This Privacy Policy describes how AllSlowly (the “Site” or “we”) collects,
uses, processes and discloses your Personal Information/Data when you visit or make a purchase from the Site.
We manifest our commitment to privacy and data protection. Personal data shall be:

● Processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’).

● Collected for specified, explicit and legitimate purposes and not further
processed in a manner that is incompatible with those purposes.
● Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’).
● Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data
that are inaccurate, having regard to the purposes for which they are processed, are erased, or rectified without delay (‘accuracy’).

● Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’).

● Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

Within the meaning of this Privacy Policy “customer” means a former, current and/or potential customer or user of a product or service offered by us, a visitor to our website, a member of a loyalty program or community.

Minors

The Site is not intended for individuals under the age of 16. We do not intentionally collect and process Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our
services and fulfill our contracts with you, as described above. For example:

● We use Shopify to power our online store. You can read more about how
Shopify uses your Personal Information here:
https://www.shopify.com/legal/privacy.

● We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Your personal data is available and accessible only by those who need the data to accomplish the intended processing purpose. To the extent necessary, your personal data may be shared between us, with suppliers, sub-contractors and independent third parties (acting as processors and sub-processors) carrying out certain tasks on our behalf. In addition, we may also disclose personal data to third parties, if we have reason to believe that using or disclosing such information is necessary or advisable to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; (iii) investigate security breaches or cooperate with government authorities pursuant to a legal matter; or (iv) to protect our rights, safety or property,
including the prevention of fraud. We reserve the right to transfer any personal data we have about you in the event that we merge with or are acquired by a third party, undergo another business transaction such as a reorganization, or should any such transaction be proposed.

Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.
For example:

● We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.
You can also opt-out of Google Analytics here https://tools.google.com/dlpage/gaoptout.

● We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at
http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
● FACEBOOK - https://www.facebook.com/settings/?tab=ads
● GOOGLE - https://www.google.com/settings/ads/anonymous
Additionally, you can opt out of some of these services by visiting the Digital
Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Using Personal Information

We use your personal Information to provide our services to you, which include: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal
information under the following lawful bases:
● Your consent;
● The performance of the contract between you and the Site;
● Compliance with our legal obligations;
● For our legitimate interests, which do not override your fundamental rights and
freedoms.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you. We do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data. Our processor Shopify uses limited automated decision-making to prevent fraud
that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

● Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.

● Temporary denylist of credit cards associated with denylisted IP addresses.
This denylist persists for a small number of days.

Your rights

If you are a resident of the EEA, you have several rights regarding data
protection/processing, namely:

● Right of access: you have the right to request information about the personal
data we hold on you at any time. Please contact us and we will provide you with your personal data via email.

● Right to rectification: you have the right to obtain the rectification of inaccurate personal data concerning you, including the right to have incomplete personal data completed.

● Right to erasure (‘right to be forgotten’): you have the right to erase anypersonal data processed by us at any time except for the following situations: (i) you have an ongoing matter with customer service; (ii) you have an open order which has not yet been shipped or partially shipped; (iii) you have an unsettled debt with us, regardless of the payment method; (iv) if you are
suspected or have misused our services within the last 4 years; (v) if you have
made any purchase, we will keep your personal data in connection to your
transaction for book-keeping purposes.

● Right to object to processing based on legitimate interest: you have the right
to object to processing of your personal data that is based on our legitimate
interest. We will not continue to process the personal data unless we can demonstrate legitimate grounds for the process which overrides your interest
and rights or due to legal claims.

● Right to restriction: you have the right to request that we restrict the process
of your personal data under the following circumstances: (i) if you object to a processing based of our legitimate interest, we shall restrict all processing of such data pending the verification of the legitimate interest; (ii) if you have
claimed that your personal data is incorrect, we must restrict all processing
of such data pending the verification of the accuracy of the personal data; (iii)
if the processing is unlawful you can oppose the erasure of personal data and instead request the restriction of the use of your personal data instead; (iv) if we no longer need the personal data but it is required by you to defend
legal claims.

● Right to data portability: you have the right to receive the personal data concerning you, which you provided, in a structured, commonly used and machine-readable format and have the right to transmit those data to another
controller without hindrance from the controller to which the personal data have been provided, where: (i) the processing is based on consent; and (ii) the processing is carried out by automated means.

According to Shopify, your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper:
https://help.shopify.com/en/manual/your-account/privacy/GDPR.

Cookies

A cookie is a small amount of information that’s downloaded to your computer order advice when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies
make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.
We use the following cookies to optimize your experience on our Site and to provide our services.

Cookies Necessary for the Functioning of the Store

Name Function

_ab Used in connection with access to admin.
_secure_session_id Used in connection with navigation through a storefront.
Cart Used in connection with shopping cart.
cart_sig Used in connection with checkout.
cart_ts Used in connection with checkout.
checkout_token Used in connection with checkout.
Secret Used in connection with checkout.
secure_customer_sig Used in connection
with customer login.
storefront_digest Used in connection withcustomer login.
_shopify_u Used to facilitate updating customer account information.

Reporting and Analytics

Name Function
_tracking_consent Tracking preferences.
_landing_page Track landing pages.
_orig_referrer Track landing pages.
_s Shopify analytics.
_shopify_s Shopify analytics.
_shopify_sa_p Shopify analytics relating to marketing & referrals.
_shopify_sa_t Shopify analytics relating to marketing & referrals.
_shopify_yShopify analytics.
_y Shopify analytics.

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.
You can control and manage cookies in various ways. Please keep in mind that
removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools”
or “Preferences” menu. For more information on how to modify your browser settings
or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.
Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Be havioural Advertising” section above.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at
info@allslowly.com.
If you are not satisfied with our response to your complaint, you have the right to
lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here in Portugal:
Comissão Nacional de Proteção de Dados (CNPD) - https://www.cnpd.pt/
Last updated: 03/01/2023