Privacy policy

Privacy Policy

Last updated: [DATE]

At VALHALLU, we respect your privacy and are committed to handling your personal data responsibly and transparently.

This Privacy Policy explains how we collect, use, store and protect personal data when you visit our website, place an order, contact us, subscribe to marketing communications, or otherwise interact with VALHALLU.

This Privacy Policy applies to the website:

[WEBSITE URL]

and is intended to comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Hungarian data protection legislation.

1. Who We Are

The data controller responsible for your personal data is:

Legal business name: [LEGAL BUSINESS NAME]
Registered address: [REGISTERED ADDRESS]
Company registration number: [COMPANY / REGISTRATION NUMBER]
Tax number: [TAX NUMBER]
Email: [CUSTOMER SERVICE EMAIL]
Website: [WEBSITE URL]

For the purposes of applicable data protection legislation, the above entity is the data controller of the personal data described in this Privacy Policy.

If you have any questions about how your personal data is handled, you can contact us using the details above.

2. What Personal Data We Collect

Depending on how you interact with VALHALLU, we may collect and process the following categories of personal data.

Information you provide when placing an order

This may include:

  • Full name

  • Billing address

  • Delivery address

  • Email address

  • Telephone number

  • Order details

  • Products purchased

  • Order value

  • Information relating to returns, refunds or exchanges

  • Other information you provide in connection with your order

Information you provide when contacting us

If you contact us by email, contact form or another customer-service channel, we may process:

  • Your name

  • Contact details

  • The contents of your enquiry

  • Information you choose to provide to us

Account information

If customer accounts are available and you choose to create an account, we may process:

  • Name

  • Email address

  • Login and account information

  • Order history

  • Saved addresses and other information associated with your account

Payment information

Payments may be processed by third-party payment providers.

Depending on the payment method selected, we may receive information such as payment status, transaction reference or other information necessary to confirm and administer your payment.

VALHALLU does not normally store complete payment-card details on its own systems.

Payment information is handled according to the applicable payment provider's own terms and privacy information.

Payment provider(s): [PAYMENT PROVIDER(S)]

Technical information

When you use our website, certain technical information may be collected automatically, such as:

  • IP address

  • Browser type and version

  • Device type

  • Operating system

  • Website pages visited

  • Date and time of access

  • Referring website

  • Technical information relating to website use

Some of this information may be collected through cookies or similar technologies. Detailed information about cookies is provided in our separate Cookie Policy.

3. How We Use Your Personal Data

We use personal data only where there is a lawful reason to do so and only for appropriate purposes.

Depending on the circumstances, we may use your personal data to:

  • Process and fulfil your orders

  • Confirm and administer purchases

  • Arrange delivery

  • Process payments and refunds

  • Issue invoices and maintain accounting records

  • Handle returns, exchanges and complaints

  • Respond to customer enquiries

  • Provide customer support

  • Maintain and administer customer accounts

  • Maintain the security of our website and services

  • Detect and help prevent fraud, misuse or security incidents

  • Comply with legal and regulatory obligations

  • Establish, exercise or defend legal claims

  • Improve the operation and performance of our website

  • Understand how customers use our website

  • Send marketing communications where legally permitted and, where required, with your consent

We do not use personal data for purposes that are incompatible with the purposes for which it was originally collected.

4. Legal Bases for Processing

Depending on the circumstances, we process your personal data on one or more of the following legal bases under the GDPR.

Performance of a contract

We may process your personal data where it is necessary to enter into or perform a contract with you, including processing and fulfilling your order.

Legal obligation

We may process personal data where processing is necessary for compliance with a legal obligation, including applicable accounting, tax, consumer protection or other legal requirements.

Legitimate interests

We may process personal data where this is necessary for our legitimate interests, provided that those interests are not overridden by your rights and interests.

Examples may include website security, fraud prevention, administration, service improvement and the establishment or defence of legal claims.

Consent

Where required by law, we process personal data on the basis of your consent.

You may withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

5. Orders and Purchases

When you place an order with VALHALLU, we process the information necessary to:

  • Accept and administer your order

  • Confirm your purchase

  • Process payment

  • Prepare and dispatch your order

  • Communicate with you about your order

  • Handle delivery issues

  • Process returns and refunds

  • Meet our legal and accounting obligations

Providing the information necessary to complete an order is generally required for us to enter into and perform the sales contract with you.

