Dear User,

We would like to inform you that this page describes the general principles of administration of the www.lacoste.pl website, which is administered by Devanlay Polska Sp. z o.o. with its registered office in Warsaw (00-120 Warsaw), ul. Złota 59, NIP number: 7010341947, REGON number: 146127374, registered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12^th Commercial Division, under the KRS number 0000419724, with a share capital of PLN 13,038,100.00, with regard to the personal data of users who visit it.

These rules apply in all cases of visiting our websites without registration or completing or entering data in web forms.

By visiting the pages of this website, you accept the terms and conditions listed below.

If you do not accept the terms and conditions, please do not visit or use the content of the services offered through our websites.

PRIVACY POLICY AND COOKIES

I.                 GENERAL PRINCIPLES

1.      This Privacy Policy document and Cookies contain information considering:

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

b.      cookies (“Cookies”).

2.       The Privacy Policy and Cookies indicate the principles of conduct in all matters relating to the processing and protecting of personal data in 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 Provision of Electronic Services of 18 July 2002, as well as with the Act on Telecommunications Law of 16 July 2004.

3.      ATTENTION: We would like to inform you that the Website may contain external links that allow Users to directly access other websites. Devanlay has no control over the privacy policies and use of Cookies on other websites and shall not be liable for them.

We suggest that before using the resources offered by other websites, please read the document of privacy policy and use of Cookies, if available, or, if not available, contact the owners of the website to get information about this matter.

Detailed information on third-party cookies can be found further in this Privacy Policy.

4.      Devanlay declares that the content of the Website shall not violate any third party rights or applicable law regulations and, in particular, shall be free from content containing information that could cause or threaten the privacy or safety of any person, information, which promote illegal activities or behaviors which are offensive, pose a threat, are obscene, defamatory or libelous, incite to racism, prejudice on grounds of ethnic origin, culture, or religious beliefs, which promote or facilitate criminal activities, violate the rights of third parties, including intellectual property rights, or otherwise constitute a violation of rights protected by law.

5.      Each person visiting the Website automatically becomes a User ("User"). By using the Website or providing personal information, the User shall accept the principles described in this Privacy Policy and Cookies. In case of lack of consent to the content of the Privacy Policy and Cookies, the User shall not use the Website or transfer personal data to Devanlay.

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

II.                PERSONAL DATA CONTROLLER

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

In order to exercise the rights and obtain further information concerning the processing of data, as well as information on whether and to what extent personal data are being processed, interested persons may contact the Controller by writing to the address gdpr@lacoste.pl

The Data Controller has appointed a Data Protection Officer available at the address gdpr@lacoste.pl  or by correspondence at: Devanlay Polska Sp. z o.o. ul. Złota 59, 00-120 Warsaw / Poland, with the annotation "Data Protection Officer".

III.               PERSONAL DATA

1.      Personal data shall mean information on an identified or identifiable individual (“data subject”) (“personal data”).

An identifiable individual is a person who may be identified, directly or indirectly, in particular on the basis of an identifier such as name and surname, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.

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.

2.      This website is designed and intended for adult Users.

3.      Devanlay does not intentionally acquire or collect personal data from children under the age of 18. In case of discovering that Devanlay has accidentally collected personal data from children under the age of 18, the data shall be deleted immediately.

4.   Devanlay, depending on the type of User's activity on the Website and the consents granted by him, may process various categories of User's personal data: contact details, such as name and surname, address, country, e-mail address and telephone number, User's ID, password, date of birth, account settings, payment information and payment history, order information, delivery information, order history, encrypted credit card data (without the CVV or CVC security code), personal data related to cookies, in particular click history and history of navigation and browsing, NIP, REGON, information on the time and place of purchase and product defects / complaints and others.

IV.              PRINCIPLES OF PERSONAL DATA COLLECTION

Personal data concerning the User may be collected by Devanlay from a number of sources, including:

a.      provided directly by the User

Devanlay collects information about how the User uses our services and products, e.g., information about the types of content that the User is viewing or dealing with, and the frequency and duration of the User's activities. Devanlay also collects the personal data provided when registering for the Newsletter, registering to purchase our products and completing surveys.

b.      personal data collected by Devanlay automatically

Devanlay also receives and stores certain types of personal data each time the User contacts Devanlay online. Personal data shall be also collected during searching, shopping, participating in contests and surveys, and communicating with our customer service teams.

c.       personal data collected by Devanlay from other sources

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

V.                SHARING OF PERSONAL DATA

Apart from the cases of providing personal data described above, the personal data may also be provided to entities belonging to the same capital group to which Devanlay belongs 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 suppliers,

·        suppliers and partners in logistics, transport and delivery services,

·        customer service providers,

·        suppliers and partners in the provision of marketing and advertising services.

In order to maximize the effectiveness of the service provided, some of these service providers are established in countries outside the EEA territory. In such cases, the Users shall be informed of the transfer of their data outside the EEA.

VI.              PLACE WHERE PERSONAL DATA IS STORED

The personal data collected by Devanlay is stored and processed in the European Economic Area ("EEA").

Devanlay shall inform that these data may also be transferred to a country outside this area and processed there by entities related by capital to Devanlay or third parties who support Devanlay in the provision of services offered.

For such operations, for entities based in countries where the European Commission has not found an adequate level of data protection, Devanlay shall use Standard Contractual Clauses, approved by the Commission as a means of securing the compliance of the operations with applicable law regulations, and data processing agreements that meet the requirements of the GDPR.

VII.             PERIOD OF STORAGE OF PERSONAL DATA

Depending on the category of personal data and the purposes of their processing, they may be stored for a different period.

Devanlay will process the User's personal data for the time strictly necessary to achieve the appropriate purpose, it will then store them properly recorded and protected for such a period of time as liability for their processing could arise, in accordance with the regulations in force at any time.

