Privacy Policy

Fantastic S.A. (Splink.) is an entity registered in Portugal with NIF/VAT PT516185128 with its registered office located at: Avenida Defensor de Chaves nº2B, 1000-109 Lisboa (Portugal).

Help us create a better Splink for you.

To create a better Splink for you, we need your help. You can do this by providing us with various kinds of information to help us serve you better, and ultimately improve Splink for everyone. In the remaining portions of this document, you will find an explanation of the reasons we request certain information from you, as well as details about how we obtain and use that information.



A. INTRODUCTON
This Privacy Policy governs the personal data which we will collect from you when you access our Services in the manners stated below, and the use and disclosure by us of such personal data in accordance with the Portugal Personal Data Protection Act 2012 (“PDPA”).

This Priva applies to personal data in our possession and/or under our control. By using our Services or otherwise interacting with us, you consent to our processing of your personal data in accordance with this Privacy Policy.

If you are under the age of 18, please seek relevant consent before using our Services. By using our Services, you confirm to us that you are 18 years old or over.

In this Privacy Policy, “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data, or (b) from that data and other information to which we have or are likely to have access. This includes your name, postal address, email address, date of birth, telephone numbers, etc.

Making sure that your personal information is secure is very important to Splink. We are committed to protecting and safeguarding your personal data.

B. COLLECTION OF PERSONAL DATA

We collect your personal information from a variety of sources (our “Services”):

I. Customer queries

In order for a customer relations representative to respond to your questions or concerns, we may require certain personal information from you such as your name, email address, PayPal name and email address and/or telephone number. We will thus collect any information contained in any correspondence between you and us. For example, if you contact us via the website, or report a problem to us by email, telephone, or post, we may keep a record of that correspondence. This information is used to answer your questions as completely and thoroughly as possible.

II. VIPs

When you create an account on our website, you will automatically be a member of our VIP Program (known as Splink Assembly). We will collect any personal data you provide to us when you register for an account with us, or subscribe to our mailing lists for the purpose of accessing our Services. This personal data might include your name, address, email address, phone number, and other information relevant to the account that you are registering for. We use the particulars you provide to ensure that you enjoy the respective VIP benefits that you are eligible for, and also keep you up to date with important announcements.

III. Your visit to our website

We may also collect certain information about your visits to our website and how you use it. This may include your IP address, geographical location, device information, browser type, referral source, length of visit, operating system, number of page views, what you have viewed or searched for on our Site, and similar information.

This information may be collected by a third party website analytics service provider on our behalf and/or may be collected using cookies. For more information on cookies please refer to section IV below.

IV. Information that we collect automatically from your device

Cookies are small files that can be used to store information you have already provided. Cookies cannot be used to "steal" information about you or your computer system. The Splink website uses cookies to remember your preferences. For example, the website may remember which page you viewed, or the items added to your cart, to make your next visit more convenient. Nevertheless, cookies can be disabled in your web browser's Internet Options. You can also find out more about Splink cookie policy here.

Our Services may also contain content and links to other sites that are operated by third parties that may also operate cookies. We do not control these third-party sites or cookies and this Privacy Policy does not apply to them. Please consult the terms and conditions and privacy policy of the relevant third party site to find out how that third party site collects and uses your information and to establish whether and for what purpose they use cookies.

V. Point of Sale

When you purchase a product from us, we require you to provide your name, postal address, email address, telephone numbers so that we are able to facilitate your purchase.

Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you.

Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.

We will protect your personal data in our possession and/or control by making reasonable security arrangements (including, where appropriate, physical, administrative, procedural and information & communications technology measures) to prevent unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal or destruction of your personal data, or other similar risks. Such arrangements include requiring our personnel to adopt appropriate access controls to the personal data.

Notwithstanding the above, please note that we do not control these third-party sites and/or platforms and this Privacy Policy does not apply to them. Please consult the terms and conditions and privacy policy of the relevant third party site to find out how that site and/or platform collects and uses your information.

