EU Privacy Statement
Last updated: February 4, 2021
Welcome to Curran Worldwide B.V., Curran Catalog LLC and/or Sisalcarpet.com LLC ("Curran"). Curran values your privacy. If you have any questions or concerns, please contact firstname.lastname@example.org.
This Privacy Statement (“Statement”), sets out how and why Curran (also “we”, “our”, or “us”) collects, stores, processes and shares your personal data as well as your ability to control certain uses of that data. It also describes certain data protection rights which apply, subject to applicable data protection law, including a right to object to some of the processing which Curran carries out. We strive to be transparent with you about what we do with your personal data.
[This Statement does not apply to you if you are not located within the EU. If you are located in other jurisdictions, we refer to the privacy statement that can be found at this link]
This Statement applies to the processing of your personal data in connection with all our U.S. sales and sales related services, online experience (including this website), products and tools, and to other situations and locations where you interact with us (collectively the “Services”). This Statement also applies if explicit references are made to it via a link or in a similar manner.) By visiting www.curranonline.com, www.curranfloor.com, and www.sisalcarpet.com (the “Websites”) or otherwise using our Services, you agree that your information will be handled as described in this Statement.
We may change this Statement at any time by posting the revised Statement on the Websites and indicating the effective date of the revised Statement. If you have any question about this Statement or your rights hereunder, please contact us at email@example.com.
1. What personal data do we collect from you and by what means?
We collect personal data directly from you when you provide it to us through our Customer Service or online or your use our Services, as well as through automatic methods of collection, as described below. The personal data collected varies depending on how you use our Services, but generally includes the personal data described below.
Personal data provided by you
You may provide the following personal data to us:
Contact information, such as name, email address, mobile/landline telephone number, your username,
Tax related data, such as VAT identification number, and tax identification numbers.
Content that you share with us through your comments on blog posts, our chats, through email, and via telephone.
Financial information, such as credit card information and billing address.
Postage, billing and other information you provide in connection with the purchase or postage of an item, as well as information required for customs clearance (such as tax identification numbers or other identification numbers) and relevant postage information (such as shipment numbers and tracking information).
Data you provide through social media (such as your name, username, and content of your post).
Other data you give us when you contact our Customer Service, when you engage with our social media platform (for example, by tagging us in a post on Instagram), when you apply for and create a Trade account, or when you otherwise interact with us.
Data we are required or entitled by applicable law to collect and process.
Data that we need for your authentication or identification, or for the verification of the personal data we collect.
Automatically collected personal data
Personal data that we collect automatically when you use our Services or create a Trade account, including by means of cookies and similar technologies:
Data that is generated through your actions when you use our Services and which is linked to your Trade account, e.g. when you place items in your shopping cart, searches or interests search our website.
Data regarding all other interactions with our Services, your advertising preferences, and your communication with us.
Data that is generated as part of one of your transactions or that is linked to your Trade account as a result of a transaction in which you are involved, such as transaction amounts, time and payment methods.
Location data, including the location data of your mobile device. Please note that for most mobile devices, you can manage or disable the use of location services for all applications in the settings menu of your mobile device.
Computer and connection data, such as statistics regarding your use of our Services, information on data traffic to and from websites, referral URL, information on advertisements, your IP address, your access times, your browser history data, your language settings and your weblog information.
Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click and other actions you take as part of your use of our Services and in advertising and email content.
The user segment or category into which you as a user fall, for example: interested in cars.
Data about your activities and interactions with our advertising partners, including data about the advertisements you were shown, how often they were shown, and whether you took any actions, such as clicking on an advertisement or making a purchase.
Data related to your device, such as the model and device type, operating system and version, browser type and settings, device ID or individual device identifier, advertisement ID, individual device token, and cookie-related data (e.g. cookie ID).
The IP address from which your device accesses the Service.
