Privacy Policy for cold-shoulder.com
1. Introduction
At cold-shoulder.com (“we,” “us,” or “our”), we are firmly committed to safeguarding the privacy and personal data of our users. This Privacy Policy illustrates our dedication to upholding the highest standards of data protection, in compliance with the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and the California Consumer Privacy Act (“CCPA”), along with other applicable data protection laws. We understand the importance of transparency and accountability and aim to inform you — our users, customers, and website visitors — how your personal information is collected, used, disclosed, and protected throughout your interactions with our website and services.
2. Scope of Policy and Data Controller
This Privacy Policy applies to all personal data collected through or in connection with your use of www.cold-shoulder.com (“Website”) and the services provided therein. We act as the “data controller” for the purposes of GDPR when processing your personal data, determining the purposes and means of processing such data. For residents in jurisdictions subject to CCPA, cold-shoulder.com is considered the “business” with respect to your “personal information.”
If you have any privacy-related concerns or questions regarding this Policy, you may contact us at: [email protected].
3. Categories of Data Processed
We collect and process various categories of personal data as outlined below:
a) Usage Data:
Collected automatically when you interact with our Website. This includes IP addresses, browser types and versions, operating systems, referral sources, page views, website navigation paths, session durations, device identifiers, and similar diagnostic data.
b) Account Data:
Personal data you provide when registering an account or making a purchase. This includes your full name, residential or delivery address, email address, and phone number.
c) Profile Data:
Includes information about your preferences, transaction history, saved items, personal settings, product interests, and browsing behavior within your user account.
d) Communication Data:
Information contained in or relating to any communications you send to us. This includes email correspondences, support tickets, chat messages, and customer service call logs.
e) Technical Data:
Details about your device used to access our Website, such as hardware model, device identifiers, screen resolution, preferred language, mobile network information, and system configurations.
f) Transaction Data:
Comprises order data, billing and shipping addresses, payment method details (excluding full payment card numbers handled by secure third-party processors), and order fulfillment records.
g) Preference Data:
Includes your consent status for marketing communications, notification preferences, and stated interests in specific products, campaigns, or services.
4. Legal Bases for Processing
Under the GDPR, we rely on the following lawful bases to process your personal data:
– Contractual necessity: To fulfil a contract with you, such as processing your purchases or managing your account.
– Legitimate interests: To conduct and manage our business in ways that do not override your rights and freedoms — including analytics, fraud prevention, and improving customer experience.
– Consent: For specific purposes such as processing cookies or sending you promotional materials.
– Legal obligation: To comply with applicable laws or regulations.
Under the CCPA, we may collect and share personal information as described, and you have specific rights to know, delete, or opt out of such use.
5. Your Rights
If you are a resident of the European Economic Area (EEA), California, or other jurisdictions with consumer data protections, you have the right to:
– Access: Request access to your personal data.
– Rectification: Request correction of incomplete or inaccurate data held about you.
– Erasure: Request deletion of your personal data, subject to certain conditions.
– Restriction: Request restriction of processing your data in specific circumstances.
– Portability: Receive your personal data in a machine-readable format and transmit it to another controller.
– Objection: Object to the processing of your data based on legitimate interests or direct marketing.
– Withdrawal of consent: Withdraw any previously provided consent without affecting earlier lawful processing.
To exercise any of these rights, please contact us at [email protected].
6. Security Measures
We implement robust technical and organizational measures to ensure a high level of security for your personal data. These include:
– Industry-standard encryption for data in transit and at rest
– Role-based access control and authentication protocols
– Secure server infrastructure and firewalls
– Regular data backups and disaster recovery practices
– Ongoing staff privacy training and awareness programs
While we take all reasonable precautions, no method of transmission over the Internet or electronic storage is 100% secure. We continuously assess and improve our security measures to mitigate any risk.
7. International Transfers
If we transfer your personal data outside the European Economic Area (EEA) or equivalent jurisdictions, we ensure suitable safeguards are in place. These may include the use of Standard Contractual Clauses approved by the European Commission, or reliance on a country’s adequacy determination. We also ensure that our third-party service providers meet strict compliance obligations.
8. Data Retention
We retain your personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, regulatory, tax, accounting, or reporting obligations. Retention periods vary by data type:
– Account and Profile Data: Retained while your account is active and for 6 years thereafter for compliance and legal reasons.
– Communications Data: Retained for 3 years from last contact.
– Transaction Data: Retained for 7 years for tax and financial reporting.
– Marketing and Preference Data: Retained until you withdraw consent or opt out.
Upon expiry of these periods, or upon valid request, your data will be securely deleted or anonymized.
9. Cookie Policy
cold-shoulder.com uses cookies and similar tracking technologies to enhance your browsing experience and analyze Website traffic. We categorize our cookies as follows:
– Essential cookies: Required for Website functionality, such as login authentication and shopping cart processes.
– Functional cookies: Support personalization features like language preference, past activity, and stored settings.
– Analytics cookies: Help us understand how users interact with our Website through tools such as Google Analytics.
– Performance cookies: Measure Website response times and general use to improve overall performance.
10. Cookie Management and Compliance
You have the right to control which categories of cookies are stored on your browser. Upon your first visit, cold-shoulder.com will present a cookie consent banner enabling you to accept, customize, or reject non-essential cookies in compliance with the GDPR and CCPA. You may also adjust your settings at any time through your browser or via our dedicated consent management tool.
We do not sell your personal data as defined under CCPA but do allow you to opt-out of targeted advertising cookies per your rights.
11. Children’s Privacy
Our Website is not intended for children under the age of 13. We do not knowingly collect or solicit personal data from anyone under 13 years of age. If we discover that we have inadvertently collected personal information from a child under 13, we will take immediate action to delete such data. Parents or guardians who believe that their child has provided information to us may contact us at [email protected].
12. Changes to This Policy
We reserve the right to update this Privacy Policy at any time to reflect material changes in our practices, technologies, or legal obligations. Where legally required, we will notify you of any significant alterations via email, Website notice, or other legally permissible methods. Your continued use of cold-shoulder.com constitutes your acceptance of the revised Policy.
13. Contact Information
If you have any questions about this Privacy Policy, your data, or wish to exercise any of your legal rights, please contact us at:
We take privacy seriously and aim to honor all applicable privacy regulations. cold-shoulder.com is fully compliant with the GDPR and CCPA. If you believe your data rights have not been respected, please contact us at the above email address.