Introduction & General Terms
These online services are operated by Destino (“we”, “us” or “our” in this policy), a website that provides:
- daily beauty and grooming news, trends, inspiration, advice and, from time to time, third party brand promotions (via the website, email newsletter and social media channels);
- expertly-curated spa and city guides, as well as products, to be purchased via affiliate networks; and
- health, beauty, wellness and grooming profiles
collectively the (“Services”).
Destino is committed to protecting and respecting your privacy. This policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data you supply through our website is processed, we are the “data controller” for the General Data Protection Regulation 2016/679.
This policy explains the following:
- What information we may collect about you
- How we will use information we collect about you
- Whether Destino will disclose your details to anyone else
- Your choices and rights regarding the personal information you have provided to us.
Our website contains hyperlinks to websites owned and operated by third parties. These third party websites may have their own privacy policies and we recommend you review them. They will govern the use of personal information you submit or which are collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of them is at your own risk.
What information will Destino collect about me?
We collect and process the following information via the following means, which may include your personal data.
Information provided by you when using our services
You may give us information about you when:
1) subscribing to our email newsletter
2) entering into a competition or sampling campaign on our website; and/or
This can include your name, age, gender, address, telephone number, profession, location, e-mail address and password (“Personal Data”).
The website may, from time to time, collect sensitive Personal Data through ad hoc surveys which may include information relating to health.
We may also collect information that you provide to us voluntarily. For example, when you communicate with us via emails, or contact form on our website.
Your Browsing Activities
This incudes collecting information relating to the web address that you arrive from or click through to, pages viewed, page response times, download errors, the length of time you spend on certain pages, page interaction information such as scrolling, clicks, wagers, and methods used to browse away from our pages.
How you use our Services (Analytics)
We may collect technical information about your computer and/or device that may identify, including your IP address, operating system, device type, browser type, device settings, location, time-zone and browser plug-in details.
The platform may collect the above information from third parties such as Google Analytics and Facebook (subject to you permitting Facebook to share such information with third parties).
In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
How we will use information we collect about you and who we will share it with in providing the Services to You
We may legally use and retain the data we collect about you, including your Personal Data, where we need to perform the contract with you, such as:
– Managing our relationship with you;
– Notifying you about changes to our terms and conditions or services;
– Responding to any enquiries you may have;
– When you enter into a competition, promotion or survey on our website.
We may also legally use and retain the Personal Data you provide to us to pursue our legitimate interest of providing our Services to you, such as:
– Providing tailored and relevant content to you; and
– Obtaining user reviews and performing market research
Prevent Fraud and Illegal Activity
We process personal data for the legitimate interests of ensuring that use of our online services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and to enforce our legal rights and comply with our legal obligations.
Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.
Marketing and Advertising
We use various forms of marketing to provide you with promotional materials about our Services in association with our third party brands.
We may process your contact information that you provide to us (either via our website, or through use of our services), if you have provided your consent for this or when such consent is not required by law, for the purposes of marketing in accordance with our legitimate interest of sending you information about our products and services.
We may share your information with third party brands for the purposes of their own marketing if you have explicitly consented to this via our website. We will not process your information or pass your information on to third parties for the purposes of such marketing unless you give your consent.
Newsletters: We may send you newsletter emails about products or services which are similar to or related to those available via our online services. If you would like to be removed from this mailing list, please contact us at email@example.com or click unsubscribe at the bottom of each newsletter.
Affiliate Marketing: From time to time we use affiliate networks and tracking links to offer you access to products and services hosted on third party websites. These providers measure effectiveness of our marketing campaigns by recording whether transactions are completed by people we refer to those sites. We may share this information for our legitimate interest of carrying on our business and generating advertisement revenue.
To Understand how our Services are used
We process information to understand how visitors use our website and to compile statistical reports regarding that activity.
This processing is necessary for us to pursue our legitimate interests of improving the functionality of our platform, improving our Services, and providing a better experience to our users.
We may share aggregated statistical data about your use of our platform with third party advertisers in order to determine the kind of people viewing our adverts. This data is aggregated and anonymous, and not personally identifiable data.
By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser. For further information about cookies, please see www.allaboutcookies.org, and how to adjust your browser settings here: www.allaboutcookies.org/managecookies.
We use third party analytics providers, such as Google Analytics, on our website for anonymous reporting of website usage. If you would like to opt-out of Google Analytics monitoring your behaviour on our website, please use this link: https://tools.google.com/dlpage/gaoptout/
Consumer Control & Opt-Out Options
If you do not wish to receive promotional or other marketing material from us or third parties then you can opt-out by clicking unsubscirbe at the bottom of each email newsletter or contacting us at firstname.lastname@example.org.
Your rights in relation to personal data which we process relating to you
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest.
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
– you consented to Destino processing the personal data, and have withdrawn that consent;
– Destino no longer needs to process that personal data for the reason it was collected;
– Destino is processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Destino, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
– the personal data was unlawfully processed;
– you need the personal data to be deleted in order to comply with legal obligations;
– the personal data is processed in relation to the offer of a service to a child.
Obtain a machine readable copy of your personal data, which you can use with another service provider
If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
If you are unhappy with the way we are processing your personal data, please let us know.
If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
We do not use the Application to knowingly solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at email@example.com. We will delete such information from our files within a reasonable time.
We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
We will notify you of any changes to this policy by email, notice on the website or account message.
International Data Transfers
Where we transfer your data outside of the EEA, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to firstname.lastname@example.org.