PERSONAL DATA CONTROLLER:
WINTRADE INTERNATIONAL s. r. o.
registered office: Mickiewiczova 16, 811 07 Bratislava
ICKO: 47 795 981
Registered in the Commercial Register of the District Court Bratislava I, Section: Sro, Insert No. 99095/B
CONTACT DETAILS OF THE PERSONAL DATA CONTROLLER:
Correspondence address: Mickiewiczova 16, 811 07 Bratislava
Telephone number: +421 905 336 051
Contact e-mail: [email protected]
Responsible person: Serhii Novikov ([email protected])
Personal data protection is very important to us. We ask you to carefully read this Policy, which contains important information about the handling of your personal data and related rights and obligations.
1.1 What governs our handling of personal data?
When handling personal data, we act in accordance with the legal regulations of the Slovak Republic and directly applicable regulations of the European Union, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the "Regulation") and Act No. 18/2018 Coll. on the Protection of Personal Data and on Amendments and Additions to Certain Acts.
1.2 Personal data we collect
We collect different data depending on which of our services you use. The scope of the processing of personal data is proportionate, relevant and limited for the fulfilment of the stated purposes.
1.2.1. If you shop with us, we collect:
Name and surname, delivery address, email address, telephone number, bank details, payment details.
Data generated by the duration of the contract - products purchased, customer segment, volume of services provided.
1.2.2. If you are a registered customer, we collect:
Name and surname, delivery address, e-mail address, telephone number, bank connection, payment details.
Login names and passwords (we do not have access to the actual password).
1.2.3 If you receive marketing messages from us, we collect:
First name and email address. Telephone number if you are a registered customer.
1.2.4 We also process the following personal data:
2.1. How do we collect your personal data?
You provide us with your personal data mainly when you complete an order or when you set up a user account. If there is any change to your personal data, please inform us.
Furthermore, when you visit and use the web interface, some personal data may be collected and stored via cookies. You can read more about cookies in the "Cookie Information".
2.2 Purposes of the processing of personal data
2.2.1.Sale of goods.
In order to sell goods and improve the shopping process, we process your personal data. Specifically, this includes:
Processing orders for goods ordered through our website. The lawful reason here is necessity for the performance of the purchase contract and, for selected data, for the fulfilment of legal obligations (e.g. accounting documents).
Notice of availability of goods.
In the event that you request to monitor the availability of goods, we will process your personal data on the basis of your consent.
2.2.2 Customer support.
To provide customer service and to troubleshoot any problems in the performance of the purchase contract.
We use the collected data in order to communicate with you and personalize it individually. For example, we may contact you by phone, email or other means to remind you that you have items in your online shopping cart, to assist you in completing your order, to notify you of the current status of your request, order or complaint or to obtain additional information from you regarding it, or to notify you that you need to take an action necessary to keep your account active.
2.2.4. Improving the shopping process.
We use the data to continuously improve our shopping process and systems, including adding new features, while making informed decisions using aggregate analytics and business intelligence, all based on our legitimate interest derived from our freedom to do business and based on the necessity to improve the services we provide in order to compete successfully. In order to ensure that your rights and interests are sufficiently protected, we use personal data that is anonymised as far as possible for the purpose of improvement.
2.2.5 Protection, security and dispute resolution.
We may also process data for legitimate interest, which is to ensure the protection and security of our systems and our customers, to detect and prevent fraud, resolve disputes and enforce our agreements on the basis of legitimate interest.
2.2.6 Marketing Offers.
We send you commercial communications regarding similar products to those you have purchased and commercial information about new products and current promotions or discounts that may be of interest to you.
You can always opt-out of these commercial communications in the manner set out in each email containing the commercial communication (by clicking on the unsubscribe link or otherwise).
If you unsubscribe from commercial communications, we will no longer use your electronic contacts for these purposes. We will start using them again if you register or explicitly request them.