Personal data will be processed:

• throughout the period of providing the Customer Account, Newsletter or other service referred to in the Regulations of the E-Store;

• for the period of using the E-Store (and may be removed after three years from the last activity of the Customer in the E-Store);

• for the time needed to process the request or request of the User or the Customer;

• for the time Devanlay carries out a specific quality action or survey or until we anonymize data relating to your browsing preferences;

• in the case of marketing activities - until the User objects, and if they are related to cookies and similar technology, depending on technical issues, until these files are deleted using the browser / device settings (while deleting files is not always the same as deletion of personal data obtained through these files, hence the possibility of objection);

• for the entire period when the law (eg accounting or tax regulations) will oblige the Administrator to process them;

Personal Data will be stored longer in the event that the User or the Customer has any claims against the Administrator, in order to pursue claims by Devanlay, or to assert or defend against claims of third parties, for the limitation period specified by law, in particular the Civil Code.

If the processing of personal data depends on the User's consent, they may be processed until the consent is withdrawn.

In each case, the longer period of storage of personal data is decisive.

VIII.            TRUSTED PARTNERS

Limited processing of personal data may involve the Devanlay’s trusted partners ("Trusted Partners"), in particular those who technically assist in the smooth running of the Website or E-Store, hosting or ICT service providers, carriers or intermediaries performing order shipments, entities handling electronic payments or payment card payments in the E-Store, companies that service the software, support Devanlay in marketing campaigns, as well as legal, accounting and advisory service providers.

With the Trusted Partners who have their registered office outside the EEA, Devanlay has signed the Standard Contractual Clauses, approved by the Commission.

Devanlay cooperates with external courier companies for performance of delivery service.

These courier companies shall receive the following data in order to carry out a specific order:

·        Name and surname of the User;

·        delivery address;

·        or postal number (if the order is to be delivered to the parcel locker);

·        or e-mail address (if the courier company wants to inform the user via e-mail about the scheduled delivery);

·        phone number (if the courier company wants to inform the user by phone or text message about the scheduled delivery).

 In order to provide services to the Users, Devanlay shall also cooperate with technical service providers. If these entities process the Users’ data outside the EEA, Devanlay shall ensure that the service provider in question 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 shall provide the Users' data to the law enforcement authorities or other third parties, if necessary.

IX.              PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

The purpose and scope of personal data processed by Devanlay result each time from a specific legal basis defined by the GDPR. In some cases it is the User's consent, in other cases law regulations, sometimes it is a necessity to implement an agreement or a legitimate legal interest of the Controller. The detailed information are presented below.

1.      Basic purposes of personal data processing

The most frequent purposes of processing the Users' personal data by Devanlay are, in particular:

·        conclusion and execution of the Service Agreement for the Customer's Account or taking action at the request of the future Customer prior to its conclusion;

·        conclusion and execution of the Sales Agreement or taking action at the request of the future Customer prior to its conclusion;

·        acceptance and processing of complaints;

·        conducting the contest, in particular, selecting the winners of the contest and execution of prizes;

·        presentation of advertisements, offers or promotions (discounts) concerning the Devanlay’s products or services;

·        implementation of the Newsletter service;

·        assessment and analysis of activity and information about the User, including in the framework of automated processing of personal data (profiling), in order to present general advertisements, offers or promotions (discounts) concerning the Devanlay’s products or services, in a manner adjusted to the interests of a given User (without, however, significantly affecting its decisions), in particular for the purpose of implementing the Newsletter service agreement, as well as 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 regulations, especially in the case of payable agreements or maintaining correspondence with the User, including responding to the User's messages.

2.      Legal basis of personal data processing

[art. 6 sec. 1 lit. b) GDPR] The basis for the processing of the User's personal data is primarily the need to perform the contract to which he is a party or the need to take action at his request before its conclusion.

Devanlay uses this legal basis among others. in the case of: personal data provided in the form when registering a Customer Account; placing orders and concluding a Sales Agreement or making reservations in the E-Store; when subscribing to the Newsletter, as well as in cases related to the complaint of the purchased Goods.

[art. 6 sec. 1 lit. f) GDPR] Devanlay may also process personal data based on the legitimate interest of the Administrator.

This is the case in the following situations: market and statistical analyzes; handling applications and inquiries formulated by Users through various available forms of contact; carry out testing the usability of the Website and the level of User's satisfaction; making the necessary verifications to detect and prevent potential abuse or illegal use of our Website when making purchases or returns by the User, as well as in cases of establishing, investigating or defending claims, correspondence with Users, also via contact forms (including replying to messages from Users).

[art. 6 sec. 1 lit. c) GDPR] The processing of User's personal data is sometimes necessary in the light of applicable law - when processing is necessary to fulfill the legal obligation incumbent on the Administrator, e.g. when on the basis of tax or accounting regulations, the Administrator settles concluded sales contracts.

It should also be noted that in the event of User's inquiries or complaints about our goods or services, Devanlay is authorized to process his data as part of our legal obligations.

[art. 6 sec. 1 lit. a) GDPR] Sometimes, for the processing of personal data by Devanlay, it is necessary for the User to express their voluntary consent.

The User's consent is necessary, among others when using the Website, participating in competitions, loyalty program, when the User receives information tailored to his individual preferences through various means; presenting, creating, granting and implementing advertisements, offers or promotions (discounts) dedicated to a given User, which are based solely on automated processing, including profiling, as much as possible adapted to his preferences, which may significantly affect consumer decisions User or receiving push notifications.

