Last update: 15/01/2024

1. Introduction

1.1 This Privacy Policy explains how we use the personal data you provide us when you use our website www.theoceanstraw.com (“Website”) or the different services available on our Website (“Services”), and the safeguards we use to protect it. The Ocean Straw Group AB is the data processor in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR).

1.2 Our Website may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

1.3 We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our Website, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Website is deemed to be acceptance of such changes, so please check periodically for updates.

1.4 You have the right to make a complaint at any time to the Swedish Authority for Privacy Protection (https://www.imy.se/en/). We would, however, appreciate the chance to deal with your concerns before you approach the Swedish Authority for Privacy Protection so please contact us in the first instance. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.5 If you have any comments on this Privacy Policy, please email them to support@theoceanstraw.com

2. Who We Are

2.1 Our company name is The Ocean Straw Group AB, org.nr 559250-6348 - Nattvindsgatan 4 - 652 21 Karlstad - Sweden.

2.2 We respect your right to privacy and will only process personal information provided by you in accordance with the GDPR and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time.

3. What Data We May Collect

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 We may collect, use, store and transfer different kinds of personal data provided by you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier. When you use our Website, email, phone, live chat or otherwise, we may collect information such as your first name, last name, email address and phone number.
• Contact Data includes billing address, invoicing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments and other details about products you may have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
• Profile Data includes your username and password, orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Interaction Data includes any information that you might provide to any blogs or discussion forums on our Website.
• Cookies Data like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our websites. Please refer to the “Cookie” section below for information about cookies and how we use them and what kind.
• Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.
• Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

3.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3.5 Under the GDPR, we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

a) You have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of an order or contract to which you are a party or in order to take necessary steps to process your order;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is not of legal age.

3.6 If we receive personal information in the course of providing our Services to you from another data subject, we expect you to have complete responsibility for ensuring that the contents of this Privacy Policy are brought to their attention and you have obtained their consent in the process.

3.7 In some instances, it may be appropriate for us to combine your information with other information that we may be holding about you, such as combining your name with your geographic location or your browsing or purchasing history.

4. How We May Collect and Use Your Data

4.1 We (or third party data processors, agents and subcontractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

a) present Website content;
b) use any of our Services;
c) create an account on our Website;
d) subscribe to our Services or publications;
e) request marketing to be sent to you;
f) enter a competition, promotion or survey; or
g) give us some feedback.

4.2 In addition to the above, we may use the information in the following ways:

a) To personalise your Website experience and to allow us to deliver the type of content and product offerings in which you are most interested.
b) To administer a contest, promotion, survey or other site feature.
c) If you have opted-in to receive a newsletter, we may send you periodic e-mails. If you have not opted-in to receive a newsletters, you will not receive these e-mails. Visitors who register or participate in other site features such as marketing programs and ‘members-only’ content will be given a choice whether they would like to be on our e-mail list and receive e-mail communications from us.
d) Present Website content effectively to you.
e) Provide information, and services that you request, or (with your consent) which we think may interest you.
f) Carry out your orders or our contracts with you.
g) Provide the relevant Services to you
h) Tell you our charges.

4.3 If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you. If you are a new customer, you will only be contacted if you agree to it.

4.4 We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.

4.5 In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section, you can let us know at any time by contacting us at support@theoceanstraw.com and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible products and services to you.

4.6 In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don’t provide your personal data in these cases.

4.7 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

a) Where we need to process your order or otherwise perform a contract we are about to enter into or have entered into with you.
b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
c) Where we need to comply with a legal or regulatory obligation.

4.8 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at support@theoceanstraw.com, and we will either delete your data from our systems or move your data to our “unsubscribe list”. However, you acknowledge this will limit our ability to provide the best possible services to you.

4.9 As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may lead to us contacting you by email, sms and/or telephone with information, news and offers on our Services. We agree that we will not do anything that we have not agreed to under this Privacy Policy, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR.

5. Cookies

5.1 All cookies used by and on our Website are used in accordance with current GDPR and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time. We use cookies to distinguish users and improve our Website.

