We-Vibe Privacy Policy
Our mission statement
We-Vibe understands that your Personal Information is exceptionally important to you, especially given the nature of our website and the products we sell, and when you trust us with it, we have a duty to keep it safe and secure. To that end you can be assured that our data handling policies and standards are fully in line with the current data protection legislation. We-Vibe complies with all applicable data protection legislation including the General Data Protection Legislation (“GDPR”), the GDPR as it forms part of UK law by virtue of section 3 of the UK European Union (Withdrawal) Act 2018 and the UK Data Protection Act 2018 (together, “UK Data Protection Laws”) and the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).
We've prepared this policy to be completely transparent about how we collect, use, and store your information. The privacy policy, as amended from time to time (“Policy”) describes the types of personal information we may collect or that you may provide when you use our we-vibe.com website (“Website”), the products available on our website (“Products”), or otherwise in connection with our services (collectively, together with the Website and the Products, the “Services”) and our practices for collecting, using, protecting and disclosing that personal information. When you use the Website, we may ask for you to provide information by which you may be personally identified, such as, but not limited to, name, postal address, email address, telephone number, mobile device identification number, or any other identifier by which you may be contacted online or offline (“Personal Information”), or information that is about you but individually does not identify you.
What we do and don't do...
(a) We do use your Personal Information to provide you with great customer service, which includes tailoring the information we share with you to help ensure that it's relevant, useful and timely.
(b) We do respect your privacy and work hard to meet strict regulatory requirements.
(c) We do go the extra mile to protect your Personal Information.
(d) We don't sell your Personal Information to third parties; however, we may allow certain third parties (such as online advertising services) to collect your Personal Information via automated technologies and certain U.S. data protection laws may consider this to be a “sale” of personal data.
This Policy describes the following important topics relating to your information (you can click on the links to find out more):
- III. Overview
- IV. Policy
- 1. How we obtain your Personal Information;
- 2. Collection of your Personal Information and how we use it;
- 3. Legal basis for the use of your Personal Information
- 4. How will we share your Personal Information;
- 5. How do we store your Personal Information;
- 6. (UK) GDPR Privacy Rights
- 7. US State Privacy Rights
- 8. Session Replay
- 9. Children
- 10. Marketing;
- 11. How we keep your Personal Information secure;
- 12. Links to other websites;
- 13. Changes to our Policy; and
- 14. Further questions and how to make a complaint.
1. Who we are: We are We-Vibe, part of the Lovehoney Group, and we are the data controller of your Personal Information. All references in this Policy to “We-Vibe”, “our”, “us” or “we” refer to WOW Tech USA Ltd. and may include its subsidiaries and affiliates if the context so requires. All references in this Policy to “our Website”, refer to the website owned by WOW Tech USA Ltd. at we-vibe.com.
2. Our values and what this Policy is for:We value your privacy and want to be accountable and fair as well as transparent with you in the way that we collect and use your Personal Information. We also want you to know your rights in relation to your information which you can find in this Policy. In line with these values, this Policy tells you what to expect when we collect and use your Personal Information. So that you can find the information that is most relevant to you and about our relationship with you we have made our Policy easy for you to navigate. We are always looking to improve the information we provide to our customers and Website users, so if you have any feedback on this Policy, please let us know using our contact details in Section IV.14.
3. Who this policy applies to:
This policy applies to:
1. visitors to our Website;
2. persons who participate in a Campaign (as defined below); and
3. customers who create an account with us.
Depending on your relationship to us, we may collect and use your information in different ways. Please click on the links in Section II. to find out the information that we collect about you and how we use this information.
4. Your right to object:
You have various rights in respect of our use of your Personal Information as set out in Section IV. 7. Two of the fundamental rights to be aware of are:
1. You may ask us to stop using your Personal Information for marketing purposes. If you exercise this right, we will stop using your Personal Information for this purpose; and
2. You may ask us to consider any valid objections which you have to our use of your Personal Information where we process your Personal Information on the basis of our, or another person's, legitimate interest.
