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PRIVACY POLICY

PRIVACY POLICY

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Dear User,

We would like to inform you that this website describes the general principles of administering www.lacoste.sk, which is administered by Devanlay Polska Sp. z o.o. with its registered office in Warsaw (00-120 Warsaw), ul. Złota 59, NIP: 7010341947, REGON: 146127374, registered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, KRS number 0000419724, with a share capital of PLN 13,038,100.00, in relation to the personal data of the users who visit it. These rules apply to all visits to our websites, without registering or filling in or entering data in web forms.

By visiting the pages of this website, you agree to the following terms and conditions. If you do not accept the principles, please do not visit or use the content of the services offered through our websites.

PRIVACY AND COOKIES POLICY

GENERAL PRINCIPLES

1. This Privacy and Cookies Policy document includes the following information concerning:

a. the manner and principles of processing and protection of personal data of users of the website http://www.lacoste.sk ("Website") administered by Devanlay Polska Sp. z o.o. with its registered office in Warsaw (00-120 Warsaw), ul. Złota 59, NIP: 7010341947, REGON: 146127374, registered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, KRS number 0000419724, with a share capital of PLN 13,038,100.00; (“Devanlay”), e-mail: gdpr@lacoste.pl , (“Privacy Policy”);

b. Cookies.

2. The Privacy and Cookies Policy indicate the principles of conduct in all matters relating to the processing and protection of personal data within the meaning given by the provisions on personal data protection, including in particular 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 (Official Journal of the European Union L 119, p. 1) ("GDPR") and the Personal Data Protection Act of 10 May 2018 ("Personal Data Protection Act"). These principles are also consistent with the Act on Rendering Electronic Services of 18 July 2002, as well as with the Telecommunications Law of 16 July 2004.

3. NOTE: We would like to inform you that the Website may contain external links that allow users to directly access other websites. Devanlay has no influence on the privacy policy and use of cookies of other websites and is not responsible for them. We suggest that before using the resources offered by other websites, please read the privacy policy and the use of cookies document, if available, or in the absence thereof, contact the owners of the website to obtain information on this subject.

4. Devanlay declares that the content of the Website does not violate any rights of third parties or applicable law regulations, in particular it is free from content containing information that could cause or pose a threat to the privacy or security of any persons, information that promote illegal actions or conduct that are offensive, constitute a threat, are indecent, defamatory or libellous, incite racism, prejudice based on ethnicity, culture or religion, which promote or facilitate criminal activity, violate the rights of third parties, including intellectual property rights, or otherwise violate rights protected by law.

5. Each visitor to the Website automatically becomes a User of the Website ("User"). By using the Website or providing personal data, the User accepts the principles described in this Privacy and Cookies Policy. In case of disagreement with the content of the Privacy and Cookies Policy, the User should not use the Website and provide personal data to Devanlay.

6. In certain cases, detailed privacy information will be additionally provided or the User will be asked to give specific, voluntary consent, directly in the place and at the time when it provides its personal data to Devanlay or interacts with Devanlay.

CONTROLLER OF THE PERSONAL DATA

The controller of personal data is Devanlay Polska Sp. z o.o. with its registered office in Warsaw (00-120 Warsaw), ul. Złota 59, NIP: 7010341947, REGON: 146127374, registered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, KRS number 0000419724, with a share capital of PLN 13,038,100.00 (“Controller”).

In order to exercise their rights and obtain further information concerning the processing of data as well as information on whether or not personal data are being processed, and to what extent, the persons concerned may contact the Controller by sending an e-mail to the following address gdpr@lacoste.pl

The controller has appointed a Data Protection Officer available at the e-mail address gdpr@lacoste.pl or by correspondence at the address Devanlay Polska Sp. z o.o. ul. Złota 59, 00-120 Warsaw.

PERSONAL DATA

Personal data mean information about an identified or identifiable natural person ("data subject") ("personal data"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name and surname, identification number, location data, web identifier or one or more factors specific to a natural person's physical, physiological, genetic, psychological, economic, cultural or social identity. The personal data may also include unique numerical identifiers, such as the IP address of the User's computer or the MAC address of the User's mobile device, as well as cookies.

PRINCIPLES FOR THE COLLECTION OF PERSONAL DATA

The personal data about the User may be collected by Devanlay from a number of sources, including:

a. provided directly by the User

Devanlay collects data about how the User uses our services and products, e.g. information about the types of content it views or handles and the frequency and duration of its actions. Devanlay also collects personal data provided during registration in the Newsletter, registration for the purpose of purchasing our products and filling in surveys.

b. the personal data that Devanlay collects automatically

Devanlay also receives and stores certain types of personal data each time the User contacts Devanlay online. The personal data is also collected when searching, shopping, participating in competitions and surveys and communicating with our customer service teams.

c. the personal data that Devanlay collects from other sources

We collect the personal data from other sources, e.g. from our trusted external partners and external platforms where Devanlay has accounts (e.g. Facebook).

The Website is designed and intended for adult Users.

Devanlay does not knowingly acquire or collect personal data from children under the age of 18. If it is discovered that Devanlay has accidentally collected personal data from children under the age of 18, the data will be deleted immediately.