The marketing offers you receive may be selected based on other information we have collected about you over time from your contact information, demographics, favorites, and usage data from our products and websites (cookies, IP address, data provided by your browser, click-through data, business notifications viewed, products visited). We do not carry out fully automated processing that would have legal effects for you.
Unless you are our customer, we process on the basis of your consent.
You have the right to object to this processing at any time free of charge. Contact details are provided at the beginning of this document.
2.2.7 Processing of cookies from websites operated by WINTRADE INTERNATIONAL s.r.o.
If you have cookies enabled in your web browser, we process behavioural records from cookies placed on websites operated by WINTRADE INTERNATIONAL s.r.o. for the purpose of ensuring better operation of the WINTRADE INTERNATIONAL s.r.o. website and for the purpose of internet advertising by WINTRADE INTERNATIONAL s.r.o. For more information, please refer to the "Information on cookies".
2.3 On what legal basis do we use your personal data?
2.3.1 The basis for the processing of customer personal data is primarily the need to perform a contract to which the data subject is a party or to take pre-contractual measures at the request of the data subject (Article 6(1)(b) GDPR). This applies in particular to the personal data provided in the account registration form, the ordering and conclusion of a purchase contract or for making a reservation in the online shop, as well as when registering for the newsletter. Also in the case of personal data provided to us in connection with a customer complaint, the legal basis for their processing is the need to execute / service the contract for the sale of the goods complained about.
2.3.2 In the case of processing for the marketing purposes mentioned above, with the exception of those carried out in the context of the newsletter, the basis for this processing is the fulfilment of the objectives of the legitimate interests of the controller or its cooperating entities (Article 6(1)(f) GDPR), in which case the cooperating entities do not participate in the processing of the customer's data. On the other hand, insofar as the controller's partners may have direct access to this information - the legal basis for such processing is the voluntary consent given by the customer (Article 6 (1) (a) GDPR).
2.3.3 For other (other) purposes, the customer's personal data may be processed on the basis of:
188.8.131.52. voluntarily given consent - e.g. persons entering competitions (Article 6 (1) (a) GDPR);
184.108.40.206. a legal obligation - where the processing is necessary for the fulfilment of a legal obligation of the controller, for example, where, on the basis of tax or accounting regulations, the controller accounts for concluded sales contracts (Article 6(1)(c) GDPR);
220.127.116.11. necessary for purposes other than those mentioned above which arise from the legitimate interests of the controller or of a third party, in particular to establish, exercise or defend claims, to communicate with the customer also via contact forms (including responses to customer messages), market and statistical analysis (Article 6(1)(f) GDPR).
2.4 How long do we use the data?
2.4.1 Personal data may be retained for as long as the online shop is used (and may be deleted after three years from the customer's last activity in the online shop), and in the case of marketing activities - until the customer objects, and, if it relates to cookie technology and similar, depending on technical issues, until these files are deleted using the browser/device settings (the deletion of the files is not always the same as the deletion of the personal data collected through these files, and therefore an objection may be possible).
2.4.2. If the processing of personal data depends on the customer's consent, personal data may be processed until consent is withdrawn.
2.4.3 In any case:
18.104.22.168 Personal data will also be stored where the law (e.g. accounting or tax regulations) obliges the controller to process it;
22.214.171.124. personal data will be kept longer in case of a possible customer complaint against the controller, in order for the controller to be able to assert its claims, or are necessary for the assertion or defence of third-party claims, within the limitation period established by law, in particular the Civil Code.
2.4.4 Depending on the scope of the personal data and the purpose of their processing, they may be stored for a different period of time. In any case, the longer of the retention periods of the personal data is decisive.
2.5 Transfer of personal data to third parties
2.5.1 We use all personal data collected from customers exclusively for the internal use of the controller, protect it from misuse and do not disclose it to third parties without prior notice or your consent. The exceptions are external companies that provide support services for us (e.g. transport, payment or e-shop development) and public authorities. We may or must disclose your personal data to these companies to the minimum extent necessary for the smooth processing of your order or the functioning and improvement of the purchasing process.