3.      A detailed description of the principles and purposes of personal data processing in specific situations

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

a.      THE CUSTOMER’S ACCOUNT SERVICE

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name and surname, address, country, e-mail address and phone number, User ID, password, date of birth, account settings, and, if the User makes purchases, also payment information and payment history, information on orders, deliveries, order history, encrypted credit card data (without CVV or CVC security code), personal data related to Cookies, in particular, click history and navigation and browsing history, and, if the User requests a VAT invoice, also NIP and REGON numbers. During the CUSTOMER'S ACCOUNT service Devanlay may also process such personal data as age (to check if the User is of legal age) or gender (to properly address the correspondence). The Customer's Account of a registered User may be closed at any time by contacting us through our Customer Service: gdpr@lacoste.pl

PURPOSE: Devanlay processes the above-mentioned personal data in order to perform the Customer's Account service (free of charge electronic service referred to in Article 10.1 b of the Regulations of the Online Shop) and enable the User to use certain functionalities of the Website and provide him/her with access to various functions, products and services which are available to him/her as a registered User, e.g. to be informed individually about changes to the Regulations of the Online Shop or the Privacy Policy and Cookies or about promotions, as well as saving products in the shopping cart. In case of purchase, Devanlay processes the above-mentioned personal data in order to complete 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.

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

PERSONAL DATA SHARING: Devanlay transfers the User's personal data to the Trusted Partners only to those who are responsible for the correct and uninterrupted operation of the Customer's Account and as part of the capital group to which Devanlay belongs. In case of a purchase made by the User, Devanlay transfers the User's personal data to the Trusted Partners, i.e. in particular to courier companies, payment processing companies, companies performing IT services, debt collection companies, law firms, accounting firms, solely to ensure the achievement of the goals specified above.

LEGAL BASIS: The processing of personal data shall take place on the basis of an agreement with the User to open the Customer's Account service or is necessary to take action at the User's request related to the activation of this service (Article 6 sec. 1 letter b) of the GDPR). At the same time, in case of a purchase made by the User or a complaint lodged by him/her, apart from the legal basis indicated above, Devanlay shall also have the right and obligation to process data not less than for the period required by law regulations, including in particular the regulations of tax acts and the Accounting Act (Article 6 sec.1 letter c) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for the purposes resulting from legally justified interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1) letter f) of the GDPR). If the User wishes to use the option of sending him/her direct marketing information, organising contests, promotions, surveys, competitions, loyalty programme, the processing of the personal data takes place on the basis of the User's consent (Article 6 sec. 1) letter a) of the GDPR).

b. THE USER’S ONLINE SHOPPING

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name and surname, address, country, e-mail address and phone number, payment information and payment history, age, gender, country, encrypted credit card data (without CVV or CVC security code) and, if the User requests a VAT invoice, also NIP and REGON numbers. In case the User additionally uses the Customer's Account service, the information on history of orders, delivery, User ID, password and account settings as well as personal data related to Cookies shall also be processed, in particular the click history and navigation and browsing history.

PURPOSE: Devanlay processes the above-mentioned personal data in order to complete orders and returns, to manage the questions about the availability of clothes, product reservations through the Website or to provide personal tailoring services, depending on the availability of these services at a given time and to 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, for invoicing purposes and to issue receipts and invoices for purchases made through the Website or to process complaints.

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

PERSONAL DATA SHARING: Devanlay transfers the User's personal data to the Trusted Partners, i.e. in particular to courier companies, payment processing companies, debt collection companies, law firms, accounting firms, solely to ensure the achievement of the goals specified above and as a part of the capital group to which Devanlay belongs.

LEGAL BASIS: The processing of personal data is necessary to perform the online shopping service or to take action at the User's request prior to concluding an agreement (Article 6 sec. 1 letter b) of the GDPR). At the same time, Devanlay shall also have the right and obligation to process data not less than for the period required by law regulations, including in particular the regulations of tax acts and the Accounting Act (Article 6 sec.1 letter c) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for the purposes resulting from legally justified interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1) letter f) of the GDPR).

c. PROCESSING OF THE USERS' REQUESTS

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name and surname, address, e-mail address and phone number, payment information and payment history, date of birth, age, country, encrypted credit card data (without CVV or CVC security code) and, if the User requests a VAT invoice, also NIP and REGON numbers, correspondence with the User concerning its demands and expectations. In case the User additionally uses the Customer's Account service, Devanlay shall also process information on history of orders, deliveries, 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 above-mentioned personal data in order to answer the User's questions (Article 6 sec. 1 letter a) of the GDPR), process the User's complaints concerning the products and technical questions submitted by e-mail or phone (Article 6 sec. 1 letter a) or b) of the GDPR), as well as in case it is necessary to contact the User in connection with his/her order, delivery of the product, return of the product or shipment of the product (Article 6 sec. 1 letter b) of the GDPR). Devanlay processes the above-mentioned data in order to better understand the needs and expectations of the Users and thus improve its services, products and brands as well as for statistical purposes (Article 6 sec. 1 letter f) of the GDPR).

DATA RETENTION PERIOD: Devanlay shall process the above-mentioned personal data until the User's request is definitively completed. If the data processing by Devanlay is based on another legal basis indicated below in the section LEGAL BASIS, then the User's personal data shall be stored for the entire period of existence of this legal basis. In any case, a longer period of personal data retention is decisive.

PERSONAL DATA SHARING: Devanlay transfers the User's personal data to the Trusted Partners, i.e. in particular to courier companies, payment processing companies, debt collection companies, law firms, accounting firms, solely to ensure the achievement of the goals specified above and as a part of the capital group to which Devanlay belongs.