STORAGE OF PERSONAL DATA

The personal data collected by Devanlay is stored and processed in the European Economic Area ("EEA"). Devanlay informs that this data may also be sent to a country outside this area and processed there by entities affiliated with Devanlay or third parties that support Devanlay in the provision of services offered.

For such operations, with respect to entities located in countries where the European Commission has not determined an adequate level of data protection, Devanlay applies Standard Contractual Clauses, approved by the Commission as a means to safeguard the compliance of operations with applicable law and data processing agreements that meet the requirements of the GDPR. The content of the Standard Contractual Clauses can be viewed by clicking on the link:

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contractstransfer-personal-data-third-countries_en

In the case of transfers of data from Europe to the US, some entities located in the US may additionally ensure an adequate level of data protection under the so-called EU-US Privacy Shield programme. Some providers have a Privacy Shield certificate, which can be checked by clicking on the link below:

https://www.privacyshield.gov/welcome

The personal data of the User is stored by Devanlay for the time absolutely necessary to achieve the relevant purpose (unless this Privacy Policy specifies in detail the time of storage of the personal data). Devanlay will then keep the personal data properly stored and protected for such a period of time as could give rise to liability for its processing, in accordance with the regulations in force at any time. After the limitation period of possible actions, depending on each case, Devanlay will proceed to delete the User's personal data.

Devanlay ensures that any person acting under its authority and having access to the User's personal data processes them only at the request of Devanlay, unless other requirements arise from the Union or Member State law.

Devanlay reserves the right to transfer personal data within the capital group to which Devanlay belongs on the basis of Devanlay legitimate interest for the purposes of internal management, compliance with legal obligations, fraud prevention and/or to secure tools, improve Devanlay products and services or after obtaining the User's consent to do so.

Depending on the purposes for which they were collected, and only if necessary, certain personal data of the User may be made available to entities within the capital group to which Devanlay belongs, which are also located outside Poland, on the basis of the legitimate interest of Devanlay for the purposes of internal management, where possible in a pseudonymised manner and where necessary to provide the User with the requested service.

The catalogue of recipients of the personal data processed by Devanlay always results primarily from the scope of services used by the User.

The catalogue of recipients of the data also results from the User's consent or from law regulations and is more precise as a result of actions taken by the User in the E-Shop (see Regulations of the E-Shop).

TRUSTED PARTNERS

The processing of the personal data to a limited extent may involve trusted Devanlay partners ("Trusted Partners"), in particular those who technically assist in the efficient operation of the Website or E-Shop, providers of hosting services or ICT services, carriers or intermediaries processing order shipments, entities handling electronic payments or card payments in the E-Shop, companies that service the software, support Devanlay in marketing campaigns, as well as providers of legal, accounting and consulting services.

With the Trusted Partners established outside the EEA, Devanlay have signed Standard Contractual Clauses, approved by the Commission.

Devanlay cooperates with external courier companies to deliver the goods. These courier companies receive the following data in order to carry out a specific order:

·         Name and surname of the User

·         Delivery address

·         Potential postal number (if the order is to be delivered to a parcel station)

·         Potential e-mail address (if the courier company wishes to inform the user by e-mail about the planned delivery date)

In order to provide services to the Users, Devanlay also cooperates with technical service providers. If these entities process the User’s data outside the EEA, Devanlay ensures that the service provider has contractually or otherwise guaranteed an equivalent level of data protection.

In case of obligations imposed by offices or courts or for the purpose of legal or criminal prosecution, Devanlay will provide the Users' data to law enforcement authorities or other third parties, if necessary.

THE SCOPE OF PERSONAL DATA, THE PURPOSES AND THE LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

The purpose and scope of the personal data processed by Devanlay is each time based on a specific legal basis specified by the GDPR. In some cases it is the User's consent, in others the law regulations, sometimes the need to perform an agreement or the legitimate legal interest of the Controller. Detailed information is presented below.

The most frequent purposes of processing the Users' personal data by Devanlay are in particular: concluding and performing the Agreement for the provision of the Customer Account Service or taking actions at the request of a prospective Customer prior to its conclusion; concluding and performing the Sales Agreement or taking actions at the request of a prospective Customer prior to its conclusion; accepting and handling complaints; organising a competition, in particular, selecting the winners of the competition and granting prizes; presenting advertisements, offers or promotions (discounts) concerning the products or services of Devanlay, the performance of the Newsletter service; evaluation and analysis of activities and information about the User, including automated personal data processing (profiling), in order to present general advertisements, offers or promotions (discounts) concerning the products or services of Devanlay, in a manner tailored to the interests of a given User (without significantly affecting the User's decisions), in particular in order to perform the agreement for the provision of the Newsletter and market and statistical analyses; pursuing claims and defending against claims, including those of third parties; fulfilling legal obligations arising from law regulations, e.g. tax and accounting, especially in the case of paid agreements or correspondence with the User, including responding to the Users' messages.

