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Privacy policy

Effective date: May 24, 2018

Our website www.alarica.eu (“website”, “platform”, “we”) is an international B2B marketplace that connects footwear & accessories manufacturers with wholesale buyers.

Protecting your privacy is important to us. We collect and use all data only in accordance with legal requirements (including, but not limited to, General Data Protection Regulation (Regulation No. 2016/679 of the European Parliament and of the Council) - “GDPR”). 

This Privacy Policy aims to tell you how we collect, process, use your personal data and the scope of data collected by us. Also, it is informing about the rights you have and how to get in touch with us if you need to.

The Controller
The Controller of your personal data is:
COMENIUS ANALYTIKA, s r.o. registered in the Commercial register of the District court, Bratislava I. Section: Sro, Insert No. 117305/B
Headquarters: Márie Medveďovej 34, 851 04 Bratislava
Phone: +421 915 378 601
E-mail: privacy@alarica.eu

You can, at any time, contact us directly with all questions and suggestions concerning your personal data.

Data that we collect
Our platform provides a lot of features for manufacturers, that produce and sell their goods (“manufacturers” or “sellers”) and for the persons, who are interested in buying such goods (hereinafter also as - “buyers”).

Whether you are a manufacturer or a buyer, for using our platform, you should provide your personal data and register yourself by filling the respective forms on the website.

Before the registration, it is obligatorily required to provide your consent with this Privacy policy by opting-in the relevant checkbox.

Our website collects a series of data and information when you call up the website (hereinafter – «General data»). This General data may be: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the date and time (so-called timestamp) of access to the website, (5) an Internet protocol address (IP address), (6) the internet service provider (ISP) of the accessing system, and (7) any other similar data and information that may be used in the event of attacks on our information technology systems.

If you are the seller, you need to provide us with your personal data before the usage of the platform, such as:

- Your name (as a contact person);
- Your company;
- Your e-mail address;
- Phone (Viber, Whatsapp, Wechat, Telegram).

If you are the buyer and want to have an access to the manufacturers’ goods, you need to provide us with the following data, prior to the registration:

- Your First and Last Name;
- Your Company and position;
- E-Mail address;
- Phone (Viber, Whatsapp, WeChat, Telegram);
- The site of the Company.

Please be informed that we do not collect any payment and payment processing information related to the manufacturers and buyers.

Why do we collect your personal data? (data processing purposes).

We collect and use your personal data for the following purposes:

(i) To determine whether the registered user (you) is the target audience of our website (either the manufacturer or the buyer). For this purpose we collect: your name, your company and position, e-mail address and phone number.

(ii) To notify you about the new offers on the website - to send your our newsletter (with your prior consent); For this purpose we collect: your name and e-mail address.

(iii) To display target advertising on the website; For this purpose we collect a series of general data, as described above in cl.2.1. and cookies, according to our cookies policy.

(iv) To perform our mutual intention to conclude a contract between you and us (if you register as a seller). For this purpose we collect: your name (as a contact person), your company; your e-mail address; and Phone (Viber, Whatsapp, Wechat, Telegram).

Legal basis for the processing
According to the GDPR, the basis on which we process your personal data is your given prior consent to the processing of your personal data for the purposes, described above within data processing purposes.

In addition, if you are the manufacturer, the basis of the processing might be the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our platform.

Finally, data processing could be based on the basis, when such processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. 

Personal data storage and protection measures
We take all appropriate technical and organizational measures to ensure the protection of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular but not limited to where the processing involves the transmission of data over a network, and against all other unlawful forms of processing. 

All personal data is safely stored on secure servers, processed by the Hetzner Online GmbH, which is considered as a data Processor, pursuant to the signed agreement between the parties. For further information or questions regarding data protection at Hetzner Online GmbH, please send an email to: data-protection@hetzner.com

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure.

