Privacy policy

PRIVACY NOTICE

Last updated: [Date of publication should be included here/to be updated each time changes are made]

IVINA BOUTIQUE LTD (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This privacy notice (“Privacy Notice”) explains how we collect, use, and share your personal data when you visit our website or purchase products from our online store.

This Privacy Policy applies to (a) persons who visit or make purchases from our online store, (b) existing employees, (c) prospective employees, and (d) individuals whose personal data we may process in connection with providing our products to third parties (including, without limitation, service providers, partners, or vendors). References in this Privacy Policy to “you”, “your” or “yours” should be construed as references to the foregoing individuals.

To the extent applicable, this Privacy Policy should be considered and read in conjunction with our Terms & Conditions and any other agreement which you may have in place with us (such as an employment agreement).

1.     IDENTITY OF DATA CONTROLLER

• Company Name: IVINA BOUTIQUE LTD
• Registered Address: Arch. Kyprianou & Agiou Antreou, 1, LOUCAIDES BUILDING, 2^nd floor, Flat/Office 21, 3036, Limassol, Cyprus
• Email: [Insert email]
• Phone: [Insert phone]

We are the data controller for the personal data you provide to us.

2.     PERSONAL DATA WE COLLECT[AGE1] 

We commonly collect the following  categories of personal data for the following purposes:

Category of Data	Typical Examples	Purposes / Why We Use It
Identification Data	Full name	To identify you, create and maintain your account, manage orders, and exercise or defend legal claims if needed.
Contact Data	Email address, telephone number, shipping address, billing address	To communicate with you about orders, deliveries, returns, support matters; to ship products to you; to respond to enquiries, complaints or requests you may have. To enable us to exercise or defend legal claims, if needed.
Payment & Billing Data	Payment card information, PayPal or other payment‑provider info or billing data	To process payments and refunds securely via third‑party payment providers; to maintain accounting records and comply with our legal/tax obligations; to handle refunds/returns or chargebacks; to defend legal claims, if needed.
Order & Transaction Data	Order history, items purchased, purchase date, amounts, delivery status, returns/returns history	To fulfill orders, to manage deliveries and returns, to support warranty or guarantee claims; for record‑keeping and possible legal claims or disputes.
Website & Technical Data	IP address, device/browser type, cookies, session data, browsing behaviour, analytics data	To improve website functionality, user experience, and security (prevent fraud, detect abuse); to analyse traffic & usage patterns; to customise website display and performance.
Communications & Support Data	Emails or chat records with customer service, support tickets, complaints, feedback, delivery issues	To respond to queries, handle complaints, support returns or warranty claims, and to document interactions (useful in dispute resolution or legal claims).
Legal & Compliance Data	Records necessary for tax, accounting, shipping logistics, invoicing, compliance with local and EU laws which apply to us; documentation of orders/returns/communications; logs of consent /changes	To satisfy legal and any applicable regulatory obligations; to keep records for auditing, warranty periods, potential disputes; to enable us to exercise or defend legal claims; for tax and financial compliance.
Marketing Data (optional / with your consent)	Newsletter subscription status, marketing preferences, past purchase preferences, consent records	To send promotional emails/offers/newsletters — only if you have obtained explicit consent; to tailor marketing content based on preferences; to manage opt‑out/unsubscribe requests.[AGE2]
Security & Fraud Prevention Data	Payment verification data, device/browser fingerprints, transaction history, IP logs, past user behaviour	To detect and prevent fraud, unauthorised access or abuse; to secure transactions and protect all users; to comply with applicable laws and regulations; to preserve our legitimate interests.

3.     LEGAL BASIS FOR PROCESSING:

We most commonly rely on the following legal grounds when processing your personal data, depending on the purpose of processing:

Lawful basis	Example when we rely on it (in our online boutique)
Performance of contract	When you place an order — we process your name, address, payment, shipping info, order history etc., because that data is necessary to fulfil the purchase contract (including to ship items, process payment, manage returns).
Legal obligation	We retain billing, payment, and transaction data after purchase to comply with accounting, tax, VAT, or other legal/regulatory obligations imposed on us under Cyprus/EU law.
Consent	When you opt‑in / give explicit consent for cookies or tracking that are not strictly necessary (e.g. analytics cookies, marketing cookies, third‑party cookies), or when you subscribe to newsletters or marketing communications.
Legitimate interests	For necessary business operations not strictly related to contract performance — e.g. website analytics, fraud prevention, site security, improving user experience, customer-support efficiency, maintaining records in case of disputes or warranty/returns claims. Provided those interests are balanced against your rights and freedoms.

