Privacy policy

# Privacy Policy

Last updated: [PUBLICATION DATE]

[BRAND] is operated by Gains Promotion, a sole proprietorship based in the Netherlands (“we,” “us” or “our”). This policy explains how we handle personal information when you visit [STORE URL], place an order or contact us. Gains Promotion is the controller of the personal information we process for our own purposes.

Contact: [SUPPORT EMAIL]. Business address: [COMPLETE VERIFIED BUSINESS ADDRESS, NETHERLANDS].

## Information we collect
We collect information you provide, information generated when you use the store and information from providers that help us operate it. Depending on your interaction, this includes:

• Contact and delivery details, such as your name, email, billing and shipping addresses, and any contact number you voluntarily provide.
• Order information, including products, sizes, quantities, order history, returns, refunds, shipment and delivery status.
• Payment and transaction information, such as payment status, payment method, transaction identifiers and limited payment details made available by our payment providers. Payment information entered at checkout is processed through Shopify and the payment provider; do not send card numbers to customer support.
• Account and preference information, if you use an account, including sign-in information, saved preferences and marketing choices.
• Messages and any attachments you choose to send us.
• Device and usage information, such as IP address, browser/device identifiers, pages viewed, cart activity, referring pages, approximate location inferred from IP address and cookie or similar identifiers.

We obtain information directly from you, automatically through our Shopify store, and from payment, delivery and other service providers that report on transactions and service activity.

## How we use information
We use information to process payments, fulfill and track orders, provide support, handle returns and refunds, manage accounts, prevent fraud, secure the store, troubleshoot problems, understand store performance and comply with accounting and other legal obligations.

We also use information to provide relevant shopping experiences and, where permitted, send email offers and reminders. You can unsubscribe from marketing emails through the link in the message or by contacting us. Order and service messages may still be sent after you unsubscribe. We do not currently offer an SMS or WhatsApp marketing signup at checkout.

Where the GDPR applies, our legal bases include performance of a contract for purchases and support; legal obligations for required records; legitimate interests in operating, securing and improving the store where those interests are not overridden by your rights; and consent when required for marketing, optional technologies or particular uses of sensitive data. You may withdraw consent without affecting the lawfulness of processing already carried out. We do not treat merely visiting the website as consent to every use described here.

## Shopify, tracking and other providers
Our store is hosted by Shopify. Shopify processes personal information to run the storefront, checkout, accounts, payments, security and related services. We use Shopify Network Intelligence, which supports enhanced services using information about interactions with our store, other merchants and Shopify. These services can support personalization, fraud prevention and advertising. For these enhanced services, Shopify may act as a separate controller and is responsible for responding to requests concerning its own processing.

Read Shopify’s Consumer Privacy Policy at https://www.shopify.com/legal/privacy/app-users and use its privacy portal at https://privacy.shopify.com/en for details and available choices.

Track123 is installed to support shipment tracking. Tracking services and carriers may process order, delivery and tracking details to show shipment progress and help resolve delivery problems. Shopify Messaging is installed to support customer communications and email marketing where enabled and permitted.

We also use store-management tools, including Atlas: AI Store Builder, Shopify Claude Connector App and Claude connector app: Chatty. The information these tools can process depends on their permissions and how we use them. [COMPLETE THE APP DATA DISCLOSURE: verify each tool’s customer/order-data access, any data actually submitted to AI services, provider recipients and retention; state the confirmed uses here.] We do not ask you to provide medical records to use this store.

## Cookies and privacy controls
Shopify and enabled services use cookies and similar technologies for functions such as keeping items in your cart, maintaining sessions, security, preferences, analytics and enhanced services. Optional uses are subject to consent or opt-out requirements where applicable. Blocking all cookies in your browser may affect store functions.

You can use the store’s privacy controls where displayed and visit our data-sharing opt-out page: [STORE URL]/pages/data-sharing-opt-out. Shopify’s controls currently provide opt-out choices in supported US states. Where applicable, a recognized Global Privacy Control signal is treated as an opt-out request for the browser/device and, where Shopify can associate it, the relevant account. Other browser “Do Not Track” signals are not treated as a universal opt-out request.

