Terms written in capital letters not defined in this document have the meaning defined in the Kavaha Regulations. By information about you (“Information about you”) we also mean your personal data as defined by 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 (“GDPR”): any information relating to an identified or identifiable physical person; an identifiable physical person is a person who can be directly or indirectly identified, in particular on the basis of an identifier such as name and surname, identification number, location data, internet identifier or one or more specific physical, physiological, genetic, mental factors, the economic, cultural or social identity of a physical person (“Personal Data”).
We will be the administrator of your Personal Data – Bulago Sp. z o.o. based in Warsaw (00-238), Poland registered in the Register of Entrepreneurs of the National Court Register under number 0000971211.
We are responsible for using information about you in a safe manner, in accordance with applicable law, in particular in accordance with the provisions of the GDPR and in accordance with the Regulations.
Information we collect
We may collect certain types of information to better provide the Services on kavaha.eu:
1. We collect information that you provide to us:
a. When placing an order (either via an account, or as a guest): name and surname, address, delivery address, e-mail address, invoice data, order history, documents authorizing to act on behalf of the Company;
b. Content available to other customers or users of the kavaha.eu website: reviews and comments;
c. Surveys and promotions: we may ask you to participate in a survey or invite you to participate in a promotion; in this case, we will require certain personal data, such as name and surname, address, e-mail address, telephone number.
2. Information that arises when using kavaha.eu:
a. Transaction Information: After you place an order, in addition to the information you provide us directly, we also collect certain information such as the date and time you placed your order or the status change of your order;
b. Information about your approximate geographic location or IP address from your browser using cookies or other internet technologies and inferring your location based on other information collected by us;
c. Other information regarding browsing kavaha.eu and your device: browser type, name of the domain that led you to kavaha.eu, the website you go to after leaving kavaha.eu, dates and times when you use kavaha.eu, device ID and browsing activities, e.g. searches, date and time of order, amount of time spent on kavaha.eu; We may collect certain information through cookies and other internet technologies;
d. Communication: We may store information that you provide when you communicate with us, including telephone calls and e-mails.
3. Information collected from other sources:
a. If we use a loyalty program in which you participate, the provider of the loyalty program may provide us with the personal information it has collected in connection with that program to enable the delivery of the Product;
b. Third party service providers may provide us with: payment details and information collected about you via cookies or other internet technologies;
c. Other external sources: if you create an Account using a third party login service (e.g. Facebook), the provider of that login service will provide personal information such as your name and email address to enable us to create an Account; in addition, we may obtain information about you from external sources and combine it with information in our possession.
Legal basis for the processing of Personal Data
1. Art. 6 sec. 1b) GDPR: processing is necessary to perform the order or to take action before its implementation.
2. Art. 6 sec. 1c) GDPR: processing is necessary to fulfil legal obligations.
3. Art. 6 sec. 1f) GDPR: processing is necessary for purposes resulting from the legitimate interest of data analysis in order to match the offer.
4. Art. 6 sec. 1a) GDPR: based on an explicit and voluntary consent, Personal data is processed for marketing purposes.
How we use information about you
We may use information about you to:
1. Fulfil your order or other request for Services or information;
2. Provide you with a good level of service;
3. Provide personalised offers;
4. Promote Kavaha Products;
5. To improve and update kavaha.eu;
6. Administer kavaha.eu, create backups for disaster recovery;
7. Detect security incidents and prevent illegal activities;
8. To achieve specific purposes for which we obtained your consent;
How we share information about you
In general, we do not share Information about you, unless it is necessary to fulfil your order and only to the extent necessary. Kavaha transfers Personal Data to intermediaries in the execution of the order, including those who pay for the Products – depending on the payment method chosen by the Customer.
In addition, as part of the implementation of a legitimate interest, Kavaha may transfer Personal Data to entities cooperating with the provision of electronic services that support the operation of kavaha.eu, provide technical services, including hosting services, concerning the development and maintenance of IT systems and websites, support the promotion of offers, cooperate in marketing campaigns.
Personal data is not transferred to countries outside the European Economic Area (EEA), unless the entity outside the EEA is an entity that meets an adequate level of protection, through:
a. cooperation with entities processing personal data in countries for which a relevant decision of the European Commission has been issued;
b. use of standard contractual clauses issued by the European Commission;
c. application of binding corporate rules approved by the competent supervisory authority;
d. other security that meets the appropriate level of protection based on appropriate legal security.
