1 Introduction
1.1 We respect your privacy and are committed to protecting your personal data. This policy lies to your use of (and to any related communications with us about) the Sofina website, (together with the terms and conditions set out at www.sofinaactive.com/policies/terms-of-service including any data you may provide through the Website when you sign up to our newsletter, purchase a product or take part in a competition/prize promotion.
1.2 The Website is not intended for children and we do not knowingly collect data relating to children.
2 Important information and who we are
2.1 Sofina Active Ltd ("Sofina", “we”, “us” or “our”) is the controller responsible for processing your data in connection with the Website.
2.2 We have appointed a data privacy manager. If you have any questions about this privacy policy, or about how we use your data, please contact them using the details set out below:
Email address: alex@sofinaactive.co.uk
2.3 We appreciate the opportunity to answer any questions you may have in the first instance. You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO).
3 Changes to the privacy policy and your duty to inform us of changes
3.1 We keep our privacy policy under regular review. This version was last updated on 20/04/2022. It may change and, if it does, these changes will be posted on this page. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Website.
3.2 Please keep us informed if your personal data changes during our relationship with you.
4 Third party links
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
5 The data we collect about you
5.1 We may collect, use, store and transfer different kinds of personal data about you as follows:
(a) Identity Data: including first name, last name, username or similar identifier, date of birth, gender.
(b) Contact Data: including billing address, delivery address, email address and telephone numbers.
(c) Financial Data: including bank account and payment card details.
(d) Transaction Data: including details about payments from you and other details of products and services you have purchased from us.
(e) Device Data: including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system and the type of mobile browser you use.
(f) Technical Data: including your internet protocol (IP) address, 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 the Website.
(g) Content Data: including information stored on your Device, sign-up information, login information and items in your shopping basket.
(h) Profile Data: including your username and password, sign-up information, purchases or orders made by you on the Website, your interests, preferences, feedback and survey responses.
(i) Usage Data: including details of your visits to our Website including, but not limited to, traffic data, whether this is required for our own billing purposes or otherwise.
(j) Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties and your communication preferences.
5.2 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 privacy policy.
5.3 We do not intend to 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, genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Please do not provide us with any copies of special categories of personal data.
6 How is your personal data collected?
6.1 We will collect and process the following data about you:
(a) Information you give us. This is information you consent to giving us by registering to use the Website and the information you give us when you purchase our products or services via our Website, or by corresponding with us (for example, by email, social media or chat). It also includes information you provide when making purchases,enter a competition, promotion or survey, or report a problem with the Website. If you contact us, we will keep a record of that correspondence. Certain features of the website, such as reviews submitted about products, may allow you to upload further information, such as photographs. Please do not submit special categories of personal data via these functions. For more information on our rules around “User Generated Content”, please see our Website terms and conditions www.sofinaactive.com/policies/terms-of-service.
(b) Information we collect about you and your device. Each time you visit the Website we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
(c) Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
(i) Device Data from the following parties:
(A) analytics providers such as Google based outside the UK;
(B) advertising networks based inside or outside the UK; and
(C) search information providers based inside or outside the UK.
(ii) Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as Stripe, based outside the UK.
We use cookies to distinguish you from other users of the Website and to remember your preferences. This helps us to provide you with a good experience when you use or browse the Website and also allows us to improve the Website. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.
8 How we use your personal data
8.1 We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
(a) where you have consented before the processing;
(b) where we need to perform a contract we are about to enter or have entered with you;
(c) 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; or
(d) where we need to comply with a legal or regulatory obligation.
8.2 Please see “Lawful Basis” at paragraph 17 below to find out more about the types of lawful basis that we will rely on to process your personal data. You have the right to withdraw that consent at any time by contacting us. Where we rely on consent as our lawful basis you have the right to withdraw your consent at any time by contacting us.