5.2 A cookie is a small data file sent from our Website and stored on your computer. We can use four different types of cookies on our Website.

a) Strictly necessary cookies: These cookies are strictly necessary for our Website to function properly. Without these cookies, we cannot guarantee that you will be able to navigate around our website.
b) Functionality cookies: These cookies remember the choices you make on our Website to improve your experience.
c) Performance cookies: These are cookies that allow us to understand how our visitors use and interact with our Website. We use this information to help us improve our Website so that we can offer you the best possible user experience. These cookies are not linked to personal information about you.
d) Targeting / advertising cookies: These cookies are used to display advertisements that are relevant to you on other websites you may visit. They are placed on our Website by third-party advertising networks on our behalf and with our permission.

5.3 By using our Website, you consent to our use of cookies. We use cookies for several reasons, such as helping us see which features are most popular, counting visitors to a page, improving the user experience, keeping our services secure and simply giving you a better, more intuitive and satisfying experience. Cookies we use usually fall into one of the above mentioned categories.

5.4 Your browser or device may allow you to block or otherwise limit the use of cookies. However, cookies are an important part of how our Website and Services work, so removing, rejecting or limiting their use may affect the availability and functionality of our Website and Services.

5.5 Browser Cookies: Your browser may give you the option to refuse some or all of the browser cookies. You may also be able to remove cookies from your browser. For more information on how to manage your browser cookies, follow the instructions provided by your browser.

5.6 Mobile device identifiers: The mobile operating system may allow you to opt out of having certain device identifiers used for interest-based advertising. You should refer to the instructions provided by the manufacturer of your mobile device. This information is usually available under the "settings" function of the mobile device.

6. Where We Store Your Data and Security

6.1 We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfill your order and to receive our Services and deal with payment. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved model contractual arrangements. Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the EEA if it is necessary for us to do so.

6.2 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see the European Commission: EU-US Privacy Shield.

6.3 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

6.4 We have in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6.5 By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

6.6 Any payments made by you, will be encrypted.

6.7 We have implemented security measures such as a firewall to protect any data and maintain a high level of security.

6.8 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.

6.9 If we give you a password upon registration on our Website, you must keep it confidential. Please don’t share it.

6.10 We will keep personal data for as long as is necessary, which is usually the life of our relationship and up to a period of seven years after our relationship has ended. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

7. Disclosing Your Information

7.1 We are allowed to disclose your information in the following cases:

7.2 We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data.

7.3 Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the GDPR.

8. Your Rights

8.1 When you submit information via our Website, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided above in this Privacy Policy.

8.2 Under the GDPR, you have the right to:

• request access to, deletion of or correction of, your personal data held by us at no cost to you;
• request that your personal data be transferred to another person (data portability);
• be informed of what data processing is taking place;
• restrict processing;
• to object to processing of your personal data; and
• complain to a supervisory authority.

8.3 You also have rights with respect to automated decision-making and profiling as set out in section 10 below.

8.4 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

8.5 To enforce any of the foregoing rights or if you have any other questions about our Website or this Privacy Policy, please contact us at support@theoceanstraw.com 

9. Links to Other Sites - Changes

9.1 Please note that our Privacy Policy will not apply to other websites that you may visit via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

9.2 If we change our Privacy Policy, we will post the changes on this page. If we decide to, we may also email you.

10. Automated Decision-making and Profiling

10.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.

10.2 The right described in section 10.1 does not apply in the following circumstances:

a) the decision is necessary for the performance of an order or for the
entry into, or performance of, a contract between you and us; or
b) the decision is authorised by law; or
c) you have given you explicit consent.

10.3 Where we use your personal data for profiling purposes, the following shall apply:

a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk
of errors and to enable such errors to be easily corrected shall be implemented;
d) All personal data processed for profiling purposes shall be secured in
order to prevent discriminatory effects arising out of profiling.

11. Terms of Use & Service

11.1 Please also visit our Terms of Use & Service at: https://theoceanstraw.com/pages/terms

12. Dispute Resolution

12.1 This Privacy Policy shall be construed in accordance with and governed by Swedish law. Any dispute arising out of or in connection with this Privacy Policy shall be settled, if possible by friendly negotiation and in good faith. If settlement cannot be reached by negotiation, the dispute shall be finally brought to the courts of Karlstad, Sweden, and each party waives any right to object to an action being brought in those courts, including on the basis of an inconvenient forum or those courts not having jurisdiction.

12.2 Any dispute shall not affect your or our ongoing obligations under this Privacy Policy.