Personal data will not be processed in an automated manner (including in the form of profiling).
How long we keep your Personal Data
We store information about you only for the time necessary to achieve the above-mentioned purposes and legal obligations:
1. Data processed for order fulfilment – for the period necessary to perform the order and possible complaint handling;
2. Data processed for purposes resulting from legitimate interest – for the period necessary to achieve the purpose for which they are stored, i.e. better match the offer;
3. Data processed based on consent for marketing purposes – until the consent is withdrawn.
After the expiry of the processing period, Personal data is irreversibly deleted or anonymized.
Management and deletion of Personal Data
You can exercise the right to protect your Data, resulting from the applicable regulations:
1. The right to access and manage your Data:
You have the right to know whether we process information about you: specific Personal Data that we have collected about you; the categories of Personal Data we have collected about you; categories of sources from which your personal data is collected; categories of third parties to whom your Personal Data has been disclosed, provided that they have been disclosed and the fulfilment of this obligation is permitted by law; the nature of the processing of Personal Data. You do not need an Account to submit a request for viewing/accessing Personal Data. If you submit multiple requests to view/access Personal Data, we may charge a fee. You will receive information about the amount of the fee before processing your request in this regard. We reserve the right to decline a request if it is excessive or manifestly unfounded. If we are unable to comply with your request, we will let you know the reason. You can also exercise your right to correct or update the information you provide to us. You can exercise this right and manage your data by directly updating your Account or by submitting a request to us. You are responsible for the information you provide to us and you should keep it accurate and up to date so that we can best deliver Products and Services to you. You can also block the use of certain data through the settings of your device or browser, which may, however, adversely affect your experience with the functionality of kavaha.eu.
2. The right to remove or limit the processing of your Data:
You have the right to delete some of the Personal Data that you provide to us as part of Account registration – if you decide to delete the information, we will not be able to provide Services for you, including fulfilling orders. You can exercise the right to delete data by sending us a request (also if you do not have an Account and you have provided us with your data by placing an order without registration). In some circumstances, we may retain information about you – in order to comply with legal obligations (tax, billing, etc.). Some information may remain in backups maintained for data integrity and disaster recovery. We make every effort to keep your information no longer than necessary and will take steps to delete your information where reasonably possible.
3. The right to receive a copy of Personal Data:
Copies of Personal Data may be sent by electronic means, if possible, or by traditional mail. If you submit multiple requests for copies of Personal Information, we may charge a fee. You will receive information about the amount of the fee before processing your request for sending a copy of Personal Data. We reserve the right to decline a request if it is excessive or manifestly unfounded. We will try to respond to a correct and confirmed request for copies of Personal Data as soon as possible.
4. The right to cancel or modify consent to marketing communications
You have the right to cancel or modify your consent to receive marketing messages. You can exercise this right by logging into your Account and changing your communication preferences. Please note that this will not affect the lawfulness of data processing prior to the withdrawal of consent. You can also withdraw your consent by sending us an e-mail containing such a request. Please note that you cannot opt out of receiving certain administrative, transactional or legal messages that we may send as part of our legitimate business if you have a User Account or use certain features available on kavaha.eu. A complete cessation of sending e-mails is only possible if you submit a request to delete your Account.
We have implemented several measures to help protect your personal information. These measures include, but are not limited to, minimizing access to personal data to employees who must have access to it, and encrypting personal data transmitted through our websites using the SSL/TLS protocol. We update our security measures to increase the security of your Personal Data.
We regularly review the rules governing the processing of Personal Data, including security solutions. We have implemented procedures for dealing with suspected personal data breaches. The security of your Personal Data also depends on you. Be sure to choose an Account password that no one else knows or can easily guess, and to keep your login details and password confidential. When finished, log out of your Account, especially if you are using a shared computer.
We are not responsible for the actions of unauthorized persons to whom login details have been disclosed. In such cases, we are not responsible for any acquisition or distribution of your Personal Data by such unauthorized party. If you believe that your personal information has been compromised, we encourage you to notify us immediately.
Right to file a complain
In the event of objections to the processing of Personal Data, you can submit a complaint to the President of the Office for Personal Data Protection (ul. Stawki 2, 00-193, Warsaw, Poland).