- General information about data processing
The personal data manager is KULER LTD.. By opening and using the Online Store, various information and data are exchanged between your device and the server, which may also include personal data under the EU General Regulation. Below we present to you the data exchange closely, and we carefully define the use, interest and reasons. The data processing software and the marketing tools we use are fully compliant with the EU General Regulation so that your data is safe.
The website is accessible on the HTTPS secure protocol, which provides encrypted connection and the data exchange, our servers are also updated to the latest versions, which increases the level of security.
- Personal data and processing
- Basic user information collected only in case of an order in an online store (name, surname, the address of residence)
- Information about user purchases and invoices issued
- Data from voluntarily filled forms from users
- The device’s IP address
- Date and time of access
- The URL of the webpage and the referral URL (channel and campaign – the way to get a visitor or the source through which the visitor came to the site)
- Retention time on the website, the number and URLs of the pages visited, and the total time of the visit
- The type of browser you are using and the operating system used
The Owner does not collect or process your personal information except when you enable or consent to it or there is a legal basis for this and the provider has a legitimate interest in processing.
- Data processing on the basis of a law or contractual relationship
3.1. Online store purchase
In the case of the conclusion and implementation of the contract with the Owner (in the case of an online purchase), you must provide personal information for the purpose of concluding a contract.
The processing of an order in an online store is not possible without the provision of personal data. In order to fulfil the contract, there is thus a legitimate interest of the provider in accordance with Article 6 of the GDPR.
3.2. Sending promotional messages
In accordance with the second paragraph of Article 158 of ZEKom-1, the Owner may send you emails about sales actions or news items to the e-mail address you provided on your order, or you have signed in with it in the pop-up box on the website and by doing so, you agreed to receive promotional messages. The Owner does not forward your e-mail address to any third party under any circumstances, and you can always opt-out of receiving promotional messages by clicking on the link in the message itself. Your decision is always respected by the Owner and cancellation can be made in an automated manner and will take in effect immediately.
- Processing of personal data on the basis of a legitimate interest
According to GDPR, the Owner can also process the data on the basis of legitimate interest. The Owner always strives to always override the rights and freedoms of the individual or visitor of the website over these interests. If you do not want the processing of the data or you want to cancel or discontinue the processing, you can email us via e-mail to email@example.com.
4.1. General statistical processing
For the purposes of optimizing the website, monitoring the proper operation of websites, analyzing sales, repurchasing and customer behaviour, and for business optimization purposes and measuring business performance, we use the Google Analytics.
With the tool, we monitor sales by sales channels, how many customers make their purchases, and in what quantity and value, we monitor responses of advertising campaigns and general statistics about the visit. We use the anonymization of the IP address so that your IP address is never forwarded. After your IP address becomes anonymous, your person’s finding is no longer possible, so Google Analytics can by no means connect your device to other Google data.
4.2. Accessing order history and other data
Upon your e-mail request, the Owner can, if you provide them with your personal information or an account or order number, access your history of orders and personal information.
4.3. Customized communication with existing and potential buyers
Personalized communication (via e-mail, notifications in the browser or social networks) is used to present an appropriate offer, send discounts and other content that might be of interest to you based on your past interactions with our site. To carry out this type of communication, we use your demographic data (gender, age, location), purchase history (purchased products, number of purchases), product reviews and views (message opening, clicking on links) and dealing with behaviour and clicking on a website that can trigger sending customized messages. To carry out this type of communication, we use your demographic data (gender, age, location), purchase history (purchased products, number of purchases), product reviews and views (opening messages, clicking on links) and dealing with behaviour and clicking on a website that can trigger sending customized messages.
When using customized communication, we never create user profiles, nor do we profil you and we do not devote to your personal information, but we only perform processing on the basis of larger groups, which makes it impossible to identify you as an individual.
4.4. Using a Facebook marketing tool “Custom Audience”
We also use the Facebook Custom Audience service as part of the customized communication mentioned in the previous section. The service is performed on a legitimate interest basis or as part of the obtained consent from your site. Facebook Custom Audience works by uploading the email address that you entered in the purchase process to Facebook and linking it to your database with your Facebook profile as if it exists. Then Facebook adds you to the list of personalized audiences aka. Custom Audience and allow us to show customized ads in this way.
