Thank you for your interest in our products. We are pleased with your positive reaction to our wares. Our clients’ right to protection of personal data is of utmost importance to Vestel Holland B.V. Sp. z o.o. Oddział w Polsce (as defined below). We strive to maintain the highest quality of our services, acting in compliance with all applicable laws and regulations on data trading. Privacy Notice.
Below we explain in detail how we process personal data at the subsequent stages of each transaction. In connection with the above, Vestel Holland B.V. Sp. z o.o. Oddział w Polsce, a company incorporated under Polish law, with its registered office in Warsaw at ul. Salsy 2, 02-823 Warsaw (‘Vestel’), acting as a data controller, aims to provide individuals, including the users (‘Users’) of this website (‘Website’) with information on the methods applied to collect and process personal data in accordance with the General Data Protection Regulation No. 679/2016 (‘Regulation’) in force within the European Union, as well as any national laws and regulations applicable.
Information we collect
We collect (1) personal data that you voluntarily provide, (2) all data regarding your activity on our Website, and (3) information provided to us or collected from other sources. We do not collect special categories of personal data (e.g. data concerning health or court proceedings).
How do we protect your personal data?
The security of your personal data is our priority. To operate effectively, we use appropriate administrative, technological and physical measures designed to protect your personal data against theft, unauthorized use, disclosure or modification.
How do we use your personal data?
We use data to provide services requested by our clients, e.g. to allow users to browse the Website, to view our products, to answer questions we receive. The processing personal data in order to send you personalized marketing messages, such as special offers and discounts from us and our partners, is only possible upon your consent.
On what basis is your personal data used?
Your personal data is used in order to enable you to use all the features and functionalities of the Website and to have access to all services we provide. Personal data is also collected with a view to fulfilling legal obligations and protecting Vestel's interests. If you do not provide us with relevant data, in some cases we may not be able to allow you to use certain services or have access to specific content of the Website.
Who has access to your personal data?
If required, we may disclose your personal data to service providers, our affiliated companies and public authorities, provided that it is permitted by applicable regulations. With your consent, we may also share your personal information with our trusted partners who will use it for marketing purposes.
How long do we store your personal data?
We use your personal data only for the period necessary to attain intended purposes.
How is your personal data transferred outside the EEA?
Your personal data may be transferred to entities operating outside the European Economic Area (EEA). In any case, however, we make sure that all appropriate safeguards have been implemented in accordance with the applicable Regulation.
What are your rights?
Each person visiting the Website has, inter alia, the right to access, update, correct and delete his/her personal data.
Do you have further questions? Contact us
You can contact us by email at email@example.com. We reserve the right to change or update this Privacy Notice, among others with a view to complying with applicable laws.
1. Groups of processed personal data
Vestel shall process the following categories of data:
- User Data: Vestel shall process your personal data collected or supplied from several sources, including personal data provided directly by you upon the creation of an account and/or the registration of the purchased product, as well as upon submitting a request for information, assistance and purchase of Vestel products in an online store; such data includes your name, surname, home address, email address and telephone number.
Data is processed only to the extent necessary to attain the objective set out in this Privacy Notice. Vestel is obliged to preserve the anonymity of all personal data and to delete it when further processing of personal data in a form that allows identification for processing purposes is no longer necessary.
- Data regarding Website browsing: The Website collects users' personal data for technical and functional purposes. Data is not collected with a view to identifying the User, although this may mean that identification requires comparing the data with other data held by third parties. This category of data includes the IP address and the domain name of the user's computer, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method of sending the request to the server, the size of the file received as a response, a numerical code associated with the status of the response from the server and other parameters of the operating system on the user's device. Such data is used solely in order to collect anonymous statistical information on the use of the Website and to ensure its proper operation. It is collected and secured in accordance with our data storage requirements. Such data may be used to determine liability in the event of cybercrime against the Website. We may also collect personal data on our Website using various categories of cookies.