5. What you need to do and your confirmation to us:
Please read this Policy carefully to understand how we handle your Personal Information. By engaging with us in the ways set out in this Policy, you confirm that you have read and understood the entirety of this Policy, as it applies to you.
You may give us Personal Information about yourself by using:
- online forms provided on our Website;
- setting up an account with us
- purchasing product(s) from our Website;
- entering a competition, promotion, give-away, survey or other campaign on our Website or elsewhere (each a “Campaign”);
- contacting us by phone, email, or other means.
When you access our Website, or use the Services, technology may be used to automatically collect certain information, including, but not limited to:
- Usage Details. When you access and use the Services, we may automatically collect certain details of your access to and use of the Website, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the Website. This may include the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page.
- Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, time zone setting, browser type, browser plug-in types and versions. Web servers, the main computers that serve up web pages, automatically identify your computer by its IP address. As permitted under applicable law, we collect IP addresses for the purposes of system administration, gathering and analyzing aggregated information, creating a better experience for users and auditing the use of our site.
- Stored Information and Files. The Website also may access metadata, tags and other information associated with other files stored on your device.
The technologies we use for automatic information collection may include:
- Cookies (or mobile cookies). Please refer to Section IV. 2.2 of this Policy or the
- Web Beacons. Pages of the Website or our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
2.1 Visitors to our Website
(a) What Personal Information we collect about you
We may collect and use any of the following information about you
(i) your name;
(ii) your email address;
(iii) your telephone number;
(iv) information provided when you correspond with us or with our Website tools;
(v) usage details, device information and other automatically collected information as described above (this Personal Information is created and recorded automatically when you visit our Website).
(b) How we use your Personal Information
We will collect, use and store the Personal Information listed above for the following reason
i) to allow you to access and use our Website (including protected areas of our Website);
(ii) for improvement and maintenance of our Website and to provide technical support for our Website;
(iii) to ensure the security of our Website;
(iv) to recognise you when you return to our Website, to store information about your preferences, and to allow us to customise the Website according to your individual interests;
(v) to evaluate your visit to the Website and prepare reports or compile statistics to understand the type of people who use our Website, how they use our Website and to make our Website more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected; and
(vi) to deal with any enquiries or issues you have about our Website, products and services. If we do not have a contract with you, we may process your Personal Information for these purposes where it is in our legitimate interests for customer services purposes.
Please see Sections 2.7 and 2.8 for more details about how we use your Personal Information.
(a) Some pages on our Website use cookies, which are small files of text, often encrypted for privacy, sent to your browser by a website you visit. For example, the information includes the products you have added to your basket, and whether you prefer to view products by 'what's new' or new 'what's best-selling'.
(b) We use cookies to keep track of your current shopping session so that you may retrieve your shopping basket at any time, and to personalise the contents of our Website as well as to ensure a consistent experience. We also use cookies to track how visitors interact with our Website to monitor how we are performing.
(c) Where we use cookies on our Website, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Website or to use all the functionality provided through our Website.
(d) For detailed information on the cookies we use and the purposes for which we use them, please refer to the .
(a) What Personal Information we may collect about you
We may collect and use any of the following information about:
(i) your name;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) your IP address
(vi) your age;
(vii) your gender;
(viii) your day of birth;
(ix) your anniversary;
(x) your sexual preference;
(xi) your relationship status;
(xii) your credit/debit card details;
(xiii) information provided when you correspond with us (such as where you report a problem with your order or account);
(xiv) any updates to information provided to us;
(xvi) information you provide when you enter a competition, promotion or survey;
(xvii) information about your account and associated services we provide to you:
(xviii) information needed to provide our services to you (including information on account opening forms, order details, order history and payment details);
(xix) customer services information; and
(xx) customer relationship management and marketing information.