4.     HOW WE SHARE YOUR DATA

We may share your personal data with the following categories of recipients and for the following purposes:

Recipient / Category of Recipient	Purpose for Sharing
Payment service providers (e.g. payment processors)	To process payments, complete your orders, and handle refunds or returns.
Delivery / shipping companies (couriers)	To arrange and fulfill shipment and delivery of the goods you ordered.
IT, hosting and infrastructure providers	To host and maintain our website, store data securely, run our online store, and provide technical support.
Customer‑service, returns, or logistics partners	To handle customer support, returns, exchanges, warranty or guarantee claims, complaints, or after‑sales services.
Analytics and website‑performance providers (e.g. for site analytics, cookies, performance monitoring) — only if you consent (where required)	To analyse website traffic and usage, improve site functionality, security, and user experience.
Marketing / email‑newsletter service providers — only if you have consented	To send you promotional emails, offers, newsletters, or marketing communications, if and only if you opted in.
Authorities, tax or accounting professionals, auditors (when required)	To comply with legal obligations — accounting, taxation, financial reporting, invoicing.
Any third‑party required for legal or compliance purposes (e.g. to defend or assert legal claims)	To protect our legal interests and fulfil legal obligations and when required to establish, exercise or defend legal claims.

We do not sell or lease your personal data to unrelated third parties for their independent marketing purposes[AGE3] .

If we need to transfer personal data outside the European Economic Area (EEA), we will only do so where adequate safeguards are in place (e.g. standard contractual clauses, adequacy decision, or your explicit consent), and we will inform you about this with relevant detail before the transfer.

5. DATA RETENTION[AGE4] 

We retain personal data only for as long as needed to fulfil the purposes for which it was collected (such as processing orders, payments, deliveries, customer service, returns or warranty handling, and running our website), or for as long as required by applicable law. Once the relevant purpose is achieved, we securely delete or anonymize the data — unless retention is necessary to comply with our legal obligations, or to allow us to exercise or defend legal rights, warranties, returns or accounting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

6. YOUR RIGHTS

Subject to applicable law and any relevant exemptions, you have the following rights regarding your personal data:

1.     Access: You may request a copy of the personal data we hold about you.

2.     Correction: You may ask us to correct or complete any inaccurate or incomplete personal data.

3.     Deletion: In certain circumstances, you may request that we delete your personal data. We may retain data where we are legally required to do so.

4.     Restriction / Objection: In certain circumstances, you may object to how we process your personal data or request that we restrict its processing.

5.     Withdrawal of consent: If we rely on your consent to process your personal data, you may withdraw that consent at any time.

6.     Data portability: You may request a machine-readable copy of the personal data you have provided to us, where it is processed by automated means and based on your consent or necessary for a contract with you.

We work to address all legitimate rights requests within the required legal timeframe. If a request is especially complex, the law may allow us extra time, and we’ll let you know if that’s the case.

If you have any questions about your rights or wish to exercise any of these rights, please contact us at: [please insert link or contact email].

7. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies to operate and secure our website, enhance your browsing experience, analyze site traffic, and support our marketing activities.

Consent: Where required by law, we will request your explicit consent before placing non-essential cookies (such as analytics or advertising cookies) on your device. Essential cookies—strictly necessary for the website to function—are always active and do not require consent.

Managing your preferences: You can manage, accept, or withdraw your consent for non-essential cookies at any time via our cookie management tool available on the website. Additionally, you can adjust your browser settings to block or delete cookies, though some cookies may remain necessary for certain website functions.

For detailed information about the types of cookies we use, their purposes, legal bases, and retention periods, please see our Cookie Notice[AGE5]  available on our website.

8. SECURITY OF YOUR DATA

We take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures are designed to ensure the confidentiality, integrity, and availability of your data.

Access to personal data is restricted to our authorized personnel and trusted service providers who require it to carry out their work. All third parties processing personal data on our behalf are required to implement similar security measures.

We regularly review and update our security practices to maintain a level of security appropriate to the risk associated with the processing of your personal data.

9. LODGING A COMPLAINT

If you believe that the processing of your personal data violates the GDPR or your rights as a data subject, you have the right to lodge a complaint with a supervisory authority.

In Cyprus, the competent supervisory authority is the Office of the Commissioner for Personal Data Protection (DPS). You can contact them at:

·       Address: Kypranoros 15, Nicosia 1061, Cyprus

·       Telephone: +357 22818456

·       Email: commissioner@dataprotection.gov.cy

·       Website: https://www.dataprotection.gov.cy

If you reside in another EU Member State, you may also contact your local data protection authority.

We encourage you to first contact us directly at [IVINA BOUTIQUE LTD, email: [contact link] with any concerns, and we will do our best to resolve the matter promptly.

10. CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time. The latest version will always be available on our website. We encourage you to check this page regularly.