PERSONAL DATA PROCESSING POLICY
wilderoben s.r.o. with the registered office at Páričkova 24, 811 02 Bratislava, Slovakia
Company ID: 50 724 401
VAT ID No.: 2120458802
VAT ID for VAT No.: SK2120458802
the company registered at the Regional Court in Bratislava I, Section Sro, Insert 128022/B.
In this section, we would like to inform you about the principles under which we process your personal data and analyse some aspects of the behaviour of visitors to our website, and your rights related therewith.
The protection of your personal data and your privacy is really important to us, so we treat your personal data with due care and, in accordance with the applicable law, we take care of their proper protection.
Please read this information carefully. Whenever we collect your personal data from you, we refer to this Policy and we encourage you to read this Policy. We have tried to make this Policy as clear as possible. If anything still has not been clear to you, do not hesitate to contact us with a question or comment; we will be happy to explain any concept or passage to you.
This Policy comes into effect from 10 October 2018.
Contact details of wilderoben:
Address: Páričkova 24, 811 02 Bratislava
Telephone: +421 918 666 624
Office hours: Mon – Fri from 9:00 AM to 5:00 PM
Personal data are processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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 “Regulation”).
Data subject: A natural person (consumer and self-employed) to whom the personal data relate (hereinafter referred to as “you” or “Customer”);
Personal data: Any information about an identified or identifiable customer; an identifiable customer is a natural person who can be identified, directly or indirectly, in particular by reference to a particular identifier, such as name, identification number, location data, network identifier or one or more specific physical, physiological, genetic, psychological, economic, cultural or social identity elements of this individual (hereinafter referred to as “Data” or “Information”);
Controller: An entity that determines the purpose and means of processing personal data, carries out processing and bears responsibility for such processing. A controller of personal data processed in connection with the operation of the wilderoben website is wilderoben s.r.o., Company ID No.: (hereinafter referred to as “We” or “wilderoben”);
Processor: An entity that processes personal data for the Controller, by law or under the authority of the Comptroller, based on an agreement on personal data processing (hereinafter referred to as “Business Partner” or “Partner”);
Website: The website available at wilderoben.com.
Purpose for Personal Data Processing: A reason why personal data is processed. Such reasons may include, for example, performance of an agreement, management of user accounts, handling of ideas and complaints, sending commercial communications (newsletters) or showing advertisements on the basis of customer interests;
Cookies: Short text files saved by your web or mobile browser. Most cookies contain a unique identifier, a so-called cookie ID. This is a string of characters assigned by websites and servers to the browser that saved the cookie. This allows websites and servers to distinguish and identify individual browsers. Cookies are used to improve the performance of websites, evaluate their traffic, and better target marketing activities. If you browse our website, we assume you agree to use these files.
2. What personal data are processed?
Wilderoben and its contractual processors, following the relevant legal title and purpose of processing, process the following personal data, or categories of personal data:
- identification and address data: e.g. name, surname, postal address, billing address, registered office address, company ID number, VAT number;
- electronic contact details: e.g. phone number, e-mail address;
- other electronic data: IP address, cookies, social network identifiers,
- location data of the device used by the customer, etc.;
- other personal data related to a contractual relationship: a bank account number, data on the use of our services; other personal data: typically, data provided by the customer in an order form or other documents and in communication with us, including later updates.
3. What is the origin of your personal data?
We process data you provide e.g. when ordering our services, registering a user account, communicating with us, or opting in for a newsletter. Typically, they include:
- identification and address data;
- electronic contact details;
- other personal data related to a contractual relationship;
- cookies the website you came from to our website;
- IP address;
- date of access and access time;
- search queries;
- http and https answer code;
- transmitted data groups;
- information about the browser and operating system of your computer.
4. Why personal data is processed?
Your personal data may be processed bywilderoben for the following purposes:
Contractual relationship performance:
- Purpose: Under an agreement with us, you are entitled to be provided the ordered products. On the other hand, we are entitled to be paid the agreed price. In order to be able to fulfil our part and to check the fulfilment of your part of the obligation, we need to process your identification and address details, contact details and other personal data related to the contractual relationship (e.g. an account number etc.).
- Legal basis: Personal data processing for the purpose of performing a contractual relationship is justified by the contractual relationship between you and us. The provision of personal data in this case is a contractual requirement without which the agreement cannot be concluded.
