Regulation (EU) 2016/679

As of 25 May 2018, the new data protection regulation - Regulation (EU) 2016/679 - is in force for all EU citizens.

This Privacy Policy describes how we store, process and protect your personal information you provide to us in connection with the use of our services. This policy is an integral part of the Site Terms of Use.

If you have any questions or comments regarding this Policy, please visit our site Contacts where you can find contact information or contact us directly.

Please read this Policy carefully before using our Services.

It is important to know:

  • If you do not agree to process your Personal Data in the manner described in the Policy, please do not provide it to us. The provision of Personal Data is voluntary, with a view to using or accessing our Platform Services. Any refusal to provide the Personal Data required to use the Services on our platform would be a refusal to use the relevant services or features.
  • In certain cases, your explicit consent to the processing of Personal Data may not be necessary if another legal basis is available, for example: compliance with the legal obligations of the Administrator; the need to perform a contract, etc.
  • The control body with regard to the protection of personal data is: Personal Data Protection Commission.

    CONCEPTS

PERSONAL DATA: Any information relating to an individual who is identified or can be identified directly or indirectly by an identification number or by one or more specific attributes.

PERSONAL DATA PROCESSING: This is any action or set of data that may be performed in relation to Personal Data by automatic or other means, such as collection, recording, storage, organization, adaptation or modification, restoration, consultation, use, disclosure or transmitting, distributing, updating or combining, blocking, deleting or destroying data.

PERSONAL DATA PERSON: Any individual whose Personal Data is processed.

PLATFORM: Software or co-working software modules that serve the site. The platform includes modules for:

Ability to post reviews.

Ability to ask questions.

Abitilty for creating online profile.

Buying products.

Others.

PERSONAL DATA

  1. Types of Data Subjects, Categories of data processed, Purpose of processing, Terms of storage

According to the way individuals use our Platform and the services it provides, they fall into the several divisions listed below. Depending on them, the data of the Subjects are processed in separate registers of personal data, each processing of which may include different categories of data, purposes and grounds, storage periods, safeguards and others.

The same entity may fall into more than one of the divisions listed at the same time. For example, every Buyer Consumer is also a Visitor.

  1. Visitor
  • A visitor is any person who loads a page, part of the Platform, or visits various sections and pages in his / her web browser (whether by directly entering the address in the browser or by referring from another website or resource).
  • Categories of data that can be processed: Online identifiers stored in local cookies in the visitor's device / browser; Location details provided by the visitor; Country / city data based on the IP address of the user device, an integral part of the information received from each web site; Information about actions taken by the entity in the Platform; Subject's preferences regarding specific aspects and settings for platform functionality; Information about the type of browser / device used.
  • Purpose of the processing: Provide basic and ancillary functions necessary for the proper and full functioning of the Platform; Platform traffic counts; Providing the necessary conditions for the implementation of services on marketing platforms.
  • Shelf life: Until the expiration of each cookie (up to 1 year from the moment of its recording), the media of the relevant information, or until its deletion by the subject in whose device / browser is stored.
  • Legal Grounds for Processing: Consent to Cookie Policy.
  1. Email subscriber
  • An e-mail subscriber is any Visitor who has subscribed to the platform's automatic e-mail newsletter for receiving e-mail letters containing commercial offers and more. The e-mail newsletter is sent directly by the Administrator, without the use of external intermediary services.
  • Categories of data that can be processed: Names, E-mail address, Location data, phone number, orders, subscriptions (e-mail newsletters) for which visitors subscribe - to be e-mailed to different type of platform information, sales offers and more.
  • Term of storage: Up to 6 months after termination of the subscription by the subscriber or by the Administrator.
  • Legal basis for processing: Consent to be included in the list of recipients (subscription to e-mail newsletter).

4. Consumer Buyers

  • Consumer Buyer is any Visitor who, through the technical means of the Platform, executed (or requested the execution of) a product order in order to purchase at a distance a platform / service offered by the latter (or similar action).
  • Categories of data that can be processed: Names, Address, Phone Number, Email Address, IP Addresses, Purchase Information, Information about the actions performed by the entity on the Platform.
  • Term of storage: 2 years after the last purchase by the buyer.

YOUR RIGHTS

If we process your Personal Information, you have the following rights, which you can exercise by sending a letter online - to office@white-thorn.com, or via the site Contact page:

  • Right of access to your personal data: You have the right to receive confirmation from us whether personal data about you are processed and, if so, access to personal data and information.
  • Right to Correct Personal Data: If you find that the personal information we process for you is inaccurate, you have the right to request that we correct that personal data.
  • Right to delete personal data (right to be forgotten): In certain circumstances, such as if your personal data were processed unlawfully or you withdrew your consent (if the processing of personal data is based on consent) and there is no reason to continue. you have the right to request the deletion of your personal data by us.
  • Right to restrict processing: In certain circumstances, such as if you have doubts about the accuracy of your personal data or have objected to our legitimate purpose for processing your personal data, you have the right to request that we restrict the processing of your personal data until it is a solution found.
  • Right to object to processing: In certain circumstances, such as if you have doubts about our legitimate interest in processing your personal data, you have the right to object to such processing for reasons of your particular situation.
  • Data Transfer Right: If your personal data is processed by automatic means at your consent or for the purpose of fulfilling our contractual relationship, you have the right to request that we provide your personal data in a machine-readable format for transfer to another data controller.
  • Right to file a complaint with a supervisory authority: You have the right to file a complaint regarding the processing of your personal data by us in the relevant supervisory authority - Personal Data Protection Commission, or to the court.

IN ALL THESE CASES, YOU CAN CLAIM THESE YOUR RIGHTS AS YOU FILL OUT OUR CONTACT FORM

  1. Provision of Personal Data to third parties

We do not provide data to third parties except in the following cases:

  1. If we have a legal obligation to disclose or share data;
  2. If we have obtained consent from the data subject concerned;
  3. Digitally pseudonymized data for the Visitors, Users and Subscribers of the Platform may be provided automatically to external services of our vendors integrated into the Platform for the purpose of counting our attendance or for advertising purposes. More information about these external services can be found in the Cookie Policy, as well as settings for opt-out of different types of services. Such opt-out can also be done through external tools (for Google Analytics - here; for Google ad platforms - here; for Facebook ad platforms - here; for other platforms - here and here);
  4. If a Buyer Consumer has made a payment and the payment is subsequently investigated by a banking or payment institution or by a legal authority for suspected fraudulent or unrecognized payment or for fraudulent investigation, the Administrator may provide data to the Purchaser Consumer with the relevant bank or payment institution or statutory body.

DATA SECURITY

For our part, we have taken the necessary technical and organizational measures to ensure the protection of your Personal Data against unauthorized access or disclosure, accidental or unlawful destruction or alteration.

The information in electronic form is stored in secure data centers throughout the European Union. Data transfer between servers and client device / browser is encrypted using HTTPS.

IP addresses

We store the IP addresses of data subjects in order to be able to adequately assist users in various circumstances (for example: unintentional purchases, purchase status reports, etc.). IPs are stored for up to 1 year (this period is consistent with the behavior of some of the platform's audience in terms of frequency of purchases and other actions). IPs are not provided to third parties under any circumstances except as described.

COOKIES

Platform websites, as well as third-party third-party services they use, use cookies to store small pieces of information temporarily in order to function properly and provide the best possible service.

FINAL PROVISIONS

  1. Any future changes to this Policy will be posted on this page.