LEGAL BASIS: The processing of the User's personal data by Devanlay is necessary for the purposes resulting from the legally justified interests exercised by the Controller, in particular to establish, pursue or defend claims, maintain correspondence with the Users, also through contact forms (including responding to the messages of the Users), market and statistical analyses (Article 6 sec. 1 letter f) of the GDPR). In case of responding to the User's inquiries, the processing of the User's personal data by Devanlay shall take place on the basis of the User's consent (Article 6 sec. 1 letter a) of the GDPR), and in cases connected with the User's notifications resulting from the execution of a sales agreement concluded on-line, the processing may be necessary both for the execution of the agreement (Article 6 sec. 1 letter b) of the GDPR) and subsequently to fulfil the legal obligation imposed on the controller (Article 6 sec. 1 letter c) of the GDPR).

d.     THE NEWSLETTER SERVICE

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name and surname, address, gender, country, e-mail address and phone 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 above-mentioned personal data in order to provide the Newsletter service (free of charge electronic service referred to in Article 10.1 a of E-Store Regulations) and enable receiving information via e-mail about new services or products offered by Devanlay. For more information, please go to the section concerning Profiling.

DATA RETENTION PERIOD: Devanlay shall store the User's personal data during the term of the Newsletter service agreement. If the data processing by Devanlay is based on another legal basis indicated below in the section LEGAL BASIS, then the User's personal data shall be stored for the entire period of existence of this legal basis. In any case, a longer period of personal data retention is decisive. If the User refuses to receive individual product proposals from Devanlay by e-mail, it is possible for the User to cancel this service in any form, e.g. by e-mail, at any time, without incurring costs other than the cost of providing information according to basic tariffs (e.g. Internet connection costs, postal charges).Of course, there is a cancellation link in every e-mail. If the User refuses to receive individual product proposals from us using the push service, the User may deactivate this function at any time in the settings of particular application. In most of our applications, a specific function is available in the "Settings" section, in the "Notifications" or "Push messages" menu.

PERSONAL DATA SHARING: Devanlay provides the User's personal data to the Trusted Partners, only to those who are responsible for the correct and uninterrupted operation of the Newsletter service.

LEGAL BASIS: The processing of personal data shall take place on the basis of an agreement with the User to open the Newsletter service or to take action at the User's request related to the activation of this service (Article 6 sec. 1 letter b) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for the purposes resulting from legitimate interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1 letter f) of the GDPR).

e.      THE CONTACT FORM SERVICE

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name, e-mail address and phone number, age, date of birth, personal data related to Cookies, in particular click history and navigation and browsing history.

PURPOSE: Devanlay processes the above-mentioned personal data in order to provide the Contact Form service (free of charge electronic service referred to in Article 10 c of the Online Shop Regulations) and allow the User to send messages to Devanlay through the form available on the E-Store website.

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

PERSONAL DATA SHARING: Devanlay provides the User's personal data to the Trusted Partners, only to those who are responsible for the correct and uninterrupted operation of the Contact Form service.

LEGAL BASIS: The processing of personal data shall take place on the basis of an agreement with the User to open the Contact Form service or to take action at the User's request related to the activation of this service (Article 6 sec. 1 letter b) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for the purposes resulting from legitimate interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1 letter f) of the GDPR). Responding to the User's inquiries shall take place on the basis of the User's prior consent to the processing of personal data (Article 6 sec. 1 letter a) of the GDPR).

f.       CONTESTS

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name and surname, e-mail address and phone number, age, date of birth, personal data related to Cookies, in particular click history and navigation and browsing history as well as information provided in the contest.

PURPOSE: Devanlay processes the above-mentioned personal data on the basis of the User's consent which the User gives when applying for participation in the contest. The User's personal data shall be used to enable Devanlay to contact the Participant in matters relating to the contest, before and after the event, in order to establish the identity of the Participants and verify their age, in order to contact the winners and to deliver the prize and determine the delivery method.

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

PERSONAL DATA SHARING: Personal data shall be transferred by Devanlay to the Trusted Partners, i.e. to external companies exclusively in order to provide the above-mentioned services and enable courier companies to deliver the prizes.

LEGAL BASIS: The processing of personal data is subject to the User's consent (Article 6 sec. 1 letter a) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for the purposes resulting from legitimate interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1 letter f) of the GDPR).

g.      DIRECT MARKETING OF THE DEVANLAY PRODUCTS

CATEGORIES OF DATA TO BE PROCESSED: In case the User uses the Customer's Account service, Devanlay processes contact details such as name and surname, e-mail address and phone number, age, date of birth, gender, purchase history, personal data related to Cookies, especially click history and navigation and browsing history. In other cases, Devanlay processes contact details such as e-mail address, phone number and postcode, gender (if the User provides such information) and details of products and offers opened on the Website by the User.

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

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

PERSONAL DATA SHARING: Personal data shall be transferred by Devanlay to the Trusted Partners, i.e. to external companies, exclusively in order to provide direct marketing services to Devanlay. These data shall never be made available to third parties.

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

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

Upon withdrawal of the consent, Devanlay shall not send the User any offers in the framework of direct marketing or information previously sent on the basis of the consent to the processing of data.

h. LACOSTE’S LOYALTY PROGRAM

PERSONS WHO DATA CONCERN: As part of this process, we only process Personal Data of adult members of the LACOSTE Loyalty Program.

PROCESSED DATA CATEGORIES: Devanlay processes the following data of the Participants of the LACOSTE Loyalty Program: name and surname, e-mail address, correspondence address and mobile phone number.

PURPOSE: Personal data will be processed for the following purposes: (i) to enable receiving information about new services or products offered by the Administrator via e-mail, SMS and traditional mail; (ii) conclusion of a sales contract taking into account the conditions of the currently applicable Loyalty Program; (iii) implementation of the Administrator's legal obligations and rights resulting therefrom, e.g. analytical regarding trade statistics, improvement of the quality of services offered, archival services related to the protection of the Administrator's legal interest (e.g. pursuing claims, protection against unlawful actions to the detriment of the Administrator).

DATA STORAGE PERIOD: Your Personal Data will be stored for the period necessary for specific data processing. Personal data processed for the purposes of direct marketing of products and services will be processed by us until you withdraw your voluntary consent, unless the law obliges us to further process your Personal Data or we will store it in the event of potential claims. Certainly, the data will be processed for the duration of the sales contract that connects us, using the benefits of the Loyalty Program, as well as for the period of maturity of any related claims, and for a period not shorter than required by law, including in particular legal provisions tax and the Accounting Act.

