Privacy Policy

ABOUT US and THIS PRIVACY POLICY

This privacy policy sets out Thumbelina Limited’s current policies and practices concerning

personal data collected by Thumbelina Limited via the website [https://okfashion.com.mt/ ]

(the ‘Site’). The Site is operated and managed by Thumbelina Limited, a Maltese registered

company bearing company registration number C 46987 and with VAT registration number

MT24052311 (the ‘Company’).

This Privacy Policy complies with the General Data Protection Regulation (Regulation (EU)

2016/679) and the Data Protection Act (Cap 586 of the laws of Malta) on the processing of

personal data and the protection of privacy in the electronic communications sector. Within this

Privacy Policy, the term personal data means any information relating to you (as a ‘data

subject’) the supply of such information means that you can be identified, directly or indirectly,

such as by means of your name and surname, birth date, gender, email address, delivery and

billing addresses, phone number, signature (for delivery or collection of online purchase orders),

payment details, historical purchase information and other factors specific to you.

The Company will improve and update the Site from time to time and this Privacy Policy will as a

result also be updated. You will be notified of any such updates on the Site. This policy was

last updated 30 th March 2020.

The Company is not responsible for the content or privacy policies of other third party websites

which may be linked to the Site.

Your use of this Site or by providing the Company with your personal data through the Site, you

will be bound by the current Privacy Policy.

THE PERSONAL DATA WE COLLECT

The Company collects and processes your personal information when you save a ‘Wish List’ and

make a purchase order through the use of the Site. If you choose not to provide the Company

with your personal data, we will not be in a position to fulfil our services to you including fulfilling

any purchase order and will not deliver the items to you.

The Company also stores the IP address or the location of your device for security and

information purposes. This data is not shared or disclosed to third parties save for the exceptions

as stated below.

WHY WE USE YOUR DATA

In order to process your purchase requests from a Wish List created by You on the Site, certain

personal data attributable to you is required. In general and on a case by case basis, the

personal data the Company will require may include:

(a) Information of your identity

This may include, your name, surname, language and country from which you access the

Site from, contact information etc.

(b) Information of economic and financial nature

This may include your payment option information such as your card data, information of

your purchases, orders and returns history.

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(c) Information of geographical nature

This may include your connectivity data such as if you are accessing the Site via a

mobile device or from a desktop device, your location information etc.

Certain personal data is required from you in order to allow you to access functionality or service

of the Site. The necessary fields will be marked as compulsory because such information is

required to be able to fulfil your orders and deliver the items of choice to you. Should you not

wish to provide such personal data, you may be unable to carry on with the purchase order of the

products.

The services provided by the Company depend on your requests and on the services, products

or functionalities you wish to use from the Site and the Company processes your data for the

following purposes:

(a) To fulfil your orders

If you wish to purchase an item or items from our Site we will request your personal data

to be able to execute and fulfil your order, prepare an invoice for the completion of the

sale contract between you and the Company and manage a request for returns of

purchased if required. This data may also be used to contact you via the contact means

you provide including email, telephone or sms to update you on the status of your

purchase order and other communication related to the purchase order.

(b) To meet requests made to Customer Care

Only personal data which is strictly necessary to manage or resolve a request made by

you will be processed.

The Site stores your browsing data anonymously for analytic and statistical purposes in order

to allow the Company to understand your interaction with the Site however we do not process

personal data to do so.

OUR PARTNERS AND WHO WE SHARE YOUR DATA WITH

The Company requires your personal data to achieve the purposes mentioned in this Privacy

Policy and the Company must give access to your personal data to third parties, both internal

and external, to the Company, in order to allow us to fulfil your purchase order. Therefore, your

personal data may be shared with the following and by requesting a purchase order you are

expressly authorising the Company to disclose and/or transfer such data to the following entities

and for the purpose of executing your purchase orders or requests:

– Financial institutions (such as Revolut);

– Credit institutions (such as any of the local banks registered with the MFSA in Malta);

– Logistic, transport and delivery service providers (such as couriers to deliver your

purchase order);

– Customer support representatives of the Company (to assist you with any queries or

problems you may have in connection with your purchase order);

– Group companies operating under the OK Group.

The Company discloses such personal data only if it is required and permitted to do so by law or

we believe, in good faith, that such action is necessary to:

(a) Comply with legal provisions;

(b) Protect and defend our rights and property;

(c) Protect against the misuse of unauthorised use of the Site and its content; or

(d) Protect the personal safety or property of the users or that of the public.

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DATA RETENTION

The Company will hold and store your personal data for no longer than is necessary bearing in

mind the purpose for which we first collected the data. The Company may however keep your

data for longer if it cannot be deleted for legal or regulatory reasons including:

– Responding to your purchase order requests or queries, complaints or questions;

– Compliance with tax or VAT reporting requirements;

– Maintaining records according to rules which apply to the Company;

– Establishing, bringing or defending legal claims;

– Evidencing that the Company has treated you fairly.

USER DATA RIGHTS

We undertake to keep your personal data confidential and to ensure that you may exercise your

rights. The request to exercise any of your rights may be made to the Data Controller of the

Company in writing at no expense setting out the reason for your request and the right you wish

to exercise.

Access

The Company will provide you with information following any reasonable request for data subject

access. The Company will seek to ensure that the data is kept in an accessible format to

facilitate access by the data subject.

Data Portability

In certain circumstances you have the right to request a copy of your personal information from

the Company or to have that information passed to an organisation of your choice in a format

that can be easily re-used.

Verification and Rectification

You may write to us to request us to rectify the personal data that we hold. You hereby

guarantee that the personal data provided to the Company are true and accurate and undertake

to notify us of any change or alteration of them. Any loss of damage to the Site or the Company,

or to any third party through the provision of erroneous, inexact or incomplete information on the

purchase request form, will be exclusively the responsibility of the user.

Erasure

You may write to us to request us to erase the personal data that we hold to the extent that the

information is no longer necessary for the purpose for which the Company must hold it for

processing or when we are no longer legally allowed to process the information.

Withdraw consent

If you have given us your consent to process your data for any purpose, you have the right to

withdraw such consent at any time.

Right to file a claim

You have the right to file a claim before the responsible data protection regulatory authority in

Malta, that is, the the Office of the Information and Data Protection Commissioner in Malta:

CONTACT DETAILS

If you have any questions in connection with this Privacy Policy or if you wish to make a

complaint about the processing of your personal data, please contact us at any time:

(a) By post at The Director

4

Thumbelina Limited (C 46987)

4, Timber Wharf,

Marsa

Malta

(b) By email on okfashion@okgroup.com.mt

(c) By using the applicable contact form on the Site.

Any method listed above may be utilised in order to contact us in connection with this Privacy

Policy and/or any request concerning your personal data.