Personal data processing principles

We process personal data in accordance with applicable data protection legislation, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as "GDPR").

We process your personal data transparently. Therefore, all purposes of processing are expressed in this policy, and processing is always only carried out to the extent necessary for the identified purpose for which it is processed. 

We have an interest in ensuring that you always know what data we collect about you and for what reason, how long we keep it and to whom we pass it on if necessary. We also want you to be informed about who you can contact if you have any doubts about this processing. Therefore, if something is not clear to you, you can contact us using the contact details below.

1. PERSONAL DATA CONTROLLER

The controller of your personal data is us, the company KLEO team s.r.o., ID No.: 10745475, with registered office in Cukrovarnická 504/35, Střešovice, 162 00 Praha 6, Czech Republic, registered in the Commercial Register maintained by the Municipal court in Prague, section C, insert 347671. As a data controller, we determine the purposes and means of processing personal data and are responsible for the processing of personal data. 

If you have any questions or wish to exercise your rights (see below), you can contact us by email at www.support@wearmillo.com.

2. TYPE AND MANNER OF PROCESSING OF PERSONAL DATA

As a rule, we process personal data automatically, in accordance with the purpose for which we obtained it from the data subject. We use profiling in some cases as part of our marketing activities. By means of automated data processing, we thus evaluate selected factors relating to you or the device from which you visit the e-shop in order to analyse your purchasing behaviour and/or create a forecast of future behaviour. This enables us to tailor the content displayed to your individual preferences.

In relation to personal data, only such data is processed as is necessary for the purposes of the processing. Your identification and contact data and any other data that you actively provide to us are processed in the context of order processing. For marketing, statistical and analytical purposes, we also process your IP address and other identification data and information collected by cookies or other similar technology.

We usually obtain your personal data directly from you via the forms provided for this purpose, during the placement of orders in our e-shop, when registering a customer account, when subscribing to our newsletter or when you contact us yourself. We also collect your data when you use the services of the e-shop, in particular when you browse the products offered there. 

3. REASON AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

The data controller may only process personal data if there is a legal basis for the processing. The object of our activity is the sale of goods, and therefore the basic reason for processing your personal data is the performance of a contract. However, we also process your personal data for other purposes. For more on this, please see below. 

The provision of personal data is not obligatory on your part, but please note that without providing it, many of the services we offer cannot be implemented and a purchase contract cannot be concluded with us at all.

3.1 Processing based on consent [Article 6(1)(a) GDPR]

In the event that you provide us with data beyond the mandatory data required for order processing for the purpose of registering your customer account or when placing an order, your consent is the legal basis for processing it. Please note in this context that you may withdraw your consent to the processing of your personal data at any time, without prejudice to the lawfulness of the processing based on consent given prior to its withdrawal. 

3.2 Processing for the performance of a contract [Article 6(1)(b) GDPR]

For the provision of services related to the registration and operation of a customer account in the e-shop, in connection with the provision of content that you have collected in the e-shop (e.g. shopping cart), for the execution of an order placed by you or for the return of goods purchased by you, we process your personal data for the purpose of fulfilling the contract that we conclude with you on the basis of the order you have placed. 

3.3 Processing for compliance with legal obligations [Article 6(1)(c) GDPR]

Sometimes we process your personal data because we are required to do so by law. This is in particular the case of processing of data in the performance of obligations arising from tax and accounting regulations, but also, for example, when handling a complaint or return of goods submitted by you. 

3.4 Processing based on the legitimate interest of the controller [Article 6(1)(f) GDPR]

We may also process your personal data where we have our own legitimate interest in doing so. This is the case when processing the data for the following purposes:

1. protecting our rights and enforcing our legal claims;
2. marketing, statistical and analytical purposes consisting in analyses of customer activity in the e-shop, queries of the customers and their preferences in order to improve and personalise the services we offer;
3. identification and handling of your queries if you contact us with any.

If you give us your consent, we may also send you marketing content via various communication channels (email, SMS, telephone or post) in view of our legitimate interest. However, you can withdraw your consent at any time by clicking on the link in the email or by contacting us at any time at www.support@wearmillo.com.

4. WEBSITE AND COOKIES

Cookies are files that are stored on the device through which you visit our e-shop. These files act as identifiers and facilitate the use of the e-shop, which thus stores information about your activity in the e-shop and your preferences for a certain period of time. If you wish to restrict the processing of cookies, you can simply use the anonymous browsing function of one of the internet browsers that include this function, as this function generally prevents the storage of data about the websites you visit. Alternatively, you can change the settings in your browser to disable the storage of cookies altogether. However, this may limit some of the functions of our website.

