can be used to contact or identify you
(“Personal Data”). Personally identifiable information may include, but is not
limited to:

* Email address
* First name and last name
* Phone number
* Address, Town/City, County, Postal code.
* Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or
promotional materials and other information that may be of interest to you.
You may opt out of receiving any, or all, of these communications from us by
contacting us. We do not currently send out newsletters or similar promotional
and marketing material to customers and have no immediate plans to do so,
however we reserve the right to send such marketing material in the future.

Usage Data
**********

We may also collect information how the Service is accessed and used (“Usage
Data”). This Usage Data may include information such as your computer’s
Internet Protocol address (e.g. IP address), browser type, browser version,
the pages of our Service that you visit, the time and date of your visit, the
time spent on those pages, unique device identifiers and other diagnostic
data.

Tracking & Cookies Data
************

We use cookies and similar tracking technologies to track the activity on our
Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous
unique identifier. Cookies are sent to your browser from a website and stored
on your device. Tracking technologies also used are beacons, tags, and scripts
to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a
cookie is being sent. However, if you do not accept cookies, you may not be
able to use some portions of our Service.

Examples of Cookies we use:

* Session Cookies. We use Session Cookies to operate our Service.
* Preference Cookies. We use Preference Cookies to remember your preferences
and various settings.
* Security Cookies. We use Security Cookies for security purposes.

Use of Data
———–

Bitzal Trading uses the collected data for various purposes:

* To provide and maintain our Service
* To notify you about changes to our Service
* To allow you to participate in interactive features of our Service when
you choose to do so
* To provide customer support
* To gather analysis or valuable information so that we can improve our
Service
* To monitor the usage of our Service
* To detect, prevent and address technical issues
* To provide you with news, special offers and general information about
other goods, services and events which we offer that are similar to those
that you have already purchased or enquired about unless you have opted
not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection
Regulation (GDPR)
—————————————————————————————-

If you are from the European Economic Area (EEA), Bitzal Trading legal basis
for collecting and using the personal information described in this Privacy
Policy depends on the Personal Data we collect and the specific context in
which we collect it.

Bitzal Trading may process your Personal Data because:

* We need to perform a contract with you
* You have given us permission to do so
* The processing is in our legitimate interests and it’s not overridden by
your rights
* For payment processing purposes
* To comply with the law

Retention of Data
—————–

Bitzal Trading will retain your Personal Data only for as long as is necessary
for the purposes set out in this Privacy Policy. We will retain and use your
Personal Data to the extent necessary to comply with our legal obligations
(for example, if we are required to retain your data to comply with applicable
laws), resolve disputes, and enforce our legal agreements and policies.

Bitzal Trading will also retain Usage Data for internal analysis purposes.
Usage Data is generally retained for a shorter period of time, except when
this data is used to strengthen the security or to improve the functionality
of our Service, or we are legally obligated to retain this data for longer
time periods.

Transfer Of Data
—————-

Your information, including Personal Data, may be transferred to — and
maintained on — computers located outside of your state, province, country or
other governmental jurisdiction where the data protection laws may differ than
those from your jurisdiction.

If you are located outside the Isle of Man and choose to provide information to
us, please note that we transfer the data, including Personal Data, to the Isle of
Man and process it there.

Your consent to this Privacy Policy followed by your submission of such
information represents your agreement to that transfer.

Bitzal Trading will take all steps reasonably necessary to ensure that your
data is treated securely and in accordance with this Privacy Policy and no
transfer of your Personal Data will take place to an organization or a country
unless there are adequate controls in place including the security of your
data and other personal information.

Disclosure Of Data
——————

Business Transaction
~~~~~~~~~~~~~~~~~~~~

If Bitzal Trading is involved in a merger, acquisition or asset sale, your
Personal Data may be transferred. We will provide notice before your Personal
Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Under certain circumstances, Bitzal Trading may be required to disclose your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).

Legal Requirements
~~~~~~~~~~~~~~~~~~

Bitzal Trading may disclose your Personal Data in the good faith belief that
such action is necessary to:

* To comply with a legal obligation
* To protect and defend the rights or property of Bitzal Trading
* To prevent or investigate possible wrongdoing in connection with the
Service
* To protect the personal safety of users of the Service or the public
* To protect against legal liability

Security Of Data
—————-

The security of your data is important to us, but remember that no method of
transmission over the Internet, or method of electronic storage is 100%
secure. While we strive to use commercially acceptable means to protect your
Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)
—————————————————————————

If you are a resident of the European Economic Area (EEA), you have certain
data protection rights. Bitzal Trading aims to take reasonable steps to allow
you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you
want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

* The right to access, update or to delete the information we have on you.
Whenever made possible, you can access, update or request deletion of your
Personal Data directly within your account settings section. If you are
unable to perform these actions yourself, please contact us to assist you.

