PRIVACY POLICY

This Privacy Policy sets out what information “Karuselle“ collects, how and from what sources that information is collected, what “Karuselle“ does with the collected information, and how that information is protected. By using our services and/or creating an account on the Website, you agree to the provisions of this Privacy Policy, as well as the General Terms and Conditions (hereinafter referred to as the “Terms and Conditions”).

All personal data of the User is collected and processed in accordance with the Lithuanian and EU data protection laws.

The terms that are capitalized and not defined in this Privacy Policy have the meaning set in our Terms and Conditions.

1. COLLECTION AND USE OF PERSONAL DATA

1.1 Data controller, data processors and scope of application

The controller of any personal information that has been provided to or collected on the Website is UAB “Karuselle”, legal entity code 304497677, address: Sakalų str. 6-40, LT-08124 Vilnius, Lithuania.

This Privacy Policy does not apply to personal information collected by third parties who may interact with our Website and does not apply to personal information collected on any other website or collected when you are not connected to “Karuselle“ (unless stated otherwise).

Payment transactions and data are processed by “Paysera LT”, UAB; “UAB OPAY solutions”; or UAB Click2Sell (depending on the selected payment method).

1.2 Information collected

“Karuselle“ collects and processes this information:

• User’s name and surname, year of birth;
• contact information: the exact postal address, including the addresses to which invoices and Products are to be sent, mobile phone numbers and e-mail address;
• User-uploaded photos;
• historical data on previous purchases, Orders, and Product lists;
• User’s IP address, as well as login details and location data when the User gives permission;
• User registration information and passwords;
• correspondence and communication with “Karuselle“, historical data on claims and incidents;
• User’s “Facebook” account details (if one is using the “Facebook Connect” functionality);
• User’s bank account or “PayPal” account to which “Karuselle“ will make payments;
• other publicly available personal data shared by the User on the Website.

This list is not exhaustive and in special cases “Karuselle“ may need to collect additional data in order to achieve the purposes set out in this Privacy Policy.

The Website and services of “Karuselle“ are generally not intended for persons under the age of 18 years. “Karuselle“ does not knowingly collect personal information from persons under the age of 18 years.

All Users are informed about what data must be provided to “Karuselle“ in order for it to provide services (usually this field is marked with an asterisk when providing data). Other information is optional and may be provided on a voluntary basis to improve the quality of our services.

“Karuselle“ will not store User data for longer than necessary to achieve the purposes set out in this Privacy Policy. The data must be kept until:

• User stops using our services and deactivates his/her account; or
• 2 years after the User’s last use of his/her account; or
• data is no longer needed and is not relevant to our operations.

Retention of personal data for longer than specified above may be carried out when:

• it is necessary for “Karuselle“ to be able to defend itself against claims or lawsuits and to exercise its rights;
• there are reasonable suspicions of an illegal activity that is being investigated;
• your data is necessary for proper resolution of a dispute or complaint;
• it is necessary for creating back-up copies or other purposes related to the operation and maintenance of information systems or similar;
• in other cases provided by law.

1.3 Legal basis for data processing

“Karuselle“ collects and uses Users’ personal data on the following grounds:

· to fulfill our legitimate interests (e.g., administration and coordination of Orders for Products, management of the Website, performance of other duties of “Karuselle” as the Seller, etc.);

• processing is necessary for the performance of contracts between Buyers and Sellers (to ensure the operation of the Account, to sell/deliver the Products);
• compliance with our legal obligations as set forth in applicable law.

With the consent of the User, “Karuselle“ processes the data for direct marketing purposes in order to send subscribed newsletters and promotional offers. The User can revoke its consent at any time.

1.4 Purposes of data processing

The main purpose of Users data processing is to offer for the Users an optimal, efficient and personalized experience on the Website. “Karuselle“ uses your personal data:

• to provide services or execute contracts concluded between Buyers and Sellers;
• to act as a representative of the Sellers;
• to communicate with the Buyers regarding Orders and other issues;
• to resolve any problems and disputes related to the use of the Website, ordering and returning the Products;
• to evaluate, improve the services and content, and personalize them;
• to inform Users about our services and offers;
• to prevent, detect and investigate all types of illegal activities in accordance with applicable law;
• to ensure that all policies and regulations of “Karuselle” are rigorously implemented;
• to fulfil our legal obligations;
• to contact and inform you of changes in the use of the Website, and/or changes to the Website and/or to the Website’s policies;
• for business administration and management purposes of “Karuselle“;
• for other purposes that are disclosed to you at the time you provide your data.