- Retention period: The data retention period is determined by the duration of customer's contractual relationship with us.
Customer account management:
- Purpose: Customers can register and manage their personal settings on our website. For this purpose, we need to process your e-mail address, or you can also provide us with your name, surname, address, and phone number. These data are then used to simplify ordering our services and provide customer benefits.
- Legal basis: The processing of personal data for the purpose of managing customer accounts is justified by your consent. The provision of personal data is voluntary in such case. However, it would not be possible to register without agreeing to the processing of an email address. You can withdraw your consent at any time.
- Retention period: The data retention period is determined by the duration of your consent. We will consider your consent to be withdrawn when you do not log in to your account for 4 years.
Customer communication, satisfaction assessment, handling of ideas, complaints and claims:
- Purpose: We use your data to manage your queries, handle ideas and complains with our customer support. We can also contact you for filling in a satisfaction questionnaire. If you decide to use one of social networks to communicate with us, it is important to keep in mind that the processing of data provided in this way is also governed by the terms of such social networks that we cannot influence. We also use your information to notify you of the status of your order and to advise you of a failure to pay the agreed price. If you do not complete your order, we may send you an e-mail or SMS with a reminder that you have not completed the order, and may offer you an advantage. We believe this is a useful service because thanks to it, you can continue with your order and do not have to search again for a selected travel service provider. We also process your data in cases where your rights arise from defective performance and in the exercise of your rights in relation to the processing of your personal data.
- Legal basis: The processing of personal data for the purpose of customer communication, satisfaction assessment, handling of ideas, complaints and claims is justified by our legitimate interest in communicating with customers. The provision of personal data in this case is not a legal or contractual requirement. You are under no obligation to provide us with your personal data for this purpose.
- Retention period: The data retention period depends on the duration of the customer's contractual relationship with us, and then it lasts for a period of 4 years after its termination.
Sending commercial communications and offering our services
- Purpose: We regularly send our customers and those who have given their consent news about our services by e-mail. You can quickly and easily stop receiving these commercial communications at any time by using the opt-out link contained in each communication. You can also manage your preferences on sending commercial communications in your customer account. Therefore, if you are our customer (for example, if you have made an order with us), we may use your e-mail address that you have provided us to send commercial communications about similar products unless you express your disapproval of it. In other cases, we ask you to agree to receive commercial communications about our products, events and promotional campaigns. We can use the information you provide to us, as well as information obtained otherwise in relation to our products - such as how you use the website, ordering details or information about your participation in events and competitions, to personalize our commercial communications. We will ask you for your consent with sending commercial communications whenever your consent is required by the applicable laws.
- Legal basis: The processing of personal data for the purpose of sending commercial communications and offering our services is justified by your consent or by our legitimate interest in direct marketing. Providing personal data based on your consent in this case is voluntary, but it would not be possible to send you commercial communications without it. You can withdraw your consent at any time. The provision of personal data in this case is not a legal or contractual requirement. You are under no obligation to provide us with your personal data for this purpose.
- Retention period: The data retention period is determined by the duration of your consent. We will consider withdrawing consent or terminating a legitimate interest if you do not open our commercial communication for 3 years.
Direct marketing and creation of personalized content and advertising:
- Purpose: A personalized content and advertising creation technologies allow us to show visitors who have already expressed their interest in our website and services, our advertisements on partner websites. We strive to show you only the advertisements that you are really interested in, and not advertisements without any connection to your person and interests. Based on the history of your orders, interests, and website behaviour, personalized content and offers can be displayed on our website and on third-party websites and applications (including social networks). This is especially possible with cookies. To manage your cookie preferences, read the section Cookies.
- Legal basis: The processing of personal data for the purpose of direct marketing and creation of personalized content and advertising is justified by your consent or by our legitimate interest in direct marketing. Providing personal data based on your consent in this case is voluntary, but it would not be possible to provide you personalized content and advertisements. You can withdraw your consent at any time. The provision of personal data in this case is not a legal or contractual requirement. You are under no obligation to provide us with your personal data for this purpose. However, some data are processed automatically for this purpose when you browse our website.