Devanlay processes the personal data only for specific and limited purposes, including in particular:

a.     CUSTOMER ACCOUNT SERVICE

CATEGORIES OF THE PROCESSED DATA: contact information such as name and surname, address, sex, country, e-mail address and telephone number, User ID, password, date of birth, age, account settings, and if the User makes a purchase also payment information and payment history, order information, delivery information, order history, encrypted credit card information (without security code CVV or CVC), personal data related to Cookies, in particular click history and navigation and browsing history, and if the User asks for a VAT invoice, also NIP and REGON. The registered User can close its account at any time by contacting us through Customer Service gdpr@lacoste.pl

PURPOSE: Devanlay processes the aforementioned personal data in order to provide the Customer's Account service (free electronic service referred to in Art. 10.1 b of the Regulations of the E-Shop) and to enable the User to use certain functionalities of the Website and provide him/her with access to various functions, products and services that are available to him/her as a registered User, e.g. being individually informed about changes in the Regulations of the E-Shop or the Privacy and Cookies Policy or promotions, as well as saving products in the shopping cart. In case of purchase, Devanlay processes the aforementioned personal data in order to process orders and returns and send the User notifications about the status of delivery or in case of any problems with the delivery of products, as well as to manage payments or process complaints.

THE DATA RETENTION PERIOD: Devanlay will store the User's personal data during the term of the agreement for the provision of the Customer Account service, in which this account will be active. If the processing of data by Devanlay takes place on the basis of another legal basis indicated below in the section LEGAL BASIS, then the personal data of the User will be stored for the entire period of the existence of this legal basis. In any case, a longer retention period for personal data is decisive.

ACCESS TO PERSONAL DATA: Devanlay transfers the personal data of the User to Trusted Partners only to those who are responsible for the proper and uninterrupted operation of the Customer's Account. In the event of a purchase by the User, Devanlay transfers the personal data of the User to Trusted Partners, i.e. in particular to courier companies, payment companies, debt collection companies, law firms, accounting firms, solely to ensure the fulfilment of the purposes specified above.

LEGAL BASIS: Processing of personal data takes place on the basis of the agreement with the User for opening the Customer Account service or is necessary to take action at the request of the User related to the launch of this service (Art. 6 sec. 1 letter b) of the GDPR). At the same time, if the User makes a purchase or lodges a complaint, in addition to the legal basis indicated above, Devanlay also has the right and obligation to process the data for no less than the period required by law regulations, including in particular the provisions of Tax Laws and the Accounting Act (Art. 6 sec. 1 letter c of the GDPR). Additionally, Devanlay has the right to process the User's personal data when it is necessary for purposes resulting from legally justified interests pursued by the Controller, i.e. in the case of establishing, pursuing or defending against the User's claims (Art. 6 sec. 1 letter f) of the GDPR). If the User wishes to use the option of sending direct marketing information to him/her, organising competitions, promotions, surveys, competitions, loyalty programmes, the personal data is processed on the basis of the User's consent (Art. 6 sec. 1 letter a) of the GDPR).

b.    ON-LINE PURCHASES MADE BY THE USER

CATEGORIES OF THE PROCESSED DATA: contact information such as name and surname, address, e-mail address and telephone number, payment information and payment history, date of birth, age, sex, country, encrypted credit card information (without security code CVV or CVC), and in the event that the User requests a VAT invoice also NIP and REGON. In the event that the User is additionally using the Customer Account service, Devanlay will also process information on order history, delivery history, User ID, password and account settings, as well as the personal data related to Cookies, in particular click history and navigation and browsing history.

PURPOSE: Devanlay processes the aforementioned personal data in order to process orders and returns, to manage questions about the availability of clothing, to manage product reservations on the Website or to provide personal tailoring services, depending on the availability of these services at any given time and to send the User notifications about delivery status or in the event of any problems with the delivery of products, as well as to manage payments, for invoicing purposes and to issue receipts and invoices for purchases made on the Website or to process complaints.

THE DATA RETENTION PERIOD: Devanlay will store the User's personal data for as long as they are necessary for the performance of the purchase agreement by the User. If the processing of the data by Devanlay takes place on the basis of another legal basis indicated below in the section LEGAL BASIS, then the personal data of the User will be stored for the entire period of the existence of this legal basis. In any case, a longer retention period for personal data is decisive.

ACCESS TO PERSONAL DATA: Devanlay transfers the personal data of the User to Trusted Partners, i.e. in particular to courier companies, payment companies, debt collection companies, law firms, accounting firms, solely to ensure the fulfilment of the purposes specified above.

LEGAL BASIS: The processing of personal data is necessary for the provision of the on-line shopping service or to take action at the request of the User prior to the conclusion of the agreement (Art. 6 sec. 1 letter b) of the GDPR). At the same time, Devanlay also has the right and obligation to process the data for no less than the period required by law regulations, including in particular the provisions of Tax Laws and the Accounting Act (Art. 6 sec. 1 letter c). Additionally, Devanlay has the right to process the User's personal data when it is necessary for purposes resulting from legally justified interests pursued by the Controller, i.e. in the case of establishing, pursuing or defending against the User's claims (Art. 6 sec. 1 letter f) of the GDPR).

c.     PROCESSING OF THE USERS' SUBMISSIONS

CATEGORIES OF THE PROCESSED DATA: contact information such as name and surname, address, e-mail address and telephone number, payment information and payment history, date of birth, age, sex, country, encrypted credit card information (without security code CVV or CVC), and in the event that the User asks for a VAT invoice also NIP and REGON, correspondence with the User regarding its requests and expectations. If the User additionally uses the Customer Account service, Devanlay will also process information on order history, delivery history, User ID, password and account settings as well as personal data related to Cookies, in particular click history and navigation and browsing history.

