Overview
ENTOEN General Trading LLC is strongly committed to respecting the privacy of all persons using our websites and mobile applications ("the Web Sites/Apps") and the protection of any personally identifiable information which we may collect on our Websites/Apps and/ or use as part of our data collection process and/ or which you may choose to share with us in our stores or via telephone, email or otherwise (“the Other Channels”). Such personal information will be collected and/ or used in accordance with the terms and conditions of this Privacy Policy, which is part of and incorporated into the Terms of Use of the Web Site.
Your Express Consent to Collection and Use of Information
ENTOEN General Trading LLC reserves the right to collect such personally identifiable information as, name, address, telephone number, e-mail address, etc., as well as demographic, transactional and profile data such as IP address, internet domain or browser, referrer or user agent information or other relevant information that we use as part of our data collection process on the Web Sites/Apps or via the Other Channels, such as the use of cookies or certain other information you may provide to us, etc. ("Personal Information") as set forth in this Privacy Policy. We hold all such Personal Information on secure servers and treat it as fully confidential.
BY CHOOSING TO ACCESS OUR WEB SITES/APPS AND/OR COMMUNICATING WITH US THROUGH THE OTHER CHANNELS, YOU ARE INDICATING YOUR EXPRESS CONSENT AND AGREEMENT TO THE COLLECTION, TRANSFER, PROCESSING, USE AND STORAGE IN ACCORDANCE WITH THIS PRIVACY POLICY OF ANY PERSONAL INFORMATION WHICH MAY BE OBTAINED FROM YOU AS A RESULT. If you do not agree with any of the terms and conditions set forth in the Privacy Policy, or have any questions, please contact us directly at virgio.policies@entoen.ae, and we will be pleased to assist you with your concerns. By accessing or using the Web Sites/Apps and/or communicating with us through the Other Channels, you grant ENTOEN General Trading LLC a non-exclusive, worldwide, royalty-free perpetual license to use your Personal Information for the purposes set forth herein.
We will not sell your Personal Information to third parties. We may, however, share selected customer information with the following third parties:
• our group companies;
• our franchisors;
• companies such as payment service providers, warehousing service providers and delivery companies for the purposes of processing your payment and managing your order, including delivery and returns;
• concessions and cosmetics partners who are responsible for delivering their products directly to you or providing services, such as makeovers, in our stores;
• purchasers and their advisors following a sale of all or part of our business, so that they can continue to provide services to you;
• third party databases to which ENTOEN General Trading LLC and/or one of our brands subscribes;
• government bodies or other authorities if necessary to comply with regulations or law or to assist with law enforcement, or to protect our property and other rights;
• agencies who help us collate statistics about site traffic, sales, demographics and other commercial information to enable us to tailor the services we provide to you and other customers.
We will retain your Personal Information for as long as it is legally required, and to support the business purposes for which it was obtained - we will then dispose of it promptly and securely.
Depending on your country of residence, we may transfer your Personal Information both inside and outside the United States. When we transfer your Personal Information, we ensure a similar degree of protection is afforded to it by ensuring we only transfer it to countries that are deemed to provide an adequate level of protection for personal data and under contractual terms that provide appropriate data protection.
You have the following rights which you may exercise in relation to the Personal Information we process about you:
to access a copy of your Personal Information;
to require us to correct inaccurate Personal Information;
to require us to delete your Personal Information;
to restrict our use of your Personal Information;
to object to our use of your Personal Information.
Where you wish to exercise any of these rights, you must first verify your identity to our satisfaction.
Social Media Data Collection
When using the social media login on our websites and mobile apps, we capture the following details:
First Name & Last Name We capture the First & Last Names to display them under the Profile Section.
Profile Picture Any image used as a profile picture is not stored on our servers, Will only be used as a customer display picture.
Email Address Any email address used is captured to display under the Profile Section. We also use it to send through our optional promotional campaigns and/or assisting the customer in case of any queries they might have with the websites/apps.
