This Data Protection Policy (“Policy”) discloses the privacy practices of the CUL DE SAC online platform (CUL-DE-SAC.ph), hereafter “CUL DE SAC”, operated by Noble House Distribution Enterprise, Inc.
We value and respect our customer’s right to privacy and we are committed to protect the personal data you provide through the use of the CUL DE SAC online platform. The terms and conditions stated in this Policy provides information on how we will collect, handle, use, record, store, share or otherwise process the personal data that you provide during your use of the CUL DE SAC platform and when you avail of the services, products or promotions we offer. Hence, we encourage you to read the terms carefully.
We reserve the right to amend or modify this Policy, as may be needed, to comply with the mandate of the Philippine Data Privacy Act of 2012 (R.A. 10173, hereinafter “DPA”) and other relevant laws, rules and regulations. All changes or modifications on the Policy shall be posted at the CUL DE SAC platform. By visiting, browsing or using the CUL DE SAC website, creating or registering an account with CUL DE SAC, or accessing the Services we offer, you acknowledge that you have read and understood the terms and conditions herein stated and agree to be bound by the terms of this Policy. You likewise give your informed consent to the collection, use, sharing or processing of your personal data in accordance with the procedures and purposes herein disclosed.
DEFINITION OF TERMS
In order to have a better understanding of this Policy, the following words shall be defined as follows:
- “Data Subject” - refers to an individual whose Personal or Sensitive Personal Information is collected, used, shared or otherwise processed.
- “DPA Legislation” - shall refer to the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations;
- “Process”, “Processes”, “Processing” or “Processed” shall have the meaning as defined in the DPA Legislation.
- “Personal Data” – any data, whether true or not, from which an individual person can be identified or ascertained; or from that data and other information which we may access to. It includes “personal information” and “sensitive personal information as defined by the DPA and its implementing rules & regulations.
- “Platform” - shall refer to the CUL DE SAC online platform (CUL-DE-SAC.ph) and mobile applications.
WHEN AND HOW DO WE COLLECT PERSONAL DATA FROM YOU
We may collect personal data from you when:
- you visit, browse, interact or use our application or website via desktop, laptop, or mobile device. This includes cookies or third-party analytics which may be deployed during the use of the application or website;
- you use our related services such as email and SMS notifications, Click & Collect pick up, returns and exchange of product/s, availment of promotions directly or through third party partners contracted by CUL DE SAC;
- you register, create or open an account with us;
- you carry out transactions through the use of the online platform; purchase any of the products offered for sale by partner merchants and submit forms relating to said products such as but not limited to Contact Form to message our Customer Care team, reviews and ratings for purchased product/s.
- you interact with us via telephone calls, letters, fax, social media, and emails, or through CUL DE SAC for order pick up or returns and exchange;
- you voluntarily submit personal data to us or to our authorized representative for any reason.
You must only submit to us, our authorized agent or the Platform, personal data which is accurate and complete and not misleading. It is your duty to keep your information up to date without prejudice to the exercise of your rights under existing DPA Legislations and regulations. Should the need arise, we may request you for documentation to verify the information which you have provided.
WHAT PERSONAL DATA DO WE COLLECT FROM YOU
CUL DE SAC collects, uses and/or processes the following personal data from you:
- First Name
- Middle Name
- Last Name
- Email address
- Date of Birth
- Contact numbers such as mobile numbers or landline
- Billing and Shipping Address;
- When you pay using your credit or debit card, you will be redirected to another website owned and operated by Paypal, a payment gateway service provider, which shall collect and process your financial information pursuant to its own terms and own policies. Upon instructions of the data subject, CUL DE SAC may store partial and masked credit/debit card details shared by Paypal for easy reference in succeeding transactions. In the event of complaints/requests for refund, or questions relating to payments made through credit/debit cards, we may request for the following personal data to be able to attend to your concern/s:
- name of the issuing bank;
- name of cardholder;
- last four digits of your credit/debit card;
- amount involved.
We may also collect certain information by automated or passive means using a variety of technologies such as when you connect your computer to the internet or when you view our website from your mobile phone. The information which may be collected include the following:
Internet Protocol (IP) address;
- computer/mobile device operating system;
- browser used;
- kind of mobile device used and the characteristics of the mobile device such as, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device;
- browsing behavior;
We respect your rights as a data subject. You may, at any time, opt-out or request to stop the processing of your personal data; or withdraw your consent to the processing of your personal data. You may likewise modify, correct or amend your personal data by notifying our Data Protection Officer (DPO) in writing through the procedure described in the succeeding paragraphs.
HOW WILL YOUR PERSONAL DATA BE USED
The personal data collected may be processed for any or all of the following purposes:
- To administer and maintain your account/user profile with us and/or to grant you access to our Services, including our website;
- To process or to complete your purchase or transactions with us;
- To process, deal with or complete transaction/s or orders and/or to respond to your inquiries or requests for certain products and/or services;
- To notify you of service issues and unusual account actions, should any occur;
- To improve the layout and/or content of the pages of the Platform and customize them for users according to their interests and preferences;
- To allow us to contact you, if necessary;
- To maintain, administer or improve the Platform, provide any software updates and/or other updates/support as may be required.
- To conduct research, analysis and activities (such as but not limited to, data analytics, surveys, product and service development and/or profiling), to analyze how you use our platform so we can improve our Services or products and/or to enhance your customer experience;
- To provide you with information which we think you may find useful or which you have requested from us, including information about our merchant partner’s products and services, provided you have indicated that you have not objected to being contacted for these purposes;
- To comply with applicable laws; our risk management procedures and the terms of our access to payment processing, financial or banking services.
