PRIVACY POLICY:
Part 1: Overview
About us and how to contact us
SYLVA PHANTOM LIMITED (the “SPL” or “we”) provides will process your Personal Information when you use our website, OFFICIALSYLVA.COM (“Site”). This Privacy Policy describes how SPL collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.
If you have any questions about our data practices, your rights or have any concerns or complaints, you can contact us at contact@officialsylva.com or send a letter to the address provided in this Privacy Policy.
Personal Information we collect
We collect Personal Information from you directly, e.g. when you browse our Site, purchase products or register as a wellbeing user and generate Personal Information about your use of our Site.
How we use your Personal Information
We use your Personal Information to provide you with our services, support and analyze your use, and improve them. We will also use your Personal Information to respond to your questions. We sometimes send you promotional emails, which you can choose to stop receiving at any time, by opting out or changing your browser or device settings. [link to further explanation below]
Who we share your Personal Information with
We rely on third parties for the purposes set out in this Privacy Policy, including support services, such as servers, support and analytics. We also work with certain partners who manage the payment and delivery of our products. [link to further explanation below]
Where we process your Personal Information
Your Personal Information is processed by us or our service providers in different countries around the world, including the United Kingdom, the United States of America and other locations. [link to further explanation below]
Your rights
Depending on the laws applicable to your Personal Information, you may have rights to access, receive a copy of, or delete, your Personal Information or restrict processing of your Personal Information, and you also have the right to object to our use of your Personal Information for certain purposes, including tailored marketing and advertising.
Changes to the Privacy Policy
Any updates or changes to this Policy will be published here. If there are any significant changes, we will notify you through the Website or via email.
Part 2: Further information
Introduction
This privacy policy (“Policy”) informs you of your choices and our practices in relation to your Personal Information (as defined below). In this Policy, “SPL”, “we” or “us” refers to SYLVA PHANTOM LIMITED, a company registered in the United Kingdom with its office located at 8 Fiery Hill Road , Barnt Green, Birmingham B45 8LF. We choose why we need to use your Personal Information and how it is used, which means we are considered the data controller in certain countries. For the purpose of this Policy, “Personal Information” means any Personal Information relating to an identified or identifiable individual.
Personal Information we collect
When you visit the Site, we collect certain Personal Information about your device, your interaction with the Site, and Personal Information necessary to process your purchases. We may also collect additional Personal Information if you contact us for customer support.
When you use our Site:
Device Personal Information: This may include the version of web browser, IP address, time zone, cookie Personal Information, what sites or products you view, search terms, and how you interact with the Site.
Purpose of collection: To load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
Disclosure for a business purpose: Shared with our e-commerce platform vendor (e.g. Shopify).
When you purchase products from our site:
Order Personal Information and customer support Personal Information: This may include your name, billing address, shipping address, payment Personal Information (including credit card numbers, email address, and phone number).
Purpose of collection: To provide products or services to you to fulfill our contract, to process your payment Personal Information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with Personal Information or advertising relating to our products or services.
Source of collection: Collected from you; when you make payments, we receive the following Personal Information from our payment providers about your transactions: transaction ID, country, payment provider used, purchased item, currency, value, and payment timestamp.
Disclosure for a business purpose: Shared with our e-commerce platform vendor (e.g. Shopify).
When you set up or use your wellbeing account
Account Personal Information: This may include your name, billing address, payment Personal Information (including credit card numbers, email address, and phone number).
Purpose of collection: To provide products or services to you to fulfill our contract with you and send our newsletter.
Source of collection: Collected from you.
Disclosure for a business purpose: Where we are collaborating with other brands to offer joint services or events, we may share your data to set the events up and enable you to take part. Where legally required, we will only send third party marketing with your prior consent; remember that you can opt out of marketing at any time.
Wellbeing profile: Please note that providing information in your wellbeing profile is optional, and we will not collect or infer any sensitive/special category of data (such as health data). Please note that the Site provides wellbeing and lifestyle Personal Information, not medical advice. Always seek the advice of your doctor or other qualified health provider regarding a medical condition.
Sharing Personal Information
We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example: We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for Personal Information we receive, or to otherwise protect our rights.
We do not sell, rent or exchange your Personal Information with any other third party for commercial reasons.
Using Personal Information
We use your Personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, providing our wellness services and keeping you up to date on new products, services, and offers.
Lawful basis
We process your Personal Information under the following lawful bases:
The performance of the contract between you and the Site;
Compliance with our legal obligations;
Where necessary, we will obtain your consent; and
For our legitimate interests, which do not override your fundamental rights and freedoms.