PURPOSE: Devanlay processes the aforementioned personal data in order to answer the User's questions (Art. 6 sec. 1 letter a) of the GDPR), to process User's complaints concerning products and technical questions submitted by e-mail or telephone (Art. 6 sec. 1 letter a) or b) of the GDPR), as well as in the event that there is a need to contact the User in connection with his/her order, product delivery, product return or product shipment (Art. 6 sec. 1 letter b) of the GDPR). Devanlay processes the aforementioned data in order to better understand the needs and expectations of the Users and thereby improve its services, products and brands and for statistical purposes (Art. 6 sec. 1 letter f) of the GDPR).

THE DATA RETENTION PERIOD: Devanlay will process the aforementioned personal data until the final processing of the User's submission is completed. If Devanlay processes the data on the basis of another legal basis indicated below in the section LEGAL BASIS, then the User's personal data will be stored for the entire period of the existence of this legal basis. In any case, a longer retention period for personal data is decisive.

ACCESS TO PERSONAL DATA: Devanlay transfers the personal data of the User to Trusted Partners, i.e. in particular to courier companies, payment companies, debt collection companies, law firms, accounting firms, solely to ensure the fulfilment of the purposes specified above.

LEGAL BASIS: The processing of the User's personal data by Devanlay is necessary for the purposes resulting from legally justified interests pursued by the Controller, in particular to establish, pursue or defend claims, conduct correspondence with the Users, also through contact forms (including responding to Users' messages), market and statistical analyses (Art. 6 sec. 1 letter f) of the GDPR). In case of responding to the Users' inquiries, the processing of the User's personal data by Devanlay is based on the User's consent (Art. 6 sec. 1 letter a) of the GDPR), and in cases related to the Users' submissions resulting from the performance of the sales agreement concluded on-line, the processing may be necessary both for the performance of the agreement (Art. 6 sec. 1 letter b) of the GDPR) and subsequently for the fulfilment of the legal obligation incumbent on the controller (Art. 6 sec. 1 letter c) of the GDPR).

d.    NEWSLETTER SERVICE

CATEGORIES OF THE PROCESSED DATA: contact information such as name and surname, address, sex, country, e-mail address and telephone number, User ID, password, age, date of birth, account settings, personal data related to Cookies, in particular click history and navigation and browsing history.

PURPOSE: Devanlay processes the aforementioned personal data in order to provide the Newsletter service (free electronic service referred to in Art. 10.1 a) of the Regulations of the E-Shop) and to enable receiving information about new services or products offered by Devanlay via e-mail or text message. In order to obtain additional information, please go to the part concerning Profiling.

THE DATA RETENTION PERIOD: Devanlay will store the User's personal data during the term of the Newsletter service agreement. If the processing of data by Devanlay takes place on the basis of another legal basis indicated below in the section LEGAL BASIS, then the User's personal data will be stored for the entire period of existence of this legal basis. In each case, a longer retention period for personal data is decisive. If the User does not wish to receive individual product offers from Devanlay by e-mail, it may resign from this service at any time in any form, e.g. by e-mail, without incurring any costs other than the costs of providing information according to basic tariffs (e.g. Internet connection costs, postal fees). Of course, there is a resignation link in every e-mail. If the User does not wish to receive individual product offers from us via the push service, it can deactivate this function at any time in the settings of the particular application. In most of our applications, a specific function is available in the "Settings" section, in the "Notifications" menu or in the "Push Messages" menu.

ACCESS TO THE PERSONAL DATA: Devanlay transfers the personal data of the User to Trusted Partners only to those who are responsible for the proper and uninterrupted operation of the Newsletter service.

LEGAL BASIS: The processing of personal data takes place on the basis of an agreement with the User for opening the Newsletter service or to take actions at the request of the User related to the launch of this service (Art. 6 sec. 1 letter b) of the GDPR). Additionally, Devanlay has the right to process the User's personal data when it is necessary for purposes resulting from legally justified interests pursued by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Art. 6 sec. 1 letter f) of the GDPR).

e.    CONTACT FORM SERVICE

CATEGORIES OF THE PROCESSED DATA: contact information, such as name, e-mail address and telephone number, age, date of birth, personal data related to cookies, in particular the history of clicks and navigation and browsing history.

PURPOSE: Devanlay processes the aforementioned personal data in order to perform the Contact Form service (free electronic service referred to in Art. 10 c of the Regulations of the E-Shop) and to enable the User to send messages to Devanlay through the form available on the E-Shop website.

THE DATA RETENTION PERIOD: Devanlay will store the User's personal data during the term of the agreement for the provision of the Contact Form service. If the processing of the data by Devanlay takes place on the basis of another legal basis indicated below in the section LEGAL BASIS, then the User's personal data will be stored for the entire period of the existence of this legal basis. In any case, a longer retention period for personal data is decisive.

ACCESS TO THE PERSONAL DATA: Devanlay transfers the personal data of the User to Trusted Partners only to those who are responsible for the proper and uninterrupted operation of the Contact Form service.

