Last Updated: 28 February 2021

1. Who We are, and why this document is important.

1.1. Cult Rhea Limited (‘Us’, ‘We’, or the ‘Company’) is a limited liability company registered under the laws of Malta with registration number C 95920 having its registered address at 10, Narcisa, Triq ta’ Stronka, Madliena, Swieqi, SWQ 1522.

1.2. We gather and process your personal data in accordance with this Privacy Policy and in compliance with the relevant data protection regulations and laws. This Privacy Policy provides you with the necessary information regarding your rights and our obligations, and explains, how, why and when We process your personal data.

1.3. We recognise our obligations as a ‘Data Controller’ in terms of the applicable data protection laws, namely the General Data Protection Regulation (EU 2016/679) as supplemented by the Data Protection Act, Chapter 586 of the Laws of Malta, together with other applicable laws.

1.4. We are committed to processing your personal data lawfully, fairly and transparently. Furthermore, We are committed to processing your personal data for the reasons specified in this Privacy Policy and ultimately doing this in a way that keeps your personal data securely stored for no longer period than is necessary for the purposes for which it is processed.

1.5. If you have any questions about how We protect your personal data, please e-mail us on hello@cultrhea.com

2. Information that We collect.

2.1. We collect and process your personal data to meet our legal, statutory and contractual obligations and to provide you with our services. We will never collect any unnecessary personal data from you and We do not process your information in any way, other than as specified in this Privacy Policy.

2.2. Most of the personal data which We may collect about you through this website is given to Us only if you choose to give it to Us. Such personal data may be requested from you when you fill out a field (for example, to submit a contact form), when you sign up for a newsletter, or when you create an online account.

2.3. If you provide personal data to Us about someone else, such as family, friends or other people, you should ensure that you are entitled to disclose that personal data to Us and that, without our taking any further steps, We may collect, use and disclose that personal data as described in this Privacy Policy. It is important that when you provide Us personal data about someone else, you do this only once these people have given their permission for you to disclose it to Us and allow Us to use it.

2.4. We are not ‘Data Controllers’ of your personal data when you give your personal data directly to third-parties. This could be the case when you are re-directed from our website to a third-party website or webpage on which you may be requested to provide your personal data, such as in the case when you are directed to a payment gateway where you are expected to provide personal data such as your name, surname, e-mail address and/or credit card information. In such cases, please note that the ‘Data Controller’ of the personal data you provide is the third-party requesting such data and you should carefully read any privacy policy provided separately.

3. Information that We collect when you contact Us using a contact form.

3.1. If you communicate Us using the contact form, or subscribe for a newsletter we issue, or may issue in the future, We will ask for:

3.1.1. Your name;

3.1.2. Your surname;

3.1.3. Telephone number

3.1.4. Your e-mail address;

3.1.5. Your message to Us;

3.2. We will use the personal data referred to above to identify you as person, to follow up on your communication, to verify whether we have previously communicated with you and to be able to communicate back. The legal basis on which we collect and process this data is our legitimate interest.

3.3. We will also use the personal data referred to above to send you marketing and promotional information about our website and the services offered on our website. The legal basis on which we collect and process this data is consent, which you are free to withdraw at any time.

4. Information that We collect when you browse our website.

4.1. When you browse our website, ‘cookies’ may be collected. These are small files downloaded and stored on your own device that are sent to our website as you pay our website subsequent visits. Cookies may be useful because they store information about your preferences or past actions.

4.2. In our case, please note that our website does not use cookies that store information about your preferences or past actions beyond one session of using the website, therefore we do not generally collect personal data through the use of cookies. Cookies deployed by our website are ‘temporal’, meaning that no information is accumulated from your computer and stored.

4.3. Currently, our website does not collect data through the use of Google Analytics, however, in the future this software may be enabled. Google Analaytics is a digital software provided by Google that will allow us to analyse and track website usage. Once this software is deployed, the following information may be collected:

4.3.1. The IP address used to access our website and network location

4.3.2. The time of visit

4.3.3. The pages visited

4.3.4. The time spent on each page of our website

4.3.5. Type of web browser used to access our website

4.3.6. Document downloads

4.3.7. Clicks on links leading to external websites

4.3.8. Clicks on multimedia objects

4.3.9. Website interactions

4.4. Personal data collected by Google Analytics is collected by means of statistics cookies deployed by the Google Analytics software. Such data is collected by us and processed by Google. The legal basis for such processing is our legitimate interest to monitor and analyse website traffic and will only be used for the purpose of collecting statistical data on our website.

