PRIVACY AND COOKIE POLICY

1. Important information and who we are

PI YEI ONLINE respects your privacy and is committed to protecting your personal data. This cookie and privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this cookie and privacy policy.

2. Purpose of this privacy and cookie policy

This cookie and privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you access our site, create a user account or purchase a service.

It is important that you read this cookie and privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This cookie and privacy policy supplements other notices and privacy policies and is not intended to override them.

3. Controller

Contact details

If you have any questions about this cookie and privacy policy or our privacy practices, please contact our Customer Care team:

Email address: INFO@PIYEI.COM

Postal address: Avenida 19 num 131-04 Bogota,Colombia

4. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version of the privacy and cookie policy was last updated on 03 April 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

5. Third-party links

The website may include links to the websites belonging to third parties. We are not responsible for any content published by any such third parties, nor we are responsible for any malware contained on any such websites. Before filling in your personal details please ensure that you are doing so on our website to avoid unauthorised use of your personal data by any third party.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy of every website you visit.

6. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect personal data when you place an order, call our Customer Care team, sign up for our marketing communications, browse our website. We also collect data regarding your shopping habits and the pages and the products that you have viewed from your use of our website.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• "Identity Data" includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
• "Contact Data" includes past and present billing addresses, delivery address, email address, telephone numbers, company details, contact details of any representatives.
• "Financial Data" includes bank account details or any other payment account which you use to pay for the orders.
• "Transaction Data" includes details about payments for the orders that you make.
• "Technical Data" includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• "Profile Data" includes your username and password, your interests and preferences.
• "Usage Data" includes data about how you came to the website; the date and time of your visit; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
• "Marketing and Communications Data" includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this cookie and privacy policy.

We do not collect any "Special Categories of Personal Data" about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you provide to us personal information belonging to someone else

If you provide personal information about other people then you must:

• seek their prior consent; and/or
• provide a copy of this privacy and cookie policy to those persons and ensure that they are aware of and understand its contents,

when providing information about other people, ensure that you have all relevant permissions and authority: (i) to make all necessary disclosures; (ii) to act on their behalf; and (iii) in relation to partners, members, shareholders or beneficial owners of borrowers, to allow us to make credit checks at credit reference agencies and otherwise for verification, in respect of those persons.

7. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

8. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our services;
• create an account on our site;
• subscribe to our service or publications;
• request marketing to be sent to you; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:

 (a)   analytics providers such as Google based outside the EU;

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
• Identity and Contact Data from data brokers or aggregators; and
• Identity and Contact Data from publicly available sources.

9. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email, text message or post. You have the right to withdraw consent to marketing at any time by contacting us at info@piyei.com

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
to register you as a new website user to take your orders to enable delivery of our marketing communications if you choose to subscribe to receive such communications via email from us to enable delivery of our marketing communications via post if you choose to subscribe to our mailing list to enable delivery of our marketing communications via SMS if you choose to subscribe.	(a) Identity (b) Contact	(a) performance of a contract with you (b) necessary for our legitimate interests
to process and deliver orders to detect and prevent fraud to verify your identity and the other information you have provided to us, including your bank account information to allow us to fulfil our contract with you including taking payment, completing any related anti-fraud checks if you choose to pay by credit/debit card, billing, shipping and delivery of the product and possible handling of the return to train our staff to give you access to services reserved for registered users to provide you help and assistance via our Customer Care team to provide product recommendations	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) performance of a contract with you (b) necessary for our legitimate interests (c) necessary to comply with our legal and regulatory obligations
to manage our relationship with you which will include: (a) notifying you about changes to our terms or privacy policy; and (b) asking you to leave a review or take a survey. to carry out statistical analysis and market research and testing to help us improve the website and our promotion of the website to allow us to provide you with the services on the website, such as placing and holding items in your shopping bag to collect the data (when you register on the website) necessary to ensure that we can recognise you on return visits and provide you with the services registration offers, or subscribing to marketing communications about our products to run the survey, competition or promotion	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) necessary to comply with a legal obligation (b) necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) to personalise your visit to the website and ensure the content from our site is presented in the most effective manner for you and for your computer to update the records we hold about you from time to time	(a) Identity (b) Contact (c) Technical	(a) necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) necessary to comply with a legal obligation
to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you to develop and improve our services, products and business, including analysing and improving our credit risk models, data collected and our customer service offering to provide and administer the marketplace and our related services	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
to use data analytics to improve our site, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
to make suggestions and recommendations to you about products that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	necessary for our legitimate interests (to develop our services and grow our business)

