1. Introduction
This Privacy Policy describes how Commissura Proprietary Limited (“we,” “us,” “our,” or “Company), operating timelessfinery.com (the “Website”), collects, uses, discloses, and protects your personal information. We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR), and other relevant privacy regulations.
Company Information:
Commissura Proprietary Limited
UIN: BW00002442681
Registered in the Republic of Botswana
Physical Address:
Plot 4821, Trans-Kalahari Highway
Sese Junction, Sese, Botswana
Postal Address:
P O Box 80256
Gaborone, Botswana
Contact Email: [email protected]
2. Scope and Application
This Privacy Policy applies to all personal information collected through:
– Our Website (timelessfinery.com)
– E-commerce transactions
– Blog subscriptions and interactions
– Newsletter subscriptions
– Contact forms and customer service communications
– Cookies and similar tracking technologies
– Third-party advertising and affiliate marketing activities
3. Information We Collect
3.1 Information You Provide Directly
Account and Order Information:
– Full name, email address, phone number
– Billing and shipping addresses
– Payment information (processed by third-party payment processors)
– Order history and preferences
– Account credentials (username and encrypted password)
Communication Information:
– Information you provide when contacting customer service
– Blog comments and forum posts
– Newsletter subscription preferences
– Survey and feedback responses
– Product reviews and ratings
3.2 Information Collected Automatically
Technical Information:
– IP address and geolocation data
– Browser type, version, and language settings
– Device type, operating system, and unique device identifiers
– Referring/exit pages and URLs
– Pages viewed, time spent on pages, and navigation paths
– Date and time stamps of visits
Cookies and Tracking Technologies:
– Session cookies and persistent cookies
– Web beacons and pixel tags
– Analytics data (Google Analytics, etc.)
– Advertising cookies and identifiers
– Social media plugins and tracking
3.3 Information from Third Parties
Affiliate and Advertising Partners:
– Conversion data and referral information
– Interest-based advertising data
– Demographic and behavioral data from data brokers
Social Media:
– Profile information when you connect social media accounts
– Public information from social media platforms
Payment Processors:
– Transaction verification and fraud prevention data
Data Enrichment Services:
– Enhanced contact and demographic information
4. How we use your information
We use your personal information for the following purposes:
4.1 Essential Business Operations
– Processing and fulfilling orders
– Managing your account and authenticating users
– Processing payments and preventing fraud
– Providing customer service and support
– Communicating about orders, deliveries, and account updates
– Enforcing our terms of service and legal rights
4.2 Marketing and Personalization
– Sending promotional emails and newsletters (with your consent)
– Personalizing your shopping experience
– Recommending products based on your preferences and browsing history
– Displaying targeted advertisements
– Conducting market research and analytics
4.3 Website Improvement
– Analyzing website usage and performance
– Testing new features and functionality
– Debugging and resolving technical issues
– Improving user experience and navigation
4.4 Affiliate Marketing
– Tracking affiliate referrals and attributing sales
– Calculating and paying affiliate commissions
– Analyzing effectiveness of affiliate partnerships
4.5 Legal and Compliance
– Complying with legal obligations and court orders
– Protecting against fraud, abuse, and security threats
– Enforcing our policies and terms
– Resolving disputes and investigating complaints
5. Legal basis for processing (GDPR)
For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we process your personal information based on the following legal grounds:
– Contractual Necessity: To fulfill our contract with you (order processing, account management)
– Legitimate Interests: To improve our services, prevent fraud, and conduct marketing (where not overridden by your rights)
– Legal Obligation: To comply with applicable laws and regulations
– Consent: Where you have provided explicit consent (marketing emails, cookies, certain data sharing)
6. How we share your information
We do not sell your personal information to third parties. However, we may share your information in the following circumstances:
6.1 Service Providers
– Payment processors (Stripe, PayPal, etc.)
– Shipping and logistics providers
– Email service providers (Mailchimp, SendGrid, etc.)
– Cloud hosting and storage providers
– Analytics services (Google Analytics, etc.)
– Customer service platforms
– Marketing automation tools
6.2 Affiliate Partners
– Commission tracking platforms
– Affiliate networks (with anonymized or aggregated data when possible)
6.3 Advertising Partners
– Google Ads, Facebook Ads, and other advertising networks
– Retargeting and remarketing services
– Data management platforms
6.4 Business Transfers
In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred to the successor entity.
6.5 Legal Requirements
– To comply with legal processes, court orders, or government requests
– To enforce our terms and conditions
– To protect our rights, property, and safety, and that of our users and the public
– To detect, prevent, or address fraud, security, or technical issues
6.6 With Your Consent
We may share your information with other parties when you explicitly consent to such sharing.
