Effective date: 10/6/2020

This Privacy Policy covers the practices of Baram International Co. Ltd., d/b/a Dear Dahlia (“Dear Dahlia,” “we,” “us,” or “our”) concerning information we obtain in connection with our European and United Kingdom websites that link to this Privacy Policy and the services available through those websites (collectively, the “Services”).

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

This Privacy Policy contains the following sections:

• The information we collect

• How we use your information

• Legal bases for use of your information

• Cookies and similar technologies

• Online analytics and advertising

• How we share and disclose your information

• Retention of your information

• Data subject rights and your choices

• Third-party links and features

• Children’s privacy

• International Data Transfers

• How we protect your information

• Employment applications

• Changes to our Privacy Policy

• Contact information

THE INFORMATION WE COLLECT

We obtain information about you through the means discussed below when you access and use the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use our Services.
 

1. Information you provide to us

Dear Dahlia collects a variety of information that you provide directly to us. For example, we collect information from you through:

• Processing your orders
• Requests or questions you submit to us via forms or email
• Your communications and dealings with us (including on the Services, on third-party social media sites and by mail or email)
• The Services that you use
• Your participation in Dear Dahlia sweepstakes, contests or research
• Any reviews that you submit about the Services and Dear Dahlia products
• Employment applications
• Account and product registration and administration of your account
• Uploads or posts to the Services
• Requests for customer support and technical assistance

 

Information about you. The specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you include:

• Name, address, telephone number, and email address
• Login credentials, if you create a Dear Dahlia account
• Billing information, such as delivery address, credit or debit card number, and expiry date
• Information about purchases or other transactions with us
• Information about your customer service and maintenance interactions with us
• Demographic information such as your age range and date and month of birth
• If you choose to participate in a Dear Dahlia research study related to our products and services, information provided in connection with such research
• User-generated content you post (e.g. product reviews, comments, and other posts to our Services)

 

Information about others. If you request that your Dear Dahlia purchase be delivered to someone other than yourself (such as a gift recipient), we use the information you provide about the other person to fulfil the delivery.

 

2. Information we collect through automated means

When you use our Services, we collect certain information about your use of and interaction with the Services as described in this Section. We and our service providers (which are third-party companies that work on our behalf) may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.

When you use the Services, we collect and analyze information such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites, the date and time you used the Services and upload or post content, error logs, and other similar information. We and our service providers may also automatically collect general location information (e.g. IP address, city/state and/or postal code associated with an IP address) from your computer or mobile device. This information allows us to enable access to content that varies based on a user’s general location.

 

3. Information We Collect from Social Media and Other Platforms

If you access the Services through a third-party connection or login (e.g. through a social network such as Facebook or Google), you may allow us to have access to and store certain information from your social network profile. This may include your gender, profile picture, and your list of friends, depending on your settings on such services. If you do not wish to have this information shared, do not use a social networking connection to access the Services. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings.

 

4. Information we collect from others

Dear Dahlia may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve Dear Dahlia’s products, analytics, and advertising.

 

HOW WE USE YOUR INFORMATION

We, or our service providers, use your information for various business and operational purposes depending on the types of information we have collected from and about you and the specific Dear Dahlia Services you use, in order to:

• Complete a purchase or provide the Services you have requested, including invoicing and accounting
• Respond to your requests for information and provide you with more effective and efficient customer service
• Provide you with updates and information about products you have purchased from us
• Review and process employment applications, as discussed further below in the “Employment applications” section
• Contact you by email or postal mail regarding Dear Dahlia and third-party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you
• Customize the advertising and content on the Services
• Help us better understand your interests and needs, and improve the Services
• Engage in analysis, research and reports regarding use of our Services
• Synthesize and derive insights from your use of different Services
• Provide, manage, and improve the Services and their performance, and test and create new products and services
• Secure our website and products
• Comply with any procedures, laws and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
• Establish, exercise or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others

Combined information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

Aggregate/anonymous data. We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

LEGAL BASES FOR USE OF YOUR INFORMATION

The legal bases for using your information as set out in this Privacy Policy are as follows:

• Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the Terms of Service ; and/or our Terms of Sale); or
• Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Services or products; operate our business and our Services; ensure safe environments for our staff; make and receive payments; comply with legal requirements and defend our legal rights; and prevent fraud and know the customer to whom we are providing Services).
• Where we have your consent, in accordance with applicable legal requirements, to use your information for a particular purpose.
• Where we use your information to comply with applicable legal obligations (for example, keeping track of purchases for tax and auditing purposes).

COOKIES AND SIMILAR TECHNOLOGIES

To collect the information in the “Information we automatically collect” section above, we and our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels and other similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.

• A cookie is a small text file that is placed on your computer or mobile device when you visit a site, which enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services that you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
• Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or emails that are designed to: (1) collect usage information like ad impressions or clicks and email open rates; (2) measure popularity of the Services and associated advertising; and (3) access user cookies.

As we adopt additional technologies, we may also gather information through other methods.

For more information on how to change your cookie settings, as well as the cookies we use and the purposes for which we use them, please refer to our Cookies Notice.

ONLINE ANALYTICS AND ADVERTISING

1. Analytics

We may use third-party web analytics services (e.g., Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on.