9 Purposes for which we will use your personal data when using the Website (and in related communications with us)
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Lawful basis for processing
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To register you as a new customer
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Your consent; and/or
Performance of a contract with you
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To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
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Identity
Contact
Financial
Transaction
Marketing and Communications
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Your consent;
Performance of a contract with you; and/or
Necessary for our legitimate interests (to recover debts due to us)
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To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) Sending you updates and marketing communications
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Identity
Contact
Profile
Marketing and Communications
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Your consent;
Performance of a contract with you;
Necessary to comply with a legal obligation; and/or
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
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To enable you to partake in a prize draw, competition or complete a survey
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Identity
Contact
Profile
Usage
Marketing and Communications
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Your consent;
Performance of a contract with you; and/or
Necessary for our legitimate interests (to raise awareness about our products/Services and to develop them and grow our business)
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To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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Identity
Contact
Technical
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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); and/or
Necessary to comply with a legal obligation
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To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
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Identity
Contact
Profile
Usage
Marketing and Communications
Technical
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Necessary for our legitimate interests (to raise awareness about our products/Servicesand to develop them, to grow our business and to inform our marketing strategy)
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To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences
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Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
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10 Disclosures of your personal data
10.1 We may share your personal data for the purposes set out in the tables above with the parties set out below.
(a) Internal Third Parties and External Third Parties as set out in the Glossary.
(b) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
10.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
11.1 We strive to provide you with choices regarding our use of your personal data, particularly around marketing and advertising.
11.2 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 products, services and offers may be relevant for you (we call this marketing).
11.3 You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
11.4 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
12 International transfers
12.1 Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
12.2 If we transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
(b) Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
12.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
13.1 All the information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. You are responsible for keeping all yourpassword confidential.
13.2 Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
13.3 You may communicate with us publicly through social networking platforms or review or forum features. You must ensure when doing so that you do not submit any personal data that you do not want to be seen, collected or used by other users.
13.4 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
14.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data 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.
14.2 To determine the appropriate retention period for personal data, we consider: (i) the amount, nature and sensitivity of the personal data; (ii) the potential risk of harm from unauthorised use or disclosure of your personal data; (iii) the purposes for which we process your personal data and whether we can achieve those purposes through other means; and (iv) and the applicable legal, regulatory, tax, accounting or other requirements. For more information on how long we hold your personal data please contact us.
15.1 You have the right to:
(a) Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(i) if you want us to establish the data's accuracy;
(ii) where our use of the data is unlawful but you do not want us to erase it;
(iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request the transfer of your personal data to you or to a third party. We will provide to you (or a third party you have chosen) your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
15.2 You also have the right to ask us not to continue to process your personal data for marketing purposes.
15.3 You can exercise any of these rights at any time by contacting us at alex@sofinaactive.co.uk
16.1 Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
16.2 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
16.3 Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
16.4 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
17.1 Internal third parties
(a) Other companies owned or controlled by Courtney Black, which may act as joint controllers or processors and who are based in the UK and provide services to you or Sofina.
17.2 External third parties
(a) Service providers acting as processors based in the UK who provide IT and system administration services and website development services, including Shopify.
(b) Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
(c) HM Revenue and Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.
(d) Social networks, such as Instagram, Facebook, YouTube and LinkedIn, but only in so far as is necessary to provide features on our Website, such as widgets, buttons or plug-ins.
(e) Advertising and marketing partners for marketing on our or a third party’s behalf. This will always be in line with our Cookies Policy, and you can manage your consent to receive cookies here. For example, we may share Usage Data with Google (in conjunction with Google Analytics, Google Tag Manager and Google Ad Manager) and Facebook (in conjunction with Facebook Pixel, Facebook Ads Conversion Tracking) and may share your data (which may include your email address) with these entities for the purpose of remarketing and behavioural targeting (where you have consented to such activities). You can also opt-out of these activities through your device and/or browser settings or third-party tools, such as the Network Advertising Initiative opt-out.
(f) Partners to help us manage your marketing consents and email marketing. For example,we may share your Contact Details with our partners Hubspot, SEMRush and AppsFlyer to enable us to send you our newsletters, offers and other updates. For more information, please see Section 12 above.
4
Cookie Policy
- Our website uses cookies and similar technologies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
- A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree. Cookies contain information that is transferred to your computer's hard drive. If you would like to learn more about cookies, you can visit https://www.allaboutcookies.org/.
- We use the following cookies:
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Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
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Analytical or performance cookies. These allow us to recognise and count the number of visitors to our website and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
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Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
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Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed on our website. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
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Cookie Name
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Purpose
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Duration
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Cookie Type
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secure_customer_sig
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This cookie is used to store customer credentials securely when processing a purchase on the website - the cookie is essential in making a secure online transaction.
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1 year
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HTTP
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localization
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Holds the users timezone.