If the required information is not provided, we may be unable to process or fulfil your order.

6. Payments

Payments may be processed through third-party payment service providers.

The payment provider may process your payment information directly in accordance with its own privacy policy and terms.

Payment provider(s): [PAYMENT PROVIDER(S)]

VALHALLU may receive information necessary to confirm whether a payment has been successfully completed, declined, refunded or otherwise processed.

We do not normally have access to or store complete payment-card details.

7. Delivery

To deliver your order, we may provide the delivery provider with information necessary to complete the delivery.

This may include:

  • Name

  • Delivery address

  • Telephone number

  • Email address, where required

  • Order or delivery reference

  • Other information necessary for delivery

Delivery provider(s): [DELIVERY PROVIDER(S)]

The delivery provider processes personal data in accordance with its own legal obligations and applicable privacy information.

8. Returns, Refunds and Customer Service

If you contact us regarding a return, refund, exchange, complaint or other customer-service matter, we may process information necessary to identify your order and handle your request.

This may include your name, contact details, order information, payment or refund information and the contents of your communication.

We retain information relating to transactions and customer-service matters where necessary to comply with legal obligations or to establish, exercise or defend legal claims.

9. Service Providers and Data Recipients

VALHALLU may use trusted third-party service providers where necessary to operate our business and provide our services.

Depending on the services actually used by VALHALLU, these may include:

  • Shopify and related ecommerce services

  • Payment service providers

  • Delivery and courier companies

  • Accounting and bookkeeping providers

  • Email and communication providers

  • Website hosting and technical service providers

  • Analytics providers

  • Marketing and advertising service providers

  • IT and security providers

  • Professional advisers

  • Public authorities where disclosure is required by law

The specific providers used by VALHALLU will depend on the services and applications active on our website.

Relevant service providers: [TO BE COMPLETED]

Where a service provider processes personal data on our behalf, we take appropriate steps to ensure that the processing is governed by appropriate contractual and legal safeguards.

10. Shopify

Our online store is operated using Shopify.

Shopify provides the ecommerce infrastructure that enables us to operate our online store and may process personal data on our behalf or in accordance with its own legal role and applicable privacy documentation.

Information about Shopify's handling of personal data is available through Shopify's current privacy documentation.

Shopify-related services used by VALHALLU: [TO BE CONFIRMED]

11. International Data Transfers

Some of our service providers may process personal data outside Hungary or the European Economic Area (EEA).

Where personal data is transferred outside the EEA, we will ensure that the transfer is carried out in accordance with applicable data protection law and that an appropriate legal safeguard is in place where required.

Depending on the circumstances, this may include:

  • An adequacy decision of the European Commission

  • Standard Contractual Clauses

  • Other lawful transfer mechanisms recognised under applicable data protection law

Where relevant, further information about international transfers can be obtained by contacting us.

12. Marketing Communications

If you subscribe to receive marketing communications from VALHALLU, we may use your contact details to send information about:

  • New jewellery

  • New collections

  • Special offers

  • Promotions

  • Seasonal campaigns

  • Other VALHALLU news

Where consent is required, marketing communications will only be sent on the basis of your consent.

You may unsubscribe from marketing communications at any time by:

  • Using the unsubscribe link included in the relevant communication; or

  • Contacting us at [CUSTOMER SERVICE EMAIL]

Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

You may also object to direct marketing at any time.

13. Cookies and Similar Technologies

Our website uses cookies and similar technologies for purposes such as website operation, functionality, security, analytics and, where applicable, marketing.

The use of cookies is explained in our separate:

Cookie Policy

Our Cookie Policy provides further information about the categories of cookies used, their purposes and how you can manage your cookie preferences.

Cookie Policy: [COOKIE POLICY URL]

14. How Long We Keep Your Personal Data

We retain personal data only for as long as necessary for the purpose for which it was collected, unless a longer retention period is required or permitted by law.

Different categories of information may therefore be retained for different periods.

For example:

  • Order and transaction information may be retained for the period required by applicable accounting and tax legislation.

