Privacy Policy

Privacy policy

BACKGROUND:

Ornela Freimane Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://www.ornelafreimane.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed by your use of Our Site.

 1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:  


“Account”  means an account required to access and/or use certain areas and features of Our Site;

“Cookie”  means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;


2. Information About Us

Our Site is owned and operated by Ornela Freimane Limited, a limited company registered in England under company number 13491383.

§ Registered address: 30 Morecambe Close, Hornchurch, England, RM12 5LU; and

§ Postal address: 30 Morecambe Close, Hornchurch, England, RM12 5LU.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

 

4. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

 

6. What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table.

Please also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policy https://www.ornelafreimane.com/privacy-policy/. 


Data Collected

How We Collect the Data

Identity information including your name, address and post code.

You provide this to us when you purchase an order or create an account.

Contact information including your email address, phone number.

You provide this to us when you purchase an order or create an account.

Payment information including card details, total spend, average order value and bank account numbers.

You provide this to us when you purchase an order.

Profile information including username, last active, preferences, interests, login details, purchase history, date registered.

You provide this to us when you purchase an order or create an account.

Technical information collected by third parties including profile information, contact information, IP address, location, genre and internet browser information.  

Google Analytics tracking and Facebook page plugin and like button cookies.



7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we use your personal data, and our lawful bases for doing so:

What We Do

What Data We Use

Our Lawful Basis

Registering you on Our Site.

Name, address and email address.

Legitimate interests to fulfil a contract.

Providing and managing your Account.

Name, address and email address.

Legitimate interests to fulfil a contract.

Providing and managing your access to Our Site.

Profile information including username, last active, preferences, interests, login details, purchase history, date registered.

Legitimate interests to fulfil a contract.

Personalising and tailoring your experience on Our Site.

Technical information collected by third parties including profile information, contact information, IP address, location, genre and internet browser information.

Legitimate interests to fulfil a contract.

Administering Our Site.

Technical information collected by third parties including profile information, contact information, IP address, location, genre and internet browser information.

Legitimate interests to fulfil a contract.

Administering our business.

Identity and contact information including your name, email, address and post code.

Legitimate interests to fulfil a contract.

Supplying our goods to you.

Identity and contact information including your name, email, address and post code.

Legitimate interests to fulfil a contract.

Managing payments for our services.

Payment information including card details, total spend, average order value and bank account numbers.

Legitimate interests to fulfil a contract.

Personalising and tailoring our products/services for you.

Profile information including username, last active, preferences, interests, login details, purchase history, date registered.

Legitimate interests to fulfil a contract.

Communicating with you.

Address or email address.

Legitimate interests to fulfil a contract.

Supplying you with information by email or post that you have opted-in-to (you may opt-out at any time by contacting us by post or email.

Address or email address.

Legitimate interests to fulfil a contract.



With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or post with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties (including Google, Cookie Law Info and PayPal) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We use the following automated system for carrying out certain kinds of decision-making. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

 

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):


Type of Data

How Long We Keep It

Identity Information including your name.

Until you submit a request to remove.

 

Contact information including your email address and address.

Until you submit a request to remove.

 

Payment information including card details and bank account numbers.

Until you submit a request to remove.

 

Profile information including username, last active, preferences, interests, login details, purchase history, date registered.

Until you submit a request to remove.

 

Technical information collected by third parties including profile information, contact information, IP address, location, genre and internet browser information.  

Until you submit a request to remove.



9. How and Where Do You Store or Transfer My Personal Data?

We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

 

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

 

11. How Can I Control My Personal Data?

3.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails, at the point of providing your details and by managing your Account).

3.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

 

12. Can I Withhold Information?

You may access Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy https://www.ornelafreimane.com/privacy-policy/.

 

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within less than one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

The following first-party Cookies may be placed on your computer or device:

Name of Cookie

Purpose

Strictly Necessary

Cookielawinfo-checkbox-analytics 

This cookie is set by GDPR Cookie Consent plugin. The purpose of this cookie is to check whether or not the user has given the consent to the usage of cookies under the category ‘Analytics’.

Yes

Cookielawinfo-checkbox-functional 

The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category “Functional”.

Yes

Cookielawinfo-checkbox-necessary 

This cookie is set by GDPR Cookie Consent plugin. The purpose of this cookie is to check whether or not the user has given the consent to the usage of cookies under the category ‘Necessary’.

Yes

Cookielawinfo-checkbox-others 

This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Other”.

Yes

Cookielawinfo-checkbox-performance 

This cookie is set by GDPR Cookie Consent plugin. The purpose of this cookie is to check whether or not the user has given the consent to the usage of cookies under the category ‘Performance’.

Yes

svSession

When a user in SiteMinder protected realm is authenticated, Web Agent generates an SMSESSION. The SMSESSION Cookie represents a user session. SMSESSION Contains following:

· ATTR_USERDN. The user’s distinguished name.

· ATTR_SESSIONID. The session ID returned from the login call.

· ATTR_USERNAME. The user’s name.

· ATTR_CLIENTIP. The IP address of the machine where the user initiated a request for a protected resource.

· ATTR_DEVICENAME. The name of the agent that is decoding the token.

· ATTR_IDLESESSIONTIMEOUT. Maximum idle time for a session.

· ATTR_MAXSESSIONTIMEOUT. Maximum time a session can be active.

· ATTR_STARTSESSIONTIME. The time the session started after a successful login.

· ATTR_LASTSESSIONTIME. The time the current session was last accessed.

Yes

Viewed_cookie_policy

To store if a message has been shown.

Yes


 and the following third-party Cookies may be placed on your computer or device:

Name of Cookie

Provider

Purpose

1P_JAR 

Google

Based on recent searches and previous interactions, custom ads are shown on Google sites.

ANID

Google 

The “ANID” cookie is used for advertising served across the web and stored in google.com.

CONSENT

Google 

Stores visitors’ preferences and personalizes ads.

NID

Google 

The “NID” cookie is used to play YouTube videos embedded on the website.

_Secure-3PAPISID

Google

Used by us for targeting purposes to build a profile of the website visitor’s interests in order to show relevant & personalised Google advertising. 

_Secure-3PSID

Google

Builds a profile of website visitor interests to show relevant and personalized ads through retargeting.

_Secure-3PSIDCC

Google

This cookie is used to deliver ads more relevant to you and your interests.

Cookielawinfo-checkbox-advertisement

Cookie Law Info

This cookie is set by GDPR Cookie Consent plugin. The purpose of this cookie is to check whether or not the user has given their consent to the usage of cookies under the category ‘Advertisement’.

Google-analytics

Google

This cookie is used for tracking the user’s behaviour on the website to understand the website’s performance and reach.

WELCOME_ASYNC

X-PP-ADS

_gcl_au

cookie_check

cookie_prefs

d_id

enforce_policy

fn_dt

id_token

login_email

rmuc

ts

ts_c

ui_experience

x-pp-p

x-pp-s

Paypal

Paypal cookies are necessary for making a safe transaction through PayPal. These cookies are used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website.

Facebook cookies

Facebook

Page plug in and like button cookies.




In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your computer or device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: info@ornelafreimane.com

Postal address: 30 Morecambe Close, Hornchurch, England, RM12 5LU

 

16. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy was last updated in November 2021.