LEGAL BASIS: The processing of personal data takes place on the basis of an agreement with the User for opening the Contact Form service or to take actions at the request of the User related to the launch of this service (Art. 6 sec. 1 letter b) of the GDPR). Additionally, Devanlay has the right to process the User's personal data when it is necessary for purposes resulting from legally justified interests pursued by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Art. 6 sec. 1 letter f) of the GDPR). Responding to the User's enquiries is based on the User's prior consent to the processing of the personal data (Art. 6 sec. 1 letter a) of the GDPR).

f.     COMPETITIONS

CATEGORIES OF THE PROCESSED DATA: contact information, such as name and surname, e-mail address and telephone number, age, date of birth, sex, personal data related to cookies, in particular the history of clicks and navigation and browsing history, as well as information provided in the competition.

PURPOSE: Devanlay processes the aforementioned personal data on the basis of the User's consent, which the User submits at the moment of applying to participate in the competition. The User's personal data will be used to enable Devanlay to contact the Participant in matters concerning the competition, before and after the event, to determine the identity of the Participants and verify their age, to contact the winners, to deliver the prize and to determine the method of delivery.

THE DATA RETENTION PERIOD: Devanlay will store the User's personal data for a period of 100 days after the end of the competition.

ACCESS TO THE PERSONAL DATA: The personal data will be transferred by Devanlay to Trusted Partners who are external companies, exclusively for the purpose of providing the services listed above and to enable courier companies to deliver prizes.

LEGAL BASIS: The processing of personal data takes place on the basis of the User's consent (Art. 6 sec. 1 letter a) of the GDPR). Additionally, Devanlay has the right to process the User's personal data when it is necessary for purposes resulting from legally justified interests pursued by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Art. 6 sec. 1 letter f) of the GDPR).

g.    DIRECT MARKETING OF THE DEVANLAY PRODUCTS

CATEGORIES OF THE PROCESSED DATA: If the User uses the Customer Account service, Devanlay processes contact information such as name and surname, e-mail address and telephone number, age, date of birth, sex, the history of purchases, the personal data related to cookies, in particular the history of clicks and the navigation and browsing history. In other cases, Devanlay processes contact information, such as e-mail address, telephone number and postal code, sex (if the User provides such information) as well as product and offer data opened on the Website by the User.

PURPOSE: Devanlay processes the aforementioned personal data in order to send the User marketing offers, surveys and invitations - by e-mail, text message, telephone and traditional mail.

THE DATA RETENTION PERIOD: Devanlay will store the User's personal data only during the period of the User's valid consent.

ACCESS TO THE PERSONAL DATA: The personal data will be transferred by Devanlay to Trusted Partners who are external companies, exclusively for the purpose of providing direct marketing services to Devanlay. This data will never be disclosed to third parties.

LEGAL BASIS: The processing of personal data takes place on the basis of the User's consent (Art. 6 sec. 1 letter a) of the GDPR). Additionally, Devanlay has the right to process the User's personal data when it is necessary for purposes resulting from legally justified interests pursued by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Art. 6 sec. 1 letter f) of the GDPR).

The User has the right to withdraw its consent to the processing of personal data and to receive direct marketing materials at any time.

After the withdrawal of consent, Devanlay will not send to the User any offers within the framework of direct marketing or information sent earlier on the basis of the consent for data processing.

h.    ON-LINE SEARCH

CATEGORIES OF THE PROCESSED DATA: depending on the frequency of the User's on-line interaction with Devanlay, this data may include use of the Website, the data about the User's origin, login details, the websites visited by the User, videos viewed by the User, advertisements marked by the User, the products that the User was looking for, the User's location, the duration of the User's visit, the products selected by the User for the shopping cart, the IP address, browser information, a unique identifier allocated to each visiting User and the expiry date of such identifier.

PURPOSE: Devanlay processes the aforementioned personal data in order to enable proper functioning of the Website, proper display of its contents, creation and remembering the card, creation and remembering the User's login, personalisation of the interface, such as language selection, the User's device parameters, as well as to ensure the security of the Website and for statistical purposes.

THE DATA RETENTION PERIOD: Devanlay will store the User's personal data only during the period of a valid legal basis indicated below in the section LEGAL BASIS.

LEGAL BASIS: The processing of personal data related to cookies is done for the legitimate interest of the Controller (Art. 6 sec. 1 letter f) of the GDPR), i.e. to maintain the security of the Website and enable its functioning. In the event that the purpose is to improve the offers or services of Devanlay or sending advertisements or providing tailored content, the processing takes place on the basis of the User's consent (Art. 6 sec. 1 letter a) of the GDPR).

i.      NOTIFICATION OF THE PRODUCT AVAILABILITY

CATEGORIES OF THE PROCESSED DATA: the User's e-mail address and the data which the User was looking for and which are available.

PURPOSE: Devanlay processes the aforementioned personal data at the request of the User in order to send it information about the availability of the products indicated by you by electronic means. The condition for sending such information by Devanlay is consent to receive commercial information about the products of the on-line shop to the e-mail address provided and to the processing of personal data by Devanlay.

THE DATA RETENTION PERIOD: Devanlay will store the User's personal data only during the period of the User's valid consent.

LEGAL BASIS: Providing the data is voluntary, however, the lack of consent to the processing of personal data makes it impossible to send information about the availability of the product. The processing of personal data is based on the User's consent (Art. 6 sec. 1 letter a) of the GDPR). Additionally, Devanlay has the right to process the User's personal data when it is necessary for purposes resulting from legally justified interests pursued by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Art. 6 sec. 1 letter f) of the GDPR).