5. Information that We collect when you create an account on our website.

5.1. Our website allows you to create an account which can be used to put together a list of gifts which, once confirmed and published on our website, will be accessible to other website visitors who may purchase gifts for you. The account you create on our website could also be used simply to browse other account holders’ lists and purchase gifts for other users. In any case, when you create an account on our website, we will collect some personal data.

5.2. The personal data we ask for when you create an account on our website includes:

5.2.1. Your name

5.2.2. Your surname

5.2.3. Your e-mail address;

5.2.4. Your address at which you would like products delivered to you;

5.2.5. Your contact number (such as telephone or mobile number);

5.2.6. Account log-in credentials, namely a username, a password and an account/client reference number linked to your account that may be generated automatically by the website;

5.3. We will use the personal data referred to above to identify you as person, to verify whether we have previously communicated with you, to verify whether you have previously created another account with our website, to create and maintain an account for you on our website, to continue allowing you to use the account we create for you on our website, and to be able to communicate with you on matters concerning your account and the provision of our services to you. The legal bases on which we collect and process this data are our legitimate interest, to enter into a contract of services with you, to fulfil our contractual obligations toward you, and to execute any contractual agreement with you. Please note that our contractual agreement with you is contained in the ‘Terms & Conditions’ available on our website www.cultrhea.com/privacypolicy

5.4. We will also use the personal data referred to above to send you marketing and promotional information about our website and the services offered on our website. The legal basis on which we collect and process this data is consent, which you are free to withdraw at any time.

5.5. As part of the provision of our services to you, we may sometimes be required to share your personal data with third-parties (‘Data Processors’), such as vendors Users select to purchase gifts from. When we share your personal data with Data Processors, we do so with an understanding with the other entities that the personal data is to be used only for the purposes stated in this Privacy Policy.

6. What you need to know about sharing and disclosing your personal data.

6.1. Under normal circumstances, we do not share your personal data with third-parties. However, sometimes we may be required to share your personal data with third-party Data Processors, particularly when this is necessary for the purpose of providing our services pursuant to a contractual agreement between yourself and Us (for example, such as when you purchase gifts as or when you receive gifts). In other words, we do not share or disclose any of your personal information other than for the purposes specified in this Privacy Policy or where there is a legal requirement.

6.2. When We share your personal data with Data Processors, We do so with an understanding with the other entities that the personal data is to be used only for the purposes stated in this Privacy Policy.

6.3. Currently, the third parties We may share your personal data with are:

7. Information about your rights.

7.1. As data subject, you enjoy several rights relating to your personal data, namely:

7.1.1. The right to informed: You have the right to be told in a clear, transparent, intelligible and easily accessible manner how your personal data is being used. From our end, We communicate on this point specifically through this Privacy Policy.

7.1.2. The Right of Access: You have the right to access the personal data We collect on you.

7.1.3. The Right to Rectification: You have the right to request Us to rectify any inaccurate personal data We hold on you.

7.1.4. The Right to Erasure: You have the right to request Us to delete your personal data. However, please note that this right is not absolute. In some cases, We may be justified to keep personal data which we need to keep (for example, in order to comply with a legal obligation or to enable Us to fulfil our contractual obligations).

7.1.5. The Right to Restrict Processing: You have the right to request that We restrict some of the ways We process your personal data. For instance, you have a right to request that we stop communicating marketing and promotional content.

7.1.6. The Right to Object: Where the legal basis for processing your personal data is our legitimate interest, you have the right to object to our use of your personal information.

7.1.7. The Right to Data Portability: You have the right to receive the personal data concerning yourself which you have provided in a structured, legible and readable format.

7.1.8. The Right to Refuse Automated Decision Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

7.1.9. The Right to Withdraw: Where the legal basis for processing your personal data is consent, you have the right to withdraw such consent at any time.

7.1.10. Right to go to Court: You have the right to Court against Us in case of infringement.

7.2. Feel free to exercise such right by e-mailing our Data Protection Officer on hello@cultrhea.com.

8. Information about how long We store your data.

8.1. We will keep your personal data for no longer than is necessary having regard the purpose or purposes for which We first collected the personal data and the purposes set out in this Privacy Policy.

9. Changes to Privacy Policy

9.1 This website may change from time to time and such changes may include changes to functionalities affecting what personal data is collected from you. As such, you are encouraged to visit this page frequently to keep yourself updated changes to this Privacy Policy.