The store does not currently have a Meta, Google or other app/custom pixel registered in Shopify’s Customer Events settings. That does not mean no data is collected: Shopify, installed services and any enabled storefront integrations can still process information. [VERIFY STOREFRONT SCRIPTS AND APP EMBEDS BEFORE PUBLICATION; add any additional analytics, advertising or session-recording providers found.]

## How we disclose information
We disclose information as needed to Shopify, payment providers, fulfillment partners, carriers, tracking services, communication providers and other contracted service providers for the purposes described above. We may also disclose information when you request it, where legally required, to protect rights and investigate fraud, or as part of a business transfer subject to appropriate safeguards.

Certain uses of identifiers, device information and browsing or shopping activity for Shopify enhanced services or advertising may constitute a “sale,” “sharing” or “targeted advertising” under state privacy laws even without a payment for the data. Use the opt-out page above to exercise applicable choices. We do not describe this store as having no data sharing while these services are enabled.

## Sensitive information
Purchases of products marketed for bladder leaks, bunions or other physical concerns, or information you include in a support message, may reveal health-related information. Please share only what is necessary to resolve your request; do not send intimate photographs, diagnoses or medical records.

[HEALTH-DATA DISCLOSURE TO COMPLETE BEFORE PUBLICATION: confirm which health-related purchase, browsing or support information is processed; necessary order-processing uses; any nonessential sharing; applicable consent/legal basis; and recipients. If a consumer health data privacy notice is required, insert a direct link to the separate notice here and prominently on the homepage. A general advertising opt-out is not a substitute for required health-data consent.]

## Retention and security
We keep information for as long as reasonably necessary for the purposes described, including completing orders, providing support, keeping required business and tax records, preventing fraud and resolving disputes. The period depends on the type of record and applicable legal requirements. Marketing suppression records may be retained to honor an opt-out. When information is no longer needed, it is deleted or de-identified, subject to lawful recordkeeping and backup cycles.

We use reasonable safeguards and access restrictions, but no online system can guarantee absolute security.

## International processing
We operate from the Netherlands and use Shopify and service providers in other countries, including the United States. Information may be processed outside your state or country. Where required for a transfer from the EEA, we rely on an applicable adequacy decision, contractual safeguards such as standard contractual clauses, or another lawful transfer mechanism. Contact us for information about the safeguards relevant to your data.

## Your rights
Depending on applicable law, you may have rights to access or know about your personal information, receive a portable copy, correct inaccuracies, request deletion, restrict or object to processing, withdraw consent and opt out of sale, sharing or targeted advertising. Additional rights may apply to sensitive information and automated decisions. Rights are subject to lawful exceptions, including retention of records needed to complete transactions or meet legal obligations.

Submit a request to [SUPPORT EMAIL] or use the opt-out page above. We may verify your identity using information reasonably necessary to protect your data. An authorized agent may submit a request, subject to verification of authority. We will respond within applicable legal deadlines and will not unlawfully discriminate against you for exercising privacy rights.

If we deny a request, you may appeal by emailing [SUPPORT EMAIL] with “Privacy appeal” in the subject line. We will explain our decision and any further options required by law. You may also complain to the relevant regulator, including your state attorney general or the Dutch Autoriteit Persoonsgegevens at https://www.autoriteitpersoonsgegevens.nl/en.

## Children
This store is directed to adults and is not intended for children under 13. We do not knowingly collect personal information from children under 13. If you believe a child has provided information, contact us so we can investigate and take appropriate action. We do not knowingly sell or share personal information of individuals under 16.

## Updates and contact
We may update this policy when our practices or legal obligations change. We will update the date and provide additional notice or obtain consent where required. Contact [SUPPORT EMAIL] or write to Gains Promotion at [COMPLETE VERIFIED BUSINESS ADDRESS, NETHERLANDS] with questions.