The User has the right to withdraw its consent to the processing of personal data and to receive direct marketing materials at any time.

After the withdrawal of consent, Devanlay will not send to the User any information about the availability of the product.

j.      RETARGETING

Based on cookies, we use technology that allows us to reach, with the advertising message, the users who have already visited our Website, on other websites that they visit, including those belonging to entities cooperating with our partners.

The lack of connection between the advertisement displayed to the User and its interests and needs may be burdensome for it. Devanlay is aware that it is more attractive and practical for the User to receive a message that corresponds to its interests and needs as identified by the analysis of its previous behaviour, based on the cookies technology. Therefore, Devanlay is interested in following the advertising content of a user using different websites in order to provide advertising content tailored to its previous on-line activity.

k. FULFILLMENT OF THE LEGAL OBLIGATIONS OF DEVANLAY

CATEGORIES OF THE PROCESSED DATA: All information about the User required by the applicable law regulations depending on the specific law regulations or decisions of the competent authorities, in particular name and surname, contact information (e.g. e-mail address, mobile phone number), correspondence; information about the time and place of purchase and defects / complaints about the product, the history of purchases, other information. In order to fulfil the tax and accounting obligations, Devanlay will in particular process the following personal data of the Users: contact information, such as name and surname, address, payment information and payment history, NIP and REGON.

PURPOSE: Devanlay processes the aforementioned personal data in order to fulfil legal obligations only when necessary. Devanlay must process personal data in order to manage the obligations imposed on the company and to combat criminal activity and other abuses or to fulfil other legal obligations arising from law regulations, judgments or official decisions. Such requirements may include, but are not limited to, product liability and product security requirements such as communicating and providing information to the public and consumers about product warnings and withdrawals, e.g. in the case of defective or health hazardous products, or to the extent required by individual laws. Devanlay will also process the Users' personal data in order to comply with legal obligations resulting from the law regulations concerning taxes and accounting.

THE DATA RETENTION PERIOD: The processing of data by Devanlay takes place during the entire period of existence of this legal basis. In the event that the Devanlay also processes the personal data of the Users in order to fulfil the legal obligations resulting from law regulations, e.g. tax and accounting obligations, the storage period will be 6 years.

ACCESS TO THE PERSONAL DATA: Devanlay transfers the User's personal data to competent authorities and institutions. In the event that Devanlay also processes the Users' personal data in order to fulfil legal obligations resulting from law regulations, e.g. tax and accounting obligations, the personal data (usually aggregated) may also be transferred to Trusted Partners or made available within the capital group to which Devanlay belongs.

LEGAL BASIS: The processing is necessary to comply with the legal obligation of the Controller (Art. 6 sec. 1 letter c) of the GDPR).

ACCESS TO THE PERSONAL DATA

Apart from the cases of disclosing personal data described above, the personal data may also be disclosed to entities belonging to the same capital group as Devanlay and to third parties who support Devanlay in the provision of services offered by the company, i.e.:

-financial institutions,

-institutions involved in the detection and prevention of fraud,

-technology service providers,

-suppliers and partners in the provision of logistics, transport and delivery services,

-customer service providers.

- providers and partners in the provision of marketing and advertising services.

In order to maximise the efficiency of the service provided, some of the aforementioned service providers are established in countries outside the EEA. In such cases, the Users will be informed about the transfer of their data outside the EEA.

PROFILING

When Devanlay sends or displays personalised information or contents (advertisements, offers, promotions, discounts), in such a situation Devanlay may use so-called "profiling", which is any form of automated processing of the personal data that involves the use of the personal data to evaluate certain personal factors of a natural person, in particular to analyse or forecast aspects of personal preferences, interests, economic situation, behaviour, location, health, reliability or movement. This allows Devanlay to better understand the User's expectations and adapt to their needs, without significantly influencing its decisions. Thanks to the Controller's use of advanced technologies, the above actions will often be performed by the system in an automated manner, thanks to which the content sent will be the most up-to-date and the User will be able to get acquainted with them quickly (ordinary "profiling").

Only in the case of adult Users, the aforementioned analysis of interests and preferences performed by Devanlay will also serve to create, grant, implement dedicated and, as far as possible, adjusted to them advertisements, offers or promotions (discounts), in an automated manner, which may cause legal consequences for the User or have a similar impact on it, potentially limiting access to them to other Users (an option unavailable to the Users who are not of age and did not consent to such actions of the Controller). These actions, contrary to ordinary "profiling", may have a significant impact on the User's shopping choices. The more frequently a given User uses the Devanlay services and purchases its products, the better promotions and surprises can be prepared for the User.

In certain circumstances described below, the User has the right to object to the use of its personal data for profiling by revoking its consent to profiling or changing its Cookies settings.

DISCLOSURE OF THE DATA OF THIRD PARTIES BY THE USER

The functions and services offered and provided by Devanlay may require Devanlay to process the personal data of third parties made available to Devanlay by the Users.

In the event that the User provides the personal data of third parties, Devanlay assumes that the User has informed these third parties about the purposes and manner of their processing.