- Retention period: The data retention period data is determined by the duration of your consent. The retention period may vary depending on the type of cookies. Some cookies are limited by the duration of the session (so-called relational or session cookies). These are processed while the browser is running, and are automatically removed after shutting down. Other cookies are persistent (persistent cookies). These cookies remain in the browser even when it is turned off until the specified date, or when the user manually deletes them. According to these cookies, the user's computer can be identified when the web browser is restarted and the Internet is browsed. You can read more about the retention period of cookies in the section Cookies.
Improving quality of provided services, our website traffic analyses and analyses of your behaviour on websites:
- Legal basis: The processing of personal data for the purpose of improving quality of provided services, our website traffic analyses and analyses of your behaviour on websites is justified by your consent, or by our legitimate interest in direct marketing. Providing personal data on the basis of your consent is optional in such case, but it would not be possible to improve the quality of the services provided to you, analyse the traffic to our website and your website behaviour. You can withdraw your consent at any time. The provision of personal data in this case is not a legal or contractual requirement. You are under no obligation to provide us with your personal data for this purpose. However, some data are processed automatically for this purpose when you browse our website.
- Retention period: The data retention period is determined by the duration of your consent. The retention period may vary depending on the type of cookies. Some cookies are limited by the duration of the session (so-called relational or session cookies). These are processed while the browser is running, and are automatically removed after shutting down. Other cookies are persistent (persistent cookies). These cookies remain in the browser even when it is turned off until the specified date, or when the user manually deletes them. According to these cookies, the user's computer can be identified when the web browser is restarted and the Internet is browsed. You can read more about the retention period of cookies in the section Cookies.
Running customer competitions and delivering prizes:
- Purpose: We run a customer competition, from time to time, and we also process your personal data according to the parameters of the competition. Typically, they include your e-mail address, name and surname.
- Legal basis: The processing of personal data for the purpose of running a customer competition and delivering prizes is justified by your consent. Providing personal data in this case is voluntary, but it would not be possible to participate in a customer competition. You can withdraw your consent at any time.
- Retention period: The data retention period is determined by the duration of the customer competition.
Protection of our rights, property or safety or rights, property or safety of others:
- Purpose: We may use information about how you use our website or data about your orders to prevent or detect frauds, misuse, illegal use, and violation of our Business Terms and Conditions, and to comply with a decision of the court or other law enforcement bodies, the state administration or the conditions established by the applicable legal regulations.
- Legal basis: Processing of personal data in order to protect our rights, property or safety or the rights, property or safety of others is justified by the fulfilment of legal obligations, or our legitimate interest in the protection of our rights, property or safety or the rights, property or safety of others. The provision of personal data in this case is not a legal or contractual requirement. You are under no obligation to provide us with your personal data for this purpose. However, some data are processed automatically for this purpose when you browse our website.
- Retention period: The data retention period is 4 years upon the termination of our contractual relationships, or 4 years upon their receipt.
Accounting and tax purposes:
- Purpose: We also need to process your personal data because we are obliged to do so according to the appropriate accounting and tax legislation.
- Legal basis: Processing of personal data for accounting and tax purposes is justified by the fulfilment of legal obligations. We must process this data about you.
- Retention period: We process personal data for accounting and tax purposes for a period of time set by the applicable law (e.g. accounting data are processed for 10 years).
Performance of other legal obligations:
- Purpose: Other legal obligations we must comply with include, e.g. anti-money laundering laws.
- Legal basis: Processing of personal data for the performance of other legal obligations is justified by the fulfilment of legal obligations. We must process this data about you.
- Retention period: Accounting data are processed for a period of time set by the applicable law.
5. Who has access to the personal data?
Your personal data are primarily made available to our employees who need the data to provide you with our products and services. In addition to our employees, we need to pass on your personal data to various business partners that enable wilderoben to function and help us deliver better, more accurate and more personalized content, products and services. The partners that we entrust your personal data with are very carefully selected. We only work with those who are able to provide such technical and organizational security of your personal data so as to prevent unauthorized or accidental access to your data or their misuse. All of these partners are authorized to process your data solely on the basis of a personal data processing contract in which they undertake the obligation of confidentiality. The data provided must not be used for any other purpose than for which we have made the data available to them. The following categories of our partners (recipients) can have access to your personal data:
- Partners who provide transport of our products for us
- In order to supply you with our products, we use services of forwarding agents
- Partners whom we provide the data to analyse the visit rate of our website, your website behaviour, and business conversions
- We strive to make your experience of using our website as enjoyable as possible. That is why we work with partners who conduct visit rate and your behaviour analyses on our website. Thanks to these partners, we have information about which part of our website is unclear, where you are looking for the information you are looking for and whether you find it, which offers on our website you have clicked, etc. Based on this information, we regularly improve our website.