(b) How we use your Personal Information
We will collect, use and store the Personal Information listed above for the following reasons: (i) to provide you with our services as an online retailer;
(ii) to facilitate deliveries of our products to you;
(iii) to deal with any enquiries or issues you have about our Website, products, services and your orders;
(iv) to verify your identity;
(v) to send you certain communications you have consented to (including by email, SMS or telephone) about our products and services such as administrative messages (for example, setting out changes to our terms and conditions and this Policy); and
(vi) if you have consented, we may contact you by email with information about our products and services which we feel will be of interest to you.
Please see Sections 2.7 and 2.8 for more details about how we use your Personal Information.
(a) What Personal Information we may collect about you
We may collect and use any of the following information about:
(i) your name;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) your bank account;
(vi) your age and/or date of birth;
(vii) your profession;
(viii) your opinion to our products or other topics;
(ix) any other information as specified in the rules of the Campaign, as the case may be.
(b) How we use your Personal Information
The main purpose of the data processing is to verify your eligibility to participate in the Campaign and, in case you win a price or are entitled to get a gift, to send or transfer the price or gift to you. The Rules could provide for further purposes.
We process your data for that purpose(s) based on your meaningful and express consent. You can revoke your consent at any time with effect for the future under the provided contact information. Please note, that, should you revoke your consent during an ongoing Campaign, your application can then no longer be considered and you will no longer have the chance to win a price.
Based on your consent we will also use your data to send you information about products, services, events and other information worth knowing about the sponsor(s) and/or We-Vibe. If you do not wish to receive any further marketing promotions, you can revoke your consent at any time with effect for the future at GDPR@lovehoneygroup.com.
Some of the Personal Information that we collect about you or which you provide to us about you may be special categories of data. Special categories of data include information about your sex life or sexual orientation. We treat special categories of data with extra care.
We need certain types of Personal Information so that we can provide services to you and perform contractual and other legal obligations that we have to you. If you do not provide us with such Personal Information, or if you ask us to delete it, you may no longer be able to access our services.
(a) to deal with any enquiries or issues you have about how we collect, store and use your Personal Information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your Personal Information for these purposes where it is in our legitimate interests for customer services purposes;
(b) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your Personal Information for these purposes where it is in our legitimate interests to do so;
(c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
(d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
We will not use your Personal Information in any way that is incompatible with the purposes set out in this Section 2. Please contact us using the details in Section 14 if you would like further information on the analysis we will undertake to establish if a new use of your Personal Information is compatible with these purposes.
(a) our use of your Personal Information is necessary to perform our obligations under any contract with you (for example, to fulfil an order which you place with us); or
(b) our use of your Personal Information is necessary for complying with our legal obligations (for example, if we are asked by regulatory bodies or law enforcement agencies to share the information); or
(c) where neither (a) nor (b) apply, use of your Personal Information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our Website). Our legitimate interests are to:
(i) run our business;
(ii) operate and ensure the security of our Website;
(iv) provide services to our customers and receive payment and provide customer services; and
(v) for internal group administrative purposes.
If we rely on our (or another person's) legitimate interests for using your Personal Information, we will undertake a balancing test to ensure that our (or another person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the Personal Information. You can ask us for information on this balancing test by using the contact details in Section IV.14.
(a) website services providers who help us host and administer our Website;
(b) email services providers;
(c) delivery services providers (such as Royal Mail) for the purposes of delivering your orders and sending you tracking notifications about your delivery and returns services providers;
(d) Trustpilot who we work with closely to help provide our independent reviews database;
(e) our other service providers and sub-contractors, including payment processors, suppliers of technical and support services, insurers, logistic providers, and cloud service providers; and
(f) analytics and search engine providers that assist us in the improvement and optimisation of our Website.
