1. Data Subject to Processing:

• First and last name;
• Contact information, including phone number and email address;
• Billing and shipping address;
• Bank account number;
• Cost of goods and services, payment data (purchase history);
• Customer service data;
• Other information related to customer surveys and/or offers to customers.

Details on the use and storage of cookies are provided in Attachment 1.

2. Purposes of Data Processing

The processing of personal data is carried out to fulfill the contract with the client and to comply with legal obligations (e.g., accounting and resolution of consumer disputes). Data is used to manage client orders, deliver goods, and process refunds. Purchase history is analyzed to create reviews of purchased goods and services, as well as to understand client preferences. IP addresses and network identifiers are processed to provide online store services and site statistics.

3. Data Transfer to Authorized Processor

The Seller is committed to keeping client personal data confidential and only transferring it to third parties with the client’s consent, except when data transfer is required by law. Data may be transferred to the following parties:

• IT service providers — to ensure the operation and data storage of the online store;
• Business software — to conduct accounting operations;
• Suppliers — for order delivery: Itella;
• Payment intermediaries — for order payments: Modena / ESTO;
• Statistics collection — to improve user experience: Google Analytics, Facebook.

4. Data Security and Access

Personal data is stored on Microsoft Azure servers within EU or EEA countries. If necessary, data may be transferred to countries with an adequate level of data protection. The Seller takes measures to protect data from destruction, loss, alteration, or unauthorized access.

5. Access to and Correction of Personal Data

The client can view and edit their data in the account management section of the online store. If a purchase was made without creating an account, a request for data access can be submitted via a special form.

6. Withdrawal of Consent

The client has the right to withdraw their consent for data processing in the account management section.

7. Data Retention

Personal data is deleted upon the closure of the client’s account, except when data is needed for accounting or dispute resolution. Personalized purchase history is stored for 3 years, and accounting data is retained for 7 years.

8. Data Deletion

Personal data can be deleted via the account management section or by submitting a request. A response to a data deletion request will be provided within one month.

9. Data Portability

Data can be downloaded from the account management section. A response to a data portability request is also provided within one month.

10. Direct Marketing

Email and phone may be used for marketing communications with the client’s consent. The client can opt-out of such communications at any time by clicking the link in the email or by contacting customer support.