1. Data Controller and Data Protection Officer
Aburi has appointed a data protection officer who can be contacted at the following e-mail address: firstname.lastname@example.org
2. Types of processed data
We collect and store certain personal data about you (i.e., information which may directly or indirectly identify you in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity; (“Personal Data”) through the Site. We may request that you submit Personal Data in certain instances, such as when you sign up as a member, use a special request form to order products and services offered by us, submit comments or questions, request information, participate in a promotion or utilise other features or functions of a Site. Aburi will not collect Personal Data from your visits to our Sites unless you provide it to us voluntarily, except for some items of Personal Data collected by information systems and programs used for the operation of the website, transmission of which is inherent in the use of Internet communication protocols (e.g., IP addresses) and will not require you to provide more information than is necessary to participate in the activities on our Sites. If you opt not to provide us with Personal Data (Apart from Personal Data referred to the use of Internet communication protocols which is typically collected when you request to visit a website), you can still access our Sites, however you will be unable to participate in certain promotions, create login credentials in order to use certain functionalities on the Sites, activate or use a service, have a purchase order fulfilled or receive product information.
Moreover, when you connect to a Site, there are certain Personal Data (e.g. IP address, purchase preferences, profiling features) that may include identifiers that may permit us to serve tailored ads to your device, along with technical, non-Personal Data which itself may not identify any individual (“Non-Personal Data”, e.g.,, internet browser type) that may be collected and stored through the use of “cookie” and other tracking technologies. In addition, other parties such as advertising partners and analytics providers may collect information about your online activity over time and across the Sites, with your informed consent. This information assists us to update a Site so that it remains interesting to our visitors and contains content that is tailored to visitors’ interests. If you disable cookies, we may be unable to optimise your visit to a Site and certain features on the Site may not be available.
3. Purposes, legal basis of the processing and possible consequences of failure to provide Personal Data
A. To take steps at your request prior to entering into a contract (e.g. to respond to your questions and comments; to fulfil your requests; to communicate with you about your activities on a Site);
B. To perform a contract to which you are a party (e.g. to provide you with access to certain areas and features on a Site; to fulfil your order in connection with shopping or commercial services offered on a Site; to provide customer service);
C. To investigate suspected fraud, harassment, physical threats, or other violations of any law, rule or regulation, the rules or policies of a Site, or the rights of third parties; or to investigate any suspected conduct which we deem improper;
D. To comply with a legal obligation to which Aburi is subject to (e.g. for disclosures required by law, regulation, or court order);
E. For the purpose of or in connection with legal proceedings, establishing, defending, or exercising legal rights;
F. to send advertising or direct sales materials or to conduct market research, carry out data analytics or deliver commercial communications, by means of electronic tools (SMS, email, social network), whether automated (calls without an operator) or not automated (snail mail and calls with an operator), in compliance with appropriate legal grounds;
G. to communicate your Personal Data to selected third-party advertising partners for their own marketing purposes in compliance with appropriate legal grounds;
The provision of Personal Data for the purposes from A to E above is voluntary, however, any refusal to provide such data may not allow Aburi to enter into a contract with you, reply to your requests, fulfil your purchased order and to comply with legal obligations to which Aburi is subject to.
The provision of Personal Data for the purposes described in sections F and G above is also voluntary; failure to provide such Personal Data, or objecting to the relevant data processing on appropriate grounds
relating to your particular situation, may prevent Aburi to send advertising or direct sales materials or to conduct market research, carry out data analytics or deliver commercial communications, and/or to communicate your Personal Data to selected third-party advertising partners for their own marketing purposes. We may still contact you for administrative purposes, such as confirming a purchase order or request further requests you’ve made.
Your Personal Data may be disclosed, in close relation to the purposes specified above, only to:
subjects necessary for order fulfilment, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analysing data and providing marketing assistance, processing credit card payments, and providing customer service, which typically process Personal Data on behalf of Aburi as data processors
persons authorised by Aburi to process Personal Data, that are committed to/ or under an appropriate statutory obligation of confidentiality (Aburi’s employees and affiliates);
law enforcement agencies and public authorities when so required by the applicable law or in the good faith belief (e.g., to conform to the edicts of the law or comply with legal process served on Aburi; to protect and defend the rights or property of Aburi, this Site; or, to act under exigent circumstances to protect the personal safety of users of Aburi, its Sites or the public); third-party commercial partners for their own purposes only in compliance with appropriate legal grounds.
Aburi will process your Personal Data only for the duration necessary to achieve the purposes described in section 2. Regarding the purposes described in section 2.F and 2.G, your Personal Data will be processed until you will exercise your right to object to or to restrict the processing. Apart from the above, Aburi will retain your Personal Data for a period of time necessary or permitted to comply with the applicable data protection law.
6. Your rights
Aburi informs you that, pursuant to and to the extent allowed by the applicable law, you have the right to request from Aburi access to and rectification or erasure of Personal Data or restriction of the processing concerning your Personal Data or to object to relevant processing activity, and to lodge a complaint with the competent supervisory authority. You also have the right to know the recipients or categories of recipient to whom your Personal Data have been or will be disclosed, in particular recipients in third countries.
7. Links to other Sites
A Site may contain links to other websites that are not owned, operated, or maintained by Aburi. When you leave a Site you should note and read the terms and conditions and privacy policies of each and every website that you visit. You should also independently assess the authenticity of any website which appears or claims that it is one of our Sites (including those linked to through an email). Despite any links that might exist on a Site, unless expressly stated otherwise, we do not control, recommend, or endorse and are not affiliated with these websites or their content, products, services, or privacy policies. Downloading material from certain websites may risk infringing intellectual property rights or introducing viruses into your computer system.
8. Protection of Children’s Privacy
Aburi takes the protection of children’s privacy seriously. We operate the Sites in compliance with all applicable laws in the jurisdiction set forth below. We do not collect Personal Data from any person under the legal age of eighteen (18). If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Data without his/her parent/guardian’s consent and we will not authorise/provide such person a membership. Without such consent, though, the child may not be able to participate in certain activities. A parent/guardian can review, remove, change, or refuse further collection or use of their child’s Personal Data by contacting us via: email@example.com (please provide child’s name, address, and e-mail address).
9. Security Practices
The security of your Personal Data is very important to us. We have put in place appropriate physical, electronic, and managerial procedures to safeguard the information we collect. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us or information stored on a Site or our servers will be completely free from unauthorised access by third parties, such as hackers. Your use of a Site demonstrates your assumption of this risk. To the fullest extent permitted by the applicable law, we disclaim all liability and responsibility for any damages (including, but not limited to, any and all direct, special, indirect, consequential, or punitive loss or other damages of any kind, whether in contract (including fundamental breach), tort (including negligence), or otherwise) that you may suffer due to any loss, unauthorised access, misuse, or alteration of any information you submit to a Site.
10. Governing Law/Jurisdiction
11. Transfer of Assets
During the course of our business, we may sell or purchase assets. If another entity acquires Aburi or all or substantially all of our assets, Personal Data and Non-Personal Data that we have collected about the users of the Sites may be transferred to such entity. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties.
14. Contact Information