 

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

Who we disclose your personal information to as part of our services?
We may retain the services of external suppliers to help meet our business needs and may share your data with these suppliers. These suppliers have been selected after a rigorous evaluation process and chosen for their security, reliability and competence. They will process your data only under our instructions. We may disclose your personal data: 

• to companies in our group and our affiliates; and
• to our suppliers, sub-contractors and third-party data processors (including payment processors, marketing and data analytics service providers, collection agents, tracing agents, professional advisers and persons who provide us with the following services from time to time: marketing; technology; marketplace support; and back-up and business continuity);
• with any third party you have asked us to share your personal data with, including social media sites if you have asked us to connect with your social media account;
• to a third party if it acquires all or part of our business or assets in connection with the acquisition, or to a successor in interest in the unlikely event of our insolvency, winding up or liquidation;
• if we are required to do so by applicable law and regulation or by any governmental, tax, regulatory body or law enforcement agency;
• if you are represented by an agent, to your agent; and
• to any other person with your prior consent to do so.

Any such third parties who process your personal data on our behalf are only permitted to process your personal data in accordance with our instructions and we take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable data protection laws.

Mention Me

We work with MentionMe as a 3rd party service provider who will place functional cookies should our customers interact with our refer-a-friend programme. As these cookies are functional, they are strictly necessary for the operation of the MentionMe platform and will be applied whether you accept or reject optional marketing cookies. For more details about these cookies, please visit this link: https://mention-me.com/help/privacy_policy_s#cookies

These are all “strictly necessary” for the referral programme to function effectively.  As such, consent is not required under either PECR or GDPR.

The same is true in terms of Mention Me’s processing of personal data during the provision of the programme: Mention Me acts as a data processor, under our instructions and on the basis of legitimate interests, not consent.

Experian

Your personal data is shared with Experian Ltd for the purposes of managing a service called Club Canvasse, a home shopping and direct retailer data co-operative of which Desmond & Dempsey are members. By sharing information on what customers buy and pooling that with contributions from other members of the co-operative, the service allows Desmond & Dempsey to better understand our customers and to communicate with you more effectively. Please note, your personal information is not shared with any of the other members of the co-operative, and only aggregated data on the number and value of purchases is provided to members e.g. we will receive a report which states how many customers who have bought from us in the last 0-12mths, and who have also bought from other members of the co-operative in the last 0-12mths, or the last 24mths, last 36mths etc.  To understand more please click through to Experian’s website to understand more about their marketing services.

Klarna

In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.

Marketing
If you opt-in to receive marketing information from us, we will send you messages by email, text and post to keep you informed of new arrivals, special offers, sales and promotions.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You may opt out from receiving our marketing communication at any time by contacting our Customer Care team at info@piyei.com. Once you opt out, we will cease sending you marketing communications, however our system may take some time to adjust and you may still receive marketing emails before our system is fully updated.

Stopping marketing messages will not stop service communications, such as order updates.

We also work with Rakuten Advertising who may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalisation of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links. 

https://rakutenadvertising.com/legal-notices/services-privacy-policy/

https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/

If at anytime you want to opt out of interest-based advertising, please do so by following the instructions on this link: https://optout.networkadvertising.org/?c=1 

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, product/service experience or other transactions.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@piyei.com

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

10. Disclosures of your personal data

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
 
We may share your information with selected third parties including:

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; or
• analytics and search engine providers that assist us in the improvement and optimisation of our site.

 
We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
• If all or substantially all of our assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms set out herein.