Facebook/Google ID The social media ID is captured to only identify that the user has logged into the websites/apps using their respective login(s). If a customer wishes to delete these details that we’ve captured, they can reach out to our Customer Care team here by submitting a request or through live chat which will be processed within 24 hours.
Cookies
As part of our normal data collection process on our Web Sites, the Web Site may deposit "cookies" in your device in order to identify you and/ or as a means of tracking the validity of sessions as well as enhancing your browsing experience. Cookies are small pieces of data that a website automatically sends to your computer, tablet or mobile phone while you are viewing the website.
We use two types of cookies on our website:
• “Session” cookies, which are used to allow you to:
• carry information from one page of our website to another without having to re-enter information; and
• access stored information when you are logged in to your online account.
• “Persistent” cookies, which allow us to offer you tailored content on our website by helping us to remember:
• any personal information that you have provided on previous visits to our website;
• the number of visits that you have made to our website; and
• your preferences
Third parties are not able to identify customers using cookies.
We also reserve the right to use an outside advertising company to display ads on our Web Sites. These ads may also contain cookies. While we may use cookies in other parts of our Web sites, cookies received with banner ads or from other third-party sources may be collected by any such third-party companies, and we do not have direct access to or control over such processes. No cookies used by ENTOEN General Trading LLC are stored permanently on your device. All cookies are automatically removed from your device either when you close your browser or your session times out.
By using our Websites, you agree to the placing of cookies on your device. However, if you do not want to receive a cookie from our Website, you may set your browser to refuse cookies or to notify you when you receive a cookie (to find out how to do this, please consult your browser’s help section). If cookies aren’t enabled on your device, it may limit your enjoyment of the Web Site.
To enable cookies:
If you're not sure of the type and version of web browser you use to access the Internet:
For PCs: click on 'Help' at the top of your browser window and select the 'About' option
For Macs: with the browser window open, click on the Apple menu and select the 'About' option
If you'd like to learn more about cookies in general and how to manage them, visit aboutcookies.org.
If you'd like to opt out of cookies, please go to the Network Advertising Initiative website.
Please note that we're not responsible for the content of external websites.
Protection of Personal Information Against Third-Party Access or Use
We store all Personal Information on a secure server and we seek to use procedures designed to protect Personal Information from accidental or unauthorised access, destruction, use, modification or disclosure. We will seek to ensure that your Personal Information is kept confidential and secure in accordance with this Privacy Policy, and that the appropriate technical and organisational measures to prevent unlawful or accidental destruction, accidental loss, unauthorised disclosure or access or other unlawful forms of processing are implemented. Although we will strive to take commercially reasonable security precautions regarding all Personal Information, visitors or users to the Web Sites/Apps acknowledge and agree that ENTOEN General Trading LLC does not control the transfer of information or data via the Web Sites/Apps or over any other electronic facilities or media.
Changes to Privacy Policy
Since we are constantly making changes and upgrades to our systems and services in order to better serve you, we anticipate updating this Privacy Policy from time-to-time. Therefore, we reserve the right to revise or alter the content of this Privacy Policy in any manner and at any time, without notice. Your subsequent and/ or continued use of the Web Sites/Apps and the other Channels following a posting of changes to the Privacy Policy will constitute your acceptance of such changes.
Third Party Web Sites
You may be able to access certain third-party websites through links on our Web Sites/Apps. We are not, however, responsible for any other websites, their respective privacy policies or other content nor how they treat information about their visitors or users. We strongly advise you to check their privacy policies to find out how they are treating your Personal Information.
All credit/debit cards details and personally identifiable information will NOT be stored, sold, shared, rented or leased to any third parties.