2. DATA COLLECTION AND USE BY THIRD PARTIES

2.1 Data exchange with third parties

The personal data collected on the Website is intended for the use of “Karuselle”, as described in Section 1.4 of this Privacy Policy. “Karuselle“, acting as a representative, transmits the data of the Buyers, who have purchased the Products, to the Sellers of the said Products (information about the Order, Buyer’s contact details, delivery information and/or other information necessary for the proper execution of the Order).

“Karuselle“ may also transfer data to the service providers who assist “Karuselle“ in providing its services. Such service providers are: data processing service providers, providers of data center services, providers of internet browsing or internet activity analysis and services, providers of software development, provision, support and maintenance services, providers of accounting services, IT infrastructure service providers, providers of electronic communications, security, call center services, and other service providers to whom your personal data is disclosed only to the extent necessary for the provision of their services.

Payment transactions and data are processed by “Paysera LT”, UAB; “UAB OPAY solutions”; or UAB Click2Sell (depending on the chosen payment method). “Karuselle“ does not collect any data regarding the Users’ payment methods, only information on the payments made for the Products.

2.1.2 Compliance with legislation

“Karuselle“ may share your data with government agencies, regulators, law enforcement agencies, courts and insurance companies when required to do so and in order to:

• comply with our legal obligations under applicable law;
• protect the Website having regard to the Terms and Conditions, or any other applicable policy, including the investigation of possible breaches of such policies, and to enforce our legal rights;
• ensure the security, rights, ownership or protection of the Website, any User or a third party;
• detect, prevent or otherwise deal with fraud, security or technical issues.

2.2 Third-party advertising

Third-party advertising service providers, or advertising agencies acting on their behalf, sometimes use specific technologies to show advertisements on the Website. In such case, they automatically get your IP address. They may also use their own cookies to evaluate the effectiveness of their advertisements, and to tailor content of the advertisements to a specific person. “Karuselle“ does not have an access to and/or ability to manage cookies and other functionalities that may be used on the websites of advertisers and third parties, and this Privacy Policy does not govern the use of data on the websites of such advertisers and third parties.

3. RIGHTS OF USERS AS DATA SUBJECTS

Users have specific rights regarding protection of their data. These rights are listed below:

• get acquainted with the information collected about the User;
• the right to rectification of incorrect or inaccurate information about you;
• the right to transfer all or part of the information collected about you to you or another data controller when technically possible (right to data portability);
• the “right to be forgotten”. Users may request the immediate deletion of information for legitimate reasons, such as where the data are no longer needed for the purposes for which they were collected or where the data were processed unlawfully;
• the right to restrict data processing. Users may be entitled to restrict the processing of their personal data;
• the right to object to the processing of personal data, where that personal data are processed on the basis of legitimate interests.

To exercise any of the above rights, please contact us by e-mail: pagalba@Karuselle.com.

Please note that if “Karuselle“ has reasonable doubts regarding identity of the User, who has contacted us regarding the above rights, we will ask for additional information in order to verify his/her identity. Once the identity has been confirmed, the request is executed within 1 month, unless it is impossible to do so for justified reasons, in which case this deadline is extended for another 2 months.

In case the User believes that the protection of his/her personal data is not ensured, he/she has the right to submit a complaint to the State Data Protection Inspectorate (www.vdai.lrv.lt). However, we recommend contact us first and try to find an amicable solution to a potential dispute.

4. SECURITY

By implementing appropriate technical and organizational measures, “Karuselle“ protects Users’ personal data from loss, misuse, unauthorized access, disclosure and alteration.

In addition, “Karuselle“ recommends for Users to take the following measures to increase their safety on the internet:

• maintain the confidentiality of account login information and passwords;
• use at least 8 characters when creating a password;
• avoid using the same password for multiple internet accounts;
• install software updates and security updates.

5. GENERAL PROVISIONS

“Karuselle“ may update its Privacy Policy from time to time. After making the changes, “Karuselle” will inform its Users about the update by publishing a new version of the Privacy Policy on the Website, along with the dates of the changes made.