VI. Payment

If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

For more insight, you may also want to read Shopify’s Terms of Service at: (https://www.shopify.com/legal/terms) or Privacy Statement (https://www.shopify.com/legal/privacy).

C. PERSONAL DATA WE RECEIVE FROM THIRD PARTIES

We may collect personal data about you from third parties that we work closely with for the purposes of providing the Services. We may also engage third parties to operate websites on our behalf; these entities may collect personal data directly from you about your visits to our website on our behalf.

We may also receive personal data about you from third parties where you have consented to such third party sharing your personal data with us for specific purposes. For example, we might receive personal data about you from third parties if you have indicated to that third party that you would like to hear from us, with more information about our Services.

D. USE AND DISCLOSURE OF PERSONAL DATA

By providing your personal data to us, you agree that we may collect, use and/or disclose your personal data for any or all of the following purposes:

a. to allow us to perform our obligations to you, including responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

b. managing your relationship with us, including, tracking your purchase records, allocating points according to your purchase records, updating you periodically about relevant promotions or new product launches, redeeming your VIP points for discount codes on our website;

c. perform data analytics and update our profiling of customer preferences so that we may be able to serve you better such as providing customised recommendations to you based on your preferences and shopping history;

d. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

e. transmitting to any unaffiliated third parties including our third party service providers and agents, for the aforementioned purposes;

f. any other purposes for which you have provided the information; and/or

g. any other incidental business purposes related to or in connection with the above

Further, you agree that we can share your personal data with:

a. any other selected third parties that we work with where necessary for the purposes of delivering you with the Services or any other services that you request from us. We might also engage other third party subcontractors or service providers to help us host our website, such as Shopify Inc, as mentioned above;

b. any other selected third party that you consent to our sharing your personal data with for marketing purposes;

c. any prospective seller or buyer of our business or assets, in the event that we decide to sell or buy any business or assets; and/or

d. any other third parties where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.

E. MANAGING YOUR PERSONAL DATA / YOUR RIGHTS

If you do not want us to continue sending any marketing materials to you, you can decide to opt-out of these types of marketing material at any time by changing the settings in your profile or by clicking the unsubscribe link at the bottom of any email we send to you.

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. Please note that depending on the nature and scope of your request, this may adversely affect our ability to continue to serve you.

By providing your personal data to us, you have ensured that the data is accurate. You may, at any time, log in to your account to amend / correct any of your personal data. If you would like us to update your personal data, remove your name from our mailing list, or if you have any questions about our privacy policy or your personal information we have on record, do reach out to us in writing or via email to our Data Protection Officer at the contact details provided below.

F. CONTACTING US

You may contact our Data Protection Officer at dpo@besplink.com.

Occasionally, we may amend this Privacy Policy without any prior notice. We advise our customers to review the Privacy Policy periodically to be updated of any changes. By your continued use of this site, you consent to this Privacy Policy and any changes that may be made from time to time.

G. GOVERNING LAW

You agree that the terms of this Privacy Policy shall be governed by Portugal laws and any relevant regulations and you agree to submit to the exclusive jurisdiction of the Portugal courts.

H. TrueDepth API

The Splink app (IOS) makes use of automatically collected information using the device camera and the TrueDepth API provided by Apple. The only use of this information is to track the user’s head and face so that the user can control the AR experience and the selfie filters by moving their device and their head. For this to work, the app requires access to the user’s device camera.

None of the information collected by the TrueDepth API ever leaves the user's device nor is it persistently stored on the device. We do not collect, use, save, or have access to any of your personal data from within our apps.

The Splink app does not and will not use customer face data to personally identify any user. Contact us if you have any privacy questions, concerns or suggestions at hello@besplink.com

I. Klarna

In order to offer Klarna payment methods, at the time of payment, we may transmit to Klarna during the purchase process your personal data included in the contact form and order details, so that Klarna can assess whether you meet the requirements to access your payment methods and to adapt these payment methods to your profile. Your personal data is processed in accordance with the provisions of Klarna's privacy policy.