SHARING OF PERSONAL DATA: We may transfer your Personal Data to entities from the capital group to which Devanlay Polska Sp. z o.o. and other entities that help us run the website and applications, including marketing campaigns (e.g. they support us in sending e-mails or text messages), provide support for our tools and IT systems (e.g. they service our software, store data) and our legal and advisory service providers.

Your personal data will be transferred outside the European Economic Area only to the extent necessary, related to the provision of services by partners, especially IT services. In the case of such operations, in relation to entities established in countries for which the European Commission has not found an adequate level of data protection, the Administrator applies Standard Contractual Clauses, approved by the Commission as a measure securing the compliance of operations with applicable law and data processing agreements, meeting the requirements of the GDPR.

The content of the Standard Contractual Clauses can be found by clicking on the link:

https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX:32010D0087  

LEGAL BASIS: The processing of personal data will be based on:

1) art. 6 sec. 1 point a) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, i.e. your voluntarily expressed consent.

2) art. 6 sec. 1 point b) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, i.e. in order to conclude a sales contract using the benefits of the Loyalty Program.

3) art. 6 sec. 1 point c) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, i.e. processing is necessary for the performance of our obligations, such as, for example, for financial and tax settlements.

4) art. 6 sec. 1 point f) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, i.e. due to the legitimate interest of the administrator, e.g. for the purpose of pursuing claims and defending against your claims.

WITHDRAWAL OF CONSENT

Each LACOSTE Loyalty Program Participant may withdraw consent to the further processing of his personal data and leave the Loyalty Program at any time. The easiest way to do this is in one of the following ways:

1.      Via the link provided in the Welcome SMS / e-mail, provided that you do not delete the SMS / e-mail with this link. It is possible to generate such a link in the future by going to the website: https://devanlay.com.pl/

Then, a Welcome SMS will be sent to the telephone number provided during registration, which will contain a link to withdraw consent. In order to withdraw consent to further processing, open the link and click: "REJECT".

2.  When visiting one of the LACOSTE boutiques, ask our employee to generate / send the Welcome SMS again to the phone number provided during registration. There you will find a link to manage consents. In order to withdraw consent to further processing, open the link and click: "REJECT".

3. Send an e-mail to the following address: gdpr@lacoste.pl with the description in the title of the e-mail: "Withdrawal of consent to participate in the Loyalty Program" and in the text of the message your name and phone number, which was provided during registration.

i. ONLINE SEARCH

CATEGORIES OF DATA TO BE PROCESSED: depending on the frequency of the User's online interaction with DEVANLAY, these data may include the use of the Website, data about the User's origin, login details, websites visited by the User, videos viewed by the User, advertisements marked by the User, products that the User was looking for, the User's location, duration of the User's visit, products selected by the User for the shopping cart, IP address, browser information, unique identifier assigned to each visitor and the expiry date of such identifier.

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

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

LEGAL BASIS: The processing of personal data related to Cookies shall take place due to the legitimate interest of the Controller (Article 6 sec. 1 letter f) of the GDPR), i.e., among others, to maintain the security of the Website and enable its functioning. In case the purpose is to improve offers or services of Devanlay or to send advertisements or to provide matching content, the processing shall take place on the basis of the User's consent (Art. 6 sec. 1 letter a) of the GDPR).

j. RETARGETING

Based on Cookies, we use technology allowing us to deliver advertising messages to users who have already visited our Website, on other websites that they visit, including those belonging to entities cooperating with our partners. Detailed information on third-party cookies can be found further in this Privacy Policy.

The lack of connection between the advertisement displayed to the User and its interests and needs may be burdensome for the User. Devanlay is aware that it is more attractive and practical for the User to receive a message that matches its interests and needs identified through the analysis of its previous behavior, 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 adjusted to its previous online activity.

k. IMPLEMENTATION OF THE DEVANLAY'S LEGAL OBLIGATIONS

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

PURPOSE: Devanlay processes the above-mentioned personal data in order to fulfil its legal obligations only when necessary. Devanlay must process personal data in order to manage the obligations imposed on the company and in order to combat criminal activity and other misuse, or to comply with other legal obligations resulting from law regulations, judgments or official decisions. Such requirements may include, among others, requirements concerning product liability and product safety, such as communication and informing the public and consumers about product warnings and recalls, e.g. in the case of defective products or products that pose a health risk or to the extent required by the provisions of individual acts. Devanlay shall also process the Users' personal data in the order to fulfil the legal obligations resulting from the regulations, e.g. tax and accounting.

DATA RETENTION PERIOD: The processing of data by Devanlay shall take place during the entire existence of this legal basis. In case Devanlay also processes the Users' personal data in order to fulfil the legal obligations resulting from the regulations, e.g. tax and accounting, the retention period shall be 6 years.

PERSONAL DATA SHARING: Devanlay transfers the User's personal data to competent authorities and institutions. In case Devanlay also processes the Users' personal data in order to fulfil the legal obligations resulting from the regulations, e.g. tax and accounting, the personal data (mostly aggregated) may also be transferred to the Trusted Partners or made available as part of the capital group to which Devanlay belongs.

LEGAL BASIS: Processing is necessary to fulfil the legal obligation of the controller (Article 6 sec. 1 letter c) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for purposes resulting from legitimate interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1 letter f) of the GDPR).

l. PROFILING

When Devanlay sends or displays personalized information or content (advertisements, offers, promotions, discounts), in such a situation it may use so-called "profiling", i.e. any form of automated processing of personal data, which involves using personal data to assess certain personal factors of an individual, in particular to analyze or forecast aspects relating to personal preferences, interests, economic situation, behavior, location, health, reliability or movement. This allows Devanlay to better understand the User's expectations and adapt to its needs, without significantly influencing its decisions. Thanks to the Devanlay's use of advanced technologies, the above activities shall often be performed by the system in an automated manner, thanks to which the content sent shall be the most up-to-date and the User shall be able to get acquainted with it quickly (ordinary "profiling").

