Privacy Policy

Last Updated: January, 14th 2022

 

Who are we?

We are lemlem (“we”, “us” “lemlem”), an artisan-driven brand of beautiful resort wear made entirely and responsibly in Africa with a core mission of preserving the local art of weaving in Ethiopia and inspiring economic growth on the continent. We offer our products through our website at lemlem.com and through other retailers and stores around the world.

 

What does this Policy cover?

This Privacy Policy explains our use of personal information processed through the website and if you otherwise choose to contact us. By “personal information” we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or, under some laws, household. This is sometimes referred to as personal data.

 

What personal information do we collect and why do we use it?

The table below explains who we collect personal information about, what that personal information is and the purpose we process it for. The last column sets out the ‘lawful basis’ we rely on for processing that personal information which is a requirement of UK and European data protection rules when we process the personal information of individuals based there. Essentially, companies may only process personal information if they can identify a lawful basis from a list set out in the legislation.

 

Individual

Personal information

Source and Purpose

Lawful Basis for Processing

Customers

Contact and delivery details and purchase choices.

We don’t store your payment details since our website uses third party payment providers including: Shopify Payments, Shop Pay Instalments, Afterpay, Stripe, ApplePay and Returnly. You can also make payments through Apple Pay, Facebook Pay and Google Pay, but similarly this does not store your payment information.  

This information is given to us by you.

Fulfilment of the purchase contract with you.

Compliance with consumer and accounting and tax laws.

Customers and potential customers

Email address and telephone numbers.

This information is given to us by you. We use it to send you email and SMS promotions and updates.

We will only send such emails and SMS with your consent. You can unsubscribe at any time by following the unsubscribe link or writing to us at shop@lemlem.com.

Individuals who contact us with general queries

 

Contact details provided and correspondence.

This information is given to us by you.

It is used to respond to the query and keep a record of it.

Our legitimate interests as a business in responding to and keeping a record of correspondence.

Website visitors

Information from cookies. For more details see later in this Privacy Policy.

This information is collected via the cookies when you use our website.

We only install non-essential cookies with your consent. We use essential cookies based on our legitimate interests and contract of providing the website and services to you.

Suppliers and contractors

Contact details and provided correspondence.

This information is given to us by you or from publicly available information (for example on your website).

 

It is used for us to fulfil contracts and engage in business discussions.

Our legitimate interests as a business in responding to and keeping a record of correspondence. Some information is also necessary for us to perform our contract – for example certain contact details.

 

Where we have indicated in the table above that we rely on legitimate interests for processing of personal information, we carry out a ‘balancing’ test to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. You can contact us for more details using the details below.

 

How long do we keep your personal information for?

We keep your information only for as long as is necessary for the relevant purpose. For example, if we have a contract with you, this will be retained for the relevant contract limitation period to assist with any contractual claims. We use a number of criteria for determining the retention period including obligations under law, our need to defend or bring contractual claims within the statutory limitation period and consideration of the original purpose we collected it for.

 

 

Who do we share your personal information with?

Data may be shared in the following circumstances:

  • With professional advisors;
  • In the event of a sale or potential sale of the company or its assets;
  • With suppliers, contractors, and third party service providers, but only subject to robust contractual protections;
  • Other companies in our group;
  • If required to do so by law or regulation, or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process; (b) protect and defend the rights or property of lemlem; or (c) act under exigent circumstances to protect the personal safety of users of lemlem or the public.

 

What happens if you do not provide us with the information we request or ask that we stop processing your information?

If you do not provide personal information which is necessary, we may not be able to respond to your query or provide our products to you. In the case of email and SMS marketing and non-essential cookies, you can choose to refuse or stop the processing at any time.

 

Do we use cookies or other similar technologies?

Yes, we use cookies or similar technologies on our website for a variety of purposes including to ensure the website and ecommerce functions work, as well as for analytics and advertising. You can find out more about the specific cookies we use and manage your preferences through our cookie consent management solution on our website. This is presented to you when you first visit the site or visit in incognito mode, but you can also change your preferences any time via the website or through your browser settings. We always ask for your consent before deploying any non-essential cookies or similar technology.

 

Do we make automated decisions concerning you?

Automated decisions are decisions made without human intervention. We do not carry out this type of processing activity.

 

Do we transfer your data overseas?

We are a US based company and will process your personal information in the US. From time to time, we may also use suppliers and fulfilment providers who are based in other countries. We ensure that appropriate contractual protections are in place with such third parties in line with applicable law including appropriate EU/UK standard contractual clauses where necessary. Please contact us if you would like more details about our safeguards for data transfers.