 

11. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

12. Data retention

How long will you use my personal data for?
We will not keep your personal information for longer than is necessary, for the purposes for which it was collected and is processed and for the purposes of satisfying our legal, accounting or regulatory reporting requirements. We may retain personal information for longer than this in certain circumstances, for example in the event of an ongoing dispute. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.  

 
In some circumstances you can ask us to delete your data by contacting our Customer Service Team at info@piyei.com

In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

13. Where we store your personal information

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
 
Overall, cookies help us provide you with a better site, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. 
 
You can set your browser to refuse all or some browser cookies, or to alert you when sites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
 
All Cookies used by and on the website are used in accordance with the Data Protection Legislation. We may use some or all of the following types of Cookies:
 

• Strictly Necessary Cookies

A Cookie falls into this category if it is essential to the operation of the site, supporting functions such as logging in, your shopping basket and payment transactions.
 

• Analytics Cookies

It is important for us to understand how you use the site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping us to improve the website and your experience of it.

• Functionality Cookies

Functionality Cookies enable us to provide additional functions to you on the website such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
 

• Targeting Cookies

It is important for us to know when and how often you visit the site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make the website and advertising more relevant to your interests.
 

• Third Party Cookies

Third party Cookies are not placed by us; instead, they are placed by third parties that provide services to us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on the site, or by third parties providing analytics services to us (these Cookies will work in the same way as analytics Cookies described above).
 

• Persistent Cookies

Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit the site.
 

• Session Cookies

Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit the website until you close your browser. Session Cookies are deleted when you close your browser.
 
We may use the following Cookies:

Cookie	Purpose
_ session id, unique token, sessional	allows Shopify to store information about your session (referrer, landing page, etc.)
_shopify_visit, no data held	used by our website provider’s internal stats tracker to record the number of visits
_shopify_uniq, no data held	counts the number of visits to a store by a single customer
_cart	stores information about the contents of your cart.
Storefront_digest	if the shop has a password, this is used to determine if the current visitor has access
Google Analytics Tag	reviews performance and audience browse and shopping behaviours
Facebook Pixels	display the right message to the right people on Facebook paid advertising
Twitter Pixels	displays the right message to the right people on Twitter paid advertising
YouTube	displays video footage related content hosted in our YouTube channel

 

14. Where we store your personal information

Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. They store your data on a secure server behind a firewall. You may view Shopify’s privacy policy at www.shopify.com/legal/privacy and cookie policy at www.shopify.com/legal/cookies.

We may also transfer your limited personal data such as name and e-mail address to Klaviyo for the purposes of generating highly-relevant marketing e-mails and other communications via Instagram and Facebook. Klaviyo’s system is integrated with Shopify and therefore Klaviyo may receive your personal information from us as well as from Shopify. You may view Klaviyo’s privacy policy at https://www.klaviyo.com/privacy.

If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS).

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this cookie and privacy policy.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access and will ensure that any third party receiving your personal data adopts such appropriate measures necessary to safeguard your personal data.

Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it. We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.

15. Overseas transfers

Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Some of our suppliers and some group companies may be based in non-EU countries. Where this is the case, the transfer of your personal data to these countries is carried out in compliance with the guarantees provided by law.
• The USA is not a country in respect of which there is a European Commission decision of adequacy. To transfer personal data from the EU to the US we use different tools which are available, such as contractual clauses, binding corporate rules and the Privacy Shield. Where we use providers based in the US, we may also transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield. The US Department of Commerce is responsible for managing and administering the Privacy Shield and ensuring that companies live up to their commitments.

The Privacy Shield allows your personal data to be transferred from the EU to a company in the United States, provided that the company there processes your personal data according to a strong set or data protection rules and safeguards. The protection given to your data applies regardless of whether you are an EU citizen or not. 

In order to be able to certify, companies in the US must have a privacy policy in line with the relevant privacy principles. They must renew their “membership” to the Privacy Shield on an annual basis. If they do not, they can no longer receive and use personal data from the EU. In this case, we will use the standard contractual clauses prescribed by the relevant data protection legislation in the EU for the purpose of transfers to the countries outsider the EEA. 

• Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

16.