Only in the case of adult Users, the above-mentioned analysis of interests and preferences performed by Devanlay shall also serve to create, award, implement dedicated and, to the highest possible extent, customized advertisements, offers or promotions (discounts), in an automated manner, which may cause legal effects towards it or significantly affect it in a similar manner, potentially limiting access to them for other Users (option unavailable for Users who are not of age and have not given consent to such Devanlay’s activities). These activities, in contrast to ordinary "profiling", may have a significant impact on the User's purchasing choices. The more often a given User uses the Devanlay’s services and purchases its products, the better promotions and surprises may be prepared for the User.

Under certain circumstances described below, the User shall have the right to object to the use of his/her data for profiling by revoking the consent to profiling or changing the settings of Cookies.

X.                PROVIDING DATA OF THIRD PARTIES BY THE USER

Functions and services offered and provided by Devanlay may require Devanlay to process personal data of third parties provided to Devanlay by the Users.

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

XI.               THE USER’S RIGHTS

The User shall have the right to:

THE RIGHT OF ACCESS TO DATA: The User shall have the right to access its personal data, which are stored by Devanlay according to the principles set forth in the GDPR. Devanlay may require a reasonable fee, taking into account the administrative costs of providing such information. Requests that are manifestly unjustified, excessive or repetitive may remain unanswered. To exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl

THE RIGHT TO CORRECT PERSONAL DATA: The User shall have the right to demand the correction of its personal data if they are incorrect or out of date, as well as to fill in incomplete data. In order to exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl  If the User uses the Customer's Account service, the User may correct or update its personal data itself.

THE RIGHT TO DELETE DATA: The User shall have the right to delete any data processed by Devanlay. This right shall not be exercised by Devanlay in case of, among others, unfinished proceedings within the framework of processing the Users' applications, an open order which has not yet been sent or has been sent only partially, unpaid debt to Devanlay, regardless of the payment method, existence of at least a suspicion that the User has used Devanlay's services in the last three years in an improper manner, making any purchases, because then Devanlay shall store the User's personal data concerning transactions for accounting and tax purposes. To exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl

THE RIGHT TO NOT EXPRESS CONSENT TO THE PROCESSING OF DATA ON THE BASIS OF THE LEGITIMATE INTEREST OF DEVANLAY: The User shall have the right not to consent to the processing of his/her data on the basis of the legitimate interest of Devanlay. In such a situation, Devanlay shall stop processing his/her personal data unless it is able to demonstrate a lawful justification for this process that takes precedence over the interest of the User or due to legal claims. To exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl

THE RIGHT TO TRANSFER DATA: In case Devanlay processes the User's personal data in an automated manner, on the basis of his/her consent or concluded agreement, the User shall have 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 only applies to personal data that has been provided to Devanlay. To exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl

THE RIGHT TO LIMIT THE PROCESSING: The User shall have the right to request that Devanlay limits the processing of his/her data. This right means that the processing of the User's data by Devanlay shall be limited to storage and shall not be used or processed in any other manner. This shall apply in the limited cases specified by GDPR, i.e. (i) the User questions the accuracy of the personal data for a period of time that allows Devanlay to verify the accuracy of the data, (ii) the processing is illegal, and the User objects to the deletion of the personal data, requesting instead a limitation of their use, and (iii) Devanlay no longer needs personal data for the purposes of the processing, but the data are needed by the User to establish, pursue, or defend claims, (iv) the User has objected to the processing based on the legitimate interest of Devanlay - until it is determined whether the legitimate grounds on the part of Devanlay take precedence over the grounds for objection of the User. To exercise this right, please contact us at 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 shall click the "unsubscribe" link in any e-mail or message that has been sent to him/her by Devanlay. To object to the profiling, please contact us at the following e-mail address: gdpr@lacoste.pl

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

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

THE RIGHT TO DEACTIVATE COOKIES: The User shall have the right to deactivate Cookies. The default settings of browser usually accept cookies, but they may be easily changed in the User's browser. Many Cookies are used to increase usability and improve 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 provided in the "Help" menu in the browser in use or the information provided under the link http://www.aboutcookies.org

THE RIGHT TO INFORMATION: The User shall have the right to be informed in a clear, transparent and easily understandable manner about how Devanlay uses his/her data and about his/her rights. Devanlay shall ensure that this right is exercised by publishing the Policy on the Website.

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

In any case, within one month of receiving the request, Devanlay shall inform the User of the action taken and (if applicable) the extension of the period, giving the reason for such a delay.

XII.             COOKIES

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

2.      Cookies collect and store information regarding the User's use of the Website on the basis of the User's consent or sometimes due to the legitimate legal interest of the Administrator.

3.      [consent] By clicking ["Go to the website"] or closing this window informing about cookies by clicking the X sign, the User gives consent to the processing of his / her personal data regarding his / her activity on the Internet (e.g. device identifiers, IP address) by us and our Trusted Partners for marketing purposes (including personalization of advertisements and taking measurements) and to adapt the content provided. The consent is voluntary. You can refuse it or limit its scope (but some parts of the E-Store may then not work properly). Detailed information on how to withdraw consent is presented in the following sections below. Withdrawal of consent does not affect the lawfulness of the processing which was carried out on the basis of consent before its withdrawal.

