This Privacy Notice describes the main aspects of the user’s personal data processing under the General Data Processing Regulation.

1. DEFINITIONS
2. The terms used herein are defined as follows:

“website” - the website available under the link [вказати посилання на домен];

“user” (as well as relevant pronouns such as “you”, “your”, etc.) – any legally capable natural person (data subject), who uses the website and/or intends to buy goods and/or buys goods on the website;

“KLIFEX” (as well as relevant pronouns such as “we”, “our”, etc.) – controller of the user’s personal data.

2. All other terms used herein are defined under the General Data Processing Regulation (GDPR).

1. CONTROLLER
2. The controller is the entity which determines the purposes and means of the processing of user’s personal data.
3. The controller of the user’s personal data is legal entity KLIFEX, registered under the laws of the Poland Republic [the Federal Republic of Germany], email: zakaz@klifex.ua
   

III. PURPOSES AND BASIS OF THE PROCESSING

1. Personal data is any information relating to an identified or identifiable user, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier etc.
2. Personal data processed. We collect and process user information such as first, middle and last name, e-mail address, telephone number, contact (delivery) address and metadata (e.g. order information, date, time when you called KLIFEX, IP-address, cookies (including analytical, marketing)).
3. KLIFEX may process any other personal data that is provided voluntarily by the user. The user is not obliged to provide personal data by law or under any agreement, however, KLIFEX goods might not be available or might be impossible to be delivered without some types of personal data.
4. Purposes of the processing. The personal data received are processed for the purposes of:
5. a) user registration, execution of user’s orders for the sale of goods that are available in the catalog on the website;
6. b) user consultancy regarding the purchase of goods that are available in the catalog on the website;
7. c) researching the behavior and use of the website by the user, saving and adjusting the information on the website according to your preferences, studying the effectiveness of the website.
8. Legal basis for the processing. The legal basis for the processing is:
9. a) performance of a contract to which the user is a party or in order to take steps at the request of the user prior to entering into a contract;
10. b) legitimate interests to improve KLIFEX website, make the website usable by enabling basic functions;
11. c) user’s consent to the processing for purposes of collecting statistics, storing preferences, tracking visitors use of the website and display relevant advertisements.
12. Retention period. KLIFEX retains and processes user’s personal data as long as it is necessary to fulfill the purposes defined and the basis of the processing activity exists plus three years, if longer term is not stipulated by the law, or until a request to delete the personal data is received. We will also retain and use your data for as long as necessary to resolve disputes and/or enforce our rights and agreements.
13. Child privacy. We neither solicit nor collect personal data from anyone under the age of 16 (sixteen) or under the legal age of your country if it is different. If you are below 16 (sixteen) or you are not of legal age in your country, do not provide us with any personal data.

1. USE OF COOKIES
2. General information. Cookies are small text files placed on your computer when you visit the website.
3. Types of cookies user. On the website we use several types of cookies files based on the purpose they are used for:
4. a) 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.
5. b) preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
6. c) statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
7. d) marketing cookies are used to track visitors across websites. The intention is to display advertisement that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
8. Third party cookies. We use third-party web analytics services that assist us in better understanding of our website use and help display advertisement based on your interests (provided by Google LLC and Meta Platforms, Inc.), those services comply with the prescribed adequacy of security measures.
9. Managing Cookies. When entering the website users can choose to opt-out of preference, statistics, marketing and our proprietary cookies. In most cases, you can get up-to-date information about blocking and deleting cookies, depending on the browser, by following the links: Chrome, Firefox, Opera, Internet Explorer, Safari, Edge.
10. Retention period. The time cookies will stay on your computer or mobile device depends on the type of cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire (usually from 1 day to 2 years) or are deleted.

1. PROCESSING OF PERSONAL DATA
2. Your personal data is collected, when you consciously provide it to KLIFEX (e.g. when completing an online form) or we collect it by observation (e.g. using automated data capturing software). We do not collect personal data from publicly accessible sources.
3. KLIFEX is processing user’s personal data by automated means. The personal data is kept in electronic form on the website, in CRM-system and on computers, access to which only authorized KLIFEX employees and contractors has.
4. Automated decision-making. Your personal data is not subject for automated decision-making, including profiling. However, third-party cookies are used for analyses of your interests (advertisement preferences).

1. PERSONAL DATA TRANSFER
2. Recipients. Your personal data may be transferred to such categories of processors (subprocessors):
3. a) our contractors and subcontractors (marketing manager, IT specialist, customer support manager etc.), those operating within the jurisdiction outside the European Economic Area, particularly in Ukraine;
4. b) hosting provider “Hosting Ukraine” with servers in Ukraine (Hosting Ukraine LLC, business number: 37593550, address: Mashynobudivna st., 35-A, Kyiv city, 03067, Ukraine);
5. c) CRM system provider “SalesDrive” (individual entrepreneur Steklov Oleksiy Andriyovych, record number: 20690000000002737, address: Heroyiv Stalinhradu ave. , 24 A, kv. 170, Kyiv city, 04210, Ukraine) with servers within the EEA (the subprocessor is Hetzner Online GmbH, business number: DE 812871812, address: 25, 91710 Gunzenhausen, Germany);
6. d) third parties that perform our customer traffic analysis.
7. Those processors perform tasks on our behalf and are contractually obliged not to disclose or use collected information for any other purposes, other than specified in this PrivacyNotice.
8. International transfer. In case, where your personal data is transferred outside the EEA, KLIFEX enforces the appropriate legal documents that ensure the safeguard of personal data, particularly, the Standard Contractual Clauses.

VII. USER RIGHTS

1. User has the right:
2. a) to access. You are entitled to see the personal data held about you. You have the right to request a copy of the personal data that we hold about you.
3. b) to rectification. If your personal data is inaccurate, you have the right to have the data changed. We encourage you to contact us to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
4. c) to objection. In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data.
5. d) to data portability. You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
6. e) to erasure. You have the right to ask or require us to erase your personal data when the personal data is no longer necessary for the purposes for which it was collected, or when, among other things, your personal data have been unlawfully processed.
7. f) to restriction. You can limit the way we use your data. This is an alternative to requesting the erasure of your data.
8. g) to withdraw consent. When we rely on your consent for the processing of your personal data (particularly, when cookies are processed), you have the right to withdraw your consent at any time (e.g. by deleting or blocking cookies). However, the withdrawal of your consent will not affect the lawfulness of the KLIFEX processing based on consent acting prior to the withdrawal.
9. h) to file complaints. If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy through the courts.
10. You may, at any time, exercise any of the above rights, by contacting zakaz@klifex.ua together with a proof of your identity.

VIII. OTHER PROVISIONS

1. This Privacy Notice may be updated in the future to comply with national and international laws regulating the protection of personal data. In the event of significant changes to the provisions, KLIFEX will send an email about such changes before they take effect.
2. If you require any additional information or have any further questions concerning this Privacy Notice, please contact us at zakaz@klifex.ua.