Privacy Policy

Last modified: March 5, 2010

At Beliani we recognize that privacy is important. This Privacy Policy applies to all of the products, services and websites offered by Beliani or its subsidiaries or affiliated companies; collectively, Beliani ’s “services.” In addition, where more detailed information is needed to explain our privacy practices, we post supplementary privacy notices to describe how particular services process personal information.

Beliani adheres to the US Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement

 

Information we collect and how we use it

We offer a number of services that do not require you to register for an account or provide any personal information to us. In order to provide our full range of services, we may collect the following types of information:

• Information you provide – When you sign up for a Beliani Account or other Beliani service or promotion that requires registration, we ask you for personal information (such as your name, email address and an account password). For certain services we also request credit card or other payment account information which we maintain in encrypted form on secure servers. We may combine the information you submit under your account with information from other Beliani services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.

• Cookies – When you visit Beliani , we send one or more cookies – a small file containing a string of characters – to your computer or other device that uniquely identifies your browser. We use cookies to improve the quality of our service, including for storing user preferences, improving shopping results and tracking user trends, such as how people shop. We may set one or more cookies in your browser when you visit a website.

• Log information – When you access Beliani services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

• User communications – When you send email or other communications to Beliani , we may retain those communications in order to process your inquiries, respond to your requests and improve our services.

• Affiliated Beliani Services on other sites – We offer some of our services on or through other web sites. Personal information that you provide to those sites may be sent to Beliani in order to deliver the service. We process such information under this Privacy Policy. The affiliated sites through which our services are offered may have different privacy practices and we encourage you to read their privacy policies.

• Gadgets – Beliani may make available third party applications through its services. The information collected by Beliani when you enable a gadget or other application is processed under this Privacy Policy. Information collected by the application or gadget provider is governed by their privacy policies.

• Location data – Beliani offers location-enabled services. If you use those services, Beliani may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location (such as a cell ID).

• Links – Beliani may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our shopping technology, customized content and advertising.

Beliani only processes personal information for the purposes described in this Privacy Policy and/or the supplementary privacy notices for specific services. In addition to the above, such purposes include:

• Providing our services, including the display of customized content and advertising;

• Auditing, research and analysis in order to maintain, protect and improve our services;

• Ensuring the technical functioning of our network;

• Protecting the rights or property of Beliani or our users; and

• Developing new services.

Beliani processes personal information on our servers in the United States of America and in other countries. In some cases, we process personal information on a server outside your own country. We may process personal information to provide our own services. In some cases, we may process personal information on behalf of and according to the instructions of a third party.

 

Choices for personal information

When you sign up for a particular service that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.

If we propose to use personal information for any purposes other than those described in this Privacy Policy and/or in the specific service privacy notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Privacy Policy and/or in the supplementary service privacy notices, unless we have obtained your prior consent.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Beliani features and services may not function properly if your cookies are disabled.

You can decline to submit personal information to any of our services, in which case Beliani may not be able to provide those services to you.

 

Information sharing

Beliani only shares personal information with other companies or individuals outside of Beliani in the following limited circumstances:

• We have your consent. We require opt-in consent for the sharing of any sensitive personal information.

• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Beliani , its users or the public as required or permitted by law.

If Beliani becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice before personal information is transferred and becomes subject to a different privacy policy.

We may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who shopped for a particular product, for example, or how many users clicked on a particular product. Such information does not identify you individually.

 

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to Beliani employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

 

Data integrity

Beliani processes personal information only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services or as otherwise permitted under this Policy. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

 

Accessing and updating personal information

When you use Beliani services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. Some of our services have different procedures to access, correct or delete users’ personal information. We provide the details for these procedures in the specific privacy notices or FAQs for these services.

 

Enforcement

Beliani regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or Beliani ’s treatment of personal information by contacting us through this web site.

When we receive formal written complaints, it is Beliani ’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Beliani and an individual.

 

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). Each version of this Privacy Policy will be identified at the top of the page by its effective date.

If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time through this web site.

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