Users understand and agree that further logging in and using of the Website (after changes to the Privacy Policy have been published on the Website) constitute confirmation and acceptance of such changes.

In the event that any provision of the Privacy Policy is held to be invalid, void or unenforceable for any reason, such provision shall not affect the validity and enforceability of the remaining provisions.

The Privacy Policy is valid from the date of its publication on the Website.

Cookie Policy

When Users visit or use our Website or other tools provided by “Karuselle”, we or our authorized service providers may use a wide variety of technologies to gather information to provide you with a better, faster and more secure experience, as well as for advertising purposes.

This Cookie Policy is designed to help Users better understand these technologies and how we use them. By using our services and/or creating an account on our Website, you consent to the use of cookies and other technologies as described in this Cookie Policy and our Privacy Policy.

The terms that are capitalized and are not defined in this Cookie Policy have the meaning set forth in our General Terms and Conditions (hereinafter referred to as the “Terms and Conditions”).

1. GENERAL INFORMATION ABOUT COOKIES

What are cookies?

When you visit the Website, we want to provide content and features that are tailored to your needs. This requires cookies – small text files (up to several KB) that your web browser places on your computer, tablet or other smart device when you visit our Website. They allow the Website to collect data such as:

• connection data (IP address of the connecting device, connection time, city from which are connecting);
• browser type;
• demographics (age group, gender, occupational or marital status);
• data on how you browse the Website (which pages of the Website you visit, what services you are interested in, etc.).

Cookies help us to identify you as a previous visitor to a particular website, save the history of your visit to the Website and tailor the content accordingly, speed up searches on the Website, create a user-friendly environment, make it more efficient and reliable. Cookies also help to ensure the smooth operation of the Website, allow monitoring the duration and frequency of visits to the Website and collect statistical information about the number of visitors to the Website.

While using the information collected via cookies about your actions on the Website, we may cooperate with the analytics service providers that help us to evaluate and provide us and/or third parties with information about the use of advertisements on third-party websites and the reviews of advertisements and our content.

Why do we use cookies?

By using cookies we aim to:

• ensure efficient and secure operation of the Website; we use cookies to support our security features that help detect and identify instances of misconduct on our Website;
• ensure the proper functioning of all functions of the Website, such as ordering services, filling in the order form, etc.;
• improve the functioning of the Website; by monitoring the use of cookies, we can improve the operation of the Website, use of services, develop existing services, improve functionality;
• analyze the operation when you are visiting our Website from other websites or other devices;
• identify visitors, returning to the Website; they help to show relevant information to visitors and help to remember their personal settings;
• analyze your habits so that the operation of the Website and the Account is convenient, efficient and meets your needs and expectations, for example, ensuring that you can easily find everything you are looking for;
• measure the flow of information and data sent to our Website; we use cookies to collect statistics on the number of users who are visiting the Website and the use of the services;
• targeted advertising; by using cookies, we may collect information in order to provide advertising or content for a specific browser, creating different target groups; we may use cookies to display appropriate advertising both on and off our Website.

How are cookies used for advertising purposes?

Advertising cookies and other advertising technology, such as pixels and tags, help us to deliver advertisements more effectively. They also help us to provide research and reports to advertisers, understand and improve our services, and know when content was shown to you.

What cookies do we use?

Each time you are visiting our Website, long-term cookies may be created that remain on your computer after you log out and will be used when you visit our Website again; they are valid and are not deleted when you stop browsing the Website, and/or short-term (session type) cookies that expire and are deleted when you stop browsing the Website.

All cookies used by us are used only with your prior consent, except for the necessary technical cookies. You can express your consent by clicking on the “I Agree” button in the cookie bar that appears at the bottom of the Website’s page.

Below we list the cookies used on the Website according to their type, description, moment of creation, collected data and validity period.

Types of cookies

The following types of cookies may be used on our Website:

Necessary technical cookies

These cookies are necessary for the Website in order for you to browse and use the features of the Website, such as memorizing the information entered in the forms during the session, accessing secure areas of our Website. Without these cookies, it would be impossible to provide certain services on the Website or it would not work as smoothly as it should. For this reason, it is not possible to refuse the necessary technical cookies.

Functional cookies

By using these cookies, visitors can avoid changing settings every time they visit the Website. These cookies help us to remember your preferences and settings (such as language). Functional cookies also memorize the changes you make, as well as other actions, such as when you leave a comment on the Website (if such an option is provided). Functional cookies do not track your actions on other websites.

