GPQ-US PRIVACY POLICY
(last updated 31 August 2019)
Introduction
GPQ srl is committed to respecting the privacy of its website users and providing them with a safe and secure online experience. This Privacy Policy applies to visitors to GPQ srl’s American website
https://www.wiqo.us/home/ (the “Website”), which is owned, operated and distributed by GPQ srl, S.O. Via Flavia 23/1, 34148 Trieste, Italy. References to “GPQ,” “the Company,” “us,” “we” or “our” in this Privacy Policy means GPQ srl or one (or more) of its affiliates, subsidiaries, or joint ventures.
Please read this entire Privacy Policy before using the Website. This Privacy Policy provides notice to users of the Website regarding their Personal Data (as defined below), in compliance with data privacy laws and regulations in the jurisdiction(s) in which the Website may be used. This Privacy Policy describes how we collect, use, secure, and disclose Personal Data collected through the Website. When you provide Personal Data to GPQ via the Website, GPQ becomes a controller of that Personal Data. This means GPQ can decide the purposes for which and the ways in which the Personal Data is used.
By accessing any part of the Website, you understand and agree to the terms and conditions described in this Privacy Policy and the GPQ
Terms of Use. This Privacy Policy applies to all users who submit Personal Data through the Website. GPQ may modify this Privacy Policy at any time at its sole discretion by publishing such modifications on the Website. By accessing the Website at any time after such modifications, you are agreeing to such modifications.
If you do not agree to any of these terms, you should not use this Website. If at any time you wish to change any of your Personal Data that is collected through the Website, or withdraw your consent for processing your Personal Data, you may contact GPQ at
policies@wiqo.us or as described below.
1.
WHAT IS “PERSONAL DATA” AND HOW IS IT COLLECTED?
In order to better provide you with our products and services, we collect two general types of information about our users: Personally Identifiable Information and Non-Personally Identifiable Information (together referred to herein as “Personal Data”). Personally Identifiable Information is information that relates to you individually and allows us to identify you, either directly or in combination with other information that we may hold. We obtain this information either directly from you or from our distributors who may provide it to us. Our primary goal in collecting this information from you is to provide you with a smooth, efficient, and customized experience while using the GPQ-US Site. Information from which we cannot personally identify you is Non-Personally Identifiable Information.
We may collect Personal Data about you in the following ways:
a. Information You Give Us: We receive and store any information you enter on our Website or give to us in any other way.
Click here to see examples of what we collect. You can choose not to provide certain information, but then you might not be able to use the full functionality of the Website. We use the information that you provide for responding to your questions and requests, customizing the Website’s shopping experience for you, taking and fulfilling your orders for our products, improving our products, communicating with you, and other such purposes.
b. Automatic Information: We receive and store certain types of Personal Data whenever you interact with us. For example, like many websites, we use “cookies,” which are small bits of information that are stored by your computer’s web browser when accessing the Website.
Click here to see examples of the information we receive from cookies. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain online products, services or features on the Services. For more information, please see our
Cookie Policy.
c. Mobile: When you use your mobile device to access the Website, we may receive information about your location and your mobile device, including a mobile device ID number (a unique identifier for your device). We may use this information to ascertain the geographic areas where our potential customers are located. Most mobile devices allow you to turn off location services.
d. E-mail Communications: When you open an email from us, we can receive a confirmation that you did so (if your computer so allows). In this way, we learn what content interests our customers and can tailor emails we send to you according to your interests. We also compare our customer list to lists received from other companies in an effort to avoid sending unnecessary messages to our customers. If you do not want to receive e-mail or other mail from us, please contact us at
policies@wiqo.us.
e. Information from Other Sources: We might receive Personal Data about you from other sources and add it to our account information. Examples of such information may include updated delivery and address information from our delivery carriers or other third parties, which we use to correct our records and deliver your next purchase or communication more easily, and credit history information from credit bureaus, which we use to help prevent and detect fraud, thereby enabling us to keep our product prices down.
Please note that when you purchase GPQ goods via a GPQ distributor, the Personal Data we collect from you also will be processed by that distributor, who will be a separate controller of your Personal Data. GPQ distributors are independent and are not employed by GPQ, and GPQ is not responsible for their use of Personal Data. This means that the distributor, independently from GPQ’s business operations, will process your Personal Data in the manner and for purposes they decide, including for their own marketing purposes. In general, GPQ’s distributors will use your Personal Data in a manner compatible with this Privacy Statement. If they use your Personal Data in a different way, they are required to provide further privacy information to comply with their own legal obligations.
