Welcome to Anaghra Raoca and our website and shop at www.anaghraraoca.com.

 

For your current and any further visits to our website and use of our shop (collectively “website”), we would like to inform you about data collection, processing and use when visiting and using our service.

 

This Privacy Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum, to make sure you understand the information provided. However, to achieve this objective we would like to explain you the following two concepts.

 

What is Personal Information?

"Personal Information" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie or an IP Address) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

What is Processing?

"Processing" means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means. The term is broad and covers virtually any handling of data.

 

In principle, we will only use your Personal Information in accordance with the applicable data protection laws, in particular:

 

• Canada`s Personal Information Protection and Electronic Documents Act (“PIPEDA”),
• California`s Consumer Privacy Act (“CCPA”) and the subsequent amendments from the California Privacy Rights and Enforcement Act (“CPRA”), and
• the EU`s General Data Protection Regulation (“GDPR”).

 

The Person responsible (“Data Controller”)

The person responsible for the processing of Personal Information is:

 

Anaghra Raoca,

ANG TRADING INC,

PO box 6, Station F, Toronto

ON M4Y2L4, Canada,

 

If you have any questions about the processing of your Personal Information, you can reach us using info@anaghraraoca.com or write to us at the above address.

 

Purpose and legal basis of processing

In accordance with the above-mentioned Privacy Laws, we need to have both a purpose and a legal basis to process Personal Information. The purposes are:

 

• the provision of the website and shop and their functions and contents,
• responding to contact requests and communicating with users,
• providing our services, and
• security measures.

 

Of course, we can only do that if we have at least one of the following legal bases or in other words lawful reasons to do so. Unless specifically described below, we typically link the above purposes to one of the following:

 

• Consent: the individual has given clear consent to process Personal Information for a specific purpose.
• Contract: the processing is necessary for a contract or because you have asked us to take specific steps before entering into a contract.
• Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
• Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your Personal Information which overrides those legitimate interests.

 

General Principles

1. Security

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us.

 

You can recognise an encrypted connection if the address line of your browser contains a "https://" instead of a "http://" and also has a lock symbol. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

 

We have also implemented numerous security measures (“technical and organizational measures”) to ensure the most complete protection of Personal Information processed through this website.

 

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Information may be breached inadvertently or through wrongful intrusion.

 

Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Information may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.

 

1. Retention and Storage

We will retain your Personal Information as necessary in connection with the purposes described in this Privacy Policy, and in accordance with Canada`s Statutory Retention Periods and other applicable laws for up to 6 years.

 

1. Minors

Persons under the age of 16 should not transmit any Personal Information to us without the consent of their parents or legal guardians. We do not request Personal Information from minors and children and do not knowingly collect such data or pass it on to third parties.

 

1. Automated decision-making

Automated decision-making including profiling does not take place.

 

1. Do Not Sell

We do not sell your Personal Information.

 

1. Special Category Data

Unless specifically required and consent is obtained, for a particular service, we do not process Special Category Data.

 

1. Social Media

We are present on social media on the basis of our legitimate interest. If you contact us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis for the use of the relevant social media platform is our legitimate interest, your consent or, in the case of a (pre) contractual relationship with us, the initiation of a contractual service, if any.

 

1. International Transfer

In the course of our website operation, we process data. We usually do not transfer Personal Information to countries outside Canada. However, if we do, we ensure that processing of your Personal Information is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.

 

1. Sharing and Disclosure

We will not disclose or otherwise distribute your Personal Information to third parties unless this is a) necessary for the performance of our services for example with our web host or with our selected logistic providers to deliver your order, b) you have consented to the disclosure for example if you send someone a personal message along with an order, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfill our legitimate interests.