2.5.2 In particular, the following activities:
126.96.36.199. For the payment of an online order (credit card, bank transfer), we transmit personal data to the service provider regarding the processing of payments.
188.8.131.52 For the delivery of goods by the contracted carriers, we pass on your personal data:
Packeta Slovakia s. r. o., ID No.: 48 136 999, Kopčianska 3338/82A, 851 01 Bratislava.
184.108.40.206 Other recipients of your personal data will be operators offering marketing services and personalized advertising for the controllers:
Google Ireland Limited , Gordon House, Barrow Street, Dublin 4, Ireland
Facebook, Facebook Ireland Ltd. 4 Grand Canal Square, Grand Canal Harbour Dublin 2, Ireland.
3.1 Right to withdraw consent to the processing of personal data
If we process your personal data only on the basis of your consent (i.e. without any other lawful reason), you may withdraw this consent at any time.
You can withdraw your consent to the processing of your personal data at any time by:
Withdrawal of consent does not affect the lawfulness of data processing carried out up to the time of withdrawal of consent to processing.
3.2 Right of access to personal data
You have the right to ask us whether we are processing your personal data. If we are processing your data, you have the right to access this personal data and in particular the following information:
Upon your request, we will provide you with a copy of the processed data. We may charge you an administrative fee for additional copies not exceeding the cost of making and delivering those additional copies.
3.3 Right to rectification
If your personal data is inaccurate or incomplete, you have the right to request immediate rectification, i.e. correction of the incorrect data and/or completion of the incomplete data.
3.4 Right to object to processing
You have the right to object at any time to the processing of your personal data insofar as we process it for direct marketing purposes, including any automated processing of personal data. Upon objection, we will no longer process your personal data for these purposes.
3.5 Right to erasure ("right to be forgotten")
You have the right to request that we delete your personal data if:
If there are no lawful grounds for refusing erasure, we are obliged to comply with your request.
3.6 Right to restriction of processing
You have the right to request that we restrict the processing of your personal data if:
When restricting processing, we are only entitled to store your personal data. Further processing is only possible with your consent or for lawful reasons.
If the processing of personal data is restricted due to an objection to processing, the restriction lasts for the time necessary to determine whether we are obliged to comply with your objection.
If the processing of personal data is restricted due to a denial of the accuracy of the data, the restriction lasts for the period of time necessary to verify the accuracy of the data.
3.7 Right to data portability
You have the right to obtain the personal data you have provided to us in a structured, commonly used and machine-readable format and to have it transferred to another data controller.
3.8. How can you exercise your rights?
You can exercise your rights in relation to your personal data by using our contact details. All information and actions will be provided to you without undue delay.
We will do our utmost to protect your personal data. However, if you are not satisfied with the treatment, you have the right to contact the competent authorities, in particular the Office for Personal Data Protection of the Slovak Republic (https://dataprotection.gov.sk/uoou/sk), which supervises the protection of personal data. This provision is without prejudice to your right to address your complaint directly to this authority.
In particular, if your place of residence, place of employment or the place of the alleged personal data protection breach is located outside the territory of the Slovak Republic, in another member state of the European Union, you may contact the competent supervisory authority in that member state.
4.1 Who processes your personal data?
We are the controller of personal data within the meaning of the Regulations.
Your personal data is further processed for us in particular by tax advisors, accountants, subcontractors. To the extent necessary for the performance of the contract or other obligations, we are also entitled to pass on your personal data to other persons, e.g. carriers or other persons involved in the performance of the contract or our obligations.
Your personal data will not be transferred to countries outside the European Union unless it is necessary for the performance of a contract or for any other reason in accordance with the rules for such transfers set out in the Regulations.
4.2 How do we process personal data?
The personal and other data collected is fully secured against misuse. Personal data will be processed in electronic form in an automated manner or in hard copy form in a non-automated manner.
This Policy is valid and effective from 01.12.2021.