4.                 [legitimate interest of the Administrator]

The legitimate interest of the administrator is one of the grounds for the processing of personal data (apart from, among others, consent or the necessity to perform the contract) and it includes cases where the data administrator may process data due to lawful purposes personal data without violating the rights, freedoms and interests of data subjects. The legitimate interest of the administrator will constitute the legal basis only for the processing of personal data that is necessary to achieve the purpose resulting from this interest. The existence of a legitimate interest is assessed in the specific time and context in which the data is collected. It is examined whether the data subject can expect that the controller processes their data for a specific purpose and whether their interests, fundamental rights and freedoms are in balance with this interest. Such processing does not require the User's additional consent, but the User may object to it at any time. Unless the User decides otherwise, by making appropriate changes to the settings in his browser, Devanlay will also install cookies and similar files on the User's devices and read information from such files. Detailed information on cookies used by Devanlay is provided below.

5.      Devanlay uses cookies for the following purposes:

• maintaining the User's session on the subpage of our website, so that the User does not have to re-enter the login and password each time;

• adapting our website to the User's needs;

• determining the user's profile in order to display him matched materials in advertising networks, in particular the Google network (selection of basic ads; creating a profile of personalized ads; selection of personalized ads; creating a profile of personalized content; selection of personalized content; measuring advertising performance; measuring content performance; market research to generate customer feedback; product development and improvement; special functions such as: use of accurate geolocation data and active scanning of characteristics);

• creating statistics on the website's subpages that help to understand how website users use websites, which allows improving their structure and content;

• compiling aggregated statistics, measurement data and general trend data to enhance and optimize marketing, promotional and analytical activities;

6.      Cookies used by Devanlay may be divided according to the duration of stay in the User's device used for browsing, origin and purpose. Within the Website, two main types of Cookies are used: session cookies and persistent cookies. Session cookies are temporary files that are stored on the user's terminal device until the user logs out, leaves the website or turns off the software (web browser). Persistent cookies are stored in the user's terminal device for a period of time specified in the parameters of cookies or until the user removes them.

7.      The following types of cookies are used on this website:

•   "necessary" cookies that enable the use of   services available on the website, e.g. authentication cookies used for services that require authentication on the website, cookies that are used to ensure security, e.g. used to detect fraud in the field of authentication within the website,

•  "efficiency" cookies that allow the collection of information on the use of pages included in the website,

• "functional" cookies that allow you to "remember" the website settings selected by the user and personalize the interface, e.g. in terms of the selected language or region, font size, website appearance, etc.,

• "advertising" cookies, which enable the provision of advertising content to website users more tailored to their interests.

8.    Devanlay shall not store sensitive personal   data such as address, password, credit or debit card details, etc. in Cookies that it uses.

9.      By default, web browsers allow storage and access via Cookies to the devices of end users. The User shall have the right at any time to change the settings concerning the mechanism of Cookies, i.e. to change the conditions of storage and access to the information collected through Cookies. The stored information and access to the information shall not alter the configuration of the end-user's device or the software installed on that device.

10.   By using this Website without changing the browser settings to disable Cookies, the User agrees to place Cookies on its device and access the User's end device. The users may at any time change their web browser settings to disable Cookies. For information on changing settings for Cookies, please see the link http://www.aboutcookies.org

11.   The User shall have the right to restrict or disable the use of Cookies by its web browser by changing the settings to disable Cookies or requiring prior consent before Cookies are stored on the device used to browse the Website.

12.   After changing the cookie settings, it is possible that the User's use of the website will be less effective. The User may not be able to access some of the content or use certain functions of the Website, and in extreme cases the correct display of the Website content may not be available.

13.   Please be advised that in the event of problems with changing cookie settings, it is best to use the information on the website of the manufacturer of the program. At this point, it should be noted that when the User connects to our website, information about the number (including IP) and type of the end device of the User or other natural person from which the User connects to the website appears in the system logs of our website. our service.

14.   Devanlay will process, in accordance with the provisions of the law in force in the territory of the Republic of Poland, data regarding the number (including IP) and type of the User's end device, as well as the time of connection with the Website and other operational data regarding the User's activity on the Website.

15.   These data are processed for technical purposes. Devanlay declares that it will endeavor to provide the User with a high level of security in the use of our website, by using appropriate administrative, technical and physical data protection against accidental or unlawful destruction, loss, unauthorized disclosure or disclosure.

16.   All events affecting the security of information transmission, including, for example, suspicion of sharing files containing malware, should be reported to the following address: gdpr@lacoste.pl or by correspondence to: Devanlay Polska Sp. z o.o. ul. Złota 59, 00-120 Warsaw, with the annotation "Data Protection Officer".

17.   Detailed list of cookies we use

Detailed list of cookies uses by us:

Category: Necessary (6)

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Category: Statistic (7)

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Category: Marketing (21)

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

Category: Unclassified (25).

Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

Some personal data may be stored longer in the event that the User has any claims against the Data Controller or for the purpose of pursuing claims by the Data Controller or defending against claims (also third parties), for the period of limitation specified by law, in particular the Civil Code.

In each case, the longer period of storage of personal data is decisive

18.   [links to third parties] Third party cookies.

Devanlay offers on its website links to its own websites and to other websites that are not owned by Devanlay. These links have been established in consultation with those concerned but which are not controlled in any way. Devanlay is not responsible in any way for the content of such other sites or the way in which users use them.

The cookies used by the Administrator are primarily used to optimize the User's service when using the E-Store. However, Devanlay cooperates with other companies in the scope of their marketing (advertising) activities. For the purposes of this cooperation, the browser or other software installed on the User's device also stores cookies from entities conducting such marketing activities, which may become the administrator of the Customer's personal data. Cookies sent by these entities are to ensure that the User is presented only with advertisements that correspond to his / her individual interests and needs.