If you receive emails from us, we may use certain analytics tools, such as clear GIFs, to capture data such as when you open our messages or click on any links or banners contained in our emails. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

2. Online advertising

The Services may integrate third-party advertising technologies that allow for the delivery of relevant content on the Services, as well as relevant content and advertising on other websites you visit and other applications you use. The ads may be based on various factors, such as the content of the page you are visiting, your searches, and demographic data. These ads may be based on your current activity or your activity over time and across other websites and online services, and may be tailored to your interests.

Third parties, whose products or services are accessible or advertised via the Services, may also place cookies or other tracking technologies on your computer, mobile phone or other device to collect information about you as discussed above. We also allow other third parties (e.g. ad networks and ad servers such as Google) to serve tailored ads to you on other sites and to access their own cookies or other tracking technologies on your computer, mobile phone or other device you use to access the Services. We sometimes provide our customer information (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on the device you use to access the Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit Your Online Choices to opt out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the opt-out choices above, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.

HOW WE SHARE AND DISCLOSE YOUR INFORMATION

Dear Dahlia will share your information in the following ways:

• Affiliates and subsidiaries. We may share information we collect within the Dear Dahlia family of companies (e.g. Dear Dahlia’s US subsidiary) to deliver products and services to you, ensure a consistent level of service across our products and Services, and enhance our products, services, and your customer experience.
• Service providers. We provide access to or share your information with selected third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, marketing, advertising, analytics, research, customer service, delivery and fulfilment, data storage, security, fraud prevention, payment processing and legal services.
• Protection of Dear Dahlia and others. By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good-faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Dear Dahlia, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention and similar purposes.
• Business transfers. As we continue to develop our business, we may buy, merge with or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of Dear Dahlia’s assets are sold or transferred to a third party, customer information (including your email address) is likely to be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, Dear Dahlia will comply with such restrictions.
• Your Consent. If you have consented to our sharing of your information, we will also share your information consistent with your consent.

From time to time, Dear Dahlia may share Aggregate/De-Identified Information about use of the Services, such as by publishing a report on usage trends. The sharing of such data is unrestricted.

RETENTION OF YOUR INFORMATION

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

DATA SUBJECT RIGHTS AND YOUR CHOICES

You have certain rights with respect to your information as further described in this section.

1. Your legal rights

If you are a citizen of the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you may request that we:

• Provide access to and/or a copy of certain information we hold about you
• Prevent the processing of your information for direct marketing purposes (including any direct marketing processing based on profiling)
• Update or rectify information which is out of date or incorrect
• Delete certain information that we are holding about you
• Oppose, cancel, or restrict the way that we process and disclose certain information
• Transfer your information to a third-party provider of services
• Revoke your consent for the processing of your information

To exercise any of your rights please email us at privacy@deardahlia.com and include “EU Data Subject Request” in the subject line.

Please note your rights vary depending upon your location, and that we may request you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you or to comply with a legal obligation. In some circumstances if you still ask us to delete your information, you may no longer be able to access or use our Services.

2. Marketing communications and sharing

You may instruct us not to use your contact information to contact you by email or postal mail regarding products, services, promotions, and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational communications, such as those reflecting our relationship or transactions with you.

THIRD-PARTY LINKS AND FEATURES

The Services may connect with third-party websites (e.g. social media sites like Facebook and Twitter) and third-party plug-ins (e.g., the Facebook “like” button and Twitter “follow” button). If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally, depending on how their services function. Dear Dahlia is not responsible for the content or practices of such third-party websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

CHILDREN’S PRIVACY

We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

INTERNATIONAL DATA TRANSFERS

Please note that in providing services to you, Dear Dahlia may subcontract the processing of your data to, or otherwise share your data with, other members within the Dear Dahlia group, trusted service providers and trusted business partners in countries other than your country of residence, including the United States and Korea, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.

If you live in the EEA, please note that if we provide any information about you to any non-EEA members of our group or third-party information processors, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses in accordance with EU and other data protection laws to govern the transfers of such data. For more information, please contact us as detailed in the “Contact information” section below.

If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

HOW WE PROTECT YOUR INFORMATION

Dear Dahlia takes technical and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through or on our Services, or via the Internet, and that any such transmission is at your own risk.

Where we have given you (or where you have chosen) a password which enables you to access a Dear Dahlia account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

EMPLOYMENT APPLICATIONS

The Services may contain careers sections that link to websites where you can apply for employment at Dear Dahlia. As part of the recruitment process, Dear Dahlia collects a variety of information, including your contact information and your job qualifications. Dear Dahlia will use and share the information you provide through the recruitment process only for employment purposes, such as evaluating you for a job opportunity or communicating with you about your interests, and where sharing is required by law. If you have any questions about the handling of your employment application data, please contact us through one of the methods described in the “Contact Information” section below.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review the Policy periodically. You can find out if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

CONTACT INFORMATION

If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please email us at privacy@deardahlia.com or use the contact details below:

DEAR DAHLIA / BARAM International Co.,LTD

Attn: Legal Team

12F, Horim Art Center

317, Dosan-daero

Gangnam-gu, Seoul, Korea