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Privacy & Cookies

Version number: PPCP20.1
Effective date: 01.09.2020

1. Who are we?

1.1 We are Sanlucar Digital OÜ trading as “Fabify” (“Fabify” or “we”), a company incorporated and registered in Estonia with the company number 16118367. Fabify acts as a data controller with regard to the processing of your personal data and it is the owner of the website accessible at the following address: If you have any questions about how we protect your privacy, you can email us at [email protected]. Other contact details are on our website.

2. What’s the point of this policy?

2.1 It tells you what to expect when we collect or process your personal data via our website. Please only use our service if you are completely happy with this policy.

2.2 Generally, the policy covers only personal data provided to us. If you give personal data to other people, such as payment providers or other websites, please check their privacy policies.

3. Might the policy change?

3.1 Yes. If we decide to amend this policy, we will publish the new version on our website, which will supersede the current version. Please check it whenever you visit our website. We will assume you agree to the new version of the policy if you use the website after its effective date. We may also notify you of any changes by email or in-service message.

4. What personal data do we collect and How do we collect it?

We ask you for certain personal data to provide you with the products or services you request. For example:

4.1 When you visit, register, order products, or otherwise access our service, we collect or you may be asked to provide personal data including:

Identity Data: your name, title, gender and date of birth;

Contact Data: delivery address, billing address, email address and telephone numbers;

Transaction Data: details about your transactions on our service;

Marketing Data: contact or other data which you give or allow us and our third parties to use for newsletters or other marketing purposes; and

Profile Data: your user name and password, purchase history, your interests/preferences and your communications with us.

4.2 When you interacting with our website, automated data about your use of our service will be collected such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the website from which you arrived at our service, details of your activity with date/time stamps including pages you visited and your searches/transactions. More information about this processing is included below in the “What about cookies?” section of this privacy policy.

4.3 The following data about you may be provided to us by our providers:

limited billing data sent to us by our payment provider for verification purposes e.g., your name, email address and billing/delivery addresses.

5. What are the legal grounds and purposes for processing personal data?

5.1 Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract, e.g. send service messages, process payments and fulfil orders. This applies to initial enquiries and to contact and transaction details.

5.2 Because it’s in our “legitimate interests”, e.g. to manage and improve our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to automated usage data.

5.3 Because you’ve specifically agreed on our service (e.g. by ticking a consent box). This applies to contact data or other data which you give or allow us to use for newsletters or other marketing. You can withdraw permission at any time as explained on our service or by emailing us at [email protected].

5.4 If we decide to process your personal data for any purposes other than that for which you originally disclosed your personal data to us, we will inform you prior to such processing of your personal data.

6. How long do we keep personal data? 

6.1 Your personal data will be kept for as long as it is necessary to carry out the purposes set out in this privacy policy (unless a longer retention period is required by applicable law). Basically, we keep your personal data until your account is closed or our contract with you has otherwise ended. You can close your account by emailing us at [email protected].

6.2 For personal data related to product purchases, we may retain this longer, for legal, regulatory or tax reasons, deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions, in line with applicable legal requirements.

6.3 For personal data which we use only for newsletters or other marketing activities, we will store this data for two years from the moment you have specifically agreed on our service. Following the expiry of this period, we will ask again for your consent.

6.4 Your personal data will be deleted when it is no longer necessary for the purposes for which it has been collected or when you withdraw your consent (if the processing of your personal data is based on consent), provided that we are not legally required or otherwise permitted to continue to process such data.

7. To whom do we send or make available your personal data?

7.1 We do not sell any of your personal data to any third party. We do however share data with companies who supply us with a service, e.g., other companies in our group who provide part of our service, delivery/warehouse companies, website hosts, payment providers, and businesses which help us send communications or monitor our website and which provide us with e-commerce, online advertising and other IT services.

7.2 To credit reference agencies, regulators and the police and other law enforcement authorities to help deal with fraud and abuse and/or comply with legal requirements.

7.3 To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.

7.4 To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.

7.5 When using third party service providers we enter into agreements which will include adequate clauses to ensure the processing of personal data will be in full compliance with applicable laws and which require them to implement appropriate technical and organisational measures to protect your personal data.

8. Do we send your personal data outside the European Union (“EU”)?

8.1 The personal data we collect is stored within the EU. However, some of our external third party service providers are situated outside the EU and their processing of your personal data may entail a transfer of data outside the EU. When this occurs, we only allow data to be transferred to countries deemed by the European Commission to provide an adequate degree of protection for personal data. For countries without adequacy decisions from the European Commission, we will use appropriate safeguards for providing an adequate level of protection in compliance with the applicable laws.

8.2 Where the service provider is situated in the US, your personal data will only be transferred using appropriate safeguards to provide an adequate level of data protection in accordance with the applicable laws.

8.3 If you are located outside the EU, we may need to send your contact data to couriers or warehouse companies outside the EU in order to enable us to perform the contract with you. In this event, the transfer shall be done so in accordance with the applicable laws and by implementing appropriate safeguards to provide an adequate level of data protection.