  • Information relating to customer enquiries may be retained for as long as necessary to handle the enquiry and, where appropriate, for a reasonable period afterwards.

  • Information relating to returns, complaints or disputes may be retained for as long as necessary to resolve the matter and establish, exercise or defend legal claims.

  • Marketing information may be retained until you withdraw your consent or otherwise object, subject to applicable legal requirements.

  • Technical and cookie-related information may be retained according to the relevant service or cookie settings.

Specific retention periods / legal requirements: [TO BE CONFIRMED]

We periodically review retained personal data and delete or anonymise information when it is no longer necessary, unless we are legally required to retain it.

15. Data Security

We take appropriate technical and organisational measures designed to protect personal data against:

  • Unauthorised access

  • Unauthorised disclosure

  • Accidental loss

  • Destruction

  • Alteration

  • Other unlawful or unauthorised processing

Access to personal data is limited to persons and service providers who need it for legitimate business purposes or where disclosure is otherwise permitted or required by law.

No method of transmission or storage can be guaranteed to be completely secure. However, we take reasonable and appropriate measures to protect the information entrusted to us.

16. Your Data Protection Rights

Subject to the conditions and limitations set out in applicable law, you may have the following rights under the GDPR:

Right to access

You may request confirmation as to whether we process your personal data and, where applicable, request access to that data and relevant information about its processing.

Right to rectification

You may request that inaccurate or incomplete personal data be corrected or completed.

Right to erasure

In certain circumstances, you may request that your personal data be deleted.

This right is not absolute and does not apply where we are legally required or otherwise permitted to retain or process the information.

Right to restriction of processing

In certain circumstances, you may request that we restrict the processing of your personal data.

Right to object

You may object to certain processing based on our legitimate interests.

You have an absolute right to object to the processing of your personal data for direct marketing purposes.

Right to data portability

Where the legal requirements are met, you may request to receive personal data that you have provided to us in a structured, commonly used and machine-readable format, or request that it be transmitted to another controller.

Right to withdraw consent

Where processing is based on consent, you may withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Rights relating to automated decision-making

Where applicable, you have rights relating to decisions based solely on automated processing, including profiling, where such decisions produce legal effects or similarly significantly affect you.

VALHALLU currently does not intend to make decisions based solely on automated processing that produce such effects, unless otherwise stated in this Privacy Policy.

The GDPR requires organisations to provide clear information about these rights and how individuals can exercise them.

17. How to Exercise Your Rights

To exercise your data protection rights, please contact us at:

[CUSTOMER SERVICE EMAIL]

You may also write to:

[LEGAL BUSINESS NAME]
[REGISTERED ADDRESS]

We may need to verify your identity before completing certain requests in order to protect your personal data.

We will respond to valid requests without undue delay and, in general, within one month as required by the GDPR. Where permitted by law, this period may be extended where a request is particularly complex or where multiple requests have been made.

If we do not take action on your request, we will provide information about the reasons and about your right to lodge a complaint with a supervisory authority, where applicable.

18. Right to Lodge a Complaint

If you believe that your personal data has been processed unlawfully or that your data protection rights have not been respected, you have the right to lodge a complaint with a competent supervisory authority.

In Hungary, the relevant supervisory authority is:

National Authority for Data Protection and Freedom of Information (NAIH)
Address: 1055 Budapest, Falk Miksa utca 9–11, Hungary
Postal address: 1363 Budapest, Pf. 9
Email: ugyfelszolgalat@naih.hu
Website: [NAIH WEBSITE URL]

You may also have the right to lodge a complaint with the data protection supervisory authority in another EU Member State, particularly where you normally reside, work or where the alleged infringement occurred.

NAIH provides a procedure for data subjects seeking a data protection authority proceeding under the GDPR.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, website, legal requirements, technology or data-processing practices.

The latest version will be published on this page together with the date of the latest update.

Where required by applicable law, we will provide additional notice of material changes.

20. Contact Us

If you have any questions about this Privacy Policy or how VALHALLU handles your personal data, please contact us:

[LEGAL BUSINESS NAME]
[REGISTERED ADDRESS]
[CUSTOMER SERVICE EMAIL]
[WEBSITE URL]

Last updated: [DATE]