PRIVACY POLICY

KOKAPEK/FASHIONTAMERS  (“PRIVACY POLICY”)

LAST UPDATED: 24TH MAY 2018

This Privacy Policy will be effective from 25 May 2018. This Privacy Policy ("Information") describes the processing of personal data by Kokapek/ Fashiontamers d.o.o. (hereinafter, "Kokapek" or the "Company"), through the Web page https://www.fashiontamers.com/ (the "Site"). By applicable data protection legislation (including the General Data Protection Regulation 2016/679 (the "GDPR")), the Company is responsible for processing personal data. You must be over 16 years of age to register on this site and to allow us to collect and store your personal data. If you are under 16, we have the right to block and/or cancel your account or user profile. Parents or guardians of the child may in any case contact us to block the account or profile of the minor for which they are responsible, through the means available in the section on user rights.

WHO IS THE HOLDER OF THE TREATMENT OF YOUR PERSONAL DATA?

Identity: Kokapek d.o.o., VAT NUMBER: SI57726035

Address: Cesta Zore Perello Godina 2, 6000 Koper, Slovenia  - Telephone: +386 5 2926999

Email: [email protected]

1. ABOUT THE KOKAPEK/FASHIONTAMERS GROUP AND THIS PRIVACY POLICY

We are the Kokapek d.o.o. (“we”, “us”, “our”), and we are committed to protecting your privacy.

Kokapek d.o.o. is the controller for the purposes of the General Data Protection Regulation (the “GDPR”) a company registered in Slovenia with its registered office located in Slovenia.

This Privacy Policy provides information on how we collect and use personal data. Kokapek operates Fashiontamers.com websites (including eBay, and Amazon (collectively, the "Website").

This Privacy Policy sets out the information that we collect, the reasons for which we collect that information, and how we can use and share that information.

The Website and the services provided by Kokapek are not intended to be used by children. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, you can contact the Kokapek Data Protection Officer at [email protected].

2. THIRD PARTY WEBSITES

Our Website can contain links to and from the websites of our partner boutiques, advertisers, and affiliates, amongst others. If you follow a link to any of these websites, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.

3. WHAT INFORMATION DO WE COLLECT, AND HOW?

When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:

• information you give us: you may give us information about yourself if you sign up for an account on our Website, place an order for products, complete any online forms (such as registration forms, competitions, and surveys), opt-in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions with our Website, or correspond with us (by email, telephone, instant chat, social media or otherwise).

Depending on what you provide, this information can include your name, address or location, phone number, and email address, date of birth, gender, purchase information, shopping preferences, images, and financial information (including your credit or debit card details, although we do not hold them, our payment processors do).

If you register an account on the Website, then you may choose to give us your photograph and nickname. From your account, you can also invite your friends to shop at our Website (including by email, Facebook, or Twitter). Although we will let them know that we received their details from you, please ensure that you have the permission of your friends before sharing their contact details with us and only forward emails to people you know would be happy to receive them.

• information we receive from other accounts or sources: we can receive information about you from other sources, such as from your other accounts or other websites, including data brokers, our partner boutiques, social media providers like Facebook and Twitter, advertising networks and analytics partners, and payment and delivery service providers.

By logging in to our mobile applications via Facebook or Twitter, or linking your account on our Website to your Facebook or Twitter accounts, you are permitting us to obtain certain information and content from these accounts. The specific types of information that we may obtain depend on your settings for that account or website, and will be subject to their privacy policies.

We supplement the data you provide to us with data from data append services such as public or social graph data to better serve you with content or promotions. We will append this data to our existing customer account information to better understand customers’ interests and to provide more relevant product recommendations and advertising, to increase our customer’s security when using our Website, and to comply with our legal obligations, such as sanctions laws. This information may include household size, household income, or profession. This information can be associated with your personal information such as name, email, address, physical address, or phone number.

You can see more details about the third parties we use in section 5.

• information our IT systems collect about you: each time you visit the Website, certain information will be created and automatically recorded by our IT systems. That information includes:

cookies: you can see more details about cookies in section 7, but these small text files can help improve your experience with the Website and make it easier to interact with us. This may include storing your location or language preferences to save you from having to re-enter information when returning, or ensuring that items you wish to order don’t disappear as you navigate between pages on, our Website. We also use cookies to provide you with tailored advertising;

device information: the information provided by your device will differ depending on which type of device you are using (whether it’s a PC, Mac, iPhone, Android, or otherwise) and the settings on that device, but includes the type of device you have (such as an iPhone 6S or Samsung Galaxy S7), the device’s IP address, the browser you are using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.