7. International Data Transfer
Our Company is based in Botswana, and we may transfer, store, and process your information in Botswana and other countries that may have different data protection laws than your country of residence.
For EEA/UK Users: When we transfer personal data outside the EEA or UK, we implement appropriate safeguards, including:
– Standard Contractual Clauses (SCCs) approved by the European Commission
– Adequacy decisions by the European Commission
– Other legally approved transfer mechanisms
For Swiss Users: We comply with the Swiss Federal Act on Data Protection (FADP) and ensure appropriate safeguards for data transfers.
8. Data Retention
n your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
Specific Retention Periods:
– Account information: Retained while your account is active, plus 7 years after closure for legal compliance
– Order and transaction data: 7 years for accounting and tax purposes
– Marketing communications: Until you unsubscribe or withdraw consent
– Analytics and cookie data: Up to 26 months
– Customer service records: 5 years
After the retention period expires, we will securely delete or anonymize your information.
9. Your Privacy Rights
Depending on your location, you may have the following rights:
9.1 Rights for All Users
– Right to Access: Request access to your personal information
– Right to Correction: Request correction of inaccurate or incomplete information
– Right to Deletion: Request deletion of your personal information (subject to legal exceptions)
– Right to Opt-Out: Opt-out of marketing communications
9.2 Additional Rights for EEA/UK/Swiss Users (GDPR)
– Right to Restriction: Request restriction of processing under certain circumstances
– Right to Data Portability: Receive your data in a structured, machine-readable format
– Right to Object: Object to processing based on legitimate interests or for direct marketing
– Right to Withdraw Consent: Withdraw consent at any time (without affecting prior processing)
– Right to Lodge a Complaint: File a complaint with your data protection authority
9.3 Additional Rights for California Residents (CCPA/CPRA)
– Right to Know: Request details about the categories and specific pieces of personal information we collect
– Right to Delete: Request deletion of personal information (subject to exceptions)
– Right to Correct: Request correction of inaccurate personal information
– Right to Opt-Out of Sale/Sharing: Opt-out of the sale or sharing of personal information
– Right to Limit Use of Sensitive Personal Information: Limit the use of sensitive personal information
– Right to Non-Discrimination: Not receive discriminatory treatment for exercising your rights
California “Shine the Light” Law: California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes.
9.4 Additional Rights for Virginia, Colorado, Connecticut, and Utah Residents
– Right to confirm whether we process your personal data
– Right to access your personal data
– Right to correct inaccuracies
– Right to delete personal data
– Right to obtain a copy of your data
– Right to opt-out of targeted advertising, sale of personal data, and profiling
9.5 How to Exercise Your Rights
To exercise any of these rights, please contact us at:
– Email: [email protected]
– Subject line: “Privacy Rights Request”
We will respond to your request within the timeframes required by applicable law (typically 30-45 days). We may need to verify your identity before processing your request..
10. Cookies and Tracking Technologies
10.1 Types of Cookies We Use
Strictly Necessary Cookies: Essential for website functionality (shopping cart, checkout, authentication)
Performance Cookies: Collect information about how visitors use our website (Google Analytics)
Functionality Cookies: Remember your preferences and settings
Targeting/Advertising Cookies: Deliver relevant advertisements and track campaign effectiveness
10.2 Third-Party Cookies
Our Website uses cookies from third parties, including:
– Google Analytics
– Google Ads and DoubleClick
– Facebook Pixel
– Affiliate tracking platforms
– Social media plugins
10.3 Managing Cookies
You can control cookies through:
– Our cookie consent banner (upon first visit)
– Your browser settings (most browsers allow you to refuse or delete cookies)
– Opt-out tools provided by advertising networks
– Industry opt-out mechanisms: [www.aboutads.info/choices](http://www.aboutads.info/choices) or [www.youronlinechoices.eu](http://www.youronlinechoices.eu)
Note: Disabling certain cookies may affect website functionality.
10.4 Do Not Track Signals
Some browsers include a “Do Not Track” (DNT) feature. Our Website does not currently respond to DNT signals, but you can use the cookie management options described above.
11. Targeted Advertising and Affilliate Marketing
11.1 Interest-Based Advertising
We participate in interest-based advertising, which means you may see ads for our products on other websites based on your browsing activity. We use cookies, pixels, and similar technologies for this purpose.