Retention of data 
Your personal data is processed and stored only for the period necessary to achieve the purpose of storage (for example, as long as you are using our platform as the manufacturer and/or the buyer), or as far as this is granted by the European legislator or other legislators in laws or regulations.  

In any case, if you request us for implying your right to erasure or withdrawal of your consent, we will delete your data immediately.  

We will also retain General data for internal analysis purposes. General data is retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our platform, or we are legally obligated to retain this data for longer time periods. 

Transfer to third countries
As a default, we do not transfer your personal data to the third countries, outside of the European Economic Area. 

Despite that, the transfer of your personal data outside of the European Economic Area may be necessary in order to provide you with a service that you have requested, and your personal data may be accessed by data processors and service providers from countries that do not provide the same level of data protection as provided in the European Economic Area. Therefore, if necessary, we will take all measures which in relation to the recipients of your personal data, is necessary to ensure an adequate level of protection as defined by the applicable data protection law, in particular, through the application of the Standard Contractual Clauses issued by the European Commission. 

If, in relation to data transfers abroad, an adequate level of protection of personal data cannot be ensured, then we shall request your express consent relating to any such data transfers abroad. Please note that such data transfers may be associated with certain risks particularly that in the country of the data recipient unauthorized third parties may also have unreasonable access to said data and you may not be able to exercise the rights of the data subject and or your right to object against acts that may harm your personal data and your right to privacy. 

Service providers (data processors)
We may contract third party companies and individuals to facilitate our platform ("service providers"), to provide the services on our behalf, to perform service-related services or to assist us in analyzing how our platform is used. 

These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. 

Analytics 
We may use third-party Service Providers to monitor and analyze the use of our Service.  

Google Analytics 
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. 

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. 

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Behavioral Remarketing 
We use remarketing services to advertise on third party websites to you after you visited our website. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our website. 

Google AdWords 
Google AdWords remarketing service is provided by Google Inc. 

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads 

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. 

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Newsletter 
On our website, users are given the opportunity to subscribe to our newsletter.

We inform our users regularly by means of a newsletter about new offers and other related information. The enterprise’s newsletter may only be received by you if you provided your consent for the newsletter shipping. 

YOUR PERSONAL DATA PROTECTION RIGHTS
Pursuant  to  the  GDPR,  you,  as  a  personal  data  subject  have  the  following  rights: 

Right of access 
You  have  the  right  to  obtain  from  us  free  information  about  your  personal  data stored at  any  time  and  a  copy  of  this  information.  If  you  wish  to  avail  your  right  of  access,  please  contact  us,  referring  to  details  prescribed  in  cl.1  of  the  Privacy  Policy. 

Right to rectification 
You  have  the  right  to  obtain  from  us without  undue  delay  the  rectification  of  your  inaccurate  personal  data  concerning. 

Right to erasure (Right to be forgotten) 
You  have  the  right  to  request  from  us  the  erasure  of  your  personal  data,  and  we  will  erase  such  personal  data.  Please  note  that  in  such  case  you  will  not  be  able  to  use  our  platform  further. 

Right of restriction of processing 
You have the  right  granted  to  obtain  from  us   restriction  of  processing your personal data. 

Right to data portability 
Under certain circumstances you may have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format (i.e. in digital form) and you may have the right to request the transmission of those data to another entity without hindrance from us, if such transmission is technically feasible. 

Right to withdraw consent 
When the processing of your personal data is based on your consent, you can withdraw your consent at any time without giving any reason to us. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. 

Right to lodge a complaint with the supervisory authority 
If you feel that your personal data rights have been breached, you can also contact and lodge a complaint. For more information, please
contact your local data protection authority in the European Economic Area. 

In order to imply any of your personal rights described above, please feel free to contact us at: privacy@alarica.euPlease note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested.

Links to other sites
Our website may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy
Our Service does not address anyone under the age of 18 ("children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with personal data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Existence of automated decision-making
We do not use automatic decision-making or profiling on our website.

Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our website, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Please feel free to contact us at: privacy@alarica.eu.