- Partners who provide us with services that ensure the technical service of a particular service, and technology operators we use for our services
- In order for wilderoben to function properly and provide you with services, we need to work with a wide range of partners who provide us with services, ensure the technical operation of a particular service, or operate the technologies we use for our services.
Typically, they include these categories of partners:
- providers of information and communication services and hosting, including cloud storage,
- providers of security and integrity of our services and websites,
- providers of analytical services,
- providers of accounting and tax consultancy,
- support service providers for customer support,
- payment service providers (payment card providers),
- social network operators,
- legal service providers, lawyers,
- partners working with us in loyalty programs, during the organisation of conferences, seminars and other events.
- Our direct marketing partners and our partners and technical solution providers thanks to which we can show you personalized content and advertising
- In order to present and promote our services, we use marketing agencies to which we provide some data that we need for accurate targeting of our ads.
- In order to get the best experience while visiting our website, we will provide you with relevant information, recommend services, and send reminders of orders left in your shopping cart. All of these services are based on your previous purchases, on which items you click on our website and which information you have given us.
- In order to ensure that our ads will be shown to a relevant audience, we share your personal data, including email addresses, with providers of technical solutions to help us show you personalized content and advertising.
- Public authorities
- We make the personal data available in case of law enforcement, if it is required by law or when it is necessary to prevent, detect and prosecute criminal offenses and frauds or, as the case may be, we are otherwise legally required to do so.
- These may include law enforcement bodies (police, prosecution and courts) or tax offices.
- The transfer of the personal data to these recipients does not take place regularly but only incidentally, especially if required by law
6. Are the personal data transferred outside the EU?
If we transfer personal data of our customers for processing to a third country (outside the European Economic Area, including countries outside the European Union - Iceland, Liechtenstein and Norway) or an international organization, we do so only provided that the third country or international organizations provide an adequate level of protection, or where the recipient of the personal data provides appropriate safeguards for their protection and where the enforceable rights of data subjects and the effective legal protection of data subjects are available in the country of destination. The European Commission has so far recognized an adequate level of protection in the following countries: Andorra, Argentina, Canada (trade organizations), the Faroe Islands, Guernsey, Israel, the Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the USA (limited to the Privacy Shield framework).
7. How are personal data processed?
The personal data are processed manually and in an automated way. For all processing activities, we maintain proper records in compliance with applicable laws.
8. What are the rights of data subjects?
When you exercise your rights, please contact us through our contact details listed in the introduction of this policy. We reserve the right to verify the identity of the applicant for the rights in question in an appropriate manner.
If requests are repeated and are clearly unreasonable or inappropriate, we may charge you a reasonable fee or refuse to accept the request.
- Right of access to personal data If you want to know if we process your personal data, you have the right to obtain from us the information about whether your personal data are processed and, if so, you also have the right to access your personal data. In case of a repeated request, we are entitled, based on our administrative costs, to charge a reasonable fee for a copy of the personal data provided.
- Right to correct inaccurate and complete incomplete personal data If you believe we are processing inaccurate or untrue data about you, you have the right to request their correction. You also have the right to complete any incomplete data. We will do the correction or update without undue delay, always with respect to our technical possibilities.
- Right to have the data erased If your personal data are no longer needed for the purposes for which they were collected or otherwise processed, or if you find out that they have been processed unlawfully, you have the right to request that they are erased.
- Right to restrict the processing of personal data If you are not interested in complete erasure, but only in a temporary restriction of the processing of your personal data, you may request us to restrict the processing of your personal data
- Right to data portability In case you want us to pass on your personal data to third parties, you can exercise your right to data portability. If any rights and freedoms of third parties could be adversely affected by such exercise of your right, we will be unable to comply with your request.