Opt-Out Options:
– NAI Opt-Out: [www.networkadvertising.org/choices](http://www.networkadvertising.org/choices)
– DAA Opt-Out: [www.aboutads.info/choices](http://www.aboutads.info/choices)
– Google Ads Settings: [www.google.com/settings/ads](http://www.google.com/settings/ads)
– Facebook Ad Preferences: Available in your Facebook settings
11.2 Affiliate Marketing Disclosure
Our Website participates in affiliate marketing programs. When you click on affiliate links or make purchases through affiliate links, we may receive a commission. This does not affect the price you pay. We use cookies to track affiliate referrals and attribute sales.
Affiliate Partners May Include:
– Amazon Associates
– Commission Junction (CJ Affiliate)
– ShareASale
– Other retail and brand affiliate programs
12. Children’s Privacy
Our Website is not directed to children under the age of 16 (or 13 in the United States). We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information promptly.
If you believe we have collected information from a child, please contact us at [email protected].
13. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.
Security Measures Include:
– SSL/TLS encryption for data transmission
– Encrypted storage of sensitive information
– Secure payment processing through PCI-DSS compliant providers
– Regular security assessments and updates
– Access controls and authentication requirements
– Employee training on data protection
However, no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.
14. Third-Party Links
Our Website may contain links to third-party websites, including affiliate partner sites, social media platforms, and advertisers. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.
15. Email Marketing
15.1 Consent and Subscription
When you subscribe to our newsletter or provide your email address, you consent to receive marketing communications from us. You may receive:
– Promotional emails about products, sales, and special offers
– Blog updates and content newsletters
– Personalized product recommendations
– Abandoned cart reminders
15.2 Unsubscribe
You can unsubscribe from marketing emails at any time by:
– Clicking the “unsubscribe” link in any marketing email
– Updating your preferences in your account settings
– Contacting us at [email protected]
Note: Even if you unsubscribe from marketing emails, we may still send transactional emails related to your orders and account.
16. California Residents: Notice at Collection
Pursuant to the CCPA/CPRA, we provide the following information about the categories of personal information we collect:
Categories of Information Collected:
– Identifiers (name, email, address, IP address)
– Commercial information (purchase history, shopping behavior)
– Internet/network activity (browsing history, interactions with website)
– Geolocation data
– Inferences (preferences, characteristics, behavior predictions)
– Sensitive personal information (payment details processed by third parties)
Purposes of Collection: As described in Section 4 of this Privacy Policy
Categories of Third Parties with Whom Information is Shared: As described in Section 6 of this Privacy Policy
Retention Period: As described in Section 8 of this Privacy Policy
16.1 Sale and Sharing of Personal Information
We do not “sell” personal information in the traditional sense. However, under the broad CCPA/CPRA definition, sharing information with advertising partners for targeted advertising may be considered a “sale” or “sharing” of personal information.
Categories of Information Sold/Shared: Identifiers, internet activity, inferences
Right to Opt-Out: To opt-out of the sale or sharing of your personal information, click [Do Not Sell or Share My Personal Information] or contact us at [email protected].
17. Virginia, Colarado, Connecticut, and Utah Residents
Residents of Virginia, Colorado, Connecticut, and Utah have specific rights under their state privacy laws:
Right to Opt-Out: You may opt-out of:
– Targeted advertising
– Sale of personal data
– Profiling in furtherance of decisions that produce legal or similarly significant effects
How to Opt-Out: Use our [Your Privacy Choices] link or contact [email protected]
Appeals Process: If we deny your privacy rights request, you have the right to appeal. Contact us at [email protected] with “Privacy Rights Appeal” in the subject line.
18. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. We will notify you of material changes by:
– Posting the updated Privacy Policy on this page
– Updating the “Last Updated” date
– Sending an email notification (for significant changes)
– Displaying a prominent notice on our Website
Your continued use of our Website after changes become effective constitutes acceptance of the updated Privacy Policy.
19. Contact Information
If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:
Email: [email protected]
Postal Address:
Commissura Proprietary Limited
P O Box 80256
Gaborone, Botswana
Physical Address:
Plot 4821, Trans-Kalahari Highway Sese Junction, Sese, Botswana
20. Additional Disclosures
20.1 Automated Decision-Making
We may use automated decision-making and profiling to:
– Personalize your shopping experience
– Recommend products
– Detect fraud and prevent security threats
– Optimize pricing and promotions
You have the right to request human review of automated decisions that significantly affect you.
20.2 Social Media Features
Our Website includes social media features, such as Facebook Like buttons, Twitter sharing, and Pinterest pins. These features may collect your IP address and browsing information and may set cookies. Social media features are governed by the privacy policies of the respective social media companies.
20.3 Blog and User-Generated Content
Comments, reviews, and other content you post on our blog or product pages are publicly visible. Do not include sensitive personal information in public posts.
Acknowledgement
By using timelessfinery.com, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.
Last Updated: December 9, 2025