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13 days
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HTTP
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_orig_referrer
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This cookie is used to collect information on a visitor. This information will become an ID string with information on a specific visitor – ID information strings can be used to target groups with similar preferences, or can be used by third-part y domains or ad-exchanges.
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Session
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HTTP
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_y
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Collects data on user behaviour and interaction in order to optimize the website and make advertisement on the website more relevant.
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Session
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HTTP
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_shopify_y
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1 year
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HTTP |
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cart
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The cookie is necessary for the secure checkout and payment function on the website. This function is provided by shopify.com.
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13 days
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HTTP |
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cart_ts
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The cookie is necessary for the secure checkout and payment function on the website. This function is provided by shopify.com.
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13 days
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HTTP |
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cart.sig
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The cookie is necessary for the secure checkout and payment function on the website. This function is provided by shopify.com.
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13 days
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HTTP |
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cart.ver
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The cookie is necessary for the secure checkout and payment function on the website. This function is provided by shopify.com.
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13 days
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HTTP |
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storefront.digest
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This cookie is used in conjunction with the payment window - The cookie is necessary for making secure transactions on the website.
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13 days
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HTTP |
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hubspotutk
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Sends data to the marketing platform Hubspot about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels.
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Session
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HTTP |
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_hssrc
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The cookie is necessary for the secure checkout and payment function on the website. This function is provided by shopify.com.
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13 days
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HTTP |
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_hssrc
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The cookie is necessary for the secure checkout and payment function on the website. This function is provided by shopify.com.
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13 days
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HTTP |
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_hs_opt_out
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The cookie is necessary for the secure checkout and payment function on the website. This function is provided by shopify.com.
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13 days
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HTTP |
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locale_bar_accepted
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Stores preferred currency
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13 days
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HTTP |
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cookieMessage
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Stores cookie preferences
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1 year
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HTTP |
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keep_alive
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Saves the user's current geographical location based on the user's IP address.
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13 days
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HTTP |
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_landing_page
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Stores visitors' navigation by registering landing pages - This allows the website to present relevant products and/or measure their advertisement efficiency on other websites.
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Session
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HTTP |
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_s
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Collects data on user behaviour and interaction in order to optimize the website and make advertisement on the website more relevant.
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Session
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HTTP |
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_shopify_s
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Collects data on user behaviour and interaction in order to optimize the website and make advertisement on the website more relevant.
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Session
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HTTP |
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_tracking_consent
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This cookie is used to determine if the visitor has accepted the cookie consent box.
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Session
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HTTP |
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_shopify_tm
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Stores the user's cookie consent state for the current domain
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1 day
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HTTP |
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_shopify_m
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Stores the user's cookie consent state for the current domain
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1 year
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HTTP |
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_shopify_evids
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Contains data on the content of the shopping cart. This data is used for marketing purposes by promoting related products or for retargeting purposes.
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Session
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HTTP |
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_shopify_sa_p
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Saves the user's current geographical location based on the user's IP address.
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13 days
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HTTP |
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_shopify_pay_redirect
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The cookie is necessary for the secure checkout and payment function on the website. This function is provided by shopify.com.
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1 day
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HTTP |
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_hstc
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Saves the user's current geographical location based on the user's IP address.
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13 days
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HTTP |
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_shopify_d
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The cookie is necessary for the secure checkout and payment function on the website. This function is provided by shopify.com.
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Session
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HTTP |
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_shopify_sa_t
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Collects data on visitors' behaviour and interaction - This is used to make advertisement on the website m ore relevant. The cookie also allows the website to detect any referrals from other websites.
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Session
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HTTP |
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_shopify_evids
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Contains data on the content of the shopping cart. This data is used for marketing purposes by promoting related products or for retargeting purposes.
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Session
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HTTP |
- Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:
- providers of social-media plug-ins and functionality, such as Facebook, Twitter and LinkedIn,
To deactivate or manage the use of third party advertising cookies, visit the relevant settings in your internet browser.
- You can block cookies by activating the setting on your browser that allows you to refuse all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
- Depending on their function, cookies may have different durations. There are session cookies and persistent cookies:
- Session cookies only last for your online session. It means that the browser deletes these cookies once you close your browser;
- Persistent cookies stay on your device after the browser has been closed and last for the period of time specified in the cookie.
Except for essential cookies, all cookies will expire after the time period provided in the “Duration” column of the table above.