- Processing of personal data on the basis of consent
The Owner can process and collect your personal information if you provide consent for this purpose for the purpose of verifying and ensuring that you access and use the online account that you created by registering on a website, and for sending promotional messages and other content via e-mail, where there is no other legal basis for this and you expressly consent for this. Also, the Owner may process and collect your personal information for other purposes, but only if you have been thoroughly informed of these purposes and have given explicit consent.
If you do not want the process of the data or you want to cancel or discontinue the processing, you can email us via e-mail to firstname.lastname@example.org
5.1. Profiling potential and existing customers based on explicit consent
Based on the given consent, the Owner can perform advanced personalized communication through various marketing channels. By doing so, we can present you the best deals for you, that is based on your demographic data, the history of your purchases, website behaviours, and on the basis of your responses and clicks on the website. Based on the consent and personal information provided, we can create a user profile and, on the basis of this, we serve the best and personalized offers.
- Contact form usage
By using the contact form on the website, your information (text content and your e-mail address) are sent to our mail server owned by Google.
We store this information exclusively for the purpose of correspondence and do not provide it to third parties nor use them for the marketing purposes.
- Ordering in an online store
- The device’s IP address and the date, time of the order
- Your e-mail address and phone number, if you have entered it
- Your name, surname and address of the payer and possible address for delivery, insofar as it differs from the address of the payer
- Company tax number and the name of the company, if you entered this information
- Products you ordered and the method of payment and delivery
If you choose to pay by credit card or pay with PayPal, our website never saves or in any way holds the information about payment cards or data for accessing payment processors that are not owned by us.
When processing the order, our server transfers your data to an accounting program owned by a Slovenian company and complies with the standards required by the EU General Regulation. We also transfer your information to the DHL Express software, as this is necessary for processing and sending products to your address.
- Storage of personal data
The Owner keeps your data as long as necessary to achieve the purpose for which personal data were collected and processed.
If a special law regulates the storage of data for a certain period, then the Owner process these data in accordance with this law. If you have submitted, completed, and received the order, then the order information is kept on the server 2 years after the order was received from your site. We store the data exclusively to ensure the fast resolution of any complaints within the scope of the warranty we offer. If you provide a request for the deletion of your data from our databases, we may delete the information before, except for the information on the account that can not be deleted in accordance with the law and must be kept by the Owner for 5 years. Data in analytics tools (Google Analytics) is deleted after 26 months.
- Personal data processing on the basis of a contract
By using the web site, you are acquianted that the Owner may also entrust your personal information to other contracted processors who can handle the data exclusively on behalf of the Owner and within the limits of the Owner’s authorization. The company cooperates with the following contracted processors:
- Provider of accounting program and customer relationship management program,
- Accounting Service,
- The provider of sending emails (e.g., Google Mail, Mailerlite)
- provider of payment systems (eg PayPal, Braintree)
- Solution providers for online advertising (eg Facebook, Google)
Your privacy means a lot to us; therefore, the Owner of your personal information will never pass your information on to third parties, and also the Owner exclusively chooses verified contractors who have the software set up according to GDPR. Users of personal data do not send the data to third countries outside the EU, except in the United States. All contracted processors located in the US are part of the Privacy Shield Association.
- Contact person and your rights regarding data processing
In accordance with Articles 15, 16, 17, 18, 20 and 21 of the EU General Regulation on the Protection of Personal Data, you have the right to obtain information about your personal data stored in our base, the right to correct and amendment your data, the right to delete data, the right to limit the processing of data, the right to refuse and the right to transfer data.
The request for a copy of the data we keep can be sent by e-mail to email@example.com or by writing to the company’s address (KULER d.o.o., Staneta Severja 20, 2000 Maribor, Slovenia). You can also specify a request to delete or change the data to that email address.
For more information on data processing and additional questions, you can contact our company representative, Matej Koren, through the before mentioned e-mail or with a written request to the business address mentioned before.
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