• information we collect in-store: the Kokapek is always looking for new opportunities to improve your shopping experience and this extends to your experiences in-store. When you visit the Website, you may have the opportunity to use pioneering technology to enhance your in-store experience. You may also give us information about yourself in-store if you make a purchase using a credit or debit card, complete a survey or questionnaire, enter a competition or promotion, provide us with feedback, or otherwise interact or correspond with us in-store. Where you use a WiFi-enabled device in-store, certain information may be provided by your device, which will differ depending on your device and settings. The information that may be provided is the type of device you have, the device identifier/media access control (MAC) address, the proximity of the device from the access point, the location of the device, and where relevant, when and for how long the device is connected to the Wi-Fi network. You can prevent information from being provided by turning off the Wi-Fi feature on your device.

4. WHAT DO YOU USE MY INFORMATION FOR?

To provide you services and the Website, including allowing you to order and receive products using our Website, administer your account, and optimize your experience we need to use the information that we collect in many different ways.

We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications or when you have made a purchase using our services, we and our partner boutiques will use your personal information (including your name, email address, and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing customer information as described below), to tailor these messages to you. You may unsubscribe from email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt-out instructions in the promotional emails we send you.

We use third-party service providers to serve advertisements most relevant to you across your different devices and on our own and others’ websites and mobile applications. In addition to the information about your visits to our website or usage of our mobile application, our service providers may also use the information about your interactions with other websites or applications to target advertisements for products available from Kokapek. For information about opting out of targeted advertising and controlling the use of cookies, please see the cookies section of this Privacy Policy.

We also carry out research, analysis, and surveys on your use of our Website, and views. We keep tracking your spend on our Website to see if you can benefit from our exclusive loyalty programs as the VIP customer program and Access. Finally, we use your information to confirm your identity and perform credit checks or anti-fraud checks, to ensure your, and our, financial security.

Please note that we do not sell your information without your consent (whether your name, address, email address, financial information, or otherwise) to any third party.

Please scroll down to find out the detailed purposes for which we collect your information, what specific information is collected, and the legal basis for which we use that data.

To register and manage your account on our Website, we collect your name, email, password, and other additional details you may wish to add to your account, like phone number, address, and gender. The legal basis is the performance of a Contract with you.

To fulfill the orders you make through our website, we collect your name, address, phone number, and order details, like the products you are buying, the size, and price. The legal basis is the performance of a Contract with you.

To collect payment from you we collect your payment information, which comprises the credit/debit card number, holder’s name, and CVV we do not store them and only transfer them to our authorized payment providers. The legal basis is the performance of a Contract with you.

To provide you with our customer services (including helping you to solve any issue you have with our services, updating you about any change to our terms of service, or contacting you to know how was your experience with us) we collect your name, email, password and addresses and your contact history with us (including phone records of our conversations. The legal basis is the performance of a Contract with you and our legitimate interests in retaining you as a customer.

To monitor the quality of our customer services, we collect your name, email, password, and address and your contact history with us. The legal basis is the legitimate interests in running our business.

To administer, maintain, and optimize our Website and our services, we collect your device information (such as your device IP address and device type), Cookie identifiers, and browsing information. The legal basis is the legitimate interests in running our business.

To perform fraud and credit checks and if we can do business with you, we collect your name; email; addresses; credit/debit card details; browsing history; purchase history; date of birth; gender; device information (such as IP address and device type), any national identifiers (like driver’s license or ID cards) and any publicly available information (like social media profiles or news). The legal basis is the legitimate interests to protect Kokapek and its customers from fraudulent activities and compliance with a legal obligation.

To send you marketing communications and personalised offers, we collect your Name; Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behaviour; Device information; Shopping preferences; Cookie identifiers; Internal identifiers; and Country. The legal basis is the legitimate interests in electronic direct marketing of similar products and services to that which you have acquired using our Website or, when such is not applicable, your Consent.

To manage our loyalty programmes, we collect your Name; Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behaviour; Device Information; Shopping preferences; Nickname; Cookie identifiers; Internal identifiers; Country; Spent tier level and Wealth. The legal basis is our legitimate interest in running our business and improving the shopping experience.