9. What rights do you have? 

9.1 If the legal requirements are met: to ask us for access to your personal data, to rectify it if there are mistakes, to delete or restrict its use in certain circumstances, enable “data portability” or to withdraw any consent you’ve given (e.g. marketing).

9.2 You may also have the right to object to use of your personal data in certain circumstances.

9.3 If you have a complaint about how we are dealing with your personal data, please contact us by email at [email protected]. If you are not happy with our response or think we are not handling your personal data in accordance with the law, you have the right to complain to the National Supervisory Authority for Personal Data Processing (“ANSPDCP”).

9.4 For more information about your rights, visit the ANSPDCP’s website:

10. What about cookies?

10.1 We and other companies use cookies and other tracking technologies on our website.

A cookie is a small text file made up of letters and numbers that will be stored on the user’s computer, mobile terminal or other device from which the user accesses a web page. Certain cookies on your terminal may collect data concerning the device you are using (e.g. MAC address, operating system being used), data concerning your activity on the website or interests.

We use cookies in order to improve the navigation experience and to understand our customers’ preferences. To this end, cookies render possible the user’s terminal recognition and user preference storage, and facilitate the presentation of content in a relevant manner, which is adapted to user preferences.

We use several types of cookies, some are session temporary “session” cookies that remain in the cookie file of your browser only until your browser is closed. Whereas persistent cookies stay for longer (depending on the lifetime of the specific cookie or until they are deleted manually from the web browser).

You can restrict, block and remove cookies via your browser setting. Please note that our website’s functionality will be limited if you configure your browser to reject cookies. For further information on cookies, including how to use your browser to block them and how to delete existing cookies, visit: Please note that the list of cookies provided on this website will include all cookies placed on your terminal, not only those found on our website.

10.2 We ourselves may place the following types of cookies:

Type of cookies


Logged-in status

Access whether you are logged in to our website

“Remember me”

Remember you and speed up your login when you return to our website


Identify and authenticate you to help you move easily through the website


Store data about the preferences you’ve selected (e.g. favourites,currency, wishlists) and personalise the website

Shopping cart

Remember contents of your cart and related preferences


Track whether you have visited us from websites affiliated with us so we can pay affiliates and assess the effectiveness of the affiliate links


Provide security-related features to protect our website, for example to help stop fraudulent logins

Cookie notice

Store your response to our cookie notice

10.3 Companies which provide us with a service also place cookies. Some of these cookies (e.g. from Google) may involve certain data, such as your IP address and web address of the page you’re visiting, being sent to the company concerned. Below is a summary of the kinds of cookies used together with details about who places them and where you can go to get more information and to opt out (where possible):

Analytics cookies: These kinds of cookies recognise and count the number of website visitors as well as providing other data about the visit such as duration, route through the website and where the visitor came from. This data helps us to improve the way our website works, for example by making sure users find what they need easily. These cookies are provided by:

Google Analytics (“GA”). More:

- general information about the types of cookies placed by Google including analytics
- technical explanation of GA cookies
- Google’s use of its partners’ data including how to control data collected by Google
- how to specifically opt out from GA cookies 
- Google’s privacy policy

Advertising cookies: These kinds of cookies are typically used to personalise ads on this or other websites based on your use of our website, to measure ad effectiveness (for example, how often you click on or view ads and whether you go on to buy something from the advertiser) and to stop you being shown the same ad repeatedly. These cookies are provided by:

Google (including Analytics Ad Features/AdSense/DoubleClick)

- general information about the types of cookies placed by Google including advertising
- how Google uses cookies and other technologies in advertising including how to opt out of advertising cookies (this explains how ad personalisation works)
- Google’s use of its partners’ data including how to control data collected by Google
- Google’s privacy policy

Facebook (including “Facebook Pixel”)

- Facebook’s cookies policy (see especially under “Advertising, recommendations, insights and measurement”) including how to control Facebook’s use of cookies
- Facebook’s privacy policy

Note that there are various places where you can go to opt out of many companies’ advertising cookies in one go including some or all of the above:


Social media cookies: These kinds of cookies are placed by social media companies when you use their features on another website, for example if you play embedded audio or video, click a Facebook “like” or sent a tweet. These features may involve the relevant companies using cookies to collect data relating to your visit to our website or your interaction with their services or otherwise. Click the following links for further information including how to opt out where this is possible: Facebook, Pinterest, InstagramYouTube

Payment provider cookies: Our payment provider may place cookies if you use their payment services on our website:

- PayPal’s privacy policy
- Stripe’s privacy policy

Third party log-in cookies: If you log in through a third party website, that website will place its own cookies on your computer

- Facebook’s privacy policy

11. Contact

11.1 We welcome feedback and are happy to answer any questions you may have about your data. Please send all comments, queries and requests for more information to us at [email protected].