Retention
Your Personal Information is kept for as long as you hold a wellbeing account or for as long as it is necessary for the purpose it was collected. When deleting Personal Information, we will take measures to make the Personal Information irrecoverable or irreproducible, and electronic files which contain Personal Information will be deleted permanently.
Automatic decision-making
We do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.
Our processor uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.
Services that include elements of automated decision-making include:
Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.
Your rights
If you are based in the EEA, UK, Switzerland or are a legal resident of California in the U.S., you have certain rights in relation to your Personal Information. For Californian residents, please refer to Addendum 1 – California Privacy Rights. For the EEA, United Kingdom and Switzerland, you will find more Personal Information below on when which rights can apply.
Access. You have the right to access Personal Information, and to receive an explanation of how we use it and who we share it with. This right is not absolute. For example, we cannot reveal trade secrets, or give you Personal Information about other individuals.
Erasure. You have the right to request deletion of your Personal Information. We may need to retain some of your Personal Information where there are valid grounds for us to do so under data protection laws. For example, for the defense of legal claims, respect freedom of expression, or where we have an overriding legitimate interest to do so, but we will let you know when this is the case. Note that where the Personal Information is held by a third-party data controller, such as an advertising partner or a payment processor, we will use reasonable steps to inform them of your request, but we recommend you contact them directly in accordance with their own privacy policies to ensure your personal data is erased.
Objection and withdrawal of consent: You have the right to (i) withdraw your consent where you previously provided such consent; or (ii) object to our processing of your Personal Information where we process such Personal Information on the basis of our legitimate interests (see above under How we use your Personal Information). You may exercise this right as follows:
To stop receiving personalized advertising;
To stop receiving marketing emails: please follow the unsubscribe mechanism at the bottom of each email communication;
To stop our cookies being placed: please refer to our Cookie Policy;
Portability. You have the right to receive a copy of Personal Information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such Personal Information is transferred to a third party.
Correction. You have the right to correct any Personal Information held about you that is inaccurate.
Restriction. You have a right in certain circumstances to stop us processing Personal Information other than for storage purposes.
Cookie notice
What are cookies?
Cookies are small text files that are sent to or accessed from your web browser or your device’s memory. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or other identifier. A cookie also may contain Personal Information about your device, such as user settings, browsing history and activities conducted while using our services.
Who can drop cookies?
First-party cookies
First-party cookies are placed on your device directly by SPL. For example, SPL use first-party cookies to adapt our website to your browser’s language preferences and to better understand your use of our website.
Third- Party Cookies
Third-party cookies are placed on your device by our partners and service providers. For example, SPL use third-party cookies to measure user numbers on our website or to enable you to share content with others across social media platforms.
How long does a cookie stay on my device?
Session cookies
There are session cookies and persistent cookies. Session cookies only last until you close your browser. We use session cookies for a variety of reasons, including to learn more about your use of our website during one single browser session and to help you to use our website more efficiently.
Persistent cookies
Persistent cookies have a longer lifespan and aren’t automatically deleted when you close your browser. These types of cookies are primarily used to help you quickly sign-in to our website again and for analytical purposes.
Do you use other tracking technologies?
Other technologies (which SPL also call cookies) such as web beacons (also called pixel tags or clear gifs), tracking URLs or software development kits (SDKs) can also be used. Web beacons are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our service or opened an e-mail that SPL have sent them. Tracking URLs are custom generated links that help us understand where the traffic to our webpages comes from. SDKs are small pieces of code included in apps, which function like cookies and web beacons.
What do SPL use cookies (and other tracking technologies) for?
Like most providers of online services, SPL use cookies to provide, secure and improve our services, including by remembering your preferences, recognizing you when you visit our website and personalizing and tailoring ads to your interests. To accomplish these purposes, SPL also may link Personal Information from cookies with other Personal Information SPL hold about you.
When you visit our website, some or all of the following types of cookies may be set on your device.
Cookie type
What does it do?
Essential website cookies
These cookies are strictly necessary to provide you with services available through our website and to use some of its features, such as access to secure areas.
Analytics cookies
These cookies help us understand how our website is being used, how effective marketing campaigns are, and help us customize and improve our websites for you.
Advertising cookies
These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on your interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad.
Social networking cookies
These cookies are used to enable you to share pages and content that you find interesting on our website through third-party social networking and other websites. These cookies may also be used for advertising purposes too.
How can you control cookies?
You can set and modify your cookies preferences at any time, by using the Cookie Management Preference Tool available at the top of this Cookies Policy.
Browser and devices controls
Some web browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer. The procedure for managing cookies is slightly different for each internet browser. You can check the specific steps in your particular browser help menu.
You also may be able to reset device identifiers by activating the appropriate setting on your mobile device. The procedure for managing device identifiers is slightly different for each device. You can check the specific steps in the help or settings menu of your particular device.