Personal data from other sources
We also collect personal data about you from other sources and from third parties to the extent permitted by applicable law. We use the following categories of data and sources:
Data from public sources (e.g. demographic information)
Data from credit agencies or bureaus (e.g. when performing authorized credit checks)
Data from data providers (e.g. demographic information, interest-based and online advertising-related data)
2. For what purpose do we use the personal data that we collect from you?
We use your personal data for various purposes and pursuant to various legal bases.
Following is a summary of the purposes for which we use personal data collected from you (as set out in Section 1 above). We may also combine personal data collected automatically with personal data provided directly by you or from other sources for the purposes described in this Section.
Contract fulfillment and actions at your request
We process data to fulfill a contract or to take steps at your request prior to a contract, including providing our services and communicating with you, in particular for:
Providing our Services. Including fulfilling orders, enabling delivery of purchased items by logistics/delivery service providers, processing payments, maintaining, and servicing accounts, developing new products and features.
Responding to Requests, Inquiries and Complaints. Responding to customer service requests, inquiries, and complaints and for any other reason that you contact us.
Customer Service and Dispute Resolution. To resolve problems with your purchase, arbitration and litigation of disputes, providing other services within the scope of customer services, as well as enforcement of payment/fee claims.
If you do not provide all personal data that we need to fulfill a contract or to take steps at your request prior to a contract, we may not be able to (fully, timely or correctly) perform our Services or other contractual obligations, address your question or complaint, or to take steps at your request.
For compliance purposes and legitimate interests of Curran or a related third party
We process your personal data to comply with applicable law and for legitimate interests of Curran or a related third party, in particular for:
Improvement of our Websites as well as the Services we provide to you and others, e.g. by using your interactions with our Websites and Services.
Marketing, Advertising, and Analytics. Understanding how users access and use our Services, placing advertisements and optimizing search results, and providing you with special offers and other information we think may interest you. We may also share your personal data in our Curran family for this purpose, to the extent permitted by law.
Administrative and Business. For the general administration of our business, including accounting, recordkeeping, training, compliance auditing, research, and other operational or legitimate business purposes permitted by law.
Protection of the legitimate interests of third parties in connection with civil law disputes, unless there is a statutory obligation to this effect, if we may legitimately assume that it is necessary to disclose the data to such third parties in order to avert imminent disadvantage.
Legal Compliance, Safety, and Protection of Rights and Interests. Complying with laws and regulations, responding to legal process or litigation or as part of an investigation or request from law enforcement or governmental authority when required by law, protecting the security and rights of Curran or any of its corporate family members, employees, officers, agents, or customers.
Prevention, detection and mitigation of illegal activities.
Retention and storage of your personal data to comply with specific legal retention requirements.
Prevention, detection, mitigation and investigation of fraud, security breaches and other prohibited or unlawful activities, including assessment of corresponding risks (e.g. using captchas), unless there is a statutory obligation to this effect.
Monitoring and improvement of the information security of our Services, unless there is a statutory obligation to this effect.
Performance of identity checks, creditworthiness and other financial standing checks, evaluation of trade applications and comparison of information for accuracy and verification purposes.
Initiation, preparation, and execution of a company acquisition, e.g. in the event of a merger with another company or takeover by another company. If such an event occurs, we will require the merged entity to comply with this Statement with respect to your personal data.
Website Security. Protecting the security and functionality of our Websites, including using personal information you provide to investigate any complaints received from you or from others about our Websites or our products and Services.
Administrative and Business. For the general administration of our business, including accounting, recordkeeping, training, compliance auditing, research, and other operational or business purposes permitted by law. Subject to applicable law, you may have the right to object to our use of your personal data on the basis of our legitimate interest as described in section 6 of this Statement.
Use with your consent
We use personal data where you give us consent. Circumstances under which we process personal data with your consent, are in particular the following:
Personalization. Tracking use of the Website’s use (ex. the cart of a user when placing an order through the Website). Personalizing your experience and the information and content that we display to you, including marketing and promotional content.
Targeted and interest-based advertising. Targeted or interested based advertising to groups of individuals with similar interests or characteristics through services offered by third parties, such as Google Analytics or other similar tools.
Sharing your data for third party marketing.