No Warranty
YOU UNDERSTAND THAT ENTOEN General Trading LLC DOES NOT PROVIDE ANY WARRANTY, GUARANTEE OR REPRESENTATION OF ANY KIND CONCERNING OUR ABILITY TO CONTROL, COLLECT, CORRECT, ACCESS, PROCESS, USE, STORE, PROTECT OR TRANSFER ANY PERSONAL INFORMATION OR CONCERNING THE EXISTENCE OR EFFECTIVENESS OF ANY SECURITY MEASURES UNDERTAKEN BY US. YOU AGREE THAT ENTOEN General Trading LLC WILL NOT BE LIABLE FOR ANY CLAIMS, LOSSES, OR DAMAGES OF ANY KIND WHATSOEVER WHICH MAY RESULT FROM THE ACCESS, DISCLOSURE, USE OR MODIFICATION BY ANY PARTY NOT AUTHORISED OR AUTHORISED BY US, OR THE INTRODUCTION OF VIRUSES, WORMS, OR OTHER HARMFUL ELEMENTS INTO THE SYSTEM AND THEIR POSSIBLE EFFECTS ON YOUR PERSONAL INFORMATION.
Limitation of Liability
IN NO EVENT WILL ENTOEN General Trading LLC, ITS AFFILIATES, PARTNERS, AND THEIR RESPECTIVE EMPLOYEES, OFFICERS, DIRECTORS OR INSURERS BE LIABLE TO YOU OR TO ANY OTHER PERSON FOR ANY COSTS, DAMAGES (INCLUDING ANY SPECIAL, INCIDENTAL, EXEMPLARY, INDIRECT OR CONSEQUENTIAL DAMAGES), OR LIABILITY OF ANY NATURE, ARISING OR RESULTING FROM THE COLLECTION, USE, TRANSFER, PROCESSING OR STORAGE OF PERSONAL INFORMATION OBTAINED BY US AND RESULTING FROM YOUR ACCESS TO AND USE OF THE WEB SITES/APPS OR COLLECTED VIA THE OTHER CHANNELS.
Governing Law; Jurisdiction
This Privacy Policy will be governed by the laws of the relevant country in which your Personal Information is first registered with ENTOEN General Trading LLC (“the Applicable Territory”). For the avoidance of doubt, the relevant Applicable Territory may only include those countries in which ENTOEN General Trading LLC operates stores or the Websites/Apps as the case may be. The exclusive jurisdiction for any claim, action or dispute with ENTOEN General Trading LLC under this Privacy Policy will be in the appropriate courts of the Applicable Territory.
TERMS & CONDITIONS #Virgio - Ameyam Enterprise Private Limited
By responding to our request with the hashtag #Virgio you agree to the following:
You grant Virgio, through Ameyam Enterprise Private Limited, and ENTOEN, through ENTOEN General Trading LLC WLL, (together hereinafter referred to as “Virgio” a non-exclusive, royalty free worldwide license to use any photos and moving content in relation to which you have responded #Virgio, hereinafter referred to as “Photos and Moving Content” for its marketing and/or in its advertising, including the online store, emails, social media – Virgio channels and paid social media, store materials and other customer communications. Virgio may use, reproduce, distribute, combine with other materials, alter and/or edit your Photos and Moving Content in its sole discretion.
You hereby represent and warrant that (i) you own all rights in and to your Photos, (ii) you have permission from any person(s) appearing in your Photos to grant the rights herein, and (iii) Virgio’s use of your Photos will not violate the rights of any third party or any law. You hereby release and discharge Virgio from all and any obligation to pay you for any use of your Photos and any of the intellectual property rights contained therein in connection with the uses described above; and You hereby release, discharge and agree to hold Virgio and any person acting on Virgio’s behalf harmless from all claims, demands, and liabilities whatsoever in connection with use of the Photos as described above.
PRIVACY NOTICE - Virgio
Data privacy is very important for Virgio, and we want to be open and transparent about how we process your personal data.
We therefore have a policy that establishes how your personal data will be processed and protected.
Who is the controller of your personal data?
The Indian company, Ameyam enterprise private limited (“Virgio”), is the controller of the personal data you submit to us, and it is responsible for your personal data under applicable data protection law.
Ameyam Enterprise Private Limited
168, 19th Main Rd, Sector 4, HSR Layout, Bengaluru, Karnataka 560102
India
Why do we use your personal data?
We want to share and inspire different ways of wearing Virgio products. We will use your personal data to share user-generated content by uploading the pictures you submit to us on all our platforms.