Interest-based advertising tools
You can opt out of seeing online interest-based advertising from participating companies through the Digital Advertising Alliance, the Interactive Digital Advertising Alliance or Appchoices (apps only).
What happens if I disable all cookies?
The changes you make to your cookie preferences may make browsing our website a less satisfying experience. In some cases, you may even find yourself unable to use all or part of our site.
Opting out of advertising cookies does not mean you will not see adds – it means you won’t see personalized advertising from the companies that participate in the opt-out programs. Also, if you delete cookies on your device after you opted out, you will need to opt-out again.
Contacts and complaints
We welcome questions, comments, and requests regarding this Policy. These should be addressed to contact@officialsylva.com. Please contact us if you wish to make a complaint about how we process your Personal Information and we will endeavour to deal with your complaint as soon as possible. This is without prejudice to your right to start a complaint with a data protection authority.
Changes
We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.
Any updates or changes to this Policy will be published here. If there are any significant changes, we will notify you through the Site.
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ADDENDUM 1 - CALIFORNIA PRIVACY RIGHTS
The terms of this Addendum apply to residents of California under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”). For the purposes of this addendum, Personal Information means Personal Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA. Personal Information does not include Personal Information that is: lawfully made available from government records, deidentified or aggregated, or otherwise excluded from the scope of the CCPA.
COLLECTION AND DISCLOSURE OF PERSONAL INFORMATION
Over the past 12 months, through your use of the Site, we may have collected and disclosed the following categories of Personal Information from or about you:
Identifiers, including name, email address, IP address, device identifiers, advertising ID, and profile photos. This Personal Information is collected directly from you or your device. If you have registered through a third-party account (Apple, Facebook, or Google), we may have also collected from those third-party services your third-party ID, name, and avatar.
Internet or other electronic network activity Personal Information. This Personal Information is collected from our selected third-party analytics providers and advertising partners.
In the preceding twelve months, we have collected Personal Information from the following categories of sources:
You/Your Devices directly.
Advertising Networks and other advertising partners.
Analytics Providers.
Social Networks, to the extent this applies to you and within the limits of your permission.
We collect Personal Information for the following purposes:
To operate and administer the Site;
To improve the Site;
To communicate with you;
To serve advertising;
For security and verification purposes, including to prevent and detect fraudulent activity;
To address and remediate technical issues and bugs.
For additional Personal Information about what each type of Personal Information is used for, see “How We Use Your Personal Information” in the main portion of the Privacy Policy.
We may disclose Personal Information to the following types of entities:
Marketing and advertising partners who use your Personal Information to serve you ads in the Site and on other sites;
Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing Personal Information for any purpose other than for providing the services to us;
Regulators, judicial authorities and law enforcement agencies;
Entities that acquire all or substantially all of our business.
For additional Personal Information about how we disclose Personal Information is used for, see “Who we share Your Personal Information With” in the main portion of the Privacy Policy.
SALES OF PERSONAL INFORMATION / NOTICE OF RIGHT TO OPT-OUT
Over the past 12 months, we have used third party advertising and other tracking technologies on our Site to collect Personal Information about you, your device(s), and your use of our Site. We share that Personal Information with selected third parties such as advertising partners who use it to target advertisements to you online. You can opt-out and exercise control over the use of these technologies at any time by using the Privacy Settings.
RIGHTS UNDER THE CCPA
The CCPA provides California residents with certain legal rights; these rights are not absolute and are subject to certain exemptions. If you are a California resident, and the CCPA does not recognize an exemption that applies to you or your Personal Information, you have the right to:
Submit a verifiable request for the following Personal Information covering the 12 months preceding your request:
the categories of Personal Information about you that we collected, sold, or disclosed;
the categories of sources from which the Personal Information was collected;
the purpose for collecting or selling Personal Information about you;
the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
the specific pieces of Personal Information we collected about you;
Submit a verifiable request that we delete Personal Information we collected from you; and
Be free from unlawful discrimination for exercising your rights, including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA, subject to certain limitations.
We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
HOW TO EXERCISE YOUR RIGHTS
You can exercise your rights by emailing us at contact@officialsylva.com.
VERIFICATION
Requests for access to or deletion of Personal Information, whether submitted by you directly or via an authorized agent, are subject to our ability to reasonably verify your identity in light of the Personal Information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please be prepared to provide us with identifying Personal Information (such as your User ID, etc.) that and we can match against our records in order to confirm you are the rightful account holder.
AUTHORIZING AN AGENT
To authorize an agent to make a request to know or delete or opt out on your behalf, please email us at contact@officialsylva.com.
SHINE THE LIGHT
We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.
DO NOT TRACK
There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.