We use the following types of cookies:

• Necessary cookies that are required for the proper functioning of the e-shop. These cookies technically enable the basic functionality of the e-shop, such as processing customer orders, remembering customer logins, securing the e-shop or enabling the shopping cart function.
• Analytical cookies that allow us to analyse customer behaviour on the e-shop website. Thanks to them, we are able to determine which features of the e-shop need to be improved and how.
• Personalisation cookies that allow us to analyse customer behaviour on the e-shop website and their shopping preferences. Based on these analyses, we can provide customers with personalised product offers and display tailored content. This can make the content of the e-shop more relevant to the customer.

Only the necessary cookies listed above are required for the proper functioning of the website. You may agree or disagree to the use of other types of cookies by answering the request of the web interface when you visit the e-shop. 

5. TRANSFER OF PERSONAL DATA TO OTHER ENTITIES

Other recipients of your personal data are persons with whom we cooperate in the provision of our services and regarding marketing services. 

Depending on which delivery method you choose, we will provide your personal data necessary for the delivery of the goods to you to one of the chosen transport providers. If you use a payment gateway to pay for your order of goods, we may then provide your data to the payment gateway operator to the extent that it is necessary to make such payment.

Accordingly, your personal data may be disclosed to the following entities:

• delivery service provider, Zásilkovna s.r.o., with registered office at Lihovarská 1060/12, Libeň, 190 00 Prague 9, ID No.: 28408306
• delivery service provider in Slovakia, Packeta Slovakia s. r. o., with registered office at Kopčianska 3338/82A, 851 01 Bratislava, Slovak Republic, ID No.: 48 136 999
• delivery service provider, Direct Parcel Distribution CZ, s. r. o., with registered office at Říčany u Prahy, Modletice 135, Postal Code 251 01, ID No: 61329266
• the operator of the payment gateway, Stripe Payments Europe Limited, with headquarters at 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland, reg. no. 513174
• provider of logistics and warehousing services, Ynot s.r.o., with registered office at Prague 19 - Kbely, Herlíkovická 1021/4, Postal Code 197 00, ID No.: 26711516 

Your data is processed in accordance with this policy, so we only disclose your data to third parties to the extent necessary to fulfil the purpose of their processing. 

If we are required to do so by applicable law, we may also disclose your personal data to public authorities provided that the relevant legal conditions are met.

Your personal data is processed within the territory of the Member States of the European Union and may be processed in the future in a third country only in accordance with the applicable legislation, i.e. in particular in compliance with the terms of the relevant decision of the European Commission.

6. LENGTH OF RETENTION OF PERSONAL DATA

The retention period of personal data varies from case to case, depending on the purpose of processing. In principle, however, we retain your personal data for at least the time necessary to perform the purchase contract, including the processing of related contractual requirements - in particular the return of goods as a result of withdrawal or a complaint - and the protection of legal claims in connection with the contract, i.e. for at least 42 months. If you create a customer account, we will keep your personal data associated with it for the duration of the account. You can delete the account at any time. 

If we use your data to personalize the services we offer, we use it for three months. However, in cases where the legal basis for processing your personal data is your consent (e.g. for marketing purposes), we will always keep your personal data for no longer than the period until such consent is withdrawn. 

In cases where we process personal data to comply with legal obligations, we process it for the period of time specified by the relevant legislation, usually for ten years. 

If we absolutely need your personal data in order to enforce our claims or to defend against claims brought against us, we may extend the processing period accordingly.

7. YOUR RIGHTS 

As a data subject, the law grants you certain rights in relation to the processing of personal data, which you may exercise at any time. These rights are as follows:

• The right of access to personal data, i.e. the right to obtain information about whether and what personal data we hold about you. 
• Right to rectification of personal data. If the personal data processed is incorrect or outdated, you have the right to request its correction and completion. 
• Right to erasure. You may request the erasure of some of your personal data and we will comply, provided that it is no longer necessary for the purposes for which it was processed.
• Right to restriction of processing of personal data.  You can request a restriction on the processing of personal data, for example in the form of making the data inaccessible or temporary deletion of the data. 
• Right to data portability. At your instruction, we may transfer your data to another controller. 
• Right to object. You may object to processing of personal data for which the legal basis is the necessity for the performance of a task carried out in the public interest or in the exercise of official authority or for which the processing is necessary for the purposes of protecting our legitimate interests. Should we fail to demonstrate that there is a compelling legitimate ground for such processing, we will terminate such processing upon objection.

You also have the right to withdraw the consent you have given us to process your personal data at any time. However, this does not affect the lawfulness of their processing until such withdrawal of consent. 

If you believe that the processing of your personal data violates data protection legislation, you have the right to lodge a complaint with a supervisory authority. 

Contact the supervisory authority:

Úřad pro ochranu osobních údajů

Pplk. Sochora 27

PSČ 170 00, Prague 7

phone: +420 234 665 111 (Headquarters)
e-mail: posta@uoou.cz

databox: qkbaa2n