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INTRODUCTION

Welcome to 4Kraft’s privacy policy.

We recommend that you read this privacy policy carefully.

4Kraft respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how 4Kraft collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service.

This website is not intended for use of children even though the products are for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.

CONTROLLER AND WHO WE ARE

Thank you for visiting our e-shop at “kinderkraft.pl” or “kinderkraft.com”

Both of our e-shops above are operated by “4Kraft spółka z ograniczoną odpowiedzialnością” of ul. Tatrzanska 1/5, 60-413, Poznan, Poland, registered in Poland’s companies registrar “KRS“ under Company Number 0000378767, VAT: 7811861679.

4Kraft spółka z ograniczoną odpowiedzialnością is the controller and responsible for your personal data (collectively referred to as ”Company”, “we”, “us” or “our” in this privacy policy).

We have appointed a Data Protection Specialist who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our Data Protection Specialist using contact details below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Specialist in the following ways:

By post:

4Kraft spółka z ograniczoną odpowiedzialnością
ul. Tatrzanska 1/5
60-413, Poznań, Poland

By e-mail:

iod@4kraft.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR PERSONAL INFORMATION

We keep our privacy policy under regular review. We encourage you to visit our website regularly to stay informed of any changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name(s), last name(s), company’s name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity if it is anonymised. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions.You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • • apply for our products or services for example when using our online shop;
  • • create an account on our website;
  • • subscribe to our service or publications;
  • • request marketing to be sent to you; or
  • • give us feedback or contact us.
  • Automated technologies or interactions.As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
  • Third parties or publicly available sources.We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

  • (a) analytics providers, such as Yandex.Metrica, Facebook Pixel, Google Analytics, Google based inside and outside the EU;
  • (b) advertising networks, such as Google Ads, Facebook, Microsoft, Joomla, Shopify based both inside and outside the EU; and
  • (c) search information providers such as Google based inside and outside the EU.

Google Analytics, Google Ads, YouTube

The Google Analytics and Google Ads use cookies to monitor your choices and display proper adverts. Your IP address is anonymised before sent to Google. We refer you to section 6 below (International Transfer) should you wish to learn more on the rules of transfer of your personal data to third countries.

Should you wish to withdraw your consent for your data to be processed via Google Analytics, you may wish to install specialised software to block Google Analytics (opt-out browser add-on).

Facebook Ads manager and Facebook Pixel

We use different marketing tools offered by Facebook as for that reason third parties, including Facebook itself, may use cookies, navigation signals and similar technologies to collect relevant information online in order to display proper adverts to you. We refer you to section 6 below (International Transfer) should you wish to learn more on the rules of transfer of your personal data to third countries.

You may also wish to check the following websites to learn about the choice: http://www.aboutads.info/choices, http://www.youronlinechoices.eu/

Facebook Messenger

We use Facebook Messenger to communicate with you. In order to communicate with us that way you have to log in into your Facebook account. We do not collect or process your data transferred that way to Facebook Inc that is an administrator of your data. You may wish to click this link to learn more about how to use Facebook Messenger: https://www.facebook.com/help/1071984682876123/?helpref=hc_fna

4. HOW WE USE YOUR PERSONAL DATA?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • • Where we need to perform the contract we are about to enter into or have entered into with you.
  • • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will obtain your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer.
To process your request with accordance to ‘Safe Seat Car’ scheme

(a) Identity
(b) Contact

Performance of a contract with you

To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)


MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

LEGITIMATE INTEREST OF THE FIRM

We may process your information where it is in our legitimate interest to do so as a firm. We will do this without prejudicing your fundamental rights and freedoms. This may include:

  • • Ensuring that we are providing you with the best service,
  • • Identifying any other services we think that may be of your interest given all the information you have provided us already,
  • • Developing our professional relations with you as or customer,
  • • Protecting our rights and interest if there is any ongoing case with you involved as a party.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). The marketing communications from us will be with respect to the products or services similar to one you have purchased from us already.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

If you wish us to provide you with our marketing materials with respect to all our products (so not necessarily similar to the one you have purchased already), you can opt in by giving your express consent. The consent form can be found under the link below: [LINK].

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THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by sending us email on: iod@4kraft.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may provide your personal data to the following entities:

  • - legal advisors and lawyer’s companies that provide services to us;
  • - payment services companies;
  • - accounting companies;
  • - hosting companies;
  • - companies responsible for sending text messages;
  • - insurance companies (if necessary for purpose of any claims made or received)

We may share your personal data whenever we are legally obliged to do so. Nevertheless, we assure you that every request to disclose your personal data is analysed very carefully and thoroughly, to avoid passing any information inadvertently to unauthorized persons.

6. INTERNATIONAL TRANSFERS (OUTSIDE THE EUROPEAN UNION)

Please note that we make sure that when using services and technologies, we only transfer personal data to entities only where:

  • - The adequacy decision has been made;
  • - The restricted transfer is covered by appropriate safeguards, namely: a legally binding and enforceable instrument between public authorities and bodies or binding corporate rules.