RIGHTS OF THE USER

The User has the following rights:

THE RIGHT OF ACCESS TO THE DATA: The User has the right to access its personal data, which are stored by Devanlay on the basis of the principles specified in the GDPR. Devanlay may charge a reasonable fee taking into account the administrative costs of providing such information. Clearly unjustified, excessive or repeated requests may remain unanswered. In order to exercise this right, please contact the following e-mail address: gdpr@lacoste.pl

THE RIGHT TO RECTIFICATION OF THE PERSONAL DATA: The User has the right to request the rectification of its personal data if they are incorrect or outdated, as well as the supplementation of incomplete data. In order to exercise this right, please contact the following e-mail address: gdpr@lacoste.pl. If the User uses the Customer Account service, it can rectify or update its personal data by itself.

THE RIGHT TO ERASURE OF THE DATA: The User has the right to erase any data processed by Devanlay. This right will not be exercised by Devanlay in the case of, inter alia, an unfinished procedure within the process of the User submission, an open order which has not yet been sent or has been sent only partially, an outstanding debt to Devanlay, regardless of the payment method, the existence of at least a suspicion that the User has used the Devanlay services in an improper manner during the last three years, making any purchases, because then Devanlay will keep the personal data of the User concerning the transaction for accounting and tax purposes. In order to exercise this right, please contact the following e-mail address: gdpr@lacoste.pl

THE RIGHT TO OBJECT TO THE PROCESSING OF DATA BASED ON A LEGITIMATE INTEREST OF DEVANLAY: The User has the right to object to the processing of his/her data on the basis of a legitimate interest of Devanlay. In such a situation, Devanlay will cease processing his/her personal data, unless it is able to prove a legitimate justification of this process, which will take precedence over the interest of the User or due to legal claims. In order to exercise this right, please contact the following e-mail address: gdpr@lacoste.pl

THE RIGHT TO DATA PORTABILITY: In the event that Devanlay processes the User's personal data in an automated manner on the basis of his/her consent or the concluded agreement, the User has the right to receive a copy of its data in a structured, commonly used and readable format. This copy may be sent to the User or to another entity. This applies only to the personal data provided to Devanlay. In order to exercise this right, please contact the following e-mail address: gdpr@lacoste.pl

THE RIGHT TO LIMIT THE PROCESSING: The User has the right to request that Devanlay limit the processing of his/her data. This right means that the processing of the User's data by Devanlay will be limited to storage and will not be used or processed in any other manner. This applies in the limited cases specified in the GDPR, i.e. (i) the User questions the accuracy of the personal data for a period allowing Devanlay to verify the accuracy of such data, (ii) the processing is unlawful and the User objects to the erasure of the personal data, requesting in return the limitation of its use, (iii) Devanlay no longer needs the personal data for the purposes of the processing, but the User needs them to establish, pursue or defend claims, (iv) the User has objected to the processing based on a legitimate interest of Devanlay - until it is determined whether the legitimate grounds of Devanlay take precedence over the grounds of the User's objection. In order to exercise this right, please contact the following e-mail address: gdpr@lacoste.pl

THE RIGHT TO OBJECT TO THE AUTOMATED PROCESSING, INCLUDING PROFILING: In order to exercise this right, the User should click on the "unsubscribe" link in any e-mail or message sent to him/her by Devanlay. In order to object to the profiling, please contact the following e-mail address: gdpr@lacoste.pl

THE RIGHT TO WITHDRAW THE CONSENT AT ANY TIME WITH REGARD TO THE PROCESSING OF DATA BASED ON THE CONSENT: The User may withdraw its consent to the processing by Devanlay of his/her data if such processing is based on the consent. Withdrawal of the consent does not affect the lawfulness of the consent-based processing prior to its withdrawal. In order to exercise this right, please contact the following e-mail address: gdpr@lacoste.pl

THE RIGHT TO LODGE A COMPLAINT WITH THE SUPERVISORY AUTHORITY: The user has the right to contact the data protection authority, i.e. the President of the Office for Personal Data Protection, in order to lodge a complaint against the actions of Devanlay in the area of data protection and privacy. Devanlay asks the Users to contact the following e-mail address before exercising this right: gdpr@lacoste.pl

THE RIGHT TO DEACTIVATE COOKIES: The User has the right to deactivate cookies. The default settings of the web browsers usually accept Cookies but it can be easily changed in the User's browser. Many cookies are used to enhance the usability and improve the functionality of websites/applications. Therefore, disabling cookies may prevent the User from using certain parts of the Website. For further information, Devanlay suggests reading the information in the "Help" menu of the browser in use or the information provided under the following link http://www.aboutcookies.org

THE RIGHT TO INFORMATION: The User has the right to be informed in a clear, transparent and easily understandable manner about how Devanlay uses his/her data and his/her rights. Devanlay ensures the exercise of this right by publishing the Policy on the Website.

All information will be provided by Devanlay without undue delay - as a principle within one month from the receipt of the request. If necessary, this period will be extended by another two months due to the complexity of the request or the number of requests.

In any case, within one month from the receipt of the request, Devanlay will inform the User about the actions taken and (if applicable) about the extension of the deadline, stating the reason for the delay.

COOKIES

1.    Cookies are small text files downloaded to the User's device and used by the User to browse the Website.

2.    Cookies collect data concerning the User's use of the Website.

3.    The main purpose of cookies is to provide a more personal and interactive use of the Website and to analyse the User's activity on the Website, for example by enabling the User's personal preferences to be set. Cookies are needed in order to facilitate the use of the Website and make it more user-friendly without causing any damage to the device.