- To audit our Services or our Platform;
- To carry out legitimate business purposes
We may share or disclose your personal data with any of the following person/s in line with the purpose/s aforestated:
- Employees/personnel, consultants;
- Our branches and affiliates;
- Authorized third-party service providers such as but not limited to technology partners, payment processors, logistics providers, courier services.
- Business partners who separately maintain an account with you for loyalty or point earning/redemption programs.
- Such other party whom you authorize us to disclose your Personal Data to.
In sharing your personal information with the above mentioned persons/entities, we will endeavor to keep your personal information secure from unauthorized access, collection, use, disclosure, or similar risks and retain your personal information only for as long as they need your personal information to achieve the abovementioned purposes.
COLLECTION OF COMPUTER DATA
Cookies contain information about the web activities of the user. This allows CUL DE SAC to understand more about your visit and help us to enhance your experience and may be used for authentication and storing website information or preferences. You are free to accept or decline cookies by modifying your browser setting to decline cookies. However, should you choose to decline cookies, you may not be able to fully experience the features of the Platform.
Web beacons are small graphic images that may be included on our Service and the Platform. They allow us to count users who have viewed these pages, the time spent on the pages, the items searched for, among others, through the use of Platform so that we can better understand your preference and interests so we can improve our services further.
VARIOUS COOKIES IN CUL DE SAC
These are cookies that our website needs in order to function and if they are not accepted by you, parts of the site will not be usable. Examples of where these cookies are used include: to allow you to sign in as a registered user, to store how many items are in your shopping bag and to check out securely. Without these cookies, our site just won’t work as they should.
These cookies allow our site to remember your preferences, helping you to customize your experience on our site. That way, when you return to our site and provide you support when needed for a more relevant browsing experience.
Measurement and Analytics
These cookies tell us how users interact with the website content. The information is anonymized and aggregated for website analysis purposes. This helps us to improve the way our site works, for example, by ensuring that users find what they are looking for easily.
These cookies are used to deliver advertising content which is relevant to you. The purpose is to provide you with customized ads based on your interest, search and browsing behavior.
Third Party Cookies
Third party cookies are set on our website. These aid in measurement, analytics and ad personalization purposes. Third parties may include Google Analytics, Facebook Pixel and the like. For more information, please go to the third party website for more information.
If you do not want to accept cookies from CUL-DE-SAC.ph, you can change your browser settings so that cookies are not accepted. If you choose to do this, please be aware CUL-DE-SAC.ph may no longer function as intended.
TURNING OFF COOKIES
Within your browser you can choose whether you wish to accept cookies or not. Different browsers make different controls available to you. Generally, your browser will offer you the choice to accept, refuse or delete cookies at all times, or those from providers that website owners use i.e. third party cookies, or those from specific websites. Each browser’s website should contain instructions on how you can do this. We remind you that If you block cookies on our website, you may be unable to access certain areas of our website and certain functions and pages will not be accessible.
NO SPAM, SPYWARE, OR VIRUS
Spam, spyware or virus is not allowed on Platform. Please set and maintain your communication preferences so that we send communications to you in accordance with your preferences. You are not licensed or otherwise allowed to add other users to our mailing list (email or physical mail) without their express consent. You should not send any messages which contain spam, spyware or virus via the Platform. If you would like to report any suspicious messages, please contact us at our email address below.
WITHDRAWAL OF CONSENT
You may communicate your objection to our continual use and/or disclosure of your personal data for any of the purposes afore stated at any time by messaging us through the Contact Us page.
Please note that if you communicate your objection to our use and/or disclosure of your personal data for the purposes and in the manner as stated above, depending on the nature of your objection, we may not be in a position to continue to provide our products or services to you or perform on any contract we have with you. Our legal rights and remedies are expressly reserved in such event.
UPDATING YOUR PERSONAL DATA
You can update your personal data anytime by accessing your account on the CUL DE SAC Platform. We may share your updated personal data to the person/entities enumerated above in order to achieve the above stated purposes.
SECURITY OF YOUR PERSONAL INFORMATION
We ensure that all personal data collected will be stored and protected. We protect your personal data by:
- Restricting access to personal data;
- Maintaining technology products to prevent unauthorized computer access
- Securely destroying your personal data when it is no longer needed for any legal or business purpose
We use industry standard encryption technology and regularly run vulnerability scans and other maintenance activities to ensure that your data and the Platform are secure.
Your password should be kept confidential and should not be shared with anyone. Please use unique numbers, letters, and special characters. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences. If you suspect that your password has been compromised, you should immediately change your password. You are reminded to log off of your account and close the browser when finished using the Platform in a shared computer.
Our website is intended only for persons who are at least eighteen (18) years old. We neither offer products or services to, nor knowingly collect personal data of, persons below the age of eighteen (18) years (“Minors”) without any legal basis. Should we learn that we were provided with personal data of Minors without any legal basis, we will delete the same from our database. If you are a Minor, please do not provide any personal data to us, such as your name, age, gender, email address, contact information and the like. Parents or guardians may make purchases for minors.
The Platform stores Personal Data and other information related to your order and/or transaction/s indefinitely, as long as you have an account with us and the Platform is existent. Your data will be deactivated from the Platform and will become inaccessible from the website should we receive a written message from you indicating the purpose and nature of your request or upon Platform’s end of life.