 

How we respond to do-not-track signals?

At this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include Do-Not-Track instructions.

 

What rights do you have in relation to the data we hold on you?

By law, you have a number of rights when it comes to your personal information. Further information and advice about your rights can be obtained from the data protection regulator in your country. The rights you have depend on the jurisdiction in which you are based and we have set these out in the table below.

For all rights, we usually act on requests and provide information free of charge, but, where allowed under the law, may charge a reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or
  • further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request in some circumstances.

 

Rights for individuals in the UK and European Union

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

 

Rights

What does this mean?

1.         The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy. If you have any additional questions, for example regarding transfers and locations of data or our legitimate interests basis, do please get in touch.

2.         The right of access

You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Privacy Policy).

This is so you’re aware and can check that we’re using your information in accordance with data protection law.

3.         The right to rectification

You are entitled to have your information corrected if its inaccurate or incomplete.

4.         The right to erasure

This is also known as the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right, there are exceptions.

5.         The right to restrict processing

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

6.         The right to data portability

You have rights to obtain and reuse your personal information for your own purposes across different services. This is not a normal scenario for companies of our nature but if you have any questions you can contact us.

7.         The right to object to processing

You have the right to object to certain types of processing, including processing for direct marketing or where we are relying on our legitimate interests for processing (e.g. if you no longer want to be contacted with potential role opportunities.

8.         The right to lodge a complaint

You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator.

9.         The right to withdraw consent

 

If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal information for marketing purposes.

 

 

Rights for individuals in California

The California Consumer Privacy Act (“CCPA”) provides California residents with the following rights related to their personal information:

  

Rights

What does this mean?

1.         The right to know

You have the right to request that we disclose certain information about our collection and use of personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, the categories of third parties with whom we share such information, and information about our sale or disclosure for business purposes of your personal information to third parties. Much of this information is provided above in this Privacy Policy.

2.         The right to delete

You have the right to request that we delete any of the personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

3.         The right to opt-out of sale

California residents have the right to opt-out of the sale of their personal information to third parties. We do not sell the personal information of anyone we know to be under the age of 16 without affirmative authorization.

4.         The right to non-discrimination

California residents have the right to not be discriminated against for exercising any of these rights.

 

If you would like to exercise one or more of the above rights, please contact us by email to shop@lemlem.com. We may need you to provide additional information to verify your request, such as providing certain data elements so that we can confirm they match the personal information already maintained by us. We will not use this additional information for anything other than handling your request. You may designate an authorized agent to make a request in certain circumstances on your behalf. We will endeavor to respond to all such requests within forty-five (45) days, although there may be a brief delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If we require more time, we will inform you of the reason and extension period in writing.

 

Additionally, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request and obtain from us, free of charge, information about the Personal Information (if any) we have shared with third parties during the immediately preceding calendar year for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. California residents who would like to make such a request may send an email with the subject line “California Shine the Light Request” to shop@lemlem.com. The request should attest to the fact that the requester is a California resident, and provide a current California address. We are only required to respond to a customer request once during any calendar year. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.

 

Rights for individuals in Nevada 

Nevada law gives Nevada consumers the right to request that a company not sell their Personal Information for monetary consideration to certain other parties. This right applies even if their Personal Information is not currently being sold.  If you are a Nevada consumer and wish to exercise this right, please send an email with the subject line “Nevada Resident Do Not Sell Request” to shop@lemlem.com.

 

Updating this privacy policy 

This Privacy Policy may be updated periodically to reflect changes in personal data protection legislation and best practices. When we make changes to this Privacy Policy, we will change the "last updated" date above and will notify you of any significant changes to this Privacy Policy

 

How can you contact us?

If you are unhappy with how we’ve handled your information or have further questions on the processing of your personal information, please contact us at shop@lemlem.com or or write to us at 247 Centre Street, New York, NY 10013.

 For more information on:

- CCPA-CPRA Compliance, please visit this page;

- VCDPA Compliance, please visit this page;

- PIPEDA Compliance, please visit this page.

- GDPR Compliance, please visit this page;

 

If you are based in the EU or the UK you also have the option to contact our respective representatives as follows:

UK Representative: lemlemUKRep@datarologie.com / Broadgate Tower, 20 Primrose Street, London, EC2A 2RS

EU Representative: lemlemEURep@datarologie.com / 112 Avenue Kléber, Paris, 75116, France