2. PROCESSING OF PERSONAL DATA
We process your Personal Data only: (1) with your consent; (2) as necessary to fulfill orders from our customers; and (3) as necessary for our legitimate interests in fulfilling orders from customers and building our business, where those interests do not override your fundamental rights and freedom related to the privacy of your Personal Data. The Personal Data you provide will be processed for the following purposes only:
a. To take orders and perform related activities such as invoicing and payment, delivery, administrative, managerial and organizational services, and other purposes necessary to confirm and complete your order and transport the products you order to you
b. To fulfill our obligations under the law, regulations, applicable legislation and other requirements of the Government, law enforcement authorities and supervisory and control bodies
c. To perform marketing and promotional activities regarding our products and services and to carry out other commercial communications
d. To conduct studies and market research
The Personal Data required for the purposes set out in Subsections 2.A. and 2.B. above must be provided in order to fulfill statutory obligations and/or to execute and conclude the contractual relationship embodied by your order for a product on the Website. Therefore, full or partial refusal to provide such data would render such sales impossible. The processing of Personal Data for the purposes set out in Subsections 2.C. and 2.D. above requires your express consent. You have the right to refuse all or part of the processing of your Personal Data for the purposes set out in Subsections 2.C. and 2.D. by not checking the appropriate box at the end of this Privacy Policy or by contacting
policies@wiqo.us.
The processing of Personal Data is carried out directly by employees or other agents or appointees of GPQ by means of operations performed on Personal Data (or sets of Personal Data), whether or not by automated means, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying such data. Such processing is done in compliance with applicable laws regarding confidentiality and security and consistent with principles of fairness, lawfulness, transparency and protection of your rights.
3. USE OF YOUR PERSONAL DATA
We use your Personal Data for the following purposes:
a. To fulfill your order. When you place your order, we use your Personal Data to fulfill that order. We may contact you by email and/or SMS to confirm your order, payment and/or order status.
b. To inform you about products and offers you may find interesting. We may use the Personal Data we have about you (including your order history) to build a profile about your preferences, to show you offers tailored to you, and perhaps to show you advertising related to other GPQ products. When you interact with the Company by posting or messaging on social media, we may use the Personal Data that is included in such posts for this purpose.
c. To improve our services and our business processes. We will use your Personal Data for business purposes such as accounting, billing, marketing, statistical, tax and audit, security and legal, general management, records and business development. For example, we use IP addresses to help administer the Website, diagnose problems with our servers, identify and analyze trends, track users' movement, and gather broad demographic information for aggregate use in order for us to improve the Website and your online shopping experience on it.
d. To ask for your participation in product reviews or customer preference questionnaires. We may contact you to ask that you participate in product reviews or questionnaires about your likes, dislikes, and preferences for the types of products we sell or plan to sell, or products you have purchased from us. We do this to ensure we are meeting our customers’ needs and desires and to stay abreast of changes in market preferences.
e. To perform marketing and promotional activities regarding our products and services and to carry out other commercial communications.
If you object to the use of your Personal Data for any of the purposes set out above or wish to opt out of marketing communications, leave unchecked the appropriate box at the end of this Privacy Policy or contact us at
policies@wiqo.us. While your decision to provide Personal Data to us is generally voluntary, if you do not provide certain information, we may not be able to fulfill your order or accomplish the purposes outlined in this Privacy Policy.
The security of your Personal Data is important to us and we understand its importance to you. We have implemented and follow industry standard measures to protect against unauthorized access to and unlawful interception or processing of Personal Data. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. For example, we may store your personal information on computer systems with limited access, which are located in controlled facilities.
We also protect account information by placing it in a secure database that is only accessible by GPQ and its employees, contractors and agents. When you enter sensitive information (such as a credit card number or password) on our registration page or order forms, we encrypt that information using Secure Socket Layer (SSL) 256-bit encryption protocol, which is the industry standard and prevents unauthorized parties from viewing such information when it is transmitted. In order to most efficiently serve you, we use established third-party banking and processing agents to provide credit card processing services on our Website. These agents receive the information needed to verify and authorize your credit card or other payment information. GPQ does not currently receive any of your credit card information, however, this policy is subject to change.
Unfortunately, no storage or data transmission over the internet or any wireless network can be guaranteed to be 100% secure. As a result, while we conscientiously strive to protect your Personal Data, you acknowledge that: (a) there are security and privacy limitations of the Internet that are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the GPQ-US Site cannot be guaranteed; and (c) it is possible that any such information and data may be viewed or tampered with while in transit by a third party. We are not responsible for the theft or destruction of your Personal Data. You are responsible for maintaining the confidentiality of your account password and for any access to or use of the Website using your password, whether or not authorized by you. Please notify us immediately of any unauthorized use of your password or account or any other breach of security.
