Etsy Seller: CosyFabric Privacy Policy

CosyFabric is based in China and has been selling fabrics on Etsy since 2012. He sells mainly to buyers in United States, Canada, Australia, New Zealand, Singapore, Spain, France, Germany, and Italy, but offers his items for sale world-wide. In the past six months, CosyFabric business has started to take off, and he recently started using a third-party shipping provider to help fulfill his orders. He uses Google Cloud to host some of his buyers’ personal information.

The GDPR requires that CosyFabric provide certain information to his buyers in his privacy policy, including:

the personal information he collects;
the legal bases he relies on to collect, use, and share personal information;
the third parties with whom he shares personal information;
the length of time he keeps personal information;
if he’s transferring personal information outside of Europe (for example, if he moves his business to the United States 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.
Visit this EU GDPR help site and read Articles 13 and 14 for more details on the information that must be included in your privacy policy to comply with the GDPR.

Based on GDPR requirements, here’s how CosyFabric might introduce his privacy policy to his buyers:

This Privacy Policy describes how and when I collect, use, and share information when you purchase an item from me, contact me, or otherwise use my services through Etsy.com or its related sites and services.

This Privacy Policy does not apply to the practices of third parties that I do not own or control, including Etsy or any third party services you access through Etsy. You can reference the Etsy Privacy Policy to learn more about its privacy practices. CosyFabric should then go on to include information on the following:

1. Personal information he collects
CosyFabric 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 I Collect

To fulfil your order, you must provide me with certain information (which you authorized Etsy to provide to me), 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 me with additional personal information (for a custom order of jewelry, for example), if you contact me directly.

2. The legal bases he relies on to collect, use, and share personal information
The GDPR requires that you explain the legal bases you rely on to collect, use, and share personal information. The legal bases may include a buyer’s affirmative consent to receive marketing messages, compliance with legal obligations, and a seller’s use of the personal information in their legitimate interests (improving their services, for example). Throughout his privacy policy, CosyFabric should be as clear as possible about where and why he's relying on these different legal bases. For example:

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
as necessary for the purpose of my legitimate interests, if those legitimate interests are not overridden by your rights or interests, such as 1) providing and improving my services. I use your information to provide the services you requested and in my legitimate interest toimprove my services; and 2) Compliance with the Etsy Seller Policy and Terms of Use. I use your information as necessary to comply with my obligations under the Etsy Seller Policy and Terms of Use.
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. CosyFabric 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:

Etsy. I share information with Etsy as necessary to provide you my serv