Roseapple Global, LLC
Roseapple Global (aka RG) is based in United Stated and has been selling digital planning products on Etsy since 2021. Roseapple Global sells mainly to buyers in the United States but offers its items for sale world-wide. Since it inception, Roseapple Global is not using a third-party shipping provider to help fulfill its orders. RG does use Google Cloud to host some of its buyers’ personal information.
the personal information RG collects;
the legal bases RG relies on to collect, use, and share personal information;
the third parties with whom RG shares personal information;
the length of time RG keeps personal information;
if RG is transferring personal information outside of United States (for example, if RG moves his business to the Europe and continues to sell to buyers in Europe, or uses a third party provider located outside of Europe, or uses Google Cloud to host some of his buyers’ information), how the transfer will be handled;
his buyers’ rights regarding his use of their personal information; and
how his buyers can contact him with privacy-related requests.
1. Personal information he collects
RG should go on to explain what information he collects from buyers, why he needs the information, how he uses it to fulfill orders, the third parties with whom he shares the information, and the length of time he keeps the information. Here's an example:
Information RG Collect
To fulfil your order, you must provide me with certain information (which you authorized Etsy to provide to RG), such as your name, email address, postal address, payment information, and the details of the product that you’re ordering. You may also choose to provide RG with additional personal information (for a custom order of jewelry, for example), if you contact us directly.
2. The legal bases he relies on to collect, use, and share personal information
Why I Need Your Information and How I Use It
I rely on a number of legal bases to collect, use, and share your information, including:
as needed to provide my services, such as when I use your information to fulfil your order, to settle disputes, or to provide customer support;
when you have provided your affirmative consent, which you may revoke at any time, such as by signing up for my mailing list;
if necessary to comply with a legal obligation or court order or in connection with a legal claim, such as retaining information about your purchases if required by tax law; and
3. The third parties with whom he shares personal information
The GDPR requires that you disclose the details of any personal information you share with third parties. RG should explain to his buyers why, when, and with whom he may share buyers’ personal information. For example:
Information Sharing and Disclosure
Information about my customers is important to my business. I share your personal information for very limited reasons and in limited circumstances, as follows:
Service providers. I engage certain trusted third parties to perform functions and provide services to my shop, such as delivery companies. I will share your personal information with these third parties, but only to the extent necessary to perform these services.
Business transfers. If I sell or merge my business, I may disclose your information as part of that transaction, only to the extent permitted by law.
Compliance with laws. I may collect, use, retain, and share your information if I have a good faith belief that it is reasonably necessary to: (a) respond to legal process or to government requests; (b) enforce my agreements, terms and policies; (c) prevent, investigate, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of my customers, or others.
4. The length of time he keeps personal information
The GDPR requires you to disclose the period of time during which you will store personal information. RG should consider how long he needs to retain information for business purposes and to comply with any legal or tax obligations, and keep in mind that data shouldn't be kept for any longer than necessary. For example:
5. If transferring personal information outside of Europe, how the transfer will be handled
GDPR requires you to disclose if you transfer personal information outside of the EU and the legal bases you rely on to do so, such as consent and contractual necessity. RG uses Google Cloud, which is Privacy Shield certified, so he should explain to his buyers that he relies on Privacy Shield as the legal basis for the transfer of his buyers’ personal information outside of the EU. For example:
Transfers of Personal Information Outside the EU
I may store and process your information through third-party hosting services in the US and other jurisdictions. As a result, I may transfer your personal information to a jurisdiction with different data protection and government surveillance laws than your jurisdiction. If I am deemed to transfer information about you outside of the EU, I rely on Privacy Shield as the legal basis for the transfer, as Google Cloud is Privacy Shield certified.
6. His buyers’ rights regarding his use of their personal information and his contact details
Based on GDPR requirements, RG should finish by explaining to his buyers their rights regarding the information they provide to him on Etsy. RG should also provide his contact details and explain to his buyers that he is the data controller of their personal information. For example:
If you reside in certain territories, including the EU, you have a number of rights in relation to your personal information. While some of these rights apply generally, certain rights apply only in certain limited cases. I describe these rights below:
Access. You may have the right to access and receive a copy of the personal information I hold about you by contacting me using the contact information below.
Change, restrict, delete. You may also have rights to change, restrict my use of, or delete your personal information. Absent exceptional circumstances (like where I am required to store data for legal reasons) I will generally delete your personal information upon request.
Object. You can object to (i) my processing of some of your information based on my legitimate interests and (ii) receiving marketing messages from me after providing your express consent to receive them. In such cases, I will delete your personal information unless I have compelling and legitimate grounds to continue using that information or if it is needed for legal reasons.
Complain. If you reside in the EU and wish to raise a concern about my use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local data protection authority.
How to Contact Me
For purposes of EU data protection law, I, Roseapple Global, am the data controller of your personal information. If you have any questions or concerns, you may contact me at firstname.lastname@example.org. Alternately, you may mail me at: Roseapple Global, LLC, 8345 NW 66th Street, #4018, Miami, Florida, USA 33166
All content and other information are © 2021 Roseapple Global, LLC, Inc. All rights reserved.
Effective: 22 September 2021