5. SHARING OF PERSONAL DATA
We will use your Personal Data for internal purposes only and will never sell your Personal Data to any third parties. However, we may share Personal Data with:
- GPQ company managers, employees, or representatives only as needed to carry out the purposes set out in Section 2 above
- GPQ contractors and service providers who help us carry out our business and improve our services and your customer experience (for example, information technology services, data hosting services, e-mail delivery services, delivery services, or providers who maintain, enhance, or add to the functionality of the Website)
- If GPQ becomes part of another organization (e.g., a new parent company), that organization will possess the Personal Data we have collected and it will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy
- GPQ’s external legal advisors, auditors, and qualified designated due diligence providers (or other qualified third parties) in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock or other legal or financial matters (including in connection with any bankruptcy or similar proceedings)
- As required by governmental authorities pursuant to applicable law or in connection with dispute resolution proceedings
- As we believe necessary or appropriate for the purposes listed in Section 3 above.
We use third parties to provide web analytics on the Website, and these third parties may use their own cookies, web beacons (a.k.a., “clear GIFs”), local shared objects, and other technologies to collect information (i) that helps us with traffic measurement, research, and analytics (such as aggregate click data), and (ii) that is used to place advertisements tailored to your apparent interests. To the extent we combine information from third-party services with Personal Data we collect directly from you, we will treat the combined information as Personal Data under this Privacy Policy. When you use the Website, we will share Personal Data with third parties only so far as necessary for the third party to help carry out your order.
If you choose to link to third-party websites via our Website, third parties may collect information about your use of our Website. Similarly, where you choose to interact with GPQ’s content on social media, third parties may collect information. Information collected by third-party social media services is governed by the privacy policies of those third parties. When you are directed to a third party’s website by GPQ, GPQ is not responsible for the processing of your Personal Data by any third party.
You may choose whether to receive interest-based advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising, visit
http://www.aboutads.info/choices. Some of these companies also may be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options regarding its members, see
http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain interest-based advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). GPQ is not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
Personal Data we collect is kept on servers located within the United States, elsewhere in North America, and/or in the European Union (“EU”). In order to serve the purposes set out in
Section 2 above, we may transfer your Personal Data to our operations or servers in other countries. By providing us with any Personal Data, you consent to the transfer of that data to countries outside of your country of residence. GPQ uses appropriate safeguards to protect Personal Data that is transferred to countries that may have a lower level of protection for Personal Data, and such transfer of data takes place in accordance with applicable legal provisions set out by the European Commission (the “EC”) and/or other applicable governmental authorities. In cases involving transfer of data into or from the countries participating in the European Commission, EC-approved standard contractual clauses (or other legally acceptable transfer mechanisms) are in place with our email system provider, IT support, and IT system maintenance suppliers. Contact us at
policies@wiqo.us.
The Company may use your Personal Data while you are active with Company. Personal Data will be kept by the Company for five (5) years for legal purposes (such as tax audit, statutes of limitations, etc.), whichever is longer. Upon the expiration of the applicable period, the Personal Data will be deleted. Where your consent has previously been obtained but you later object or withdraw your consent as set out in this Privacy Policy, we will stop processing your Personal Data.
7. YOUR RIGHTS
You must be at least 18 years old to order products from this Website. GPQ does not knowingly collect, use, or disclose Personal Data from children under the age of 13 without prior parental consent, except as permitted by the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and believe we have inadvertently collected your child’s information in a manner not permitted by COPPA, you have the rights set out in this
Section 7 with regard to such information. Please contact us at
policies@wiqo.us.
This Website is not intended for use by anyone outside the United States. Nevertheless, this Website complies with the General Data Protection Regulation (“GDPR”). If you are a resident of the EU and have used this Website while you are physically located in the United States, your Personal Data may be collected. As an EU resident, you have a right to request confirmation on whether we hold any Personal Data about you and to see such data in intelligible form, as well as be provided with:
- The origin of the Personal Data;
- The purposes and modes of the processing of the Personal Data;
- The logic applied in the event that data processing is carried out with the aid of electronic tools;
- The identification details of the controller and processor of the Personal Data (and/or their designated representatives) pursuant to Articles 3 and 4 of the GDPR;
- The subjects or categories of persons to whom the Personal Data may be communicated or that may become acquainted with the Personal Data. By allowing you to access, correct, or delete the Personal Data we hold about you; and
- The rectification or update of inaccurate Personal Data we hold, or the deletion, anonymous processing or blocking of Personal Data in certain circumstances.
If you have an issue or complaint about how we handle your Personal Data, please contact us at
policies@wiqo.us.
If you live in California, California Civil Code Section 1798.83 permits California resident users of a website to request and obtain, once a year and free of charge, certain information regarding our disclosure, if any, of certain categories of Personal Data to third parties for their own direct marketing purposes in the preceding calendar year. To make such a request, please send an e-mail with "California Privacy Rights" in the heading to email us at
policies@wiqo.us. Please include your mailing address, state of residence and email address with your request.
8. HOW TO CONTACT US
If you have any questions, comments or requests regarding this Privacy Statement please email our Data Protection team at
policies@wiqo.us.