Analytical cookies

Analytical cookies show us whether you have already visited the Website. These cookies help us to track the number of visitors and the frequency of their visits. These cookies collect information about the use of the Website and help to improve the operation of the Website. For example, analytical cookies can show which pages are visited most frequently, help to register problems on the Website, and so on.

Targeted advertising cookies

These cookies allow us to record your visit to our Website, the pages you have visited before and the links you have followed. We use this information to provide you with advertising that is relevant to your interests. Targeted advertising cookies let us know if you have seen an ad and how long it has been since you saw it. We may use third-party cookies to serve you more personalized advertising.

Descriptions of cookies used on our Website:

First-party (our) cookies

Third-party cookies

Third-party cookies and plug-ins

Some cookies on the Website are provided by third parties (such as advertising and analytics service providers). These third parties use their own cookies to analyse how much and how visitors used the Website, from which other sites they have entered the Website, where they moved on, and so on. The companies that create and use such cookies have their own policies and we have no influence on the creation or storage of such cookies. On some pages of the Website, other entities (such as social network providers) may also use their own cookies to tailor programmes or applications they create to your needs. We collect and transmit the information collected by these cookies together with their owners as joint controllers, but we do not control and are not responsible for how they will process and use your information in the future. Due to the specifics of how cookies work, we do not have access to the information transmitted by these cookies, just as other entities do not have access to the information collected by us.

Our Website uses the following third-party cookies and/or plug-ins:

• “Facebook Pixel“ (“Facebook” analytics service) and “Facebook“ cookies;
• “Facebook“ account login integration;

“Google“ account login integration.

You can find out how these companies use the information we collect from cookies in their privacy policies or by contacting them directly.

“Facebook Pixel”

Our Website uses small pieces of JavaScript code that are installed on all pages of our Website. These pieces of code, called pixels, have many functions, through which we collect information about clicks on “Facebook” ads and visitors who visit the Website, information about the website where such advertising was placed and from which the visitor entered the Website, information on the visitor’s browser, IP address, clicks and other actions on the Website.

Recipients of data

Please note that certain data about your visit to the Website or data generated by your visit to our Website (such as IP address, location, cookies, browser or device settings and information, browsing date, time, duration, other browser and device activity, site navigation) may be processed, transmitted or made available to entities within and outside the European Economic Area (EEA) for the purposes related to monitoring, statistics, employment, analysis, ensuring functionality and other related purposes (e.g., when we use “Google Analytics”, “Facebook Ads” and similar services, functionalities or products, such processors or recipients are companies located in the United States or other non-EEA countries).

Please note that personal data may be less protected in non-EEA countries than in EEA countries. We closely monitor the evolving case law and guidelines of the Court of Justice of the European Union and data protection supervisory authorities on the transfer of data outside the EEA, and carefully assess the conditions under which such your data is transferred and may be further processed and stored after transfer to the above entities. To ensure the appropriate level of data security and to guarantee the lawful transfer of data, we conclude standard contractual clauses approved by the European Commission or ensure other grounds and conditions established by the GDPR.

Managing and deleting cookies

When you are using a browser to access content we provide, you can configure your browser to accept all cookies, reject all cookies, or be notified when a cookie is sent. Every browser is different, so if you don’t know how to change your cookie settings, check out its help menu. Your device’s operating system may contain additional cookie controls.

If you do not want information to be collected through cookies, use a simple procedure available in many browsers that allows you to opt out of the use of cookies, for example: Chrome; Firefox; Internet Explorer; Edge; Safari; Opera.

To learn more about managing cookies, visit http://www.allaboutcookies.org/manage-cookies/ and http://www.youronlinechoices.com/.

Please note that in some cases, deleting your cookies may slow down your internet browsing, restrict certain features of the Website or block access to the Website.

4. GENERAL PROVISIONS

“Karuselle“ may change its Cookie Policy from time to time. After making the changes, “Karuselle” will notify the User by uploading the revised version to the Website and indicating the date when the last updates were made.

Users understand and agree that further logging in and using the Website after any changes to the Cookie Policy have been posted constitutes acceptance of and acceptance of such change.

The Cookie Policy is valid from the date of its publication on the Website.