Binding corporate rules are an internal code of conduct operating within a multinational group, which applies to restricted transfers of personal data from the group's EEA entities to non-EEA group entities.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Please note that you have a right to obtain a copy of your personal data transferred to Third Country at any time.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8. DATA RETENTION

HOW LONG WE WILL RETAIN AND USE YOUR PERSONAL DATA

By providing you with products and services we create records that contain your information, such as customer account records, tax records or activity records. We may use your personal data in order to conclude and perform a contract with you.

The retention periods for the records as mentioned above are determined based on the type of record or nature of the activity. Typically however we will retain your personal information for a period of six years after your contractual relationship with 4Kraft ends.

We may however in some circumstances retain your personal information for longer periods whenever we are required by law to do so or if there is an ongoing case that requires us to retain you data.

If you wish to obtain more information on how long we will keep your information please contact us at iod@4kraft.com.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have following rights under data protection laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at iod@4kraft.com.

Therefore, you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

If you wish to obtain a copy of your personal information please contact our Data Protection Specialist (DPS) at iod@4kraft.com.

We will provide you wish such information within one month after receiving your request, however we reserve our right to exceed this time up to two months whenever we hold a large amount of data or of the request is complex.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you wish to correct your data, please contact our DPS and provide us with the correct information so we will be able to progress your request as soon as possible.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request, especially we may not be able to erase your personal data if it has been less than six years from the conclusion of your contractual relationship with 4Kraft.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • • If you want us to establish the data’s accuracy.
  • • Where our use of the data is unlawful but you do not want us to erase it.
  • • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to withdraw your consent, please contact our DPS. Note, however, that we may not always be able to comply with your request for specific legal reasons which will be notified to you, if applicable, at the time of your request.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. If we refuse to comply with your request because it is manifestly unfounded or manifestly excessive, we will inform you on the reasons why we refused to comply with your request, about your right to make a complain to ICO (Information Commissioner’s Office) and about your right to seek to enforce this right through the courts.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

  • • Service providers in Europe who provide IT and system administration services.
  • • Consulting companies, companies providing trainings for our employees.
  • • Professional advisers including lawyers, bankers, auditors, accountants, bookkeepers and insurers.
  • • Travel agencies, hotels, partnering centres of excellence.
  • • HM Revenue & Customs, regulators and other authorities.

COOKIES

Please note that our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

You may wish to inspect the following links that will redirect you to guidance on how to remove or block cookies from your device:

Please kindly note we do not take any responsibility for the content provided under the above links and they are provided only as a guidance.

Cookies perform a lot of functions on the website; most of them are useful and we will try to describe them below (if the information is insufficient, please contact us):

  • - ensuring security - cookies are used to authenticate users and prevent unauthorized use of the client's panel. They are therefore used to protect the user's personal data against unauthorized access;
  • - impact on the processes and efficiency of using the website - cookies are used to ensure that the website works efficiently and that you can use the features available on it, which is done, among other things, by remembering the settings of your subsequent visits on the website. In the result, you can efficiently navigate the website and individual subpages;
  • - state of the session - cookies often record information about how visitors use the website, for example which subpages are displayed most often. They also allow to identify errors displayed on some subpages. Cookies used to record the so-called "session state" help to improve the quality of the services and increase the comfort of browsing;
  • - maintaining session status - if a client logs in to his panel, the cookies sustain the session. This means that after switching to another subpage, you do not have to re-enter your login and password; this contributes to the comfort of using the website;
  • - external cookies - we may use materials from different websites or providers, for instance YouTube.
  • - creating statistics - cookies are used to analyze how the visitors use the website (how many of them enter the website, how long they stay there, which content arouses the most interest, etc.). In the result, we can constantly improve the website and adapt its operation to the preferences of the users. In order to track the activity and create statistics, we use Google tools such as Google Analytics; in addition to reporting the website usage statistics, the Pixel Google Analytics can also contribute, along with some of the cookies described above, to displaying more relevant content to the user in Google services (such as the Google search engine) and across the entire web;
  • - using social functions - our website has a so-called Facebook Pixel, which allows you to like our fanpage on FB while using our website. However, to make this possible, we need to use cookies provided by Facebook;

Please note that cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Yandex.Metrica

Yandex.Metrica helps us to learn on your experience after visiting our website by indication what links you clicked or time you dedicated to use it. We use this tool to provide better service for our customers. Yandex.Metrica uses cookies and different technologies to collect relevant data, namely: URL address, information on the referring page, IP address of the device (that will be anonymised), dimension of the screen, type of the device, information on browser and operation system used by the user, geographical location, time zone, preferred language.

Yandex.Metrica stores the information in a pseudomised user’s profile. Neither Yandex.Metrica nor our company will ever use the data to identify individual users or to look for different data with respect to that user.

You can always opt out from creating the user’s profile, storage of the data by the tool or usage cookies by Yandex.Metrica by following the guidance under the link: [LINK]

Yandex.Metrica will process the data we made available to them and the data may be transferred to third countries, for instance to Russia. Yandex.Metrica ensures that the data is protected with accordance to section 46 of the GDPR.