4. The cookies used by Devanlay may be divided according to the period of time they remain in the User's device used for browsing, their origin and purpose. There are two main types of cookies used on the Website: "session cookies" and "persistent cookies". Session cookies are temporary files that are stored in the user's terminal equipment until the user logs out, leaves the website or switches off the software (web browser). Persistent cookies are stored in the user's terminal equipment for a period of time specified in the parameters of cookies or until they are deleted by the user.

5. The Website uses the following types of Cookies (i) "necessary" Cookies to enable the use of services available on the Website, e.g. authenticating Cookies used for services requiring authentication on the Website and (ii) "performance" Cookies to collect information about how the Website is used.

Devanlay does not store sensitive personal data such as address, password, credit or debit card information, etc. in the Cookies that it uses.

7. The default web browsers allow storage and access through Cookies to the end users' devices. The User is entitled at any time to change the settings concerning the Cookies mechanism, i.e. to change the conditions of storing and accessing information collected by means of Cookies. The stored information and access to it does not change the configuration of the end user's device or the software installed on that device.

8. By using this Website without changing the settings of the web browser in order to disable the use of Cookies, the User agrees to the placement of Cookies on the device and access to the terminal equipment of the User. The Users can change the settings of the web browser at any time to disable Cookies. To learn how to change the settings concerning Cookies, please visit the following link http://www.aboutcookies.org.

9. The User has the right to limit or disable the use of Cookies by its web browser by changing the settings to block Cookies or requiring prior consent before Cookies are stored on the device used to access the Website. In this case, it is possible that the use of the Website by the User may be less effective. The User may not be able to access certain parts of the content or to use certain features of the Website and, in extreme cases, the correct display of the content of the Website may not be available.

SECURITY

Taking into account the state of technical knowledge, the cost of implementation and the nature, scope, context and purposes of processing as well as the risk of violation of rights or freedoms of natural persons with different probability of occurrence and seriousness of threat, Devanlay applies appropriate technical and organisational measures to ensure the protection of the personal data processed, appropriate to the threats and categories of protected data, and in particular protects the data against their disclosure to unauthorised persons, collection by an unauthorised person, processing in violation of applicable law regulations and change, loss, damage or destruction.

Making information on applied technical and organisational measures ensuring the protection of processing available outside may weaken their effectiveness, which threatens the proper protection of personal data.

Devanlay applies, in particular, the following technical measures to prevent unauthorised persons from acquiring and modifying the personal data sent by electronic means:

a. Security of the data files against unauthorised access.

b. SLL certificate on the Devanlay E-Shop Website where personal data are provided.

c. Encryption of data used to authorise a person using the functionality of the E-Shop.

d. Access to the Customer Account only after giving an individual login and password.

FACEBOOK PLUGIN

Our website contains a plugin for Facebook social networking site (Facebook Inc., 1601 Willow Road, Menlo Park, California, 94025, USA). The Facebook plugin on the Website is marked with the Facebook logo.

This plugin will directly connect the User to the Devanlay profile on the Facebook server. In this case Facebook may be informed that the User has visited the Website from its IP address.

If the User visits the Website while logged in to its Facebook profile at the same time, Facebook will register the information about this visit.

Facebook does not provide Devanlay with information about the data collected and the manner of its use. Devanlay also does not know the purpose and scope of the data collected by Facebook. For further information regarding the privacy of the Facebook portal, the User should contact Facebook directly or read the portal's privacy policy at the following address: https://www.facebook.com/about/privacy/


If the User does not agree that Facebook may obtain information about his/her visits to the Website, it should log out of the Facebook account in advance.

 DATA PROTECTION IN GOOGLE ANALYTICS

The Website uses mechanisms for analysing the Google Inc. network services (”Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA “): Google Analytics, Google Double Click and Google Tag Manger. Google Analytics, Google Double Click and Google Tag Manger use cookies, which enable the analysis of how websites are used. The information collected through cookies is transferred to the Google servers located in the USA and archived.

If the IP address anonymisation function is activated when using the Website, the IP address of the User is shortened by Google. This applies to the Member States of the European Union and other countries mentioned in the EEA Agreement. Only in exceptional cases, the full IP address is sent to the Google server in the USA and shortened there. In this manner, the IP address anonymisation function will be activated on the Website. At the request of the website operator, Google uses the collected information to analyse the website usage, prepare reports on website usage and other services related to Internet usage. The IP address transmitted by the User's browser within the framework of the Google Analytics programme is not stored together with other Google data.

The User can block the storage of cookies in the web browser. In this case, however, it will not be possible to make full use of all the functions of the website. In addition, the User can block the storage of data collected by cookies concerning the use of the website (including the IP address) and sending them to Google, as well as the transmission of these data by Google by downloading and installing the plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=pl

CHANGES AND UPDATES

Devanlay reserves the right to change or update this Privacy and Cookies Policy.

The latest version will be available on the Website.

In addition, the Users who use the Customer Account service will be informed individually about changes in the Privacy and Cookies Policy.

The Privacy and Cookies Policy comes into force on 09.09.2019

Last update: 01.09.2019