(a) where it is in our legitimate interests to do so to run our business:
(i) if we sell or buy any business or assets, we may disclose your Personal Information to the prospective seller or buyer of such business or assets;
(ii) if substantially all of our or any of our affiliates' assets are acquired by a third party, in which case Personal Information held by us will be one of the transferred assets;
(b) if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
(c) in order to enforce or apply our terms of use, our terms and conditions for customers or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
(d) to protect the rights, property, or safety of We-Vibe, our staff, our customers or other persons. This may include exchanging Personal Information with other organisations for the purposes of fraud protection.
(a) Right of access & to be informed. You have a right of access to any Personal Information we hold about you. You can ask us for a copy of your Personal Information; confirmation as to whether your Personal Information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the United Kingdom or the European Economic Area ("EEA").
(b) Right to rectification. You have a right to request we update any of your Personal Information which is out of date or incorrect.
(c) Right to erasure. You have a right to ask us to delete any Personal Information which we are holding about you. In certain specific circumstances we may have a legitimate interest to retain some of the Personal Information. You can ask us for further information on these specific circumstances by contacting us using the details in Section IV.14.
(d) Right to restrict processing: You have a right to ask us to restrict the way that we process your Personal Information in certain specific circumstances such as whilst you are requesting access to your Personal Information. You can ask us for further information on these specific circumstances by contacting us using the details in Section IV.15.
(e) Right to object: You have a right to ask us to stop using your Personal Information for certain purposes including direct marketing. If you exercise this right, we will stop using your Personal Information for this purpose. You have a right to ask us to consider any valid objections which you have to our use of your Personal Information where we process your Personal Information on the basis of our or another person's legitimate interest.
(f) Right to data portability: You have a right to ask us to provide your Personal Information to a third party provider of services, under certain conditions.
This right only applies where we use your Personal Information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
We will pass your request onto other recipients of your Personal Information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in Section IV.14.
We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies via our Website. Under certain U.S. state privacy laws, this may constitute a “sale” or “share” of personal information or “targeted advertising”. We may have “sold” or “shared” personal information, which consists of identifiers, commercial information, and internet or other electronic network activity information to data analytics providers, advertisers, and social networks for the business and commercial purposes of online advertising and to provide third-party social network features and functionality. Under certain U.S. state privacy laws, you have the right to opt-out of this disclosure of your information, which may be considered a “sale”, “sharing”, or “targeted advertising” under such laws. You may opt-out of this “sale”, “sharing”, or “targeted advertising” on our Website by setting a browser-level opt-out, the Global Privacy Control or, in some states, through rejecting cookies in our cookie banner. You may also request to opt-out of this “sale”, “sharing”, or “targeted advertising” by e-mailing us at GDPR@lovehoneygroup.com.
(a) Direct Marketing. California Civil Code Section 1798.83 permits users of the Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as noted below in Section “Further questions and how you can make a complaint.”
(b) CCPA. This Section of the Policy contains certain required information and informs California residents of certain rights arising under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).
(c) Categories of Personal Information Collected. We may have collected the following categories of personal information from you within the last twelve (12) months:
- Identifiers, such as name, address, online identifier, internet protocol address, e-mail address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
- Additional personal information described in California Civil Code Section 17980.80, such as telephone number, bank account number, credit card number, debit card number, or any other financial information, employment, and employment history;
- Characteristics of protected classifications under California or federal law;
- Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming tendencies;
- Internet or other electronic network activity information;
- Audio and visual information, including pictures and videos;
- Inferences drawn from other personal information;
- Biometric data; and
- Sensitive personal information.
(e) Business or Commercial Purposes for Collecting Personal Information. The business or commercial purposes for collecting your personal information are set forth in the “How Will We Use Your Data” Section of this Policy.
(f) Categories of Personal Information “Sold” or “Shared” to Third Parties and the Business and Commercial Purposes. The categories of personal information that we have “sold” or “shared” to third parties in the last twelve (12) months and the business and commercial purposes for “selling” or “sharing” such personal information are set forth in the “Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Policy. We do not knowingly “sell” or “share” the personal information of individuals under sixteen (16) years of age.