Analysis of your behavior and purchases on our Website, we collect your Name Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behavior; Device Information; Shopping preferences; Nickname; Cookie identifiers; Internal identifiers; Country; Spent tier level and Wealth. The legal basis is our legitimate interests in running our business and improving our Website and your experience.

Carry on research, analysis, enquiries, and surveys on your use of our website, we collect your Name; Address; Email; Device information, and legal basis as our legitimate interests in running our business and improving our Website and your experience.

Advertising and retarget advertising, we collect your email, cookie identifiers, and device information. The legal basis is our legitimate interests in running our business.

5. WHO DO YOU SHARE MY INFORMATION WITH?

To provide the Website and our services, we work with several carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:

• Group companies for business purposes: Kokapek is part of a larger family of companies in different parts of the world. Our group of companies, which means our subsidiaries, our ultimate holding company, and that company’s subsidiaries. We may share your personal information to operate our business and provide the Website and services. Rest assured, their use of information is consistent with this Privacy Policy;

• Our partner boutiques from whom you purchase products: We rely on carefully selected partners that supply the products that you see on our Website. Our partners are situated across the globe. 

• Third-party service providers for business purposes: to function properly, we rely on several carefully selected third parties to provide us with services and products. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products. Below you can find the types of third parties we use:

Courier companies, such as DHL and GLS, that we use to deliver the products to you and, as such, they need to have access to your order information, including your name and address. These providers have a global outreach, with many local companies that can be engaged depending on your shipping address;

Payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. These are based in the European Union, United States, and China and are engaged depending on your location;

Anti-fraud and credit check providers to keep us and you secure. They have access to and process your information and associated orders to check for any fraudulent behavior. Our current provider is based in Israel.

Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimization of the website. These providers are based in Europe.

Marketing Tools providers that help us to enable our marketing.  These providers are based in Europe.

Performance Marketing Providers that help us deliver advertising of Kokapek tailored to your interests and needs. These providers are based in Europe.

Research companies that we can engage to help us carry out surveys regarding your use of our Website and Services. These providers are mostly based in Europe.

IT/technology providers that we use to support, maintain, and provide our technology and IT infrastructure that supports our Website and the storage of your information. 

• advertisers for marketing purposes: we can provide your information to our advertising and social media partners (including Facebook, Instagram, and Twitter, where you choose) where they require the data to select and serve relevant adverts about our products and services to you and others;

• third-party service providers to enrich data: We may also enrich, match, or combine information we hold about you with data from other sources, for instance by sharing some of your data with selected business partners. These partners are based in the United States, Europe, China, and Dubai. We do this to better understand your customer profile and interests so that we can deliver customized offers and other personalized services;

• third parties where we are considering a corporate transaction: Kokapek is always looking for new opportunities and directions in which to grow. This means sometimes we may consider corporate transactions such as mergers, acquisitions, reorganizations, asset sales, or similar. In these instances, we may transfer your information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, your personal information may be one of the assets that are transferred;

• to comply with legal requests: on occasion, we may be required to liaise with various regulators and law enforcement agencies in many different countries, whether as a result of the law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands; and

• aggregated information with third parties: we may aggregate your information with the information of other customers, creating a dataset of information about the usage of our Website, purchase of products, and other general, grouped information about our customers based on our legitimate interest to understand the usage of our service and demand for our product. Although this dataset is aggregated and anonymized, meaning it cannot identify you as an individual, it provides valuable insight into the use of our Website and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies to help measure traffic, our partner boutiques, and other providers to allow them to better stock products, and our investors. Please note that we do not share your information with any third-party advertisers or networks for the provision of third-party advertising on our Website.

6. TRANSFERS OF YOUR PERSONAL DATA

To provide our Website and our services, in accordance with the purposes set out above, we may transfer and store the personal information that we collect from you to a destination outside of the European Economic Area (“EEA”), mostly to the United States, either to one of our Group Companies, to one of our partner boutiques or to one of the third parties with which we work with, as stated below:

•When transferring personal information to one of our Group Companies outside the EEA, which may be the USA, Brazil, Russia, Japan, or China, we rely on the Commission’s model contracts for the transfer of personal data to third countries (i.e. the standard contractual clauses) under Decision 2010/87/EU;

•We transfer the personal information to one of our partner boutiques outside the EEA, to the extent such transfer is needed to fulfill the contract between you and the boutique which you are ordering the products from.