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Privacy Policy

The Company Cielomed Enterprises Ltd C 18417, Based in Malta, 35, White Friars Street, Fgura, the operator of Paul&Waters, declares that all personal data (hereinafter also referred to as “data”) is treated as strictly confidential and is handled in accordance with applicable legal provisions in the area of personal data protection.

The security of your personal data is our priority. We therefore pay due attention to personal data and its protection. In the Personal Data Processing Policy (the “Policy”), we would like to inform you about how we collect personal data about you and how we then use it.

1.   Personal data and its processing

1.1.  Personal data categories

We collect various types of data, depending on which of our services you are using.

If you shop with us, we collect your:

  • Name and contact details. First name and surname, email address, delivery address, billing address, phone number, bank details, payment details.
  • Demographic data. Data about gender, date of birth, country and preferred language.
  • Data as a result of the duration of the agreement – products bought, customer segment, volume of services provided

If you are a member of the Paul&Waters Club, we collect:

  • Name and contact details. First name and surname, email address, delivery address, billing address, phone number, bank details, payment details.
  • Demographic data. Data about gender, country and preferred language, date of birth.
  • Login details. Login names and passwords. We have no access to the actual password.

If you are on our marketing mailing list, we collect:

  • Name and contact details – email address and first name.  Mobile number if you are a member of our Discount Club. 
  • Demographic details – country, gender.

We also process the following personal data:

  • Data from communication between website and the customer
  • Behavioural records for websites operated by Paul&Waters

 

1.2.  Purpose of processing personal data:

  • Provision of services and their improvement. In order to provide the services offered and improve them to your satisfaction, we process your personal data. This means specifically:
    • Processing orders for products or services, ordered via our website, mobile application or customer hotline. The legal reason is the need to fulfill the purchase agreement or the Paul&Waters Club Agreement and, for selected data, to meet legal obligations (e.g. accounting documents).
    • Notification of the availability of products. If you ask to monitor the availability of products, we will process your personal data on the basis of your consent.
    • Customer support. To provide customer service and prevent any problems when fulfilling a purchase agreement or Paul&Waters Club Agreement, we will process your personal data on the basis of the necessary fulfillment of these agreements.
    • Communication. We use the data that is collected to communicate with you and to adapt it for each individual. For example, we may contact you by phone, email or through the app or some other format to remind you that you have products in your online basket, to help you complete your order, give you the current status of your request, order or return or get more information from you about it, or notify you that you need to take action to keep your account active. If you are a member of the Paul&Waters Discount Club, we will process data for this purpose to fulfill the Paul&Waters Discount Club Agreement. If you shop with us as a non-member, we process this data for the purpose of fulfilling the purchase agreement or implementing the measures adopted before the conclusion of the agreement. 
    • Improving services. We use data to continuously improve our services and systems, including adding new features, and also to make informed decisions through the use of pooled analysis and business intelligence, all on the basis of our legitimate interest derived from the freedom of business and on the basis of the need to improve the services provided for competitive success. To ensure a sufficient protection of your rights and interests. 
  • Protection, security and dispute resolution. We may also process data out of legitimate interest, to ensure the protection and security of our systems and customers, detect and prevent fraud, resolve disputes and enforce our agreements  on the basis of legitimate interest.
  • Marketing offers.
    • Commercial communication
      • We send you commercial communications about similar products to those you have purchased.
      • You can always decline commercial communications via the unsubscribe link found in every email.
      • If you unsubscribe from commercial communications, we will stop using your electronic contact information for this purpose. We will start using it again if you register or request it specifically.
    • The marketing offers you see may be chosen on the basis of other information we have gathered about you over time according to contact details, demographic data, favourites and data about using our products and websites (cookies, IP address, data provided by your browser, click data, commercial communications displayed, products visited). We do not have fully automated processing which would have a legal impact on you.
    • If you are a member of the Paul&Waters Discount Club, we will process data for this purpose to fulfill the Club Agreement. If you shop with us as a non-member, we process this data because of legitimate interest, which belongs in the sphere of legitimate conventional marketing.
    • If you are not our customer, we will process your data on the basis of your consent.
    • You have the right to raise an objection to the processing at any time free of charge. Contact details are provided at the end of this document.
  • Processing of cookies from websites operated by Cielomed Ent. Ltd.
    • If you have permitted cookies on your web browser, we will process records of behaviour from the cookies located on the websites operated by Paul&Waters to ensure better operation of the Paul&Waters website and for internet advertising by Paul&Waters. More information can be found in a separate chapter of this document.  You consent with cookies through browser settings. 

1.3.  Transfer of personal data to third parties

Your personal information will be passed on to third parties or otherwise arranged only if it is necessary to fulfil a purchase agreement and delivery. It is based on legitimate interest, because of the need to outsource, or if you have given your consent to this in advance, as follows:

  • a) to affiliated companies and processors based on fulfillment of the purchase agreement or the Paul&Waters Club Agreement to perform internal processes and procedures;
  • b) to companies issuing credit cards, to providers of payment services to process payments and to banks on the basis of your order, to fulfill a purchase agreement;
  • c) to carriers to deliver your order or services and to resolve complaints, including withdrawal from an agreement;
  • d) to our partners, in loyalty schemes that you join;
  • e) to other service providers and third parties involved in data processing;
  • f) to third parties, e.g. legal or financial representatives or courts, for the purpose of the processing of tax documents, recovery of debts or for other reasons ensuing from the fulfillment of our legal obligations;
  • g) public authorities (e.g. the police);
  • h) third parties carrying out surveys among customers.

If a third party uses data in connection with their legitimate interests, the controller is not liable for this processing. This processing is governed by the personal data processing policy of the relevant companies and individuals.