Where consent is required by applicable law, such as sending you direct marketing in relation to our relevant products and Services or transmitting your personal data to third party social media websites.
We may share data among our Curran family of Websites for certain marketing, analyzation or advertising purposes with your consent where this is legally required. On other occasions where we ask you for consent, using the data for the purpose which we explain at the time.
We will not share your personal data with third parties for their third-party marketing or advertising purposes, nor will we sell or otherwise make it available to third parties for a fee without your consent.
You can withdraw your consent to the processing of your personal data by us at any time. As a result, we may no longer process your personal data based on this consent in the future. The withdrawal of consent has no effect on the lawfulness of processing based on consent before its withdrawal.
Our combination of your data
We may combine personal data collected automatically with data provided directly by you or from other sources for the following purposes:
to enable us to provide our Services to you;
to understand how users interact with our Services.
We may also share information among our affiliate companies, including Sisalcarpet.com. See section 3.
For other purposes compatible with one of the purposes listed above
Original Purpose. For reasons not described in this Statement where the reason is compatible with the purpose for which we originally collected your data and where such use is lawful.
We conduct balancing tests for the data processing we carry out on the basis of our legitimate interests, which we have described above.
Use of de-identified, aggregated, or anonymized data
We use de-identified, aggregated, or anonymized data to help us analyze the use of the Websites. Where permitted by law, this Statement does not limit our use or disclosure of de-identified, aggregate, or anonymous data to our partners, advertisers, and other third parties in our discretion.
3. With whom do we share data?
We will never sell any of your personal data to a third party without your consent.
We do not generally share data with third parties for third-party marketing or advertising purposes. However, we do share data (including personal data and aggregated, anonymized, and deidentified information) for the following purposes:
Curran Family of Companies. We share data with our corporate family members (including Curran Catalog LLC, Sisalcarpet.com and Curran Worldwide B.V.) and across the Websites. This enable us to provide you, with your consent as legally required, with information about products and Services, which we believe might interest you, and improve our products, Services, content, and advertising by analyzing your use of the services of other Curran corporate family members. We will also grant access to personal data to other Curran corporate family members for the aforementioned purpose.
Service Providers. We share data with certain third party service providers that assist us with payment processing, marketing and communications, advertising, and operational aspects of our business, including accounting and legal services; order fulfillment (i.e. shipping carrier, insurance) technical services and security; and development, implementation, and maintenance of the Websites and various features and tools available on the Websites (including to help you recover a forgotten password or confirm your account email).
Third-Party Marketing. We may send you information about companies that we think you may be interested in in compliance with applicable laws. We may partner with other companies to send you joint marketing materials.
Business Transactions. We may share your data with third parties in the context of acquisition, company bankruptcy or reorganization proceedings.
Consent, Other. We share data with third parties when we have your consent, or otherwise as described to you in paragraph 2 above concerning collection.
4. Third Party Websites and Services
Our Services may contain links to certain third-party websites, including social media websites such as Facebook, Pinterest, or Instagram (i.e. social plug-ins). Your access and use of any of these third-party websites are not governed by this Statement but are governed by the Privacy Policies of those third party websites. We are not responsible for your interaction with or the collection of your data by those websites after the transmission of your personal data to such social media website.
We do our best to safeguard user account information, including personal data. We maintain what we believe to be appropriate physical, electronic and managerial procedures to safeguard and secure your data and to prevent unauthorized access, maintain accuracy, and ensure appropriate use of your data. However, no one can guarantee the security of user account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user data. You should take steps to protect the security of your account, including, for instance, logging off when accessing your account on a shared computer and keeping your login details confidential.
Your account information (including personal data) is protected by a password set by you for your privacy and security. You are responsible for preventing unauthorized access to your account and personal data by selecting and protecting your password appropriately, and restricting access to your device and computer. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.
6. Your Rights as a data subject
You can change the data in your account by logging in and updating your profile data. If you change the data in your account, we may retain copies of that data in cached or archived pages to the extent required by law or as permitted by law for legitimate interest specified above. For information about our storage policy see section 10 below.
