Privacy Policy Content

Summary

Shops Ltd (“Shops”) is committed to protecting your personal data and handling it responsibly.  We commit to only using your data for the purposes and in the manner required to be an active customer of Shops. This policy covers the personal data that Shops processes whenever you sign up and use Shops Shopping Mall as well as when you interact with us online (such as on social media), and when you correspond with us (such as by email or over the phone). It also covers personal data that we may receive from third parties. The sections below explain in more detail:

If you would like to know how we collect information about your use of our
website, apps and social media, you can read
our Cookies Policy here.

Personal data Shops collects from you

We collect personal data from your interactions with us, such as when you engage with us online (such as on social media or by using our website), or when you email or phone us. The personal data we collect from you includes:

  • the name and contact details that you provide when you register as a Vendor
    with us
  • your purchase, payment and address details
  • your marketing preferences, including any consents you have given us
  • your browser or device information
  • information about your use of our websites and apps
  • information about your engagement on social media, including on accounts belonging to Shops.
  • if you are a Member of a Shops reward or loyalty program: (i) information about your qualifying purchases and activities, so that we can award you with your reward or loyalty points; and (ii) information about your redemption of rewards or loyalty points.

Why Shops processes your personal data

This section explains the reasons why we process your personal data and our legal bases for doing so.

Consent

If you’ve opted-in to receive information and offers relating to Shops and our commercial partners (for example by ticking a box our website or apps), then we’ll provide this information to you by email, text, or phone. We also rely on your consent to process information about your use of our website, apps and social media sites, so that we can improve your browsing experience and deliver online advertising that is relevant to you (for more information, click here to see our Cookies Policy). Wherever we rely on your consent to process personal data, you have a right to withdraw that consent. Click here for information on how to exercise your rights.

Legitimate interests

We process your personal data when necessary to pursue our legitimate interests in the following:

  • tailoring our websites and communications for you. We collect information about your engagement with us online (such as pages that you have visited on our websites or apps) and combine that with aggregated insights we have about our Vendors, to build a fuller understanding of your individual preferences
  • monitoring, improving and protecting our products, content and services
  • monitoring and enforcing compliance with our terms and conditions.
  • preventing abusive, discriminatory or otherwise inappropriate or offensive behaviour, whether in person or online, that is directed towards other Vendors registered with Shops.
  • administering any Membership you have with us
  • checking the credit or debit card details you provide (to process your payments and prevent fraudulent transactions)
  • sending you some types of direct marketing, including by email and post
  • responding to your comments or complaints
  • undertaking, or inviting you to take part in, market research
  • preventing, investigating and/or reporting fraud, terrorism,
    misrepresentation, security incidents or crime
  • managing legal claims, compliance, regulatory and investigative matters
  • administering programmes run by us that you have chosen to participate in

You have a right to object to any processing that we undertake for our legitimate interests. Click here for information on how to exercise your rights.

Contract

We process your personal data when necessary for contractual reasons, such as to administer your account registration and to provide products and services that you have requested.

Legal obligation

We are legally required to process your personal data in cases where we need to:

  • obtain parental consent to provide online services directly to children
  • respond to certain requests by government or law enforcement authorities

Sensitive data

In limited circumstances, we may need to process your sensitive personal data, such as race or ethnicity data, or data about criminal offences. This will only ever be where we meet a lawful condition for such processing, such as where we have your consent, where the data has been made public by the data subject, or where processing is necessary for: the prevention or detection or unlawful acts, the substantial public interest, or legal claims.

Who Shops shares personal data with

We will share your personal data with the following recipients:

  • Eternity Holdings Ltd Group of Companies of which Shops Ltd, is a part, for the purpose of administering our websites and apps
  • public authorities or law enforcement officials, to assist with their official requests and comply with our legal obligations, including in respect of Covid-19
  • if you are a Shops Rewards Member, we may share information about you with Rewards Affiliates in order to administer your Membership

How long Shops retains personal data

We retain personal data about your membership for as long as your account remains active, and for a 12 month period of time afterwards (in case you decide to reactivate your membership or have queries about it). We retain personal data relating to your purchases for several years from the date of the relevant transaction.   This is to understand your purchasing preferences and to meet our legal and contractual obligations.   If your purchase has enduring relevance then we’ll keep relevant information for as long as we remain responsible to you for that purchase. Where you have asked us not to send you direct marketing, we keep a record of that fact to ensure we respect your request in future. We also retain information with the potential to give rise to legal disputes for 7
years.