- Right to object You have the right at any time to object to the processing of personal data that is processed for the purpose of performing a task carried out in the public interest or in the exercise of public authority or for the purpose of protecting our legitimate interests. If we do not prove that there is a serious legitimate reason for the processing that outweighs your interests or rights and freedoms, we will terminate the processing based on your objection without undue delay.
- Right to withdraw consent at any time If the processing of your data is based on your consent, you have the right to revoke your consent at any time.
- Right to information on automated decision-making, including profiling You are not the subject of any decision based solely on automated processing, including profiling, which would have legal effects for you or would have a significant impact on you in a similar way.
- Right to file a complaint with the Office for Personal Data Protection You have the right to file a complaint with the supervisory authority, which is the Office for of Personal Data Protection of the Slovak Republic, based in Hraničná 12 820 07, Bratislava 27, Slovakia, phone number: +421/2/3231 3220, e-mail: firstname.lastname@example.org, website: www.dataprotection.gov.sk.
9. How are cookie files processed?
Cookies are used by most websites and servers to provide a whole range of basic Internet services. If you shop online, cookies are used by online shops to store the items you have previously added to your shopping cart. Cookies also allow our website to store your preferences (such as language or login) and use them during your next visit. Using cookies, one can also collect statistics on user activities, such as the number of unique visitors of the website per month, which are very valuable to the operator as they provide better, more user-friendly services.
Cookies can be divided by validity into:
- Session cookies that remain stored in your browser only until you close your browser,
- Persistent cookies that remain in your browser for a long time until their lifetime expires or until you manually delete them (cookie storage time in your browser depends on cookie settings and browser settings).
And by function into:
- Essential that are necessary for the functionality of our website,
- Preferential that allow our website to remember the information that changes how the website behaves or what it looks like (e.g. the preferred language or region you are in); these cookies are not strictly necessary for the functioning of our website, but increase the functionality and practicality of its use,
- Analytical that help us analyse your experience on our website (so-called User Experience) and thanks to which we understand how you use our website,
- Remarketing which we use to properly target and personalize content and ads,
- Conversion which analyse the performance of individual sales channels,
- Tracking that help us measure the performance of sales channels combined with conversions.
We also use third-party cookies that track multiple websites in order to provide you with personalized content and advertising on third-party websites and other sales channels. Through conversion cookies on our website, we measure the number of orders that were sent after the customer came to our website by clicking on the ads on our advertiser's website or linking them through a link on their partner's website. This is how we perform a performance analysis of our individual sales channels, based on the financial statement between us and our advertising partners. You cannot be identified through such conversion cookies, so they are not personal data. Our advertising partner will only receive information of the total number of users who clicked on the ad or placed an order with us.
10. Where can I learn more about the processing of personal data and privacy on the Internet?
Browser settings and cookies settings:
You may change your browser settings so that it removes cookies or prevents them from being stored on your computer or mobile device without your explicit consent.
For information about cookies setting, see the relevant browser help section. How it works on the most commonly used browsers can be found here:
- Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies
- Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies
- Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647
- Safari: http://support.apple.com/kb/PH5042
- Opera: http://www.opera.com/browser/tutorials/security/privacy/ Adobe (flash cookies): http://www.adobe.com/privacy/policies/flash-player.html
You can also visit http://www.youronlinechoices.com/ (English), www.allaboutcookies.org (English) or www.aboutads.info/choices (English), where you can learn about the possibilities of refusing certain targeted advertising activities offered by some third parties with whom we work. You will have to visit the websites of individual browsers and the devices to which your disagreement should relate. Because the tools for expressing disagreement may depend on cookies, you may have to visit these sites again and reset preferences if you delete the cookies. You can read about cookies on Wikipedia: https://en.wikipedia.org/wiki/HTTP_cookie (English).
11. Are data on children also processed?
Our website is not intended for children under the age of 16. Therefore, we do not deliberately collect their personal data. If we find that we have inadvertently obtained personal data on children under the age of 16, we will take steps to erase these data as quickly as possible, except when we are legally bound to keep them.
Legal regulations and our business strategies and the related ways of processing your personal data may change. If we decide to update these policies, we will post the changes to our website and we will inform you of these changes. In cases where there is a major change to these policies or, if the law imposes us to do so, we will inform you in advance. We ask you to carefully read these policies and periodically review these policies when communicating with us or using our website.
In Bratislava, 1. 9. 2018