Privacy Policy

About this policy

By this policy, Treasured Memories intends to inform the users visiting "www.treasuredmemories.ie" Website (hereinafter, the "Website") of the policy established with regard to Personal Data Protection, emphasising its own commitment and care concerning the protection of the privacy of visitors to the Website. You are kindly invited to read our Privacy Policy that applies both in case you access the Website and decide to merely browse through it using our services, without purchasing any product, and if you choose to make some purchases.

You are furthermore invited to read, if you have not already done so, the Conditions of Use as they also contain important indications about the security systems adopted by the Website.

Browsing through the Website is free and does not require any registration, except for some areas where the user can freely and expressly provide a series of data concerning his person to access specifically identified services (e.g., to be able to proceed with purchases, subscribe to the newsletter or request information from us, etc.).

Should the visitor, therefore, intend to provide us with his personal data to access such additional services, he will be expressly informed under Legislative Decree No. 196 of 30 June 2003 "Personal Data Protection Code" (the "Code") and Regulation (EU) 2016/679 "General Data Protection Regulation" (the "Regulation"), along with the indication (by way of illustration) of the purposes and methods of using the data by Treasured Memories, as well as the right to request at any time access to, the erasure of the data or their updating. Any reference to the Code found in the Privacy Policy and the Website, in general, must be considered valid and effective within limits and to the extent that the legal rules recalled remain in force subsequently to the Regulation's implementation date (25 May 2018).

The website is not intended for children under sixteen who are also forbidden from creating an account or otherwise providing their personal data.

Under the Code and the Regulation, Treasured Memories provides the following information.

The Data Controller and Data Processors

The personal Data Controller is Keeco Creative Limited, based on Unit E16, South City Business Park, Whitestown Way, Tallaght, Dublin 24, D24 HH48, Ireland; email hello@treasuredmemories.ie (hereinafter "Treasured Memories", the "Data Controller" or the "Company").

On exclusively organisational and functional grounds, we have appointed some service providers instrumental to the management of the Website as external processors of users' personal data for purposes strictly associated with and related to the performance of the services provided by the Website, including the sale of products such as Shopify (https://www.shopify.com/legal/privacy) and Customer's Canvas (https://customerscanvas.com/privacy-policy).

Types of personal data processed

Should Treasured Memories obtain personal information and data, it will inform users in advance of the purposes for which such data have been requested and how they will be used. If need be, Treasured Memories will obtain the user’s specific consent regarding the use of the data. By way of illustration, such personal data as name and surname, telephone number and e-mail address may be requested, along with other information the user accepts to provide by filling out a specific registration form (e.g., to access the customer area on the Website). Treasured Memories will use the personal data collected online solely for the purposes indicated at the time of registration.

The data pertaining to connection and browsing through the Website (such as the URI-Uniform Resource Identifier addresses of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the reply given by the server (successful, error, etc.), and other parameters relating to the operating system and the user’s computer environment) are collected for the sole purpose of drawing anonymous statistical information on Website use and to check its correct operation and are erased immediately after they are processed. In addition, the data might be used to ascertain liability in the event of possible computer crimes against the Website: apart from that scenario, the data will be erased once the time necessary for the performance of the services illustrated on the Website has expired.

Voluntary nature of the provision of personal data

The provision of personal data is, generally speaking, optional. Only in certain instances, failure to provide them might entail the impossibility of accessing specific services and obtaining what might have been requested (e.g. registration - and the provision of personal details, email address, postal address, details of credit/debit card or banking coordinates and telephone number - is necessary to proceed with the purchase of online products); failure to provide such data might accordingly prevent Treasured Memories from allowing access to the Website services or reply to users' requests.

The data from time to time required are indicated in the data collection forms found on the Website – marking them, for instance, with an asterisk (*) – and the consequences of failure to provide them are set out in the specific privacy policies found on the data collection pages.

Purposes

The data are collected and processed for purposes strictly associated with the use of the Website and its services and online purchases of products. The purposes for using the data are set out in detail in the specific information notices provided by the Website in all the instances of data collection. Therefore, we ask you to read the privacy policies that, from time to time, describe the processing to be carried out by Treasured Memories (e.g., for registration with the newsletter service, to access the customer area, etc.). Your data will be processed in full compliance with the legislation on privacy.

Method and duration of data processing and scope of the disclosure

The data may be processed on electronic and paper support (e.g., to manage purchases on the Website). Treasured Memories warrants the lawful and due processing of the personal data provided through the Website, in full compliance with the legislation in force and maximum confidentiality of the data provided at the time of registration. Furthermore, all the information collected is transmitted through a protected connection to avoid intercepting by strangers.