 

Processing of Personal Information by us

1. Log files

Each time a user accesses our website and each time a file is retrieved, data about this process is temporarily processed in a log file. In detail, the following data is stored for each access/retrieval: a) Date and time of the retrieval (time stamp), as well as the IP address of the accessing device or server, b) request details and destination address (protocol version, HTTP method, referrer, User Agent string), c) name of the retrieved file and transferred data volume (requested URL incl. query string, size in bytes) and d) Message as to whether the retrieval was successful (HTTP status code).

 

On the basis of our legitimate interest in a secure website, we store this data to protect against attacks for up to 7 days beyond the time of your visit. This data is analyzed and required for legal and criminal prosecution in the event of attacks on communications technology. The data is deleted as soon as it is no longer required for the performance of tasks.

 

1. Cookies

We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information, please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.

 

1. Shopify

We use the store system Shopify of the service provider Shopify International Limited, to host and displaying the shop. All data collected is processed on Shopify's servers. The legal basis for the data processing is our legitimate interest in providing an appealing website and shop.

 

1. Contacting us

Personal Information is processed depending on the contact method. In addition to your name and e-mail address, IP address or telephone number, we usually collect the context of your message which may also include certain Personal Information. The Personal Information collected when contacting us is processed for the purpose of dealing with your request and the legal basis is your consent. The use of your IP address takes place exclusively in the context of law enforcement and security measures in compliance with our legal requirements.

 

1. Order processing

We process your first name, last name, e-mail address, shipping, and billing address, if different, and the data related to your contract with us data to handle the contractual relationship between you and us.

 

It is also possible for you to register for your purchase. For this purpose, you can choose a password together with your e-mail address, both of which will enable you to log in more easily without having to enter your data again when you make a future purchase. We store the data you enter to set up a customer account through which your orders are recorded, executed, and processed. We will hold your data for further orders as long as you maintain your registration.

 

The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations.

 

1. Payment Data

If you make a purchase your payment will be processed via the payment system provider Shopify. Payment data will solely be processed through Shopify, and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.

 

1. Newsletter

If you have consented to receive our newsletter, we will use your e-mail address and, if applicable, your name to send you information about products, promotions, competitions, and news, as well as for customer satisfaction surveys. You can revoke your consent to receive the newsletter or to the creation of personalized user profiles at any time with effect for the future. You will find the unsubscribe link at the end of each newsletter.

 

Your Rights and Privileges

1. Privacy rights

Under the PIPA, you have the following rights:

• Right to be informed
• Right to access
• Right to rectification
• Right to erasure
• Right to object/opt-out
• Right to Consent
• Right to Redressal

 

Under the GDPR, you can exercise the following rights:

• Right to information
• Right to rectification
• Right to object to processing
• Right to deletion
• Right to data portability
• Right of objection
• Right to withdraw consent
• Right to complain to a supervisory authority
• Right not to be subject to a decision based solely on automated processing.

 

Under the CCPA and the CPRA amendment, you can exercise the following rights:

• Right to Know/Access
• Right to Delete
• Right to Opt-out of Sale
• Right to Non-Discrimination
• Right to Rectification
• Right to Limit Use and Disclosure of Sensitive Personal Information
• Further, California’s “Shine the Light” law (Civil Code Section 1798.83) requires us to respond to requests from California asking about the business’s practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. You may make a request about our collection and disclosure of your Personal Information using the contact details provided.

 

If you have any questions about the nature of the Personal Information we hold about you, or if you wish to exercise any of your rights, please contact us.

 

1. Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

 

1. Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

 

1. Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Information or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

 

1. Complaint to a supervisory authority

You have the right to complain about our processing of Personal Information to a supervisory authority responsible for data protection. The competent data protection authority in Canada is: The Office of the Privacy Commissioner of Canada, 30 Victoria Street, K1A 1H3, Gatineau, Quebec, Canada (www.priv.gc.ca)

 

Changes and Questions

We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Information, we will revise the Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Personal Information. If you would like to contact us regarding our privacy practices for any reason, you can reach us using info@anaghraraoca.com or write to us at the above address.

 

Effective Date

Tuesday, February 14, 2023