What types of personal data do we process?
We will process the following categories of personal data:
Instagram account name
photo
video
On what legal grounds may we process your personal data?
We need to process your personal data to fulfill the service of Virgio.
Where do we store your data?
Our website is built on Shopify, a leading e-commerce platform that provides a secure and reliable environment for managing your data. Shopify stores your data on its secure servers located in data centers within the United States and other jurisdictions as necessary to provide their services. Shopify is committed to safeguarding your data with industry-standard security measures, including encryption and regular security audits.
We rely on Shopify's robust security protocols to ensure your personal information is protected against unauthorized access, alteration, or disclosure. Additionally, our internal data management practices align with Shopify's standards to maintain the confidentiality and integrity of your data.
For more details on Shopify's data storage and security practices, you can refer to Shopify's Privacy Policy
Who can access your data?
Your data may be shared within the Virgio group (for details on the companies within the Virgio group. We never pass on to, sell to or swap your data with third parties outside the Virgio group for marketing purposes.
Data that is forwarded to third parties is only used to provide you with our services. You will find categories of third parties under every specific process below.
What are the legal grounds for processing?
For every specific process from personal data we collect from you, we will inform you about whether the provision of personal data is statutory or required to enter a contract, whether it is an obligation to provide the personal data and the possible consequences if you choose not to.
What are your rights?
Right to access:
You have the right to request information about the personal data we hold about you at any time. You can contact Virgio, and we will provide you with your personal data via email.
Right to portability:
Whenever Virgio processes your personal data by automated means either based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal data you have submitted to us.
Right to rectification:
You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed.
If you have an Virgio account or are an Virgio member, you can edit your personal data in your account and on membership pages.
Right to erasure:
You have the right to erase any personal data processed by Virgio at any time except for the following situations:
you have an ongoing matter with Customer Service
you have an open order which has not yet been shipped or partially shipped
you have an unsettled debt with Virgio, regardless of the payment method
you are suspected of misusing or have misused our services within the past four years
if you have made a purchase, we will keep the personal data linked to your transaction for bookkeeping purposes.
Your right to object to processing based on legitimate interest:
You have the right to object to processing of your personal data that is based on Virgio's legitimate interest. Virgio will not continue to process the personal data unless we can demonstrate either legal claims or legitimate grounds for the process which overrides your interest and rights.
Your right to object to direct marketing:
You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes.
You can opt out of direct marketing by the following means:
•following the instructions in each marketing email
•editing the settings of your Virgio account
Right to restriction:
You have the right to request that Virgio restrict the processing of your personal data under the following circumstances:
•if you object to processing based Virgio’s legitimate interest, Virgio must restrict all processing of such data pending the verification of the legitimate interest.
•if you have asserted that your personal data is incorrect, Virgio must restrict all processing of such data pending the verification of the accuracy of the personal data.
•if the processing is unlawful, you may oppose the erasure of personal data and instead request the restriction of the use of your personal data.
•if Virgio no longer needs the personal data, but you require the data to defend legal claims.
How can you exercise your rights?
We take data protection very seriously; therefore, we have dedicated customer service personnel available to handle your requests in relation to your rights stated above. You can always reach them at virgio.policies@entoen.ae.
Data Protection Officer:
We have appointed a Data Protection Officer to ensure that we continuously process your personal data in an open, accurate and legal manner. You can contact our Data Protection Officer at virgio.policies@entoen.ae. Write DPO in the Subject line.
Right to complain to a supervisory authority:
If you consider Virgio to be processing your personal data incorrectly, you can contact us. You also have the right to submit a complaint to a supervisory authority.
Internal Usability
Consent
To enable our systems to recognize your browser or device and to provide the Application to you, we use cookies. For more information about cookies and how we use them, please read our Cookies Notice.
Controlling Application Functionality
Location Services - In order to use certain Application functionality, you must enable "Location Services" in the App - that is disabled by default in the Application - by going to your “Settings”.
Alternatively, you can set the permissions in your mobile device to allow communication of this information. More information about adjusting location services on iOS devices may be found here, and additional information on managing an Android device’s location settings may be found here.