Any data provided by the users will be processed for the periods laid down in the specific privacy policies provided when collecting the data.

Regarding the storage times of data detected through the use of profiling tools (e.g. cookies), see our Cookie Policy.

The data will not be communicated or disseminated to third parties except within limits and on the conditions expressly set out in the information notice from time to time provided to the user and subject to his prior authorisation. Where data is being transferred to a separate controller, we will identify that controller to you and provide further details.

Links to other websites

This Privacy Policy is only provided for the Website www.treasuredmemories.ie and not for the other websites consulted by the user via connecting links. Treasured Memories cannot be held liable for the personal data provided by the users to external subjects or any websites linked to this Website.

"Profiling" and/or customisation tools

Treasured Memories does not carry out any activity of promotional and/or advertising communication without the user's prior express consent.

The Website uses both technical "cookies" (i.e., to facilitate Website browsing and use) and profiling ones (i.e., to analyse the users and their behaviours and preferences and let them receive customised advertisements).

For a detailed explanation of the Website's cookies, you are kindly invited to read our Cookie Policy.

Place of data processing

The processing associated with the services provided by the Website is carried out:

• at the office of Treasured Memories indicated under point "The Data Controller and Data Processors" here above and are carried out by the persons tasked with processing by Sales & Marketing Management;
• as well as by the companies that provide services instrumental to the management of the Website, appointed as external data processors.

A complete list of external data processors appointed by Treasured Memories can be requested from the contact persons mentioned under point "Data subjects' rights" of the Privacy Policy.

To enable us to manage our Website correctly and fulfil our contractual obligations, your personal data will be initially processed and storage in Ireland and may be transferred to countries outside of the European Union, such as the United States. Specifically as regards:

• In the United States, the data are transferred according to the adoption of standard contractual clauses approved by the European Commission under Article 46(2) of the Regulation.

The transfer of your data will fully comply with the warranties, the provisions, and the rights laid down by the legislation on privacy. Furthermore, upon a simple request (see the next paragraph of the Privacy Policy), you may receive more information on the transfer of your data and the warranties provided for their protection. Where we transfer your data from a location inside the EEA to parties outside the EEA that do not offer adequate protection as determined by the European Commission, we will ensure arrangements are in place which enable us to transfer the data to them and that enable you to exercise your rights following the applicable law.

Where expressly set out in the relevant agreements, the data processors referred to above may transfer users' personal data to countries outside the European Union as part of activities carried out for the benefit of the Company, so long as the purposes set out in this policy and the guarantees, measures and rights set out in the Regulation are strictly adhered to.

For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

Data subjects' rights

By sending a notice to the email address hello@treasuredmemories.ie, you may at any time exercise the rights set out in Articles 15 to 23 of the Regulation, including knowledge of which data we are processing, in which manner and for which purpose we are using them, accessing and amending the data you have provided us or erasing them, asking us to limit the use of your data, and requesting to receive or transmit your data, subject always to the possibility of amending any consent (if any have been provided). Furthermore, you may always object to the processing of your data carried out, specifically for purposes of marketing or analysis of your preferences.

Who to contact if you wish to lodge a complaint

We remind you that, should you be dissatisfied with the replies received from Treasured Memories (according to the previous paragraph) here above, you may, in any event, if you believe that the processing related to your person breaches the provisions of the Regulation, lodge a complaint with the Authority for your personal data protection (www.dataprotection.ie), or with the Data Protection Authority of the country in which you habitually reside or work or where the alleged breach occurred.

Applicable law

This Privacy Policy is governed by Regulation (EU) 2016/679 and by the national regulations applicable to the specific case, to the extent that such regulations remain in force subsequently to the Regulation's implementation date (25 May 2018).

The Regulation ensures that the personal data processing occurs in compliance with the fundamental rights and freedoms and the dignity of the data subject, especially regarding confidentiality, personal identity, and the right to personal data protection.

Revision clause

Treasured Memories reserves the right to revise, amend or simply update, in whole or in part, at its exclusive discretion, in any manner and/at any time, without prejudice, this Privacy Policy, due also to the amendment of legal or regulatory provisions in the field of personal data protection. As appropriate, the amendments and updates to the Privacy Policy will be notified to the users by:

• email sent to the registered Website users and;
• publication on the Home Page of the Website and will be binding as soon as published and communicated.

Accordingly, we invite you to regularly access this section to check the publication of the latest and most updated Privacy Policy or your email address.