In some instances, you may be eligible to a) ask us for a copy of your personal data, b) rectify, erase, or restrict processing of your personal data, c) withdraw your consent at all times and/or d) obtain the personal data you provide to us in a structured, machine readable format. Further, you may have the right under applicable law to object to the processing of your personal data in some circumstances (e.g. if we use your data for our legitimate interests). If you would like to claim any of the above-mentioned rights, please contact firstname.lastname@example.org or you can reach us at any of the contact information provided at the bottom of this page. In addition, you also have the right to lodge a complaint with a supervisory authority.
Your rights regarding your personal data may be limited, for example, if fulfilling your request would reveal personal data about another person or would infringe the rights of a third party (including our rights), or if you ask us to delete data which we are required by law to keep or have compelling legitimate interests in keeping (as set out above). We will inform you of the relevant exemption upon which we rely when responding to any request you make.
Our use of certain personal data is necessary for us to provide information to you about our sales and Services to you through the Websites or otherwise. If you choose not to provide this personal data or request that Curran deletes or restricts the processing of this personal data, you may not be able to participate in our sales and we may not be able to provide you with other Services.
The exercise of the above-mentioned rights is generally free of charge. Where requests are manifestly unfounded or excessive, we may charge an appropriate fee (at most our actual costs) in accordance with the applicable statutory regulations or refuse to process the application.
7. Your additional rights with respect to cookies and similar technologies
8. Children under 16
9. International Transfers
We will only transfer your personal data from the European Economic Area (EEA) to third countries, i.e. countries outside the EEA, on the basis of appropriate safeguards. Third countries providing an adequate level of data protection according to the European Commission currently include Andorra, Argentina, Canada (for companies covered by the Personal Information Protection and Electronic Documents Act), Switzerland, the Faroe Islands, Guernsey, the State of Israel, the Isle of Man, Japan, Jersey, New Zealand and Uruguay. In other cases, Curran provides the necessary safeguards, e.g. through the conclusion of data protection contracts adopted by the European Commission with the recipients, and/or through other or additional measures provided for or required by law.
10. Storage duration and erasure
Your personal data will be stored by us and our service providers in accordance with applicable data protection laws to the extent necessary for the processing purposes set out in this Statement. Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render information anonymous, unless we are legally obliged to keep your personal data (e.g. for tax, accounting or auditing purposes). In Europe, the retention periods are generally between 6 and 10 years (e.g. for contracts, notifications and business letters). As far as legally permissible or required, we restrict the processing of your personal data instead of deleting it (e.g. by restricting access to it). This applies in particular to cases where we may still need the data for the execution of the contract or for the assertion of or defense against legal claims. In these cases, the duration of the restriction of processing depends on the respective statutory limitation or retention periods. The data will be deleted after the relevant limitation or retention periods have expired.
How long we retain personal data may vary depending on the Services we provide and our legal obligations under applicable national law. The following factors typically affect the retention period:
Necessity for the provision of our Services
This includes such things as executing the contracts (see our Terms of Sale, etc.) with you, maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule.
Special categories or personal data
If we store special categories of personal data, a shorter retention period is usually appropriate
Consent-based processing of personal data
If we process personal data on the basis of consent (including consent to the extended storage), we store the data for as long as necessary to process it for the purposes for which your consent was obtained.
Statutory, contractual or other similar obligations
Corresponding storage obligations may arise, for example, from laws or official orders. It may also be necessary to store personal data with regard to pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.
11. Changes to this Policy
We may modify the terms of this Statement at any time. If we do modify this Statement, we will post such changes to the Websites. You should check back from time to time in order to stay updated on any changes.
If at any time you may direct any question or concerns regarding the Statement or would like to unsubscribe from receiving future emails, you can email us at email@example.com and we will promptly remove you from ALL correspondence.
You also have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence, your place of work or the registered office of Curran and Co.
Curran and Co.
1932 First Ave., Suite 800
Seattle, WA 98101 USA
Attn: Customer Service
View the previous versions of the Statement here.