Personal data collected using GPS or other location-based technologies is shared with us through the App on an optional basis.
User Responsibility
Email Communications, Push Notifications, and In-App Messages
The Application allows all users to set preferences for receiving promotional email communications from Virgio Membership, receiving push notifications on your device, and receiving inbox messages. Email communications can be adjusted by you going to “Settings” > “Communication Preferences” > “Email Newsletter”. Additionally, In-App messages can be adjusted also at “Settings” > “Push Notifications” > “Enable news updates from Virgio”.
Promotional Communication Choices
You have control over your promotional communications preferences, mobile application functionality, cookie settings, and interest-based advertising preferences. You can opt out of receiving promotional emails and mailings by informing us of your preference at the time you sign up for a Virgio Membership account, by modifying your promotional preferences online in your account’s profile management section, or by following the “unsubscribe” instructions in the promotional emails we send you. Similarly, you may opt in to receive text messages, telephone calls and mailings.
Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your Virgio accounts or purchases.
6. Your Data Protection Choices and Rights
Under certain circumstances, you have the right to:
Request Access
to obtain from us confirmation in writing as to whether or not personal data relating to you is being processed and information to the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipients to whom the personal data are disclosed.
Request Rectification
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request Erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Request Object to processing
where your personal data is processed for direct marketing purposes, including profiling to the extent that it is related to such direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the Restriction of processing
that enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Personal Data Portability
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Exercise your Rights
If you wish to exercise any of the rights set out above, please contact, at virgio.policies@entoen.ae
Lodge a Complaint
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint if you contend that there has been a contravention of the data protection legislation or an alleged breach of your rights under the law with the correspondent supervisory authority described here. We would appreciate the opportunity to first address your concerns and would welcome you directing an inquiry first to us here.
7. How We Protect Your Personal Data
We protect your information using technical, physical, and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure, or modification of your information. When you transmit highly sensitive information (such as a credit card number) through our website or in one of our mobile applications, we encrypt the transmission of that information using the Secure Sockets Layer (SSL) protocol. You are responsible for protecting your password(s) and maintaining the security of your devices.
8. Retention and Disposal of Your Personal Data
We store personal data as needed to accomplish the purposes identified in this Statement and to meet legal requirements, including record retention, resolving disputes, and enforcing our agreements. Our retention of your personal data is governed by applicable law. This storage period may extend beyond the term of your relationship with us.
As a general rule, we keep your personal data for only as long as it is needed to complete the purpose for which it was collected or as required by law. We may need to keep your personal data for longer than our specified retention periods to honor your requests or to comply with legal, regulatory, accounting, or other obligations. Under the State of Kuwait the Law No.68 of 1980 Commercial Code is for business to keep their commercial records for ten (10) years and for business correspondence and other documents for five (5) years after the termination of the respective related contractual relationship between you and us, if applicable. When personal data is no longer needed, or in any event, after legal authority to retain it has expired, personal data will be destroyed, in accordance with local law and pursuant to procedures established in relation to the relevant system or process.
9. Children
We do not intend for our websites or online services to be used by anyone under the age of 18 however we cannot prevent certain users, including children, from fraudulently representing their age in order to gain access to the Site or an App. If you are a parent or guardian and believe we may have collected information about your child, please contact us immediately as described in the “Contact Us" section of this Statement. For more information, please see our Terms of Use.
10. International Transfers
Your personal data may be transferred to, stored, and processed by Virgio in a country other than the one in which it was collected. It may also be processed by staff operating outside the UAE who works for Enten in the State of UAE or India, Virgio or for our third-party service providers. In such cases, we will take appropriate steps to ensure an adequate level of data protection of the recipient as required under the correspondent data protection regulation, including by putting in place standard contractual clauses that have been approved by the Supervisory Authority. You may obtain a copy of these clauses by directly contacting us at virgio.policies@entoen.ae
11. Contact Us
We welcome your questions, comments, and concerns about privacy. EntoenCustomer Care can be contacted here.