THIRD PARTIES COOKIES

a.    Google Analytics

The website uses Google Inc.'s web service analysis mechanisms: Google Analytics, Google Double Click and Google Tag Manger. Google Analytics, Google Double Click and Google Tag Manger use cookies that enable an analysis of the use of websites. Information collected by cookies is transferred to Google servers located in the USA and archived. Google's privacy policy can be found here:

https://policies.google.com/privacy?hl=pl

If the IP anonymization function is enabled when using the Website, the User's IP address is shortened by Google. This applies to the Member States of the European Union and other countries listed in the EEA Agreement. Only in exceptional cases is the full IP address sent to a Google server in the USA and shortened there. In this way, the IP anonymization function will be active on the Website. At the request of the website operator, Google will use the collected information to analyze the use of the website, to compile reports on the use of the website and other services related to internet use. The IP address provided by the User's browser as part of the Google Analytics program is not stored together with other Google data.

The user can block the saving of cookies in the web browser. However, in this case, you will not be able to use all the functions of the website in full. In addition, the User can block the saving of data collected by cookies regarding the use of the website (including the IP address) and sending them to Google, as well as the transmission of this data by Google by downloading and installing the plug-in available at the following link:

https://tools.google.com/dlpage/gaoptout?hl=pl

For more information on Google Analytics privacy, please visit: https://support.google.com/analytics/answer/6004245

b.    Google Ads

This website uses the Google Ads tool to be able to personalize the message we send to the User on external websites.

This makes it easier for us to reach users who have already visited the Site. They can see our ads when they browse pages belonging to the Google Display Network or when they search Google for terms related to Devanlay products or services.

More information on Google Ads can be found at the following website:

https://ads.google.com/intl/pl_pl/home/faq/faq/

For more information on Google Ads privacy, please visit: https://ads.google.com/intl/pl_pl/home/faq/gdpr/

c.     FACEBOOK CUSTOM AUDIENCE

d.    AdForm

e.    RTB HOUSE

This website uses tools offered by RTB HOUSE, i.e. marketing cookies used to conduct personalized advertising campaigns. The cookies collect information on specific pages visited, viewed or added to the cart, and purchased products along with time stamps, as well as technical data about the device and browser. RTB House uses this data to run advertising campaigns and display personalized ads to users on behalf of the advertiser. For more information on RTB HOUSE retargeting technology, please visit https://www.rtbhouse.com/privacy-center/services-privacy-policy/

PLUGIN

a.      Facebook

Our website includes a plugin for the social network Facebook. The Facebook Plugin on the Site is marked with the Facebook logo.

This plugin will directly connect the User with the Devanlay profile on the Facebook server. In such a case, Facebook may obtain information that the User visited the Website from his IP address.

If the User visits the Website while being logged in to his Facebook profile, Facebook will register information about this visit.

Facebook does not provide Devanlay with information about the collected data and how it is used. Devanlay also does not know the purpose and scope of the data collected by Facebook. In order to obtain additional information on privacy on Facebook, the User should contact Facebook directly or read the privacy policy of the portal at:

https://www.facebook.com/about/privacy/

If the User does not agree that Facebook can obtain information about his / her visits to the Website, he / she should log out of the Facebook account beforehand.

b.      GOOGLE+

Our website includes a plugin for the Google+ social network operated by Google. You can find the link to Google's privacy policy here: https://policies.google.com/privacy?hl=pl

c.       TWITTER

Our website includes the Twitter social plugin operated by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA ("Twitter").

Twitter's privacy policy is available at: https://twitter.com/privacy

d.      YOUTUBE

Devanlay uses plugins from the Youtube site operated by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, United States ("Youtube").

A link to YouTube's privacy policy can be found here:

http://www.google.com/intl/de/policies/privacy/

e.      INSTAGRAM

Devanlay uses plugins from the Instagram social network, operated by Instagram, LLC Instagram Inc., 1601 Willow Road, Menlo Park, CA 94025, USA ("Instagram").

The link to Instagram's privacy policy can be found here: http: //instagram.com/about/legal/privacy/#

f.       TUMBLR

Devanlay uses a plugin for the Tumblr microblogging platform operated by Tumblr, Inc.

The link to Tumblr's privacy policy can be found: https://www.tumblr.com/privacy/pl

g.      PINTEREST

Devanlay uses plugins for the Pinterest social network operated by Pinterest, Inc. You can contact Pinterest at: Pinterest Inc., 651 Brannan Street, San Francisco, CA 94107, USA.

Link to Pinterest's privacy policy https://policy.pinterest.com/pl/privacy-policy

19.   [website availability] Devanlay undertakes to exercise due diligence to ensure uninterrupted access for its Users to the website.

XIII.            SECURITY

Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of the processing, as well as the risk of violation of the rights or freedoms of individuals with different probability and seriousness of the threat, Devanlay shall apply appropriate technical and organizational measures to ensure the protection of the processed personal data appropriate to the threats and categories of data subject to protection, and in particular shall protect the data against unauthorized access, taking away by an unauthorized person, processing in violation of applicable regulations and alteration, loss, damage or destruction

Publishing information on the technical and organizational measures used to protect the processing may undermine their effectiveness and thus jeopardize the proper protection of personal data.

Devanlay shall, in particular, apply the following technical measures to prevent the acquisition and modification by unauthorized persons of personal data transmitted electronically:

a.      Protection of the data set against unauthorized access.

b.      SSL certificate on the E-Store Website of Devanlay where personal data are provided.

c.       Encryption of data used for authorization of a person using the E-Store functionality.

d.      Access to the Customer's Account only after providing an individual login and password.

XIV.           AMENDMENTS AND UPDATES

Devanlay shall reserve the right to amend or update the Privacy Policy and Cookies.

The latest version shall be available on the Website.

Additionally, the Users who use the Customer's Account service shall be informed individually about amendments to the Privacy Policy and Cookies.

The Privacy Policy and Cookies shall come into force from 25.05.2018.

The Last Update : 09.04.2021