(g) Categories of Personal Information Disclosed to Third Parties. All of the categories of personal information described above may be shared with third parties as set forth in the “How Will We Use Your Data” Section of this Policy. (h) Personal Information Retention. We retain the personal information that we collect to achieve the purposes for which the personal information was collected. In certain cases, we may need to retain personal information for purposes required under applicable law, for tax, accounting, or audit purposes, or for other purposes permitted or required under law.
(i) Use and Disclosure of Sensitive Personal Information. We may collect “sensitive” personal information for limited purposes, such as for selling our products and offering our Website. We do not use or disclose your sensitive personal information outside of the following purposes: (1) performing our service or providing goods, (2) detecting security incidents, (3) resisting malicious, deceptive, fraudulent, or illegal actions, (4) ensuring physical safety, (4) for short-term transient use, including certain non-personalized advertising, (5) maintaining or servicing accounts, providing customer service, verifying customer information, or providing similar services, and (6) verifying and maintaining the quality or safety of a service or product or improving, upgrading, or enhancing a service or product. As such, the right to limit our use and disclosure of such sensitive information does not apply.
(j) Your California Privacy Rights. The following rights apply to California residents:
- The right to know what personal information that we have collected about you, including the categories of information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you;
- The right to delete personal information that we have collected from you and the right to correct inaccurate personal information that we maintain about you (each subject to certain exceptions);
- The right to opt-out of the “sale” or “sharing” of your personal information (as described in the “Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Policy); and
- The right to exercise your rights under the CCPA free of discrimination by us including, but not limited to: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
This portion of the Policy describes the rights that may be available to you if you reside in certain US states, like Colorado, Connecticut, Texas or Virginia. Please be aware that some of these rights may not apply until July 1, 2024. For more information about our privacy practices related to consumer health data subject to the Washington My Health My Data Act (MHMDA) please visit our Washington Consumer Health Data Privacy Policy, available here.
If you reside in a state with a comprehensive data protection law, you may have the following rights regarding your personal data:
- Right to Know and Access: The rights to confirm whether we are processing your personal data and to access such personal data.
- Right to Correct: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and our purposes of the processing of such personal data.
- Right to Delete: The right to delete personal data provide by or obtained about you.
- Right to Obtain a Copy: The right to obtain a copy of your personal data that you previously provided to us in a portable and to the technically feasible, readily useable format that allows you to transmit to the data to another controller without hindrance, where the processing is carried out by automated means.
- Right to Opt-Out: The right to opt out of the processing of your personal data for purposes of: (1) targeted advertising, (2) the sale of personal data, or (3) profiling in furtherance of decisions that product legal or similarly significant effects concerning you. Note, however, that we do not engage in (3), so that right does not apply.
You can exercise these rights by contacting us at GDPR@lovehoneygroup.com. Please see the “Notice of Right to Opt-Out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Policy above for additional information on how to opt-out of “sale”, “sharing”, or “targeted advertising.” You may designate an authorized agent to make such requests on your behalf by having your authorized agent make a privacy request as set forth above. Please note that we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your information. We may need to collect information such as your name, email or transaction history in order to verify your identity. If you designate an authorized agent to make a request on your behalf, your authorized agent need to provide similar information for verification. If we refuse to take action upon your request, you may appeal such refusal by contacting us after your receipt of the refusal at GDPR@lovehoneygroup.com.
For this reason, We-Vibe is committed to protecting your Personal Information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your Personal Information, including through use of appropriate organisational and technical measures. For example, all information you provide to us is stored on secure servers and any payment transactions will be encrypted using TLS technology
(a) by email: GDPR@lovehoneygroup.com
(b) by post: WOW Tech USA Ltd., 103 Foulk Road, Suite 202, Wilmington Delaware, 19803-3741, USA
Alternatively, you can contact our Data Protection Officer:
FIRST PRIVACY GmbH
Konsul-Schmidt-Str. 88
28217 Bremen
Germany
office@first-privacy.com
We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your Personal Information.