* The right of rectification. You have the right to have your information
rectified if that information is inaccurate or incomplete.

* The right to object. You have the right to object to our processing of
your Personal Data.

* The right of restriction. You have the right to request that we restrict
the processing of your personal information.

* The right to data portability. You have the right to be provided with a
copy of the information we have on you in a structured, machine-readable
and commonly used format.

* The right to withdraw consent. You also have the right to withdraw your
consent at any time where Bitzal Trading relied on your consent to process
your personal information.

Please note that we may ask you to verify your identity before responding to
such requests.

You have the right to complain to a Data Protection Authority about our
collection and use of your Personal Data. For more information, please contact
your local data protection authority in the European Economic Area (EEA).

Service Providers
—————–

We may employ third party companies and individuals to facilitate our Service
(“Service Providers”), to provide the Service on our behalf, to perform
Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these
tasks on our behalf and are obligated not to disclose or use it for any other
purpose.

Analytics
~~~~~~~~~

We may use third-party Service Providers to monitor and analyze the use of our
Service.

* Google Analytics

Google Analytics is a web analytics service offered by Google that tracks
and reports website traffic. Google uses the data collected to track and
monitor the use of our Service. This data is shared with other Google
services. Google may use the collected data to contextualize and
personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to
Google Analytics by installing the Google Analytics opt-out browser add-
on. The add-on prevents the Google Analytics JavaScript (ga.js,
analytics.js, and dc.js) from sharing information with Google Analytics
about visits activity.

For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page:
https://www.google.com/intl/en/policies/privacy

* Statcounter

Statcounter is a web traffic analysis tool. You can read the Privacy
Policy for Statcounter here: https://statcounter.com/about/legal

Payments
~~~~~~~~

We provide paid products and/or services within the Service. In that case,
we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is
provided directly to our third-party payment processors whose use of your
personal information is governed by their Privacy Policy. These payment
processors adhere to the standards set by PCI-DSS as managed by the PCI
Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express and Discover. PCI-DSS requirements help ensure
the secure handling of payment information.

The payment processors we work with are:

* PayPal.

Their Privacy Policy can be viewed at
https://www.paypal.com/webapps/mpp/ua/privacy-full

Wholesale suppliers
~~~~~~~~~~~~~~~~~~~

We share some customer data with our wholesale supplier, IDWEB Ltd.
IDWEB Ltd require customer data to fulfill certain orders which are dispatched
directly by them. They have their own fully GDPR compliant privacy policy and we
have done due diligence checks and are assured that customer data supplied on their
website is subject to the same privacy controls as we
provide.

Any requests to us, by customers asking for details of their personal data
that we may hold on them, or similar requests to amend and/or delete said data, will
automatically be forwarded to IDWEB ltd if we have any reason to believe they also hold
data about the enquiring customer and the results will be returned to the enquiring customer
without them having to make a separate request themselves. Ditto any requests to amend or
delete data.

Links To Other Sites
——————–

Our Service may contain links to other sites that are not operated by us. If
you click on a third party link, you will be directed to that third party’s
site. We strongly advise you to review the Privacy Policy of every site you
visit.

We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.

Children’s Privacy
——————

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone
under the age of 18. If you are a parent or guardian and you are aware that
your Child has provided us with Personal Data, please contact us.

If we become aware that we have collected Personal Data from children we will
remove it from our servers as soon as reasonably possible and always within 24hrs
of a verified parental or legal guardian’s request.

Please note that due to the adult sexual nature of products on this site it will
almost certainly be a criminal offence for any customers to purchase products
on behalf of minors.

This is also against our own terms & conditions and we will cooperate fully
with any legitimate requests by properly authorised law enforcement officers
investigating persons suspected of purchasing our products on behalf of minors.
Depending on the exact circumstances we may disclose some or all of the following information.

*Dates and times visiting the website.
*Details of products purchased.
*Email correspondence and or Facebook messenger messages sent between us and suspected person.
*Any other information we may be able to disclose which would aid the investigation.

Changes To This Privacy Policy

——————————

We may update our Privacy Policy from time to time. We will notify you of any
changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior
to the change becoming effective and update the “effective date” at the top of
this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this
page.

Contact Us
———-

If you have any questions about this Privacy Policy, please contact us:

* By email: support@naughtytoy.co.uk