Your rights to withdraw consent and to object (including to direct marketing)

Wherever we rely on your consent to process personal data, you always have
a right to withdraw that consent.   Click here to see the situations where we rely on your consent.

You also have the right to object to any use of your personal data for direct marketing purposes, as well as to processing that we undertake based on our
legitimate interests (including profiling).   Click here to see the situations where we process data for our legitimate
interests.

Click here for information on how to exercise your rights.

Your other personal data rights

In addition to your rights to withdraw your consent and to object, you have the
right to ask us: for access

  • to information about your personal data or for a copy of your personal data
  • to correct or delete your personal data
  • to restrict (i.e. stop any active) processing of your personal data
  • to provide you with certain personal data in a structured, machine-readable
    format and to transmit that data to another organization

These rights may not always apply, for example if fulfilling your request would reveal personal data about another Vendor or person, or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest in keeping.  If this is the case then we’ll let you know when we respond to your request.

How to contact us and exercise your rights

The easiest way to stop receiving information from us is by opting out of communications through your online preference centre (this is linked to in our communications with you and is accessible at times via your account settings).
You can also correct your registration details through your online account. We will do our best to assist with any queries you have about your personal data within 30 days of receipt.   You can contact our Data Protection Officer at any time using the contact details below.   When you do so, please provide your full name, your preferred contact information, and a summary of your query.
info@Shops.bm Data Protection Officer BermudaShops Ltd
Magnolia Towers  4th Floor,
15 Parliament Street Hamilton,
Hamilton HM12.

If you have unresolved concerns, you also have the right to complain to the Privacy Commissioner Bermuda: Email: privcom@privacy.com, Telephone: 441-452-7748.

Appendix

Cookies Policy

This policy explains how we use cookies and similar technologies such as tags and pixels (together, ‘Cookies’). It also helps you to manage what Cookies are set on your device.

What is a Cookie?

A Cookie is a small text file that is set on your device when you access our websites or use our apps (‘Websites’). It collects information about your use of our websites and helps the Websites to recognize and remember you in the future.

Why do we use Cookies?

The key reasons we use Cookies are to:

  • provide you with services you have requested.
  • show you relevant content, including personalized advertisements.
  • ensure that our websites function properly.
  • understand how you use our websites; and
  • remember your log-in details.

What type of Cookies do we use?

The following types of Cookies are set when you access our Websites:

1. Necessary Cookies

These cookies are essential for the Websites to operate. Without these cookies, services you have asked for, like shopping baskets, cannot be provided.

2. Functional Cookies

These cookies recognize you when you return to the Websites. They remember information (such as your username and region), enabling us to remember your preferences and display relevant content when you return.

3. Analytical Cookies

These cookies collect information about how visitors use and engage with the Websites (such as the most visited pages), helping us to make improvements to the Websites.

4. Targeting Cookies

These cookies collect information about your browsing habits (such as products you have purchased or content you have engaged with) as well as information about your browser, device and IP address. We use this information to display more relevant content and advertisements to you, as well as to limit the number of times you see an advertisement and measure the effectiveness of a campaign.

Occasionally we share this information with partners, including other advertising organisations. Targeting Cookies help us to connect with you on our websites and on other websites, including Facebook. If you disable these Cookies, you may still see the same number of advertisements although they may be less relevant to you Some of these Cookies are controlled and set by us (‘First Party Cookies’) and some are set by third parties (‘Third Party Cookies’). Third Party Cookies are mainly used to serve relevant advertisements to you on the Websites. We do not control Third Party Cookies but we have provided some information below about Third Party Cookie providers on the websites.

How to manage Cookies

You can manage what Cookies are set on your device at any time using our Cookie Preference Centre. Please remember that if you choose to disable Cookies, certain sections of our Websites may not function properly.

Browser settings

Alternatively, you can manage Cookies through your browser settings. Information about how to do this on key browsers is provided via the links below, and more general guidance is available at: http://www.allaboutcookies.org
Please note that changes to your Browser settings will apply to all websites
that you visit on your device). However, these changes will only apply to the
device on which you make them, so if you want to manage Cookies on other devices
then you will need to update the settings on those devices separately.

  • Chrome
  • Firefox
  • Internet Explorer
  • Safari
  • iOS
  • Android