1. WE CARE ABOUT YOUR PRIVACY
This notice describes how we, Aggressive Marketing Limited (“Kumplo”, “we”, “us”), process your personal data that you provide to us when using our website https://kumplo.com/ (the “Website”). Please read it carefully. We care about your privacy. We have therefore implemented technical and organizational measures to protect the personal data that you provide to us when using our Website.
2. WHICH CATEGORIES OF PERSONAL DATA DO WE COLLECT AND WHY?
2.1 Process Orders Made via our Website
In connection with an order, we collect information regarding your name (first name and last name), e-mail address, telephone number and address. We process the collected information for the purpose of administering your order, including to communicate with you regarding the order (e.g. for support purposes in the event of any issues with the delivery of the items), and to fulfill our contractual obligations in relation to you. There is no way of being a customer of Kumplo if you do not accept the handling of the above stated personal information. Kumplo will keep your information as long as you are a customer of the company and for another 36 months for above written purposes. Thereafter they will be saved in accordance to certain law requirements, for example the Swedish bookkeeping law. After this time has passed your personal information will be deleted. Furthermore, when paying via the Website you need to provide further information, such as debit or credit card information. We use third party payment providers in order to process payments via the Website. The payment providers are data controllers for their own processing of your personal data in order to process payments. The provision of the categories of personal data outlined above is required in order for us to administrate your order. If you do not provide the required information, we will not be able to process your order. We keep information regarding your order and transaction, including any support email relating to the order should any issues arise with the delivered products and for accounting purposes.
2.2 Use of the Website and Newsletters
2.3 Direct Marketing and Surveys
Based on your consent we may process your email address to send direct marketing information to you in order to satisfy our legitimate interest of informing you of offers in relation to our products and services. We may also process information regarding your order history, order value, payment method used and from which country you accessed our Website in order to send you relevant and tailored offers via e-mail and other similar ways of electronic communication. You have the right to at any time oppose to our processing of your personal data for direct marketing purposes and de-register from future communications from us, please see contact details below. Furthermore, we may process your name, e-mail address and order history to carry out customer surveys in order to satisfy our legitimate interest of obtaining further knowledge of how our customers view us and our products and services. The individual results of the surveys are only retained during such period that it takes for us to compile the result on an aggregated level and is thereafter deleted. The aggregated information is retained until further notice.
2.4 Statistics and Business Development
We may process the personal data that you provide to us, including location, purchased product categories and information regarding payment method, when using our Website for statistical purposes, e.g. in order to see how many individuals in a certain age range have purchased our certain product. This statistical information may be used for business development purposes. The processing of your personal data is necessary in order to satisfy our legitimate interest of continuously improving our business and providing new products and services.
3. WHO HAS ACCESS TO YOUR PERSONAL DATA?
3.1 Third Party Payment Providers
Your personal information could come to be handled by a so-called data processor that helps in our communication with you. This data processor will only handle your personal information in accordance with the guidelines for which it was collected. We use third party payments providers to handle payments via our Website. In order to administer the order and for the performance of the agreement between you and us, we will disclose information regarding your name, address, order information, and debit or credit card information and device used for purchase to the third-party payment provider. As stated above, the payment providers are data controllers for their own processing of your personal data in order to process payments.
3.2 Delivery and Storage Partners and other Third-Party Service Providers
In order to handle orders, we use third party delivery service and storage partners. As such, for the purposes of administering the order and to fulfil our contractual obligations in relation to you we will share your personal data, including your name, address and telephone number in addition to order information with our delivery and storage partners. Moreover, we may for the purposes outlined above in Section 2 engage additional third-party service providers not mentioned in this section, e.g. to carry out customer surveys and to send tailored offers. The third-party service providers that we engage are contractually obligated to only process your personal data in accordance with our strict instructions and may not use your data for their own purposes. Additionally, they are obligated to implement technical and organizational security measures to protect and safeguard your personal data.
3.3 Other Third Parties
Finally, we may process and disclose the personal data that you have provided to other third parties than outlined above in order to fulfil our legitimate interest of complying with applicable law and regulations and lawful regulatory requests or relevant orders from competent courts and public authorities and to establish, exercise and defend legal claims. Additionally, we may disclose your personal data to third parties in case of a merger or a transfer of assets in order to fulfil our legitimate interest of carrying out such merger or transfer of assets.
4. WHAT ARE YOUR RIGHTS?
You have the right to request access to the personal data that we store about you. You also have the right to request that incorrect or incomplete personal data is corrected. Furthermore, you have the right, to the extent our processing is based on your consent, to at any time revoke your consent to our processing of your personal data. Should you have any issues regarding our processing of your personal data, please do not hesitate to contact us. Naturally, you also have the right to lodge a complaint with your local Data Inspection Board should you wish. As of 25 May 2018, you also have, to the extent applicable data protection laws provide, a right to erasure of personal data, restriction of processing, to object to certain processing and a right to data portability. The right to data portability covers such personal data that you have provided to us and which we process either based on your consent or in order to fulfill our contractual obligations in relation to you. This typically includes your name, e-mail address, telephone number, address, order information, order history. It may also include any products reviews that you have made on the Website and survey results.
5. TRANSFER OF PERSONAL DATA OUTSIDE THE EU/EEA
We use third party delivery and storage partners which are based in China, Japan and the U.S. As such, your personal data may in connection with a purchase be transferred outside the EU/EEA to countries which do not have the same level of protection for personal data as countries within the EU/EEA. In order to ensure that your personal data is adequately protected, we ensure that there are appropriate safeguards in place by way of data transfer agreements which include standard data protection clauses adopted by the EU Commission. As of 25 May 2018, you have the right to receive a copy of the clauses by contacting us on the contact details below.
6. HOW WILL WE NOTIFY YOU OF CHANGES TO THIS NOTICE?
If you have any questions or concerns about our processing of personal data, please contact us using the following contact details.