2. Purposes of processing personal data
- Personal data collected by or provided to us shall be used for the following purposes:
- enabling registration on the Website by opening a user account and purchasing products on the Website;
- purchasing a product online and providing additional services (after-sale services, fraud prevention, processing returns);
- delivery of our products;
- arranging the repair of purchased products;
- responding to requests for information that we receive, including the handling of complaints and messages received through our interactive chat service;
- users’ access to promotional offers and competitions;
- complying with applicable laws and regulations, and defending our rights in court;
- sending personalized marketing messages related to our products and services (including email, SMS, MMS, notifications on social networking sites, mobile applications) to users - with their consent and without damaging Vestel's legitimate interests;
- contacting users by phone (non-automatically) or by post for marketing purposes – provided that users do not renounce to this form of communication;
- sending information on customer service, products purchased or those you have shown interest in, and contacting you with a view to performing customer satisfaction surveys;
- sharing your personal data for the purpose of personalized marketing communication with our selected trusted partners specified in point 6 below, provided that the user has expressed his/her consent to it;
- any activity that may prove useful in the process of relocating business operations and branches, acquisitions, mergers, divisions or other types of reorganisation, and with a view to carrying out such transactions.
3. Legal basis for the processing of personal data
- Providing personal data for the purposes set out in paragraph 2 a), b), c), d), e) and f) is necessary for the purpose for which the data has been provided or made available to us, which includes, among others, registration on the Website, purchase of products online and use of special services, as well as participation in promotional offers and competitions with prizes;
- Sharing personal data for the purposes set out in paragraph 2 g) is mandatory, as it is required by applicable laws;
- Sharing personal data for the purposes set out in paragraph 2 h) and k) is optional. Should you fail to express your consent, Vestel and/or trusted partners will not be able to send you personalized marketing messages via automated means. If you withdraw your consent, we shall not process your personal data for the purposes specified in points h) and k) above. We expect data subjects to express their consent to receive marketing messages and to data sharing (where applicable);
- Sharing personal data for the purposes set out in paragraph 2 i), j) and l) is necessary for the pursuit of legitimate interests of Vestel and the Vestel Group, which shall be properly balanced with the interests of users.
Pursuant to applicable data protection regulations, we may also use electronic data provided by you (e-mail address, telephone number) and collected in the process of product sale transactions in order to send you personalized marketing messages regarding similar products. You may object to such use of electronic contact details in accordance with paragraph 9 of this Privacy Notice.
4. Retention of personal data
Vestel shall process personal data as long as it is necessary to attain the intended purposes in accordance with paragraph 2 above. The following data storage periods shall apply:
- data collected for the purposes set out in paragraph 2 a), b), c), d), e) and f) shall be retained for the period necessary to answer questions of data subjects, in accordance with applicable regulations;
- data collected for the purposes set out in paragraph 2 g) shall be retained for the period defined in applicable regulations (e.g. for tax purposes);
- data collected for the purposes set out in paragraph 2 h) and k) will be retained for the maximum storage period specified in applicable regulations;
- data collected for the purposes set out in paragraph 2 i), j) and l) shall be retained for the period strictly necessary to pursue Vestel's legitimate interests.
5. Personal data processing procedures
Your personal data shall be processed using information technology and/or paper means, and it shall be protected by security devices in order to ensure confidentiality and the highest standard of personal data security. Vestel shall take appropriate administrative, technical, personal and physical steps to protect stored personal data against loss, theft, unauthorized use, disclosure or modification.
6. Sharing of personal data
We may share your personal data with our trusted partners, such as our guarantee providers. Again, your personal data shall be used by them for marketing purposes only if we clearly inform you about it and you agree.
We may share your personal data with:
- Vestel Group companies operating within the EEA and outside the EEA, acting as independent data controllers;
- our trusted external suppliers operating within the EEA and outside the EEA, such as: call centre operators, shipping companies, service providers or appointed technicians and other suppliers acting on our behalf as appropriately designated entities processing personal data for the purposes indicated in this Privacy Notice; other third parties in the event of corporate transactions, such as mergers or asset sales.
In the above cases, these entities must comply with the privacy and data security requirements set out therein, and may not use the personal data received from us for other purposes. In the event of data transfer outside the EEA, appropriate safeguards shall be implemented in accordance with the Regulation.
7. EU-U.S. Privacy Shield and SWISS-U.S. Privacy Shield.
With regard to personal data received or transferred pursuant to the Privacy Shield framework, Vestel is subject to the executive powers of the Federal Trade Commission of the United States.
Vestel participates in and confirms compliance with the EU-U.S. Privacy Shield and the Privacy Shield SWISS-U.S. Frameworks. Vestel undertakes to submit all personal data received from EU Member States and Switzerland to all applicable Privacy Shield Frameworks.
Vestel is responsible for processing personal data received as part of the Privacy Shield, and then transfers it to a third party that acts as an agent of Vestel. We comply with the principles of the Privacy Shield for all further transfers of personal data from the EU and Switzerland, including provisions regarding the transfer of responsibility for such transfer of data. With regard to personal data received or transferred in accordance with the Privacy Shield framework, Vestel is subject to the executive powers of the US Federal Trade Commission.
In some cases, the Vestel Group may be required to disclose personal data in response to lawful requests from public authorities, inter alia, with a view to meeting national security or law enforcement requirements. Under certain conditions, described in more detail on the Website, you may be entitled to arbitration when other methods of dispute resolution have been exhausted.
8. Minors under 18 years of age
The Website and the online store are not directly targeted at persons under 18 years of age. Therefore, Vestel does not knowingly collect personal data from persons under the age of 18.
9. Rights of personal data subjects
Our clients and registered users can, at any time, use the following rights free of charge (based on the provisions of Articles 15-21 GDPR and 7 GDPR):
- the right to obtain information on the purposes and methods of processing their personal data;
- the right to access their personal data (commonly referred to as ‘data subject access requests’). It allows you to receive a copy of your personal data that remains at our disposal - pursuant to Article 15 of GDPR;
- the right to request an update or rectification of your personal data provided to us. You can correct any incomplete or inaccurate data, although it may involve the need to verify the accuracy of new data - pursuant to Article 15 of GDPR;
- the right to limit the processing of personal data - pursuant to Article 18 of GDPR. It means that you can request that we abstain from the processing of your personal data in the following situations:
- if you want us to verify the accuracy of the data;
- if our use of data is unlawful, but you do not want us to delete it;
- if you need us to store data, even if we no longer require it, because it is necessary in order to put forward, meet or support legal claims;
- if you have not objected to our use of data, but it must be ascertained whether we have overriding and reasonable grounds to use it;
- the right to object to the processing of personal data in whole or in part when the basis for processing is our legitimate interest (or the interest of a third party) - pursuant to Article 21 of GDPR. In the case of specific situations in which you wish to object to the processing of data, as you feel it affects your fundamental rights and freedoms. In some cases, however, we can show that we have reasonable grounds for processing information that override your rights and freedoms;
- the right to request the deletion of data - pursuant to Article 17 of GDPR. You can demand that we delete your personal data. This also applies to situations in which you have successfully exercised your right to object to data processing, or if we are required to delete your personal data due to requirements of applicable national regulations. However, please note that we may not always be able to comply with your request to delete data due to specific legal reasons, which shall be presented to you where appropriate in response to your request;
- the right to withdraw consent to the processing of personal data at any time and free of charge, also through using the ‘unsubscribe’ option at the bottom of all our marketing communication, if data is processed on the basis of your consent;
- the right to transfer your personal data to you or to another supplier - pursuant to Article 20 of GDPR. We shall provide you or a third party selected by you with your personal data in an orderly, machine-readable format;
- the right to contact us by sending an email to firstname.lastname@example.org;
- the right to lodge a complaint with the competent national data protection authority or judicial authority.
Please contact us should you have any questions or doubts, or if you wish to exercise the rights set out above regarding the use of your personal data. Please send an e-mail to email@example.com, or write to us at Vestel Holland B.V. Sp. z o.o. Oddział w Polsce, ul. Salsy 2, 02-823 Warszawa, Poland, for the attention of the Data Protection Inspector.
10. Updates and changes
We make sure that the Privacy Notice is regularly verified and updated. We may modify its content to reflect changes in our privacy practices. If we plan to introduce comprehensive changes, we shall inform you by updating this Privacy Notice prior to its entry into force. We encourage you to refer to the Privacy Notice for the latest